Georgia Institute of Technology Systems Realization Laboratory Federal Trade Commission Green Guides Apply Section 5 of FTC Act to environmental advertising and marketing Apply to: labeling, advertising, promotional materials, etc. through words, symbols, emblems, logos, depictions, brand names, etc. in connection with sale or marketing of any product or package. Not enforceable regulations, and do not preempt other regulations. Conduct inconsistent with the positions articulated in these guides may result in corrective action (i.e. lawsuit) General Principles -Qualifications and disclosures should be clear and prominent -Must be a clear distinction between benefits of product and package -Do not overstate environmental attributes, expressly or by implication -Basis for comparative claims must be made clear, and advertiser should substantiate claim

Georgia Institute of Technology Systems Realization Laboratory Specific Environmental Marketing Claims Covered General environmental benefit claims must be substantiated Degradable/biodegradable/photodegradable claims -Where customarily disposed of -Rate and extent of degradation Compostable claims Recyclable -Collected, separated from waste stream for use as raw material (does not allow reuse of products) -Unqualified claims: minor, incidental components allowed to be non-recyclable -Limited availability of recycling program must be noted Recycled content -Pre- and Post-consumer waste that has been recovered or diverted from solid waste stream Source Reduction Refillable packaging requires infrastructure Ozone safe / ozone friendly

Georgia Institute of Technology Systems Realization Laboratory Respondents to the Call for Comments American Society for Testing and Materials Free-Flow Packaging Corporation The New Consumer Institute Ecolab Center Green Seal Occidental Chemical Corporation Methyl Bromide Alternatives Network Helene Curtis Union Carbide James River Corp. Nat. Assoc. For Plastic Container RecoveryInternational Paper U.S. Environmental Protection Agency American Bakers Association Attorneys General of 12 States The Society of the Plastics Industry, Inc. Los Angeles Co. District Attorney's Office The Composting Council International Dairy Foods Association Brenda J. Cude and Robert N. Mayer Environmental Defense Fund

Georgia Institute of Technology Systems Realization Laboratory American Plastics Council APC strongly urges that the existing FTC Guides should remain unchanged, including the treatment of the plastic resin identification code We urge the Commission... to retain its current policy on the resin identification code APC shares the Commission’s view that use of the SPI resin identification code is not a claim of recyclability... in an inconspicuous location Almost four-fifths of the states...require in state law that container manufacturers use the current SPI resin identification code Advertisers and manufacturers should not be expected to change advertising practices nationally just because local or regional market conditions may, for a short time, preclude a particular package from being recovered for recycling

Georgia Institute of Technology Systems Realization Laboratory COPE Survey Please Recycle Question Option #1: If packaging sold throughout the United States is labeled "Please Recycle", does this mean that collection programs exist in your community to recycle the package? (close-ended question) -Yes31% -No49% -Maybe (volunteered)13% -Don’t Know (volunteered) 7% Please Recycle Question Option #2: If a package sold throughout the United States is labeled "Please Recycle", does this mean that the package can be recycled by consumers in all communities, most, some, a few, or no communities in the U.S.? (close-ended question) -All28% -Most27% -Some33% -A few 5% -None 1% -Don't Know (volunteered) 6%

Georgia Institute of Technology Systems Realization Laboratory Environmental Defense Foundation No absolute claims of general environmental benefit should be permitted Symbols should be accompanied by text explaining environmental benefits (Mobius loop, chasing arrows) -EPA also noted this. SPI Code should be eliminated

Georgia Institute of Technology Systems Realization Laboratory Ford Motor Company Problems noted with difference between European and U.S. views of recyclability The current language of the Guides [does not] adequately address the recyclability of durable automobiles Guides should not require that distinctions be made between pre- and post-consumer recycled material Products recycled after their final intended use by industrial customers should be included within the definition of “post-consumer material”