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Environmental Claims

Summary of the Green Guides

General Environmental Benefit Claims

O Marketers should not make broad, unqualified general environmental benefit claims like 

‘green’ or ‘eco-friendly.’ Broad claims are difficult to substantiate, if not impossible. 

O Marketers should qualify general claims with specific environmental benefits. 

Qualifications for any claim should be clear, prominent, and specific.

Q When a marketer qualifies a general claim with 

a specific benefit, consumers understand the 

benefit to be significant. As a result, marketers 

shouldn’t highlight small or unimportant 

benefits.

Q If a qualified general claim conveys that a 

product has an overall environmental benefit 

because of a specific attribute, marketers 

should analyze the trade-offs resulting from the 

attribute to prove the claim. 

Carbon Offsets

O Marketers should have competent and reliable scientific evidence to support carbon offset 

claims. They should use appropriate accounting methods to ensure they measure emission 

reductions properly and don’t sell them more than once. 

O Marketers should disclose whether the offset purchase pays for emission reductions that 

won’t occur for at least two years.

O Marketers should not advertise a carbon offset if the law already requires the activity that is 

the basis of the offset. 

Certifications and Seals of Approval

O Certifications and seals may be endorsements. According to the FTC’s Endorsement 

Guides:

Q Marketers should disclose any material connections to the certifying organization. A 

material connection is one that could affect the credibility of the endorsement. 

Q Marketers shouldn’t use environmental certifications or seals that don’t clearly convey 

the basis for the certification, because the seals or certifications are likely to convey 

general environmental benefits. 

Q To prevent deception, marketers using seals or certifications that don’t convey the basis 

for the certification should identify, clearly and prominently, specific environmental 

benefits. 

Claiming “Green, made 

with recycled content” 

may be deceptive if the 

environmental costs of 

using recycled content 

outweigh the environmental 

benefits of using it.
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Q Marketers can qualify certifications based on attributes that are too numerous to 

disclose by saying, “Virtually all products impact the environment. For details on which 

attributes we evaluated, go to [a website that discusses this product].” The marketer 

should make sure that the website provides the referenced information, and that the 

information is truthful and accurate.

Q A marketer with a third-party certification still must substantiate all express and implied 

claims.

 Compostable

O Marketers who claim a product is compostable need competent and reliable scientific 

evidence that all materials in the product or package will break down into — or become 

part of — usable compost safely and in about the same time as the materials with which it 

is composted. 

O Marketers should qualify compostable claims if the product can’t be composted at home 

safely or in a timely way. Marketers also should qualify a claim that a product can be 

composted in a municipal or institutional facility if the facilities aren’t available to a 

substantial majority of consumers. 

Degradable

O Marketers may make an unqualified degradable claim only if they can prove that the “entire 

product or package will completely break down and return to nature within a reasonably 

short period of time after customary disposal.” The “reasonably short period of time” for 

complete decomposition of solid waste products? One year. 

Q Items destined for landfills, incinerators, or recycling facilities will not degrade within a 

year, so unqualified biodegradable claims for them shouldn’t be made.

Free-of

O Marketers can make a free-of claim for a product that contains some amount of a substance 

if:

1. the product doesn’t have more than trace amounts or background levels of the substance; 

2. the amount of substance present doesn’t cause harm that consumers typically associate 

with the substance; and 

3. the substance wasn’t added to the product intentionally

O It would be deceptive to claim that a product is “free-of” a substance if it is free of one 

substance but includes another that poses a similar environmental risk.

O If a product doesn’t contain a substance, it may be deceptive to claim the product is 

“free‐of” that substance if it never has been associated with that product category
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Non-Toxic

O Marketers who claim that their product is non-toxic need competent and reliable scientific 

evidence that the product is safe for both people and the environment. 

Ozone-Safe and Ozone-Friendly

O It is deceptive to misrepresent that a product is ozone-friendly or safe for the ozone layer or 

atmosphere. 

Recyclable

O Marketers should qualify 

recyclable claims when recycling 

facilities are not available to at 

least 60 percent of the consumers 

or communities where a product 

is sold. 

O The lower the level of access to 

appropriate facilities, the more a 

marketer should emphasize the 

limited availability of recycling 

for the product.

Recycled Content

O Marketers should make recycled content claims only for materials that have been recovered 

or diverted from the waste stream during the manufacturing process or after consumer use. 

O Marketers should qualify claims for products or packages made partly from recycled 

material – for example, “Made from 30% recycled material.”

O Marketers whose products contain used, reconditioned, or re-manufactured components 

should qualify their recycled content claims clearly and prominently to avoid deception 

about the components.

Refillable

O Marketers shouldn’t make unqualified refillable claims unless they provide a way to refill 

the package. For example, they can provide a system to collect and refill the package or sell 

a product consumers can use to refill the original package.

If recycling facilities for a product are 

not available to at least 60 percent of 

consumers or communities, a marketer 

can state, “This product may not be 

recyclable in your area.” If recycling 

facilities for a product are available to only 

a few consumers, a marketer should use 

stronger qualifying language: “This product 

is recyclable only in the few communities 

that have appropriate recycling programs.”
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Made with Renewable Energy

O Marketers shouldn’t make unqualified renewable energy claims based on energy derived 

from fossil fuels unless they purchase renewable energy certificates (RECs) to match the 

energy use.

O Unqualified renewable energy claims may imply that a product is made with recycled 

content or renewable materials. One way to minimize the risk of misunderstanding is 

to specify the source of renewable energy clearly and prominently (say, ‘wind’ or ‘solar 

energy’).

O Marketers should not make an unqualified “made with renewable energy” claim unless all, 

or virtually all, the significant manufacturing processes involved in making the product or 

package are powered with renewable energy or non-renewable energy, matched by RECs. 

O Marketers who generate renewable energy – say, by using solar panels – but sell RECs for 

all the renewable energy they generate shouldn’t claim they “use” renewable energy. Using 

the term “hosting” would be deceptive in this circumstance. 

Made with Renewable Materials

O Unqualified claims about renewable 

material may imply that a product is 

recyclable, made with recycled content, or 

biodegradable. One way to minimize that 

risk is to identify the material used clearly 

and prominently, and explain why it is 

renewable. 

O Marketers should qualify renewable 

materials claims unless an item is made 

entirely with renewable materials, except 

for minor and incidental components. 

Source Reduction

O Marketers should qualify a claim that a product or package is lower in weight, volume, or 

toxicity clearly and prominently to avoid deception about the amount of reduction and the 

basis for comparison. For example, rather than saying the product generates “10 percent 

less waste,” the marketer could say the product generates “10 percent less waste than our 

previous product.”

“This package is made from 50% 

plant-based renewable materials. 

Because we turn fast-growing 

plants into bio-plastics, only half 

of our product is made from 

petroleum-based materials.”

“Our flooring is made from 100% 

bamboo, which grows at the same 

rate, or faster, than we use it.”

To view the complete Green Guides, information for business, and legal 

resources related to environmental marketing, go to business.ftc.gov.