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Bureau of Consumer Protection

 Division of Enforcement

[date]

VIA EXPRESS MAIL

[BUSINESS]

Dear _________:

The FTC enforces the Federal Trade Commission Act, 15 U.S.C. § 45, which 

prohibits deceptive advertising. In 2012, the FTC issued updated Guides for the Use of 

Environmental Marketing Claims (Green Guides), 16 C.F.R. Part 260 (enclosed). These 

Guides provide marketers with detailed information about how to make non-deceptive 

environmental claims, including through environmental certifications and seals of 

approval. 

After reviewing your website, we are concerned that your use of the 

environmental certification “______________” fails to conform to the Green Guides and 

therefore may be deceptive, in violation of Section 5 of the FTC Act. FTC staff has not 

determined whether your environmental claims violate the law. However, we 

recommend that you review your marketing materials, both on your website and in any 

other medium, with the following in mind:

The Green Guides caution marketers that unqualified general environmental benefit 

claims likely convey a wide range of meanings, including that a product has specific and 

far-reaching environmental benefits and that an item has no negative environmental impact. 

Section 260.4(b). The Guides further state: “Because it is highly unlikely that marketers 

can substantiate all reasonable interpretations of these claims, marketers should not make 

unqualified general environmental benefit claims.”

Additionally, the Green Guides state that environmental certifications or seals of 

approval may imply a general environmental benefit claim. Specifically, they state: “A 

marketer’s use of an environmental certification or seal of approval likely conveys that 

the product offers a general environmental benefit (see § 260.4) if the certification or seal 

does not convey the basis for the certification or seal . . . .” Section 260.6(d). They 

further caution:

Because it is highly unlikely that marketers can substantiate 

general environmental benefit claims, marketers should not use 

environmental certifications or seals that do not convey the basis 

UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580
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for the certification. 

The Guides advise marketers that they may prevent deception by accompanying 

the seal with “clear and prominent qualifying language that clearly conveys that the 

certification or seal refers only to specific and limited benefits.” Section 260.6(e). They 

also provide guidance on how to effectively qualify a certification based on broad-based, 

multi-attribute standards. See Section 260.6, Example 7.

The “_____________” logo featured on your website may deceptively convey 

that your product offers a general environmental benefit because it does not convey the 

basis for the certification. The logo is not accompanied by clear and prominent 

qualifying language that limits the claim to a specific benefit or benefits. Note that even 

if consumers may click on the __________ logo for more information, the logo itself is 

not likely an effective hyperlink label leading to the necessary disclosures. See “.com 

Disclosures,” https://www.ftc.gov/system/files/documents/plain-language/bus41-dot-comdisclosures-information-about-online-advertising.pdf. 

To assist you in reviewing your marketing materials to ensure that they include 

the necessary qualifications, you may also find the following information helpful: The 

Green Guides Statement of Basis and Purpose, available at 

https://www.ftc.gov/sites/default/files/attachments/press-releases/ftc-issues-revisedgreen-guides/greenguidesstatement.pdf.

Please advise us by ____________ of the steps you are taking to bring your 

marketing into compliance.

Please note that our review of your website was limited to the adequacy of the 

qualifications to the ______________ logo. We did not attempt to determine whether the 

website might be deceptive in other respects. The opinions expressed in this letter are 

those of the staff and not necessarily those of the Commission or of any Commissioner. 

Thank you for your attention to this matter. If you have any questions, please call 

me at ___________.

Sincerely,