Green advertisements haunt me like ghosts across the internet.
As the co-founder of GoodGuide, I regularly spend time on the web sites of “green” brands researching the ingredients in their products, their environmental and labor policies, and their disclosure of the supply chains behind the products we think we know. Then, sometimes two weeks after this research, while visiting totally unrelated news sites, I am served up ads from those very same green brands.
In this age of behavioral marketing – with personally targeted ads following you across the web, mobile advertising that knows where you are and what you like, and neuroscience-based research tuning emotional responses to words, icons, and impressions – the Federal Trade Commission’s new draft “Green Guides” for regulating green marketing appear almost quaint.
To paraphrase Jon Stewart…the FTC has arrived at a knife fight with an NPR tote bag filled with government reports.
The FTC’s 200 page draft Green Guide on green marketing – which is currently under review after a lengthy public comment period – asks companies to refrain from environmental claims that may confuse or deceive consumers. In particular, the FTC asks firms to stop making claims that are overly general such as “environmentally friendly” or “eco-friendly” which are “nearly impossible to substantiate.” They have also proposed clearer guidelines for the use of phrases such as: “free of,” “recyclable,” “degradable,” “compostable,” “renewable,” and “carbon offsets” in marketing materials.
The FTC is also now asking firms to qualify, specify, and back-up their claims with “reliable scientific evidence.” They are encouraging companies to move away from using “unqualified certifications or seals of approval” in their marketing.
These are all positive steps. Don’t get me wrong.
However, there are some glaring omissions in the guidelines. Amazingly, the FTC offers no guidance for the use of the words “sustainable,” “green,” or “natural.” These are probably the most frequently used terms in green marketing today. Google Insights shows the terms “green” and “natural” are used in product searches 10-20 times as often as the phrases the FTC is proposing to regulate.
The FTC argues that terms like “sustainable” are so vague that consumers are not confused into thinking products are environmentally sound when they see them in marketing materials. The FTC has also demurred on assessing newer environmental terms such as “Life Cycle Assessment” and “Green Chemistry” that have grown in use since they last updated the Green Guides in 1998.
The problem with the FTC’s partial-measures on green marketing is not just that a few consumers will be deceived by green marketing claims. More importantly, the FTC’s failure to address the most common green terms in the fastest growing online and mobile marketing channels may lead to an environment in which consumers are subtly infused with “greenwash” and thereby learn to not believe any green products.
According to a recent study by TerraChoice, green marketing claims are on the rise. The government can and should play an active role in policing the worst abuses of this greenwash. But the FTC can go further by helping to level the playing field of market information by encouraging firms to be more transparent about their actual ingredients, production processes, and environmental impacts.
It may sound counterintuitive in our current political climate, but a better regulated market – and in particular clearer rules on what firms can and should say about their products – will help the best firms and products win, and ultimately create an environment for sustained growth of greener products.
The FTC has considerable work to do to catch up with the latest in online green marketing.
In the interim, we recommend you always do your own research on sites like GoodGuide to look beneath the marketing claims to what is really inside the products you are buying.