FTC “Green Guides” warn against making deceptive claims about recycled content Go

In support of  best practices in marketing claims, we have long warned our customers against using industry average data to make environmental claims about recycled fiber in coated fine papers.  Now, more than ever, we urge corporate marketers and advertisers to do their homework.

In October 2012, the US Federal Trade Commission (FTC) updated their “Guides for the use of Environmental Marketing Claims” more commonly referred to as the “Green Guides”.  In their summary document, highlighted on the cover page, readers will find this statement:

Claiming “Green, made with recycled content” may be deceptive if the environmental costs of using recycled content outweigh the environmental benefits of using it.

Clearly the federal government has seen enough evidence that in some cases recycled content can actually increase the environmental impact. And in fact, this is true for our paper mills in regard to greenhouse gas emissions.

At Sappi, we have studied the impact of using deinked market pulp (recycled fiber) as a substitute for our virgin kraft pulp made on site at our Somerset mill (Skowhegan, ME).  Recently published results show that adding 10% recycled fiber increases the carbon footprint by 16% as compared to a product made with 100% virgin fiber.  Meanwhile, the EPN’s “Paper Calculator” indicates that for coated freesheet paper (the type we manufacture) adding 10% recycled fiber decreases greenhouse gas emissions by 3%.*

Sappi’s integrated mills use over 80% renewable energy – far more than the industry average – resulting in a lower than average level of greenhouse gas emissions.  It is clear that the “Paper Calculator” does not accurately reflect the performance of our mills. 

Sappi has fully embraced transparency in reporting and we include a comprehensive set of key performance indicators in our regional sustainability report.  We have been long time supporters of the Environmental Paper Assessment Tool wherein users can study and compare actual mill data which is updated annually.  With access to so much current, mill specific data, there is no need to resort to using averages for making claims.  Worse yet, doing so could lead to deceptive claims.


*Environmental impact estimates were made using the Environmental Paper Network Paper Calculator Version 3.2. For more information visit www.papercalculator.org.

A word (or two) about eco-labels and claims Go

It seems everywhere we turn we see eco-labels and environmental claims– from appliances and cleaning supplies to apparel and automobiles.   Labels are also ubiquitous on paper products.  And why not?  We have a lot of environmental attributes to be proud of in our industry.  That said, it is not necessary to list every attribute every time we use paper. And with the revised FTC Green Guides finally released, there is reason for marketers to use caution.  Let’s use an example. Today I spotted a claim on a small brown paper bag (a food package) that read:

“This paper contains up to 60% post consumer recycled content and is biodegradable, recyclable and compostable.”

Up to 60%?  I’m honestly not quite sure what the brand owner is trying to convey.  60% on average?  I’m not sure…and would advise more specificity. 

Biodegradable, recyclable and compostable?  I guess the intent is to cover all bases.  Let’s take them one at a time: 

“Compostable” can be an important claim – especially for applications that often don’t get recycled – like direct contact food packaging, tissue paper or tea bags.   If you want to make a compostable claim, make sure you’ve done your homework and you have the test data to back up the claim.  According to the green guides:

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.

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.

The access to composting is growing in the US, but it is still not nearly as common as recycling facilities.  

And what about “biodegradable”?  According to the green guides:

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.

The guides go on to say:

Items destined for landfills, incinerators, or recycling facilities will not degrade within a year, so unqualified biodegradable claims for them shouldn’t be made.

To put it briefly – we should not be using biodegradable claims on paper products.  Period. 

Recycling is one of the paper industry’s greatest success stories.  Since 1990, the recycling rate in the US has doubled and paper is recycled at far higher rates than other materials.  But there is still room to do more.  People are more apt to engage in a behavior after being prompted - so be an advocate for recycling. Push for recycling initiatives at home, in the workplace and in your community. Put “please recycle” in a prominent place on printed materials your company produces.  When appropriate promote reuse and then recycling as an option.  

Remember the waste management mantra:  Reduce. Reuse. Recycle.  And then compost. In that order.

Is paper biodegradable? Go

In a word: yes.  And no.

Technically speaking, wood and other plant based fibers used in paper are biodegradable. However, if you want to take this information and apply it to an environmental claim on a printed piece – don’t

 At a recent conference, James Kohm, a representative of the Federal Trade Commission indicated that they discourage the use of biodegradable claims on ANY solid materials (i.e. this may still be ok for certain liquids, like laundry detergents).

In the eyes of the FTC, if something is biodegradable it must break down to elements of nature in one year using customary disposal methods.  And in the US, customary disposal of solid materials means a landfill, an incinerator, or a recycling facility.  Not a composting facility.  Not your backyard garden. 

And while we all eagerly await revisions to the “Green Guides”, The FTC has cracked down on major corporations for making misleading and unsubstantiated claims that their paper products were biodegradable. 

Of course when it comes down to it, for printing and writing grades, we shouldn’t be making biodegradable claims in the first place.  These products can be, and should be, recycled.

So if you want to make a claim and support the responsible use of paper, don’t even think about labeling your work as biodegradable.  Use a please recycle claim or logo and help us continue to increase recycling rates. 

Forget about biodegradable claims – and stick with please recycle! 

"Please Recycle" claims and logos - a simple and important demonstration of responsibility Go

All of Sappi’s fine paper products are recyclable and we want to do everything we can to help keep these products out of landfills. So, every chance I get, I try to encourage the creative community and corporate marketers to use “please recycle” claims or logos.

Our own collateral often reads: “Please help us preserve our planet. If you choose not to keep this ____[fill in the blank], please place it in a recycling bin.  Thank you.”  We encourage reuse first and then recycling.  The statement is often accompanied by the chasing arrow symbol.

The Association for Magazine Media (formerly the MPA) has developed a recycling logo specifically for magazines.  I can just imagine the conversations that went on in the development of the logo.  Something like: “If we just say ‘please recycle’ people might think it’s a reminder to recycle in general, pat themselves on the back for recycling cans and bottles, and then throw their magazine in the trash”.  So the logo is very clear.  Magazines are recyclable.  So are catalogs.  So is direct mail.  

The Direct Marketing Association has done a good job in creating a blue bin please recycle campaign which can be seen at this link:http://www.dmaresponsibility.org/recycle/ The DMA logos are commonly found on catalogs and direct mail post cards, but use is restricted to members only.  Both of the associations offer logos in English and Spanish.

Unlike certification programs, there is a lot of room for creativity in this space.  But be sure your message distinguishes between recycled content and encouraging people to recycle.  According to the FTC Green Guides, the chasing arrow symbol alone indicates that a product is made of 100% recycled materials and is recyclable.

If you are responsible for content development - ask yourself - am I doing enough to promote recycling of paper products?  If you have any examples of creative executions, please share.