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ARTICLE · 23 DECEMBER 2022

US FTC Announces Possible Updates To "Green Guides"

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On December 14, 2022, the United States Federal Trade Commission ("FTC" or "Commission") announced that it is seeking public comment on possible updates and other changes...

United StatesEnvironment
J. Paul Forrester
J. Paul Forrester
Christopher B. Leach
Christopher B. Leach
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On December 14, 2022, the United States Federal Trade Commission ("FTC" or "Commission") announced that it is seeking public comment on possible updates and other changes ("Request for Public Comment" or "RPC") to its current "Green Guides" (Guides) on the use of environmental marketing claims. The FTC initially adopted the Guides in 1992, and they were last revised in 2012.

Background

The Guides outline general principles applicable to all environmental marketing claims and provide specific guidance regarding many common environmental benefit claims. For each claim covered, the Guides (1) explain how reasonable consumers are likely to interpret it, (2) describe the basic elements necessary to substantiate it and (3) present options for qualifications to avoid what the FTC believes may amount to deception. While the Guides include illustrative qualifications to provide examples for marketers seeking to make non-deceptive claims, the examples do not represent the

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