FTC Green Guides Explained and 3 Ways Companies Can Avoid Greenwashing

Greg Andeck
May 12, 2023
In this Q&A, Climate Neutral's Director of Partnerships, Greg Andeck, summarizes what you should know about the FTC Green Guides and offers three tips for making high integrity climate claims.

We recently sat down with our Director of Partnerships, Greg Andeck, to understand the latest news on the FTC Green Guides. Greg summarized the key things you should know about the Green Guides, as well as how companies can take action to avoid greenwashing. Let’s hop in.   

What are the FTC Green Guides? Why are they suddenly in the news?

The Green Guides are guidelines the United States Federal Trade Commission (FTC) provides to marketers who promote products as environmentally friendly or “green.” The Green Guides are not law, but they do help marketers comply with the law—specifically, Section 5 of the FTC Act that governs unfair and deceptive marketing. The Guides help marketers stay out of hot water with guardrails for “green” marketing claims.

For the first time in over a decade, the FTC is updating the Green Guides. The Agency recently sought public comments about a full range of environmental marketing messages, including how companies should talk about their climate initiatives. 

Why do the FTC Green Guides matter?

Climate change is now a leading issue of public concern. People are increasingly voting with their dollar and deciding what to buy, or not to buy, based on climate impact. We all make these purchasing decisions while walking down store aisles or perusing company websites, quickly digesting bite-sized pieces of climate marketing presented by brands. It’s critical that the public have trust in the things they read.

As FTC Chair Lina Khan has noted, if companies don’t tell the truth to consumers, “it distorts the market for environmentally friendly products. It puts honest companies, who bear the costs of green business practices, at a competitive disadvantage. And it harms consumers who want to make conscientious decisions about what products to buy and what businesses to support.”

Unfortunately, there’s more confusion than ever about corporate climate marketing claims. A smorgasbord of terms like “climate friendly,” “climate positive,” “carbon neutral,” "climate neutral," "net-zero,” and more have emerged. The FTC Green Guides offer an opportunity for companies to ensure they are being honest in their climate communications with consumers.

What did Climate Neutral recommend to the FTC in the recent comment period?  And how do those recommendations apply to companies who market their climate action? 

Climate Neutral has been on the frontlines educating companies and consumers about high integrity climate actions since 2018. We’ve seen a fair share of bad actors and deceptive actions in the market, and so we provided detailed comments to the FTC on their Green Guides update. 

Our comments can be summed up with three clear recommendations for companies that communicate their climate action: 

01 | Don’t overstate the scale of your climate initiatives

Avoid claiming your organization has taken major steps to address its emissions if those steps do not account for a substantial part of your company’s true impact. This includes taking accountability for your company’s operational emissions, as well your suppliers’ and manufacturing partners’ emissions. And only market actual results your organization has achieved—not promises or future pledges to reduce emissions by 2030 or 2050.  

02 | Use climate terms correctly - and sparingly

Steer clear of ambiguous climate terms like “climate smart,” “climate friendly,” or “climate positive,” etc. Those terms have no formal definition, and they can be easily misinterpreted by the public. 

Similarly, avoid the aspirational term “net-zero.” Next to no entities today can credibly claim to have already achieved net-zero—and so at best, net-zero should be described as a long term focal point.  

03 | Carbon offsets must be high integrity

If your organization makes climate claims that involve carbon offsetting, it is critical to invest in carbon credits that meet at least a minimum set of commonly accepted quality criteria, with transparent third-party verification. These minimum criteria can be based on the "core carbon principles" outlined by the Integrity Council for the Voluntary Carbon Market, which include independent third party validation, tracking and traceability, additionality, no double counting, and more. 

How can people take action against greenwashing?

Get involved! The initial FTC comment period recently closed, but we expect there will be additional opportunities to provide public comment to influence the final Green Guides update. We invite folks to visit www.climatelabel.org to learn more and share your thoughts directly with our team.

We also encourage you to put your values to action. Support companies leading the way, including Climate Neutral Certified brands. Reach out to companies via email or social if they are marketing climate claims you do not trust and ask them to do better. Companies listen - and your influence as an individual can go a long way toward getting them to replace greenwashed climate claims with solid, immediate actions.

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About the Author

Greg Andeck
Director of Partnerships

Our partnerships leader, Greg brings nearly two decades of nonprofit experience working on corporate, consumer, and policy solutions to the climate crisis. He loves to find opportunities for uncommon bedfellows to work together to protect the environment. Greg and his family can be found exploring the mountains and coast in North Carolina and searching out epic wilderness areas in Argentina.

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