AAF Comments on FTC Green Marketing Guides

February 12, 2008

To: AAF Members

From: Clark Rector, senior vice president – government affairs

Re: FTC Green Marketing Guides

The Federal Trade Commission is currently undertaking a regulatory review of its environmental marketing guidelines, or “Green Guides.” The Guides were last updated in 1998.

The AAF has joined with AAAA and ANA to weigh in on the issue. Our comments urge the FTC to use caution and move slowly in any revision of the guides. We cite three primary reasons for caution:

  • The existing Green Guides, as well as existing FTC requirements for the truth and substantiation of advertising claims are effective in ensuring the truth and accuracy of environmental claims;
  • The advertising industry’s self-regulatory standards requiring that claims be truthful and substantiated apply to environmental advertising claims; and
  • Revising the Guides could have a chilling effect on environmental advertising claims by creating confusion or uncertainty as to advertising requirements.

A copy of our comments can be seen here. Do not hesitate to contact us if you have any comments or questions.