Plastics Industry Association Submits Green Guide Comments to Federal Trade Commission on Behalf of Industry

April 24, 2023

Washington, D.C. – The Plastics Industry Association (PLASTICS) has submitted comments in response to the Federal Trade Commission’s (FTC) request for public comment on its Guides for the Use of Environmental Marketing Claims (Green Guides or Guides). PLASTICS’ comments strongly support and encourage national common-sense standards to promote truth in advertising on all aspects of environmental marketing.

“The FTC Green Guides have long set the marketing rules for things like recyclability and ideally they would into the future,” said Matt Seaholm, President and CEO of PLASTICS.  “Only recently did certain states begin to wade into this territory, creating confusion and establishing an unworkable patchwork of laws. Our industry is hopeful that this process provides greater clarity for manufacturers and marketers and that this review will serve as an opportunity for those states to attain guidance and adjust their respective laws accordingly. PLASTICS will be fully engaged throughout the process.”

“While updates are needed, revisions to the Green Guides should continue to offer claims guidance in a technologically and material-neutral manner,” said Patrick Krieger, Vice President of Sustainability for PLASTICS.  “The FTC green guides must promote the principle that truthful, non-misleading and substantiated marketing claims contribute to an effective circular economy, through uniform national standards for environmental marketing claims and by allowing consumers to exercise choice. These guidelines can thereby contribute positively to an environmentally conscientious understanding of responsible use by consumers.”

PLASTICS recognizes the FTC Green Guides as important guidance to industry on making environmental marketing claims, as the Guides assist the plastics industry with crafting truthful messages about the environmental benefits of their products and appropriate methods of disposal. As the market and technology have changed in the past decade, and as there is increased interest by state and local governments setting policy in this area, the Guides are now due for an update.

The Guides are non-binding statements of interpretation that are technologically and material-neutral and recognize the constitutional framework that protects truthful free speech, including advertising claims. PLASTICS’ comments have stated that revisions to the Green Guides should:

  • Continue to offer claims guidance in a technologically- and-material-neutral manner;
  • Continue to promote the principle that truthful, non-misleading, and substantiated marketing claims contribute to the marketplace of ideas that allows consumers to exercise choice; and
  • Continue to promote the goal of uniform national standards for environmental marketing claims.

The Plastics Industry Association (PLASTICS) is the only organization that supports the entire plastics supply chain, including Equipment Suppliers, Material Suppliers, Processors and Recyclers, representing over one million workers in our $468 billion U.S. industry. PLASTICS advances the priorities of our members who are dedicated to investing in technologies that improve capabilities and advances in recycling and sustainability and providing essential products that allow for the protection and safety of our lives. Since 1937, PLASTICS has been working to make its members, and the sixth largest U.S. manufacturing industry, more globally competitive while supporting circularity through educational initiatives, industry-leading insights and events, convening opportunities and policy advocacy, including the largest plastics trade show in the Americas, NPE2024: The Plastics Show