If you haven’t had an opportunity to comment on the Federal Trade Commission’s potential updates and changes to its Green Guides, don’t worry. The commission has extended the public comment period by 60 days, until April 24.

The Green Guides are a set of administrative interpretations of the FTC Act to help marketers avoid making unfair or deceptive environmental marketing claims. It’s the first time in a decade that the FTC has updated the guides, and the FTC has said it was looking for comments about the “efficiency, costs, benefits and regulatory impact” of the guides.

A number of organizations, including the National Retail Federation, Sustainable Packaging Coalition and the U.S. Chamber of Commerce, requested an extension: “Our organizations appreciate the opportunity to provide comments and look forward to advising on specific aspects of the Guides,” a letter that included those groups noted. “In order to provide FTC with fulsome and accurate responses to its request for information, especially with regard to consumer perception research, it will take additional time, resources and evaluation by our respective organizations.”

A letter from a number of food and beverage packaging groups, including the International Bottled Water Association and the Council for Responsible Nutrition, noted that the FTC’s request for comment “covers a vast array of topics and claims affecting many industries and companies, including all consumer-packaged goods.”

They added: “Given the significant changes that have occurred in the more than one decade since the Green Guides were last revised – including changes to state and environmental laws, recycling infrastructure, markets for recycled materials, the array of new claims used in marketing, changes in recycling and composting technology, changes in consumer perception – we require additional time to address the FTC’s questions in a thoughtful and constructive manner.”

The Green Guides were issued in 1992 and were revised in 1996, 1997 and 2012. They provide guidance on environmental marketing claims, including how consumers are likely to interpret particular claims and how marketers can substantiate these claims to avoid deceiving customers.

With sustainability increasingly top of mind in the promotional products industry, it’s crucial to keep an eye on such developments, both to avoid greenwashing in marketing efforts and to stay on the right side of the law. Consider that in April 2022, the FTC asked the courts to penalize Kohl’s Inc. and Walmart Inc. a total of $5.5 million for falsely marketing dozens of rayon textiles as bamboo and saying that the goods were made using eco-friendly processes. In actuality, converting bamboo to rayon requires the use of toxic chemicals and results in hazardous pollutants, according to the FTC.

In its latest revisions, the FTC has said it is hoping for feedback on things like carbon offsets, climate change and terms like “recyclable” and “recycled content.”

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