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Green Report sets guidelines, causes reactions in disposables industry.

Green Report Sets Guidelines, Causes Reactions In Disposables Industry

the recently-released report of environmental recommendations causes some controversy among manufacturers of disposable products; the Attorneys General report sets guidelines for future government and industry action As discussion of the environment, its problems and the effects of these problems reached a crescendo during the past year, some of the "powers that be" got together to do something about it. The result is the recently published "Green Report," which was released Oct. 8 from a Task Force formed by the attorneys general from California, Florida, Massachusetts, Minnesota, Missouri, New York, Texas, Utah, Washington and Wisconsin.

The report was compiled after a national public forum--co-sponsored with representatives from the Federal Trade Commission and the Environmental Protection Agency--that took place last March and included testimony and written comments from leaders in business, environmental groups and consumer groups. The Task Force has also been gathering information in a year-long investigation of deceptive environmental claims.

Divided into three sections, the "Green Report" summarizes the events of the meetings and makes recommendations for the federal government and for industry on how these two segments can make the world a "better environment" in which to live. Section One of the report explains how and why state and federal officials became concerned about the growing number of environmenatal marketing claims while the next section provides an overview of the testimony presented at the Public Forum and identifies the major areas of agreement and controversy. The final section sets forth recommendations of the Attorneys General on the Task Force.

Once the report was published, the Task Force continued its dialogue with concerned groups last month by holding open hearings on its preliminary recommendations; results of these meetings--which took place Dec. 10, 11, in San Diego, CA--are not yet available.

A Review Of The Recommendations

With the goal of reducing the current confusion and potential for customer exploitation, the Task Force made recommendations for both federal government and industry to follow. The recommendations currently hold no legal power, but the parties involve hope they will be a starting point for further legislation. The guidelines for federal action focused on the following issues:

1. Definitions. The federal government should adopt a national regulatory scheme establishing definitions for environmental marketing claims to be used in the labeling, packaging and promotion of products on the basis of environmental attributes. "This regulatory scheme should be developed with input from and after consultation with the states and should be enforceable by both state and federal officials," said the report. "In should be concurrent with existing state and federal laws governing false advertising and deceptive trade practices."

2. Testing Protocols. The federal regulatory scheme should include testing procedures and standards for determining whether a product meets a particular definition. "....Without standard testing procedures to determine if a particular product meets that definition," explained the report, "...the product might be able to technically meet the definition if it is exposed to environments or testing procedures that do not approximate the customary use or disposal method of the product." The report especially recommended a "cradle-to-grave" product assessment; a methodology for this is already in the works at several offices of the EPA (see EPA Working On `Cradle-To-Grave' Product Assessment).

3. Need for Government Regulation. While some organizations wanted industry guidelines sponsored through agencies such as the Better Business Bureau or the American Association of Advertising Agencies, the Task Force has decided that governmental regulation is preferable. "Environmental advertising affects an unprecedented and broad range of participants...There is currently no existing business or trade organization that could quickly bring together all the affected organizations," said the report. "...The wide range of business interests implicated in environmental marketing might result in competing and conflicting industry sponsored standards."

4. Seal of Approval Programs. There are two seal of approval programs underway in the U.S.--the Green Cross and the Green Seal--both of which award seals of approval only to companies that apply for them. Seal of approval programs involve a third party endorsement and generally set higher standards in a particular product category, while the Task Force recommendations would only provide minimum requirements.

Because of the differences, both systems could work side by side, the report said, but it does caution that the programs themselves could be confusing. "Because they generally involve an overall stamp of approval rather than a description of specific environmental attributes of a product, they are necessarily based on complicated value judgments aboutwhat is best for the environment," said the report.

And For Industry...

The Task Force also made a set of recommendations for business to follow. According to the Attorneys General, a comprehensive framework for environmental claims is needed, but this is a time consuming and complex undertaking and it has, in the interim, provided business with some preliminary recommendations. Included in these are:

1. Claims Should Be Specific. Environmental claims should be as specific as possible, not general, vague, incomplete or overly broad.

* Generalized claims such as "environmentally friendly" or "safe for the environment" involve value judgments and should be avoided or, if used, should also specify prominently the basis of the claim.

* A previously existing but identified environmental attribute should be identified as such; consumers should not be led to believe that the product has been modified or improved

* If a harmful ingredient has been removed, the consumer should not be given the impression that the product is good for the environment in all aspects.

* A clear distinction should be made between the environmental attributes of a product and the environmental attributes of its packaging.

* The word "recycled" alone does not provide a consumer with enough information to make meaningful comparisons between products; products should also say what percentage of recycled material is used. In addition, the distinction should be made between pre-and post-consumer recycled material.

* Any specific claim that includes a comparative statement such as "better for the environment" should only be used if a complete and full comparison is made and the basis for comparison is stated.

2. Claims Should Reflect Current Disposal Options. Environmental claims related to disposability should not be made unless the advertised disposal option is currently available to consumers in the area in which the product is sold and product complies with the requirements of the relevant waste disposal programs.

* Products currently disposed of primarily in landfills or through incineration--whether paper or plastic--should not be promoted as degradable, biodegradable or photodegradable.

* A product should not be promoted as "compostable" or "compostable where facilities exists" or "recyclable" or "recyclable where facilities exist" unless the particular item is currently composted or recycled in a significant amount in the area in which the product is sold.

* A manufacturer may not promote a product as "safe for incineration" if the product contains materials sought to be controlled by the waste district of the area in which the product is sold.

3. Claims Should Be Substantive.

* Trivial and irrelevant claims should be avoided.

* Single use disposable products promoted on the basis of environmental attributes should be promoted carefully to avoid the implication that they do not impose a burden on the environment.

4. Claims should be supported. Environmental claims should be supported by reliable scientific evidence.

* Advertising claims must be supported by tests, analysis, research or studies conducted or evaluated in an objective manner by persons qualified to do so using procedures generally accepted by others in the profession to yield accurate and reliable results.

The Public Forum

The forum that was held last March gave rise to many of the above recommendations. Companies that participated were asked to focus remarks on several aspects of environmental marketing, such as current trends, the greatest areas of potential abuse and methods for promoting honesty and full disclosure.

Among the participants were Procter & Gamble, James River Corp., Archer Daniels Midland, American Enviro, RMed International, Dow Chemical, Weyerhaeuser and Nice-Pak. Other companies in attendance included 3M, Air Products & Chemicals, DuPont, H.B. Fuller, ICI Americas, Kimberly-Clark, Personal Products, Pope & Talbot and Tambrands.

"The most surprising, and encouraging, aspect of the Public Forum," said the report," was the broad based agreement on many key issues...the Task Force has identified eight issues on which there was virtually unanimous agreement at the Public Forum."

The issues in agreement were:

* Increasing consumer demand for environmentally friendly products. "Consumer interest in purchasing products that are less harmful to the environment has increased dramatically over the past year and has become perhaps the most important marketing trend of the decade," the report said.

* Intense competitive pressures. Many companies testified that competitive pressure was the chief reason they began making environmental claims and some stated this competitive pressure had taken precedence over their concerns about whether the information contained in the environmental claim was useful and valuable to the consumer.

* Mounting consumer confusion. "The words commonly used in environmental marketing, such as 'environmentally friendly,' 'degradable,' 'recyclable' and 'ozone friendly' have no clear uniform meaning," said the report. Also, "the science involved in understanding the environmental issue underlying these claims is complicated and the related technologies associated with environmental management are undergoing rapid change."

* Derailing environmental efforts. Business and environmental groups both expressed concern that if consumers felt companies were taking advantage of them regarding environmental issues, they would stop taking environmental considerations into account when purchasing a product.

* Recognition of corporate environmental responsibility. Virtually all business representatives admitted a duty to "minimize the adverse environmental impacts of its products....this responsibility requires a careful review of all of the environmental effects at each stage of every product's lifestyle."

* Need for uniform standards. Almost every organization testifying at the forum urged the development of uniform national standards to guide businesses in making environmental claims and to assist consumers in understanding them.

* Fostering competition. Organizations cautioned that standards or guidelines designed to protect consumers from misleading environmental advertising must avoid stifling the forces of competition necessary to encourage the development and promotion of more environmentally benign products.

* Standard setting process. Two chief concerns with the procedure for the standardization of environmental claims were addressed. The first was that guidelines be adopted on a national level, since much of the advertising is carried out nationally. The other was that the standardization be established "through an on-going dialogue among all parties concerned--public officials, environmental and consumer groups and business representatives."

Some Areas Of Dispute

Not everything was agreed upon at the public forum, however. In particular, three issues were the subject of great debate. The first was the topic of degradability claims. On one side of the issue were the "degradable" plastics manufacturers, who argued that their products did degrade in certain environments and made a contribution to environmental protection, while on the other side of the coin were those who claimed these degradable products offered no environmental benefits because they were disposed of in land-fills.

Another controversial issue dealing with degradability was whether "degradable" plastic products interfere with recycling because of the additives they contain. Some participants argued that degradable plastic products do interfere with specific plastic recycling technologies and that several recycling companies had stopped recycling polyethylene plastic bags because of increasing contamination by starch-based biodegradable bags.

There was also a lack of agreement about calling a product recyclable if there are no recycling facilities in the area. Several manufacturers felt it was appropriate because such labels increase public awareness that the product is technically capable of being recycled, while others felt using the term where consumers could not recycle only added to consumer confusion.

The third point of contention had to do with the actual meaning of the word "recycled." Many manufacturers who use pre-consumer waste said that it is appropriate to label their products as recycled because recycling pre-consumer waste reduces the amount of material that must ultimately be disposed. Other manufacturers and environmental groups argued that consumers understand recycled to mean post-consumer waste only.

EPA Working On `Cradle-To-Grave' Product Assessment

To combat the growing need for monitoring the environmental impact of products, the EPA has begun work on a two year project to develop a method for a "cradle-to-grave" assessment of consumer products. At a meeting of INDA's Government Relations Advisory Board last November, Sharon Stahl, acting chief of the policy analysis branch of the EPA's Office of Pollution Prevention provided an overview of the project, tagged the "Consumer Product Comparative Risk Project."

The EPA had drafted legislation for a national labeling program similar to those in Canada and Germany, Ms. Stahl said, but then did not push the idea during the 101st Congress. One reason for this, according to Ms. Stahl, was that at least two "private" labeling programs--Green Cross and Green Seal--are currently in operation and the EPA wanted to give these programs a chance to work before stepping in with mandatory federal programs.

Instead of a labeling program, the EPA has embarked on its two year, million dollar study to develop a methodology for conducting product life assessments. The project, which began in July 1990 and is funded through October 1991, is divided into five phases. The first selects a peer group and the second develops a method for applying lifecycle impacts. The third phase selects products for initial evaluation and the fourth analyzes and refines the method. The fifth and final phase develops a communications strategy to make consumers aware of the information.

The project is a joint effort of the EPA's Office of Air Quality Planning and Standards, the Office of Solid Waste and the Office of Research and Development.

ELLEN NOONAN Associate Editor
COPYRIGHT 1991 Rodman Publications, Inc.
No portion of this article can be reproduced without the express written permission from the copyright holder.
Copyright 1991 Gale, Cengage Learning. All rights reserved.

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Title Annotation:includes related articles on the Green Report and EPA monitoring; state government attorneys general task force report of environmental recommendations
Author:Noonan, Ellen
Publication:Nonwovens Industry
Date:Jan 1, 1991
Previous Article:Private label feminine hygiene: fourth in the sanpro race.
Next Article:A commitment to nonwovens.

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