🇺🇸 FTC Green Guides: From theory to practice

While the publication of the UK’s Green Claims Code has made some noise in the industry, the Green Guides from the US Federal Trade Commission (FTC) have been around quietly and humbly since 1992. On the one hand, American marketers are trained to be in tune with legal regulations. From our side, CarbonCloud is trained to fuel fully substantiated climate footprints. That’s why we read FTC’s Green Guides for you: We walk you through how your climate footprint complies with the environmental claim guidelines in the US.

What are the Green Guides?

The Green Guides, or as formally named, Guides for the Use of Environmental Marketing Claims, are an administrative interpretation of the law that aims to outline the criteria for accurate, non-misleading environmental claims for marketers.

Environmental claims fall under the Federal Trade Commission Act, which is a United States Federal law. It was established by the Federal Trade Commission (FTC), a US governmental agency whose principal mission is the enforcement of civil U.S. antitrust law and the promotion of consumer protection. With this in mind, the Green Guides are not enforceable themselves. They encompass what the FTC may find deceptive under Section 5 of the FTC Act, which prohibits deceptive acts and practices around commerce.

The last revision of the Green Guides took place in 2012 and the scheduled ten-year review is ongoing in 2022 [1].

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    What are the Green Guides’ criteria for legitimate environmental claims?

    According to the Green Guides, an environmental claim must be truthful, not misleading, and supported by a reasonable basis.

    Let’s unpack the criteria.


    This is an easily graspable criterion. If you are making an environmental claim, it should reflect the truth. Lying in an environmental claim is a sure way to court.

    Not misleading

    Overstatements, generalizations, omissions fall under this criterion. To steer clear of an accusation of misleading consumers, the FTC states that environmental claims:

    • Should clearly state where the benefit applies: The product, the packaging, or the service. For example, if a product bears a claim “Now more eco-friendly” aiming to convey a 15% reduction in the weight of packaging, this claim will be considered misleading.
    • Should not overstate the benefits: This applies also to negligible benefits marketed as a big step. For example, if a product states “30% less emissions from packaging” and the emissions reduction from this action in the product’s total climate footprint is 1%, the claim is considered misleading.
    • Should not generalize: The FTC is side-eyeing the all-encompassing, overgeneralizing environmental claims or claims that allude that a product or a service has no negative impact on the environment. The strongly recommend route here is, if you make an environmental claim, make sure that it is specific on the benefits. Phrases like ‘green’, ‘eco’, ‘sustainable’ are not only passé but on a legal watch globally.

    Supported by a reasonable basis

    Or, in other words, your environmental claim must be substantiated. Moreover, if the claim is based on qualifications, the results should be clear, prominently featured close to the claim, and understandable. The FTC provides clear, comprehensive criteria on what it considers a reasonable basis.

    What is reasonable basis that supports an environmental claim?

    An environmental claim is considered to be made on a reasonable basis when it is based on competent and reliable scientific evidence. The FTC considers evidence ventures such as tests, analyses, research, and studies that are generally accepted to yield robust results. This evidence should be conducted and evaluated by qualified individuals and based on generally accepted standards.

    It’s important to note here that the claim must be substantiated on a reasonable basis prior to the publication of the ad. Advertisers are not allowed to create entirely new substantiation simply because their prior substantiation was inadequate.

    What does this mean for my CarbonCloud climate footprint?

    It generally means that you are covered! But in the spirit of following the Green Guides, let’s be specific!

    Your climate footprint is truthful and our 3rd party verification is in place to confirm exactly this. The footprints are verified by an impartial person with professional judgement and technical knowledge – as requested by the ISO 14066 standard on competence requirements for verification teams. The platform you are using adheres to the principles of recognized standards for climate footprint measurements, such as ISO 14067 and GHG Protocol Product Life Cycle Accounting and Reporting Standard.

    Moreover, your climate footprint is accompanied by a technical report. The report diligently and comprehensively breaks down where your emissions come from and which stages of the process are covered in the assessment. This technical report serves both as substantiation and a specification of your claim, in the format requested by ISO 14067 and GHG protocol Product Life Cycle Accounting and Reporting Standard, which provides recognized substantiation for the climate footprints.

    All in all, we’ve got your back!

    Is the climate footprint label considered an expert endorsement?

    Yes, it is – and it complies with all the criteria for an expert endorsement. Firstly, our reviewing team is selected based on their expertise in the domain you are making the claim.

    As CarbonCloud is an organization, we are diligent in complying with the organization endorsement criteria as well. Climate footprints represent the judgment of a group with collective experience that exceeds the individual reviewer and any subjective factors. This is ensured by the robust 3rd party verification process.

    And all these goodies are in the climate footprints CarbonCloud provides you with. Your next step is to ensure that any claim based on the climate footprint is transparent and not misleading. If you’ve set out to let the US market know all about your climate footprint, your CO2es have their i’s dotted and t’s crossed!


    Disclaimer: This article summarizes the general principles to follow with the goal of compliance awareness and is not legal advice. Please consult your legal advisor before publishing your marketing campaign, to make sure that you adhere to the FTC Act, and any state regulation that applies to you.