December 2010

In response to the Federal Trade Commission (FTC)’s Request for Public Comment for the Guides for the Use of Environmental Marketing Claims, I propose a two-part, science-based standard for claims. First, claims should only be allowed for product categories whose manufacture, distribution, use, or disposal have been shown, based on sound research, to contribute significant environmental impacts at the scale of the overall economy. Second, a claim is only appropriate if, in the event that every product in the category met the claimed performance, the overall reduction in environmental impacts at the scale of the whole economy would be significant.

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