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MEEF - Energy Articles - About Green Buildings
Tips for Marketing Your
Environmental Building Materials
Source: Robin Bectel,
NAIMA
Ok, we know you're the good guys. Here are some tips anyway, courtesy
of the National Insulation Manufacturers Association.
As the green building industry matures, many, if not all, manufacturers
have added environmental claims to their marketing messages. In doing
so, some companies have inadvertently and even purposely overstated or
failed to qualify their claims. When this happens, the entire industry
suffers. In such a nascent industry, it is critical that all suppliers
follow both the letter and spirit of the Federal Trade Commission’s
Guidelines on Environmental Marketing.
The members of the North American Insulation Manufacturers Association (NAIMA),
which represents companies in the fiber glass and rock and slag wool
industry, call upon building materials manufacturers to commit to an
accurate portrayal of the “green” attributes of their respective
products by adhering to the Federal Trade Commission’s (FTC) guidelines
regarding the use of environmental marketing claims. NAIMA strongly
believes that it is in the best interest of the industry to compel a
standard of conduct that, at a minimum, complies with applicable laws
and regulations governing environmental marketing claims. For its part,
NAIMA and its member companies have pledged to rigorously adhere to
these guidelines in their environmental advertising and marketing
practices for fiber glass and rock and slag wool insulation products. We
hope other building material manufacturers and suppliers will join us in
this pledge.
The FTC guidelines are composed of general principles and specific
guidance on the use of environmental claims. These guidelines apply to
claims included in labeling, advertising, promotional materials and all
other forms of marketing, including words, symbols, emblems, logos,
depictions, or product brand names.
Be able to substantiate a claim. When making a claim about the
environmental attribute of a product, a manufacturer must possess
substantiation for the claim. This often requires competent and reliable
scientific evidence, such as tests, analyses, research, studies or other
evidence based on the expertise of professionals. Claims should be made
to represent the way the product is actually used and installed in the
field using procedures generally accepted in the profession to yield
accurate and reliable results. For example, some products will claim to
be “non-toxic,” because they are made from natural materials, without
disclosing the addition of various chemicals used for mold resistance or
fire safety.
Make a distinction between benefits of product, packaging, and
service. An environmental claim should make it clear if the “green”
attribute applies to the product, the packaging or the service or to
just a portion of one of the above. For instance, don’t label a product
as recyclable without stating if the claim refers to the product or just
the box.
Don’t overstate your claim. Implication of significant
environmental benefits should be avoided if the benefit is in fact
negligible. Even if a claim is technically true, consumers could be
confused if it makes a benefit appear more significant than it really
is. For example, many building products made from combustible materials
such as paper or wood must add fire retardant chemicals to meet building
codes. Some manufacturers of these products have claimed their products
are made from “safe, natural materials.” This may be an overstatement
unless they ensure consumers are equally aware of the amount of
chemicals that have been added to that material.
Don’t make unqualified general claims. Unqualified or ambiguous
general claims of environmental benefit should be avoided. If a
manufacturer advertises its product as “environmentally preferable” the
claim is likely to convey to consumers that this product is
environmentally superior to other products. If the manufacturer cannot
substantiate this broad claim, the claim would be deceptive.
Avoid misleading comparative claims. Manufacturers should avoid
direct or implied comparative claims that mislead a consumer. For
instance, saying a product’s packaging creates “less waste than the
leading brand” should be substantiated with recent science or research.
The point of comparison should also be clear. Stating that a product
contains “20% more recycled content” should clearly show the basis for
the comparison.
Be clear on how much recycled content is used. For products or
packages that are only partially made of recycled material, a recycled
claim should be adequately qualified to avoid consumer deception about
the amount by weight of recycled content in the finished product. Few,
if any, products conation 100 percent recycled material.
Indicate clearly how a product can be recycled. A product or
package can be marketed as recyclable if it can be collected, separated
or otherwise recovered from the solid waste stream for reuse through a
widely established recycling program such as curbside recycling of
aluminum cans and glass bottles. However, indicating that a product is
“recyclable where facilities exist” should be more accurately portrayed
as “may not be recyclable in all areas.”
Examples of unqualified environmental claims made by some building
material manufacturers include:
-
”Earth Friendly”
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”Environmentally Friendly”
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”The Product of Choice for Environmentally
Concerned Builders”
Because none of these phrases are defined or
elaborated, they may confuse and mislead consumers.
Be cautious with claims of degradable/biodegradable/photodegradable.
Competent and reliable scientific evidence should exist that the entire
product or package will completely decompose into elements found in
nature within a reasonably short period of time after customary
disposal. If a product requires oxygen and light to break down, this
should be specified to avoid the implication that it will degrade in
every waste disposal environment.
Be cautious with claims of compostable. A claim that a product or
package is compostable should be substantiated by competent and reliable
scientific evidence that all materials in the product or package will
break down into, or become part of, usable compost in a safe and timely
manner in an appropriate composting program or facility.
”Source reduction”: A claim that a product or package has been
reduced or is lower in weight, volume or toxicity should be qualified to
the extent necessary to avoid consumer deception about the amount of the
source reduction and about the basis for any comparison asserted.
Make sure a product is widely refillable. An unqualified
refillable claim should not be asserted unless a system is provided for:
(1) the collection and return of the package for refill; or (2) the
later refill of the package by consumers with product subsequently sold
in another package.
“Ozone safe” and “ozone friendly”: It is deceptive to
misrepresent that a product is safe for or “friendly” to the ozone layer
or atmosphere. For example, a claim that a product does not harm the
ozone layer is deceptive if the product contains an ozone depleting
substance or indirectly contributes to ozone depletion through the
inclusion of volatile organic compounds (VOCs).
Be ready to defend your claims. Make sure you can quickly respond
to consumers’ requests for further information. Make easily available
the following types of information as appropriate to your claims:
-
Test reports or data that substantiates all
claims
-
Specific recycling procedures or information
about recycling locations nationwide
-
An estimated decomposition timetable
-
A letter signed by an officer of the company
stating that the claims have been tested and proven true
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Third-party references for further information
Because the public has demonstrated a desire and
disposition to purchase products that have less detrimental impact on
the environment they are susceptible to erroneous or inaccurate
assertions of recyclability, recycled content, or any number of
ecological benefits. This makes it imperative for building materials
manufacturers to adhere to the FTC guidelines regarding the use of
environmental marketing claims. The guidelines encourage the free flow
of non-deceptive product information, which benefits both consumers and
those producers who desire to promote the positive environmental
attributes of their products. Adhering to these guidelines will help
this industry grow and prosper, benefiting all involved.
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