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Illinois Attorney General
Kwame Raoul

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April 25, 2023

Raoul and Coalition Call for Higher Benchmarks for Green Guides Standards on Environmental Advertising to Prohibit Deceptive Marketing to Consumers 

Chicago – Attorney General Kwame Raoul, as part of a coalition of 16 attorneys general, today filed a comment letter urging the Federal Trade Commission (FTC) to strengthen its Guides for the Use of Environmental Marketing Claims, or “Green Guides,” which are used by states like Illinois to hold marketers accountable and protect consumers.

In their letter to FTC Chair Lina Khan, Raoul and the coalition call for updates to the federal Green Guides to bolster consumer protection laws against advertising that overstates environmental benefits, often called “greenwashing.”

“As consumers continue to show increased interest in environmentally-friendly products and services, it is vital they have access to accurate and timely information regarding their potential purchases,” Raoul said. “The FTC must strengthen their process for ensuring consumers are protected from companies providing overinflated or even false claims about their products’ environmental benefits.” 

The Green Guides were first developed in 1992 by the FTC to hold marketers accountable for deceptive marketing claims under state consumer protection laws. The Green Guides are an essential tool in public and private efforts to address critical environmental issues by helping to ensure that consumers are not misled when making purchasing decisions based on the claimed environmental benefits of products and services.  

Raoul and the coalition recommend the FTC continue to publish, clarify and strengthen the Green Guides, and also expand the scope to consider how the standards for each environmental marketing claim could be clarified and strengthened to better ensure they are supported by real environmental benefits. Additionally, Raoul and the coalition argue that the Green Guides should not preclude states and localities from enacting stronger standards. 

More specifically, the coalition advises that the following be included in updated guidance: 

  • Voluntary carbon offsets should ensure a reduction in greenhouse gas emissions that is additional to any reduction that would likely have occurred without the purchase of the offset.
  • The definition of “compostable” should incorporate both scientific standards and the known practical limitations of composting at scale.  
  • The FTC should make explicit that “recyclable” means what the FTC has intended it to mean and what consumers understand it to mean, namely that when the consumer properly disposes of a “recyclable” item, it is actually recycled as a matter of course.
  • A renewable energy claim should be underwritten by actual environmental benefit, wherein marketers who make renewable energy claims must actually procure and use renewable energy.

Joining Raoul in the comments are the attorneys general of California, Connecticut, Delaware, the District of Columbia, Maryland, Massachusetts, Michigan, Minnesota, New Jersey, New Mexico, New York, Oregon, Pennsylvania, Rhode Island and Wisconsin.