Understanding the New ‘Green’ Guidelines
While many industries will be impacted by the new green guidelines recently released by the Federal Trade Commission (FTC), few will be as affected as the professional cleaning industry. One reason for this is that the industry has wholeheartedly embraced green cleaning. In most cases, an environmentally preferable product is considered first, with a traditional, non-green product selected when a green alternative is not available or for some reason not cost or performance effective.
However, because the industry has jumped on the green bandwagon so enthusiastically, some of the environmental claims the industry has used to identify their products and services will need to be reexamined in light of the new FTC guidelines. Further, this will impact all parties in the industry—manufacturers, distributors, and you, the end customer—ultimately for the benefit of all.
Of the new guidelines, the first that building owners, managers, and purchasers should be aware of has to do with certification. The certifications and “seals of approval” found on the labels and marketing materials of many cleaning products, tools, and equipment fall into three categories:
- First-party certifications and seals are those that are created by the manufacturer of the product. Under the new guidelines, manufacturers must explain that the product has been “self-certified” and that this certification or seal has not been verified by an independent testing lab or similar organization. Of the three new categories, as owners, managers, and purchasers transfer to green cleaning strategies, this first-party form of certification may prove to be viewed as the least credible.
- Second-party certifications are those created by industry associations. At this time, ISSA, the leading association for the professional cleaning industry, is actively embarking on its own certification program. While this is certainly welcomed and will likely benefit the industry, products receiving such certifications will have to disclose this information, which may or may not be accepted by all purchasers of green cleaning products.
- The final category, third-party certifications, are considered the most credible. These certifications are earned after a product has been independently analyzed and meets the standards and criteria established by such organizations as green Seal, UL/Environment, and other respected enterprises.
Although it may seem easy to make a selection based on these categories—just look for a second- or, more likely, third-party seal when selecting a cleaning product—the FTC has made the process a bit more complicated.
While a third-party seal does not require a qualifying statement, as do first- and second-party seals, the new guidelines require all manufacturers to specify which attributes of the product meet the certification. This can be confusing and may require purchasers to do more due diligence when making purchases, but the goal here is to clarify that the certification may not apply to the entire product, just certain attributes, ingredients, or aspects of the product.
So what other changes has the FTC handed down that most specifically will impact the end customer?
First of all, terms such as “environmentally friendly,” “environmentally responsible,” “eco-friendly,” even the word “green” are now discouraged and may result in a fine or violation for the manufacturer and the distributor marketing the product. The FTC believes these terms have become too vague and can be deceptive, especially when used for marketing reasons. However, a manufacturer or distributor can use these terms if they explain why the product is considered a healthier alternative, assuming they meet specific FTC guidelines and criteria.
The FTC guidelines apply to environmental claims in labeling, advertising, promotional materials, and all other forms of marketing in any medium, whether asserted directly or by implication, through words, symbols, logos, depictions, product brand names, or any other means. More information is available here and here.
Another term that we may hear less and less is “free of.” In some cases, manufacturers have said a product is “free of” a potentially harmful ingredient when another ingredient, often considered just as potentially harmful, has been substituted. In addition, the term cannot be used on a product that has never contained the harmful ingredient.
These changes apply not only to the manufacturer but also, as referenced earlier, the distributors who market these products. Any environmental claims promoted for a product in marketing and sales materials must now be substantiated.
So what’s the bottom line? For the professional cleaning industry, the bottom line is that all environmental claims must be much more specific and verified. And this is actually the bottom line for the end customer as well. This greater specificity will result in much greater transparency so that purchasers will know more exactly why the products they select for use in their facilities have been labeled Green.
Stephen P. Ashkin is president of The Ashkin Group, a consulting firm specializing in greening the cleaning industry and CEO of Sustainability Tool LLC, an electronic dashboard that allows organizations to measure and report on their sustainability efforts. He is also coauthor of both The Business of Green Cleaning and Green Cleaning for Dummies.
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