recognize bamboo as a fiber.
However, a Additional information can be found in
number of producers, manufactures, and
retailers have continued to mislabel their
products for several years, disregarding
FTC regulations. Of course, products
with a “green” label get the consumers’
attention, although unsubstantiated or
deceptive claims could actually hurt sales.
(See additional coverage about this topic in
this month’s ISO Update.)
ISO Update
Environmental Claims: A Guide for
Industry and Advertisers (Part 2)
T
his month, we continue our discussion
of Environmental Claims: A Guide
for Industry and Advertisers (the
Guide), which provides a “best practice”
guide for the application of the ISO 14021
standard regarding environmental labels and
declarations in the Canadian marketplace.
The guide also helps industry and advertisers
comply with certain provisions of the
Canadian Competition Act, Consumer and
Packaging and Labeling Act, and the Textile
Labeling Act. These laws are administered
and enforced by the Competition Bureau
(http://competitionbureau.gc.ca/eic/site/
cb-bc.nsf/eng/home), an independent agency
whose mission is “to protect and promote
competitive markets and enable informed
consumer choices.”
General Requirements
The Guide applies to manufacturers,
importers, distributors, retailers, or basically
anyone likely to benefit from self-declared
environmental claims, and usually focuses
12
the FTC Business Alert, “How to Avoid
Bamboozling Your Customers,” and the
FTC alert, “Have You Been Bamboozled by
Bamboo Fabrics?” that debunk the claim that
“bamboo” fabrics are “green” or eco-friendly
(see www.ftc.gov). For more information,
see www.sustainablelifemedia.com/content/
column/strategy/ftc_mulches_false_bamboo_
textile_claims. ■
on one or more environmental aspects of
the product. Users adhering to the Guide
should contribute to a level playing field
in the marketplace, help reduce the risk of
communicating misleading environmental
claims, provide an incentive to improve an
organization’s environmental performance,
and meet the growing consumer demand for
products and packaging that have a smaller
carbon footprint.
Environmental labeling is recognized by
the World Trade Organization as an effective
environmental policy tool. The applicable
Canadian laws are:
The Competition Act, which contains
provisions addressing false or misleading
representations and deceptive marketing
practices in promoting products or services.
The Consumer Packaging and Labeling
Act, which requires that prepackaged
consumer products have accurate and
meaningful labeling information for the

consumers’ benefit to make informed
purchasing decisions. False or misleading
representations are prohibited.
The Textile Labeling Act, which requires
that consumer textiles have accurate
and meaningful labeling information to
help consumers. False or misleading
representations are similarly prohibited.
Environmental Claim Requirements
The environmental claims a company makes
about itself, its products, or its services are
basically advertisements, and can take on
any form attributable to a media source,
such as statements, symbols, product
or package labels, product or service
collateral, advertising, etc. For example,
banners on the sides of buildings of many
organizations proclaiming “We’re certified to
ISO 14001” fall within this category, so such
proclamations are also subject to the scrutiny
of consumers should they decide to inquire
further (one of the elements of ISO 14001
describes this process for concerned
outside parties). The recent rush to attain
and proclaim Leadership in Energy and
Environmental Design (LEED) certification
is another example of such claims.
The Guide describes 18 specific
requirements that apply to an organization’s
self-declared environmental claims that
basically reinforce the overarching theme
of transparency: they must be accurate,
not misleading, and relevant to the product
or service in question, and specific to the
environmental aspect or improvement that is
being claimed. In addition, the information
provided must be substantiated and verified.
OCTOBER 2009
The ancillary requirements revolve around
these main themes.
Examples of specific claim requirements
are listed below.
Vague and Non-Specific Claims
The Guide describes how claims should
neither be vague nor non-specific; rather,
the claims should be clear and specific
in an attempt to protect consumers from
deceptive practices. Among the claim
terms that should not be used are: “safe
for the environment,” “non-polluting,”
“environmentally friendly,” “eco,” and
“green.” The Guide recommends such terms
only for those products and services whose
life cycles have been thoroughly examined
and verified. Other examples: “… product
uses green power” should be replaced with
“… product uses x% less electricity than our
previous model.”
“Free” Claims
Such claims should only be made when
the substance in question is no greater than
“background levels” attributable to naturally
occurring substances. Similarly, “trace
contaminants” refers to impurities in the
manufacturing process. The examples the
Guide refers to relate to “odor free” paints
and products “free of HCFCs.”
Another example would be “purity”
claims coming from the bottled water
industry. Bottlers have come under fire
repeatedly for some of their claims related
to purity of the product, along with its
source, such as so-called “pristine” water
13
sources, and whether there could also be
issues with the plastic used in some bottles.
The US Government Accountability Office
(GAO) recently issued a report in which
the agency raised concerns regarding
the US Food and Drug Administration’s
(FDA’s) regulation of bottled water under
the US Federal Food, Drug and Cosmetic
Act (FFDCA), and urged the FDA to
require bottlers to use labels that would tell
consumers where they could get additional
information about the products, their
sources, water purification processes, and
the amount of any trace contaminants that
may be present in the water. The full GAO
report can be downloaded at www.gao.gov/
new.items/d09861t.pdf.
Climate Change Update
Online Tool Helps Track States’ Climate Progress
T
he New America Foundation’s Climate
Policy Program recently released an
online tool to track carbon and energy
saving measures now being implemented
across the United States. The State Climate
Policy Tracker is a spreadsheet with one tab
for each state that has completed, or is in the
process of completing, a climate action plan.
The information is organized by economic
sector, and reports on the progress of each
measure, its cost or cost-saving potential,
and the estimated annual reduction in carbon
emissions expected from its implementation.
“Examine the Policy Tracker and you see
that US states — many with economies the
size of nations — have shown leadership on
climate action, but it hasn’t been sufficiently
14
Sustainability Claims
This metric has a long lead time and
organizations are encouraged to make such
claims using a long time horizon. The
Guide’s example looks at wood products.
The preferred label for such products
could be “this wood comes from a Forest
Stewardship Council (FSC) certified forest.”
The Guide further emphasizes that product
sustainability claims require life cycle
analysis to verify the claim.
We’ll finish up our discussion next month. ■
CONTACT: For BATE, Gabriele Crognale,
PE; E-mail: misteriso14k@aim.com.
appreciated,” said Climate Policy Program
Director Terry Tamminen. “We expect the
Policy Tracker will be extremely useful to
policymakers in the White House and on
Capitol Hill, to staff at [federal agencies],
as well as for other nations … to see what’s
working in real time.”
Since 2006, 33 US states have created
climate action plans to guide greenhouse gas
(GHG) reduction efforts. Each plan contains
on average 50 policy recommendations, and
states have already started to implement
many of them. The majority of measures in
these state plans were approved unanimously,
and so the Policy Tracker provides a snapshot
of measures that have already surmounted
political hurdles.
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