IBA Submits Comments on Guides for the Use of Environmental Marketing Claims
Wednesday, April 26, 2023
Posted by: Arnyae Neal
IBA provided public comment to the Federal Trade Commission (FTC) as part of the request notice "Guides for the Use of Environmental Marketing Claims," Green Guides Review, Matter No. P954501, 87 Fed. Reg. 77766 (December, 2022). IBA fielded input from committee members who represented a cross-section of the industry and were familiar with the FTC Green Guides, a resource developed by the Commission to help companies avoid making unfair or deceptive environmental marketing claims. IBA’s comment letter included feedback on the need to harmonize guidance with laws and standards in other jurisdictions to reduce confusion, the need to manage costs and ensure a level playing field for entrepreneurial companies, and a more frequent review period to keep pace with rapidly evolving technology and innovation. IBA also provided a list of environmental marketing claims commonly used in the beauty industry, and that further definitions and substantiation guidance would be helpful, as claims may differ across industries. You can read IBA’s letter and read other public comments on the Regulations.gov website (Docket FTC-2022-077).
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