Press Release

Consumer Brands Weighs in on FTC’s Green Guides Review

ARLINGTON, Va. – The Consumer Brands Association pushed for the Federal Trade Commission (FTC) to account for major shifts in consumer expectations and stakeholder commitments around environmental marketing claims this week in its update to the Guides for the Use of Environmental Marketing Claims (“Green Guides” or “Guides).”

“Consumer Brands strongly supports this much-needed update to the Guides, as research shows that consumers are growing more conscious about the environmental impacts of their purchasing decisions,” said Joseph Aquilina, senior director and associate general counsel of Consumer Brands.

“We encourage the FTC to engage with state regulators to seek recognition and reinforcement of the key role the Guides play as a framework on how to appropriately validate truthful environmental claims, while encouraging innovation to expand possibilities for sustainable practices and solutions.”

Consumer Brands’ formal comment submission detailed recommendations the FTC should pursue in the Green Guides update to facilitate companies’ efforts to clearly convey their sustainability efforts and recycling information on product packaging and promote innovation:

  • Provide clear, specific and actionable insights for industry that accurately reflect consumer expectations, marketplace dynamics and innovation.
  • Address emerging technologies, such as digital labeling tools like SmartLabel that can deliver localized recycling information to consumers and consider new recycling capabilities on the horizon to empower further sustainability and recycling innovation.
  • Ramp up interagency collaboration with other federal agencies grounded in environmental policy expertise to enhance consumer protection efforts.

Consumer Brands also urged the FTC to distinguish environmental marketing claims from recycling instructions in the Guides update.

“Recycling instructions speak to the process consumers should follow for effective end-of-life management, while composition claims speak to the packaging’s sustainable production or recycling potential,” said John Hewitt, vice president of packaging sustainability at Consumer Brands.

“The Guides update should accurately reflect this distinction in order to provide a more effective tool for consumer protection.”


The Consumer Brands Association champions the industry whose products Americans depend on every day, representing nearly 2,000 iconic brands. From household and personal care to food and beverage products, the consumer packaged goods industry plays a vital role in powering the U.S. economy, contributing $2 trillion to U.S. GDP and supporting more than 20 million American jobs.