The Federal Trade Commission (FTC) announced on December 14, 2022, that it is seeking public comment on potential updates and changes to the Guides for the Use of Environmental Claims (Green Guides). FTC intends the Green Guides to help marketers avoid making environmental marketing claims that are unfair or deceptive under Section 5 of the FTC Act. FTC states that it seeks to update the Green Guides “based on increasing consumer interest in buying environmentally friendly products.” FTC has posted a pre-publication version of the Federal Register notice. Publication of the notice in the Federal Register, which is expected in mid-January 2023, will begin a 60-day comment period. Given the commercial imperative to be “green” and “sustainable” and a member of the “circularity” crowd, the Green Guides are arguably more important now than they were when first issued. For more information and our Commentary, please read the full memorandum.
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