Small Logos, Big Meaning:Hot on the Trail of Credible Certification

Green Roundtable Webinar 12.1.10Mark T. Petruzzi, VP of Certification & Strategic Relations

Green Seal Background

• 501 (c)(3) science-based non-profit • Beginning 22nd year• Environmental mission with exclusive focus on

products, services, purchasing, operations • Encompass multiple product & service categories• Utilize a multiple criteria / life-cycle approach• No financial interest in certified products/services

or in any manufacturer or company

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Why is Credible Certification Important?• Rise of Greenwashing and environmental claims: “green” = $• Reluctance to trust manufacturers claims – they want to sell

products• Single attributes sometimes “apples to oranges” (non-toxic vs. low

VOC – what about performance?)• Manufacturers are not required to provide full disclosure, even if

available hard to interpret• Reduce the effort needed for identifying, selecting and purchasing

environmentally responsible products and services• Distinguish brand from competitors• Obtain business from purchasers at all levels looking (or mandated)

to procure green products & service• Validated by recognized third-party

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Policing Greenwashing

FTC Guides for the Use of Environmental Marketing Claims

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Electrical & Fire Safety

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UL/c-UL Listed UL listed for indoor/outdoor use UL listed

Kosher

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Public Health/Food Safety

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Used Vehicles

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Water Filters/Treatment

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Diamonds

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The distance from production usually makes third-party certification vital to purchasers who shop with their values.

Especially where health, safety, religion or extra cost may be involved.

Green Seal Standards• Dozens of standards covering 182 product and

service categories• Establish a benchmark for industry and purchasers• Provide a basis for certification• Promote leadership in the market• Provide a tool to promote a more sustainable

economy

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Principles of Green Seal Standards

• Objective• Science-based• Transparent• Life-cycle environmental and health considerations

(multi-attribute)• Include functional performance• Compliant with regulations and legislation• Peer-reviewed• Attainable for leadership products• Economically feasible

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Standard Development Process1.Feasibility Assessment2.Project Proposal3.Project Initiation and Notification (PIN)

and Scoping4.Drafting5.Proposed Standard6.Final Review & Approval7. Issued Standard

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Green Seal Certification• Rigorous science-based evaluation• On-site inspections of manufacturing facilities and service

locations (hotels, restaurants, janitorial)• Products evaluated without bias or conflict of interest• Evaluation fees are fixed/flat, so Green Seal has no direct

financial ties to certified products & services• Includes review of ancillary materials (literature, labels,

catalogs, website) for GS, FTC, unsubstantiated claims• Certified products and services must participate in

ongoing compliance monitoring to remain certified

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Guidelines for Type I “Seal of Approval” Ecolabels

• ISO 14020 Environmental labels and declarations – General principles

• ISO 14024 Type I Environmental labelling – Principles and procedures

• Global Ecolabelling Network (GEN) membership (Green Seal is the US member )

• ANSI-accredited standards developing organization• EPA criteria for third-party certifiers• Consumers Union criteria for “What Makes a Good Ecolabel”• FTC Guides for the Use of Environmental Marketing Claims

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The Global Ecolabelling Network (GEN)founded 1994, currently 26 member programs

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Commonalities Among Guidelines• Voluntary participation• Run by organizations without conflicts of interest• Standards process involves stakeholders & the public• Criteria, assumptions, methods & data used are open & transparent (i.e., publicly available, easily accessed & understandable) • Legally protected mark

• Criteria based on product life-cycle

• Open access to licensees of all sizes, all countries• Authority to inspect manuf. facility or service location• Criteria that encourage products & services that are significantly less damaging to the environment (leadership)• Periodic review of criteria, considering technology & marketplace

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FTC Green GuidesFederal Trade Commission16 CFR Part 260Guides for the Use of Environmental Marketing Claims

First issued in 1992, revised in 1996 and 1998.

Proposed revisions posted in the Federal Register in October with comments due by December 10, 2010.

http://www.ftc.gov/green

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Logos/Seals Considered Endorsements16 CFR Part 255 - Guides Concerning the Use of Endorsements & Testimonials in Advertising

Must disclose “material connections”“When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement (i.e., the connection is not reasonably expected by the audience), such connection must be fully disclosed.”

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OAKLAND, Calif., (March 1, 2010) - The Green Works® natural cleaners brand today announced that it is giving $645,000 to Sierra Club® to support the organization's ongoing conservation efforts. The donation, based on 2009 calendar year sales, raises the Green Works® brand's two-year contribution total to more than $1.1 million.*Sierra Club logo is used with permission, which does not constitute sponsorship or endorsement of any company or product.

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Logos Created by Manufacturers

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Example 1: An advertisement for paint features a “GreenLogo” seal and the statement “GreenLogo for Environmental Excellence.” This advertisement likely conveys that: (1) the GreenLogo seal is awarded by an independent, third-party certifier with expertise in evaluating the environmental attributes of paint; and (2) the product has far-reaching environmental benefits. If the paint manufacturer placed the GreenLogo seal in its advertisement, and no independent, third-party certifier evaluated the paint, the claim would be deceptive. The claim would not be deceptive if the marketer accompanied the seal with clear and prominent language: (1) indicating that the marketer itself created the GreenLogo seal; and (2) limiting the general environmental benefit representation to the particular product attributes for which the marketer has substantiation, provided that the advertisement’s context does not imply other deceptive claims.

Trade Association Logos

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Example 2: A product advertisement includes a seal with the text “Certified by the Renewable Energy Association.” The product manufacturer is a dues-paying member of that association. Even if the association certified that the manufacturer uses only renewable energy, the use of the seal is deceptive because it likely conveys that the association is independent from the product manufacturer. To avoid deception, the manufacturer should accompany the seal with clear and prominent language disclosing the material connection.

Trade Association Logos (cont’d)

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Example 3: A manufacturer advertises its product as “certified by the American Institute of Degradable Materials.” The advertisement does not mention that the American Institute of Degradable Materials is an industry trade association. Regardless of whether the manufacturer is a member, this advertisement is deceptive because it likely conveys that the product is certified by an independent certifying organization, not an industry group.The advertisement would not be deceptive if the manufacturer accompanies its statement that the product is “certified by the American Institute of Degradable Materials” with clear and prominent language indicating that the Institute is an industry trade association, and if the manufacturer otherwise complies with § 260.8 of the Guides.

The “USGBC” Example

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Example 4: A marketer’s industry sales brochure for overhead lighting features a seal with the text “U.S. EcoFriendly Building Association” to show that the marketer is a member of that organization. Although the lighting manufacturer is, in fact, a member, this association has not evaluated the environmental attributes of the company’s product. This advertisement would be deceptive because it likely conveys that the U.S. EcoFriendlyBuilding Association evaluated the product through testing or other objective standards. It also is likely to convey that the lighting has far-reaching environmental benefits. The use of the seal would not be deceptive if the manufacturer accompanies it with clear and prominent qualifying language: (1) indicating that the seal refers to the company’s membership only and that the association did not evaluate the product’s environmental attributes, and (2) limiting the general environmental benefit representation to the particular product attributes for which the marketer has substantiation, provided that the advertisement’s context does not imply other deceptive claims. For example, the marketer could state, “Although we are a member of the U.S. EcoFriendly Building Association, it has not evaluated this product. Our lighting is made from 100 percent recycled metal and uses energy efficient LED technology.”

Credibility is Crucial to Most Customers

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Creating a logo, sending in a check or answering some online questions will only get you so far.

Contact InformationGreen Seal, Inc.1001 Connecticut Ave, NWSuite 827Washington, DC 20036-5525Tel: (336) 956-2211Email: mpetruzzi@greenseal.orgWebsite: www.greenseal.org

Thank You!!

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