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       A growing number of consumers have begun to express their
environmental concerns by demanding safer products that are less
harmful to the environment.  Surveys have revealed three things:
consumers are concerned about the environmental qualities of the
products they purchase, they refer to product packaging for
information on these qualities, and that they will buy products
which make "green" claims over other products.  
       As this concern for our environment has increased,
environmental advertising, or "green marketing" has expanded
dramatically.  Manufacturers and marketers are responding to
consumers' demands through "green marketing" and promoting the
environmental "friendliness" of their products and packages.  One
study revealed that new products making environmental claims are
introduced at a rate 20 to 30 times greater than other products. 

       According to EPA, in 1989 green products represented 4.5% of
the total number of new products and in 1991 such products
accounted for 13.4% of the new products introduced.  However, this
trend has resulted in claims that are misleading, vague, or totally
false.  Rhode Island is one of several states that have laws and
regulations controlling the use of certain terms in labelling, but
many products violate these rules since they are shipped from other
states or countries.

       Some of the overly broad statements or unqualified claims that
green marketing has spawned are: "environmentally friendly,"
"environmentally safe," "ozone friendly," "natural,"
"biodegradable," "photodegradable," "degradable," "recycled,"
"recyclable," or just "green."  Two of the most frequently used
phrases are "environmentally safe," and "environmentally friendly."
They are meaningless because every product has had some negative
environmental impact, though the impact may vary depending on the
product or material.  "Environmentally safe," "environmentally
friendly," as well as "biodegradable" claims are not permitted in
Rhode Island according to state regulations.  

       Biodegradable materials, generally organics, break down and
decompose when exposed to air, moisture, bacteria or other
microorganisms.  Photodegegradable materials, usually plastics,
disintegrate into smaller pieces due to prolonged exposure to
sunlight.  Neither of these properties is relevant because
degradation of any material occurs extremely slowly in landfills. 
[see LANDFILLS section].  Detergents, shampoos, or other cleaning
products are frequently labeled "biodegradable."  A majority of
these products do degrade in waste-water systems and have for
       Many products or packages make  environmental claims which
cannot be proven or which do not provide the specific information
necessary to make comparisons with other products or packaging.

When evaluating environmental claims, one should examine product
labels for specific information about the product and its
packaging.  Claims that are specific will probably be more
credible.  For example, if a product is labeled "recycled," see how
much (%) of the product or packaging is recycled and where the
recycled material comes from.  

       Post-consumer material was discarded after being used, and by
being recycled, was kept out of the waste stream.  Conversely, pre-
consumer material was not used and disposed of by consumers.  Pre-
consumer material can be manufacturing scrap (millbroke), or items
meant for but not utilized by consumers (like unsold publications). 
A high percentage of post-consumer content in a product or package
is significant because this material would have been incinerated or
landfilled had it not been recycled.  

       Some products or packaging are labeled "recyclable," and in
theory this may be correct because the technology currently exists
to recycle almost anything.  However, if the product is not
recyclable in your area, this claim is irrelevant and the product
may as well not be recyclable at all.  In Rhode Island, according
to state labeling regulations "Recyclable" claims can only be made
for products defined by regulation as recyclable or that have a 50%
recycling rate in this state.  Also, where "recycled" claims are
made, the percentages of pre- and post-consumer content must be

The proliferation of questionable environmental claims on products
and packaging requires careful scrutiny on the part of consumers
and reliable sources to verify these claims, since consumers
themselves often do not have that ability.  The Federal Trade
Commission (FTC), in cooperation with the Environmental Protection
Agency and the Office of Consumer Affairs, issued national
guidelines in 1992 to help businesses make valid environmental
claims and to help consumers assess product claims.  

       The FTC "Guide for the Use of Environmental Marketing Claims"
gives examples of different environmental marketing claims and why
certain claims are deceptive and others are not.  In addition, two
national independent organizations: "Green Seal" and The Scientific
Certification Systems "Environmental Certification Program" (or
S.C.S. Green Cross) were begun in 1990 to clarify environmental
claims.  The intention of these two organizations is to lend some
credibility to the countless environmental claims pervading the
marketplace.  However, the approach that these two organizations
have taken is quite different, and both have their respective
strengths and weaknesses.  

       Green Seal sets environmental standards for certain categories
of consumer products.  Once the standards have been set,
manufacturers can submit their products in that category for
evaluation.  The product evaluation is done primarily by
Underwriters Laboratories (UL), which is known for performing
product-safety certification.  UL tests the products, evaluates
packaging, and inspects the  manufacturers facilities for
compliance with Green Seal standards.  Once a product has been
certified, the manufacturer must agree to periodic re-testing and
plant inspection to ensure continued compliance.  

Green Seal's Standards are based on four primary considerations:

þ  Protect the Earth: reduce air and water pollution, reduce the
   waste of energy and resources, protect wildlife and habitats.

þ  Public Review: all standards are published for review by
   business, government, environmental and consumer organizations,
   and the public.

þ  Reduce Packaging Waste: Green Seal requires the minimal use of
   packaging.  Also, toxic metals (sometimes found in inks on
   packaging) cannot be added to packaging materials.

þ  Quality Performance: to ensure that "environmental" products
   perform as well as or better than mainstream consumer products.

Green seal has currently published standards for the following
product categories:

�  Tissue Paper (bath and facial tissue)
�  Re-refined Engine Oil
�  Compact Fluorescent Lamps
�  Water Efficient Fixtures
�  Printing and Writing Papers
�  Paper Towels and Napkins
�  Paints
�  Clothes Washers
�  Clothes Dryers
�  Dishwashers

Other standards are under development, undergoing public comment or
are being revised following public comment.  Nine new standards are
to be published soon.  Thus far, "seals" have been issued for 12
products from four companies.  When the Green Seal program first
began, it was stated that they would perform a complete life-cycle
analysis (LCA) for each product that they would endorse.  

   A LCA is an inventory which enables a manufacturer to quantify
how much energy and raw materials were used, and how much solid,
liquid, and gaseous waste is generated at each stage of a product's
life.  The LCA is an attempt to assess the resource cost and
environmental impact of a product's life from "cradle-to-grave."  
However, it is very time-consuming and can cost many thousands of
dollars to do an LCA for just one product.  

   There is also disagreement among the scientific community about
the interpretations and conclusions of some LCA's.  Because of the
cost and complexity of conducting full scale LCA's, Green Seal
decided to perform what they call an "Environmental Impact
Evaluation"--a scaled back version of an LCA.  Hannah Holmes of
Garbage states that, "The short-cut approach to LCA is costing
Green Seal some credibility."

   Scientific Certification Systems' approach to labeling is
somewhat different than that of Green Seal, and slightly more
complicated.  The two aspects of SCS's labeling scheme are the
"Environmental Report Card" and the "Environmental Claims
Certification Program."  The Environmental Report Card displays
detailed information about the environmental impacts resulting from
the production, use, and disposal of a product.  SCS evaluates a
product based on a LCA which assesses the environmental impacts
from production to disposal.  

   Listed on the report card are 18 criteria divided into the
following categories: resources depleted, energy used, air and
water pollution, and solid waste generated by a product's 
production, distribution, use, and disposal--(ie. throughout the
life of a product).  Although SCS has performed the LCA, it is the
consumer's responsibility to evaluate an "environmental" product's
performance compared to the usual norms for that type of product. 

   This process is almost as complicated as it sounds, and it is
debatable whether shoppers will have the desire or ability to
comprehend the specifics of the Environmental report card.  The
presence of an environmental report card on a product's package may
be equated by a consumer to a "seal of approval" even though that
is not its intention.  

Also maintained by SCS is the Environmental Claims Certification
Program (formerly known as Green Cross) which scientifically
validates environmental claims made by different companies for
their products.  SCS has documented claims on hundreds of products
as to recycled content, biodegradability, and other environmental
marketing catchwords.  

   Rather than establishing standards and qualifying products as
being "environmentally superior," SCS positions its two programs as
being descriptive in nature.  SCS has issued Environmental Report
Cards to nine companies and has certified the validity of
individual claims on over 1000 products to date.

   Having a product or package evaluated by one of these two
labeling organizations is costly and time-consuming.  It can cost
between $17,000 and $30,000 for a company to be inventoried by
S.C.S. and about $10,000 for Green Seal.  Periodic re-evaluations
are also required to insure that compliance is maintained.  Whether
smaller companies with good products will be able to afford these
evaluations for report card or a seal raises some questions.  

Environmental labeling is not unique to the United States:

þ  Germany's "Blue Angel" label began in 1978, and is displayed on
   over 3,200 products in 64 categories.  More than half of the
   products wearing the symbol are in four categories: varnishes &
   coatings, gas burners, recycled paper, and waste-water-treatment
   agents.  Germany's Federal Environment Agency reviews the life-
   cycle of a product category and sets criteria for products to

þ  Canada's "Environmental Choice" started in 1990 and has issued 60
   seals for 18 product categories emphasizing recycling and reduced
   pollution.  The standards will be based on life-cycle analysis
   and will be continually updated so that only the most advanced 10
   or 20 percent of the eligible products in a category will
   qualify, thereby encouraging innovation.

þ  Japan's "EcoMark" program was initiated in 1989 and has awarded
   over 850 labels in 31 categories.  Products are evaluated for
   energy efficiency and environmental impacts during manufacturing. 
   Assessments are not based on life-cycle analysis.

   In addition to these, the European Community has developed an
environmental label and so has the Nordic Council (Finland,
Iceland, Norway & Sweden).  These different programs have had mixed
success, which reveals the challenges inherent to green labeling. 
Even with labeling programs like Green Seal and S.C.S. Green Cross,
the FTC guidelines, and various state laws, the challenges to
environmentally conscious consumers remain daunting.  

   There may be cases where a product is "green" but the packaging
is not--or, conversely, the packaging is "green" but the product is
not.  For example, 100% recycled paper towel may come wrapped in
virgin plastic, or a toxic cleaning product in a recycled plastic
bottle.  There may also be cases of "green" products being
manufactured by un-green companies.  

   Fortunately for consumers, the Federal Trade Commission steps in
to eliminate product claims that are patently false. The FTC has
taken action against twenty companies making deceptive claims
ranging from biodegradable plastic trash bags to "ozone friendly"
cleaning products.  The FTC supports the use of labeling programs
when they can lend some credibility to environmental claims.

                                SCS and Green Seal Compared

Green Seal
þ  "Environmental Impact Evaluation," identifies burdens and makes
   value judgements about impacts.
�  Results in a simple straightforward, "yes/no" outcome.  
�  Experts, not consumers do the judging.
�  Judgements can't be validated scientifically.
Scientific Certification Systems
þ  Single-attribute approach assesses single attributes of products. 
   Environmental Report Card is "informational labeling," not a
   "seal of approval."

Strengths                                        Weaknesses
�  Potentially educational.                                    � May be too complex.
�  Detailed.                                            � May overburden consumers.
�  Doesn't make value judgements.                       � May be mistaken for a
�  Measures burdens relative to performance.                   � Rewards recycling
   but not reduction.

For More information about Green Seal:
1250 23rd. Street NW
Washington, DC 20037               (202) 331-7337

For More Information about S.C.S. Green Cross
1611 Telegraph Avenue
Suite 1111
Oakland, CA 94612-2113             (800) ECO-FACTS

Federal Trade Commission
"Guides For Use of Environmental Marketing Claims"
Correspondence Branch
Federal Trade Commission
Washington, DC 20580               (202) 326-3753