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Lifecycle Assessment and Green Seal Certification


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Purchasers, specifiers and manufacturers are now faced with the challenge of identifying which product labels to trust. The good news is that robust guidance on what makes a credible ecolabel already exists – it just needs to be used. In addition, the recent proposed changes to the Federal Trade Commission’s Guides for the Use of Environmental Marketing Claims provide further screens to help sort through the crowd.

This presentation will highlight key elements from the most widely cited “standards for standards,” explore how Green Seal conducts standard-setting and certification, and share a practitioner perspective on what the revised FTC Guides may mean for the use of environmental labels and logos.

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Lifecycle Assessment and Green Seal Certification

  1. 1. Small Logos, Big Meaning: Hot on the Trail of Credible Certification Green Roundtable Webinar 12.1.10 Mark 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 2
  2. 2. 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 3Policing Greenwashing FTC Guides for the Use of Environmental Marketing Claims 4
  3. 3. Electrical & Fire SafetyUL/c-UL Listed UL listed for indoor/outdoor use UL listed 5 Kosher 6
  4. 4. Public Health/Food Safety 7 Used Vehicles 8
  5. 5. Water Filters/Treatment 9 Diamonds 10
  6. 6. 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. 11 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 12
  7. 7. 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 13 14
  8. 8. Standard Development Process 1. Feasibility Assessment 2. Project Proposal 3. Project Initiation and Notification (PIN) and Scoping 4. Drafting 5. Proposed Standard 6. Final Review & Approval 7. Issued Standard 15 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 16
  9. 9. 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 17 The Global Ecolabelling Network (GEN) founded 1994, currently 26 member programs 18
  10. 10. Commonalities Among Guidelines• Voluntary participation • Criteria based on product• Run by organizations without life-cycleconflicts of interest • Open access to licensees of• Standards process involves all sizes, all countriesstakeholders & the public • Authority to inspect manuf.• Criteria, assumptions, facility or service locationmethods & data used are • Criteria that encourageopen & transparent (i.e., products & services that arepublicly available, easily significantly less damaging toaccessed & understandable) the environment (leadership)• Legally protected mark • Periodic review of criteria, considering technology & marketplace 19 FTC Green Guides Federal Trade Commission 16 CFR Part 260 Guides 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. 20
  11. 11. Logos/Seals Considered Endorsements16 CFR Part 255 - Guides Concerning the Use of Endorsements &Testimonials in AdvertisingMust disclose “material connections”“When there exists a connection between the endorser and the seller ofthe advertised product that might materially affect the weight or credibilityof the endorsement (i.e., the connection is not reasonably expected bythe audience), such connection must be fully disclosed.” 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 organizations ongoing conservation efforts. The donation, based on 2009 calendar year sales, raises the Green Works® brands 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. 21 Logos Created by ManufacturersExample 1: An advertisement for paint features a“GreenLogo” seal and the statement “GreenLogo forEnvironmental Excellence.” This advertisement likelyconveys that: (1) the GreenLogo seal is awarded by anindependent, third-party certifier with expertise inevaluating the environmental attributes of paint; and (2)the product has far-reaching environmental benefits. Ifthe paint manufacturer placed the GreenLogo seal in itsadvertisement, and no independent, third-party certifierevaluated the paint, the claim would be deceptive. Theclaim would not be deceptive if the marketeraccompanied the seal with clear and prominentlanguage: (1) indicating that the marketer itself createdthe GreenLogo seal; and (2) limiting the generalenvironmental benefit representation to the particularproduct attributes for which the marketer hassubstantiation, provided that the advertisement’s contextdoes not imply other deceptive claims. 22
  12. 12. Trade Association LogosExample 2: A product advertisement includes a sealwith the text “Certified by the Renewable EnergyAssociation.” The product manufacturer is a dues-paying member of that association. Even if theassociation certified that the manufacturer uses onlyrenewable energy, the use of the seal is deceptivebecause it likely conveys that the association isindependent from the product manufacturer. Toavoid deception, the manufacturer shouldaccompany the seal with clear and prominentlanguage disclosing the material connection. 23 Trade Association Logos (cont’d)Example 3: A manufacturer advertises its product as“certified by the American Institute of DegradableMaterials.” The advertisement does not mention that theAmerican Institute of Degradable Materials is an industrytrade association. Regardless of whether the manufactureris a member, this advertisement is deceptive because itlikely conveys that the product is certified by anindependent certifying organization, not an industry group.The advertisement would not be deceptive if themanufacturer accompanies its statement that the productis “certified by the American Institute of DegradableMaterials” with clear and prominent language indicatingthat the Institute is an industry trade association, and if themanufacturer otherwise complies with § 260.8 of theGuides. 24
  13. 13. The “USGBC” ExampleExample 4: A marketer’s industry sales brochure for overhead lightingfeatures a seal with the text “U.S. EcoFriendly Building Association” to showthat the marketer is a member of that organization. Although the lightingmanufacturer is, in fact, a member, this association has not evaluated theenvironmental attributes of the company’s product. This advertisementwould be deceptive because it likely conveys that the U.S. EcoFriendlyBuilding Association evaluated the product through testing or other objectivestandards. It also is likely to convey that the lighting has far-reachingenvironmental benefits. The use of the seal would not be deceptive if themanufacturer accompanies it with clear and prominent qualifying language:(1) indicating that the seal refers to the company’s membership only and thatthe association did not evaluate the product’s environmental attributes, and(2) limiting the general environmental benefit representation to the particularproduct attributes for which the marketer has substantiation, provided thatthe advertisement’s context does not imply other deceptive claims. Forexample, the marketer could state, “Although we are a member of the U.S.EcoFriendly Building Association, it has not evaluated this product. Ourlighting is made from 100 percent recycled metal and uses energy efficientLED technology.” 25 Credibility is Crucial to Most Customers Creating a logo, sending in a check or answering some online questions will only get you so far. 26
  14. 14. Contact InformationGreen Seal, Inc.1001 Connecticut Ave, NWSuite 827Washington, DC 20036-5525Tel: (336) 956-2211Email: mpetruzzi@greenseal.orgWebsite: Thank You!! 27