The document provides a detailed comparison of various green marketing claims such as biodegradable, compostable, renewable, biobased, and natural, highlighting their distinct definitions and implications according to the FTC's Green Guides and other regulatory standards. It emphasizes the importance of using these terms correctly to avoid accusations of greenwashing and provides guidance on how these claims should be substantiated. The document also includes insights on relevant industry standards and eco-label certifications that can support marketing claims.

1. 1
Biodegradable? Renewable? Natural?
Compostable? Biobased?
Think these green marketing claims all mean the same thing? Think again! They are all very different, with
unique scientific and legal definitions. Using them interchangeably or incorrectly (according to either the
dictionary or more pointedly, the FTCʼs Green Guides for Environmental Marketing) could result in accusations
of greenwashing or just confuse your customers and end-consumers. Hereʼs a “cheat sheet” based upon
Webster dictionary definitions, FTC Guidelines for Environmental Marketing Claims (the ʻFTC Green Guidesʼ
ftc.gov/greenguides), and as applicable, FDA and USDA. When available, weʼve included a reputable eco-label
and made some additional comments.
ʻBiodegradableʼ
Webster:
Capable
of being
broken
down
especially
into
innocuous
products
by the
action of
living
things (as microorganisms)
FTC Green Guides (Section 260.8): Entire item will
completely break down and return to nature within a
reasonably short period of time after customary
disposal; must completely decompose within one year
if entering solid waste stream (i.e., a landfill).
The FTC has consistently found that unqualified
biodegradable claims for both plastics and paper are
misleading. Below are links to recent decisions:
• http://www.ftc.gov/news-events/press-
releases/2014/03/ftc-approves-final-order-
settling-charges-down-earth-designs-inc
• http://www.ftc.gov/news-events/press-
releases/2013/10/ftc-cracks-down-misleading-
unsubstantiated-environmental
Ottman and Eisen: Biodegradable and compostable
are cousins. The terms are related in that both, when
used properly, represent the breakdown of materials into
harmless components, either aerobically (with air) or
anaerobically (without air). Something that is
compostable is by definition biodegradable under the
proper conditions. Liquids can also be biodegradable
(like a cleaning product). Suggestion: use the claim
ʻbiodegradableʼ for liquids that are designed to ʻgo down
the drainʼ and ʻcompostableʼ for solids intended for
composting in municipal or industrial facilities. And keep
in mind that landfills are designed so that their contents
—not even food or paper— will not degrade
(Degradation results in methane, a greenhouse gas that
is 23 times more potent than CO2 and highly
combustible, and landfills often support structures.
LaGuardia and JFK are both built on landfill.). So if a
potato chip bag or a plastic cup is marked ʻcompostableʼ
chances are it will not degrade in a landfilll (ever or for
hundreds of years), and consumer confusion over same
can result in greenwash accusations and possibly
lawsuits.
Like many green marketing claims, biodegradability is
proven by laboratory tests conducted according to
agreed upon industry standards; if desired, the claim
and its third party scientifically supported proof can
then be certified by an independent organization and
awarded a label for marketing purposes. (Government
agencies, nonprofits, trade groups and for-profit
companies can all certify claims and award labels.)
In the US, industry standards are issued by ASTM
International, a nonprofit organization that develops
and publishes approximately 12,000 technical
standards, covering the procedures for testing and
classification of materials of every sort. Their
standards cover biodegradation of plastics under
accelerated landfill conditions; non-floating
biodegradable plastics in the marine environment;
degradation in the environment by a combination of
oxidation (including photodegradation) and
biodegradation; and anaerobic biodegradation in the
presence of municipal sewer sludge.

2. 2
The Biodegradable label pictured here is a service of
SCS Global Services, a Certified B Corporation
based in Oakland, California. Using internationally
recognized ʻreadily biodegradabilityʼ standards
(ASTM 1720E and OECD 310), SCS verifies that
cleaning and sanitation products degrade safely and
efficiently in an aerobic environment and confirms
that chemicals are not building up in the environment
to harmful concentrations before degradation occurs.
ʻPhotodegradableʼ (degradation in the presence of
sunlight) claims for plastics are largely out of vogue
since Hefty trash bags made this claim in 1991 and
was sued by attorneys general in seven states. The
issue: although the bags would ʻdegradeʼ in the
presence of sunlight, 90% of the bags would wind up
in landfills where there was no sunlight. Further, their
their claim would need to have been qualified by
indicating that the plastic component (which
represented 94% of the product; the other 6% being
cornstarch) breaks into little pieces only, but does not
return to nature.
Some petroleum-based plastics are ʻoxo-degradableʼ
indicating that the material may oxidize and begin the
process of breaking down but does not return to
nature. Naturally, manufacturers donʼt want to claim
their plastic degrades but stays in the environment.
ʻCompostableʼ
Webster: adj. for compost, a mixture that consists
largely of decayed organic matter and is used for
fertilizing and conditioning land
FTC Green Guides (Section 260.7): All the
materials in the item will break down into or
otherwise become part of usable compost (e.g., soil
conditioning material, mulch) in a safe and timely
manner (i.e., in approximately the same time as the
materials with which it is composted) in an
appropriate composting facility, or in a home
compost pile or device; qualify if municipal or
institutional composting facilities are not available to
a substantial majority of consumers or communities
where the item is sold.
Ottman and Eisen: When products that claim to be
compostable without scientific substantiation are
accepted into composting facilities, sewage
treatment facilities, or used in agriculture, they can
leave behind significant amounts of non-
biodegradable fragments (often plastic). Each year
municipal composters lose thousands of dollars from
eliminating plastic fragments and litter that
contaminate finished compost. Partially degraded
plastic fragments can harm fertile farmland or spoil
natural surroundings.
ASTM standard D6400 and ASTM D6868 are used to
verify compostability of plastics designed to be
aerobically composted in municipal or industrial facilities,
as well as to determine aerobic biodegradation of
plastics under controlled composting conditions. That
standard undergirds the Compostable logo viewed here,
issued by BPI (formerly, the Biodegradable Products
Institute, bpiworld.org). According to BPI, there is no
ASTM standard (or accompanying certification) for items
that will breakdown in backyard facilities.
ʻRenewableʼ (materials)
Webster: Capable of being replaced by natural
ecological cycles or sound management practices
USDA: In the context of biobased products,
renewable resources include agricultural, forestry,
and marine resources such as algae.

3. 3
FTC Green Guides (Section 260.16): (Advises
marketers to) minimize risk of consumer
misinterpretation by identifying material used and
explaining why it is renewable; qualify any “made with
renewable materials” claim unless the product or
package is made entirely with renewable materials.
Ottman and Eisen: Whereas biodegradable and
compostable are kissing cousins, renewable and
biobased (see below) are the fraternal twins of
claims. Renewable is a term that resonates with
consumers, while biobased is a technically accurate
scientific term. Keep in mind, as detailed in the
section below, that ʻnon-renewableʼ (as a descriptor
for fossil fuels) means ʻmore than 62,000 years oldʼ,
so unless qualified, ʻrenewableʼ could technically
mean able to be regrown in 61,000 years!
The LEED certification system for green buildings
defines ʻRapidly renewableʼ resources as agricultural
products derived from both plant and animal sources
that take ten years or less to harvest.
ʻBiobasedʼ
Webster: Not defined
Business dictionary.com: Material or product
derived from biological or renewable resources
FTC Green Guides: FTC Green Guides defer to
USDA, who defines biobased as follows:
USDA Technical Definition of ʻBiobasedʼ: A
product determined by the USDA Secretary of
Agriculture to be a commercial or industrial
product (other than fuel or feed) that is composed,
in whole or in significant part, of biological
products, including renewable domestic*
agricultural materials (including plant, animal and
aquatic materials), forestry materials or an
intermediate ingredient or feedstock. A ʻforest
productʼ means a product made from materials
derived from the practice of forestry or the
management of growing timber and includes pulp,
paper, paperboard, pellets, lumber and other wood
products; and any recycled products derived from
forest materials. (Biopreferred.gov) *includes
trading partners
According to the USDA, Biobased products
generally provide an alternative to conventional
petroleum derived products and include a diverse
range of items including lubricants, detergents, inks,
fertilizers, and bioplastics.
Ottman and Eisen: The USDA Certified Biobased
Product label pictured here is based upon the ASTM
D6866 Standard Test Methods for Determining the
Biobased Content of Solid, Liquid, and Gaseous
Samples. Biobased is a scientific term and the
percent biobased content of a product is verified
using radiocarbon dating and internationally
recognized standards that measure the ratio of new
organic carbon to total organic carbon in a product.
New organic carbon is derived from plants and other
renewable agricultural, marine (including algae), and
forestry materials. Total organic carbon consists of
new organic carbon and old organic carbon that
originates from petroleum. Biobased product content
percentage does not include water or inorganic
material and can be measured using ASTM D6866.
The USDA Certified Biobased label generally
supports a claim of renewability and the word
ʻrenewableʼ can be readily used and understood
when used as a claim for most commercially grown
materials without qualification or FTC challenge.
Products made from bio-based materials are often
biodegradable but this is not always the case. For
instance, the materials may have undergone a
certain type of processing that renders them non-
biodegradable, or they may be united in processing
with non-degradable materials, e.g., a blend of
bamboo and polyester that hinder biodegradation.
Over 1500 products have been recognized as USDA
Certified Biobased Products since the labelʼs launch
in 2011.

4. 4
ʻNaturalʼ
Webster: Existing in nature and not made or
caused by people: coming from nature: not having
any extra substances or chemicals added: not
containing anything artificial
FTC Green Guides: Not defined in FTC Green
Guides (presumably because is has been defined
by the FDA and USDA for use in food products
including flavoring, colorings, additives, and in
meat and poultry products.) Nevertheless, FTC
has stated that advertisers must be able to
substantiate whatever message their ʻnaturalʼ
claims reasonably convey to consumers.
Ottman and Eisen: The term ʻnaturalʼ is more strongly
associated with ʻheathʼ than ʻenvironmentalʼ claims,
hence its prevalence in personal care products,
apparel, and food products. ʻNaturalʼ ingredients are
not necessarily healthy (or healthier or less harmful to
health than synthetics) — Arsenic is natural!) Not
surprisingly, claims of ʻnaturalʼ are problematic and
much litigation has resulted.
The ecolabel viewed here is a service of the Natural
Products Association, an advocacy group whose
members consist of manufacturers and retailers of
personal and home care products, foods, dietary
supplements, and health/beauty aids. According to
its website, the Natural Products Association was
founded in 1936 and is the nationʼs largest and
oldest nonprofit organization dedicated to the natural
products industry. Its 1,900 members represent
over 10,000 retail and manufacturing locations, $117
billion in sales and have certified over 1,100
products and ingredients based on the
organizationʼs published standards.
In addition…
The FTC Green Guides do not define the term
ʻSustainableʼ, for various reasons, given confusion with
the term ʻrenewableʼ, and presumably because
ʻsustainabilityʼ encompasses ʻenvironmentʼ, as well as
ʻeconomyʼ and ʻsocialʼ, which are outside the scope of
the Guides.
The FTC Green Guides defer to the USDA for a
definition of ʻorganicʼ. In Europe, ʻorganicʼ means
ʻbiobasedʼ. According to the USDA Organic website
(USDA.gov/organic), USDA Organic is a labeling term
that indicates that the food or other agricultural product
has been produced through approved methods that
integrate cultural, biological, and mechanical practices
that foster cycling of resources, promote ecological
balance, and conserve biodiversity. Synthetic
fertilizers, sewage sludge, irradiation, and genetic
engineering may not be used. EN
Prepared by Jacquie Ottman and Mark Eisen of J. Ottman Consulting, Inc., NYC-based advisors to business and government
for environmental marketing and eco-innovation. Ottman is the author of The New Rules of Green Marketing: Strategies, Tools
and Inspiration for Sustainable Branding (Berrett-Koehler, 2011) and co-author (with David Mallen) of How to Make Credible
Green Marketing Claims: What Marketers Need to Know about the Updated FTC Green Guides (Advertising Age, 2013). Mark
Eisen is the founding Director of Environmental Marketing at The Home Depot. He resides in Atlanta. Ottman and Eisen were
advisers to the USDA on the development and launch of the USDA Certified Biobased label.
The information contained herein is intended as educational/ reference only and does not constitute technical or legal advice.
Consult with appropriate technical and legal resources when making environmental marketing claims.
Copyright © 2014 J. Ottman Consulting, Inc. All Rights Reserved.