The document discusses the importance of credible certification, focusing on green seal standards and the rise of greenwashing in environmental marketing. It outlines the rigorous certification process and the principles behind green seal standards, emphasizing the need for transparency and third-party validation in ensuring environmentally responsible products. Additionally, it highlights FTC guidelines and the significance of distinguishing authentic claims from deceptive marketing in the industry.

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
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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
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Policing Greenwashing
FTC Guides for
the Use of
Environmental
Marketing Claims
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3. Electrical & Fire Safety
UL/c-UL Listed UL listed for
indoor/outdoor use UL listed
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Kosher
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4. Public Health/Food Safety
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Used Vehicles
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5. Water Filters/Treatment
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Diamonds
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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.
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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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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
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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
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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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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
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The Global Ecolabelling Network (GEN)
founded 1994, currently 26 member programs
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10. Commonalities Among Guidelines
• Voluntary participation • Criteria based on product
• Run by organizations without life-cycle
conflicts of interest • Open access to licensees of
• Standards process involves all sizes, all countries
stakeholders & the public • Authority to inspect manuf.
• Criteria, assumptions, facility or service location
methods & data used are • Criteria that encourage
open & transparent (i.e., products & services that are
publicly available, easily significantly less damaging to
accessed & understandable) the environment (leadership)
• Legally protected mark • Periodic review of criteria,
considering technology &
marketplace
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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.
http://www.ftc.gov/green
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11. Logos/Seals Considered Endorsements
16 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.”
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
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.
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12. Trade Association Logos
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.
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Trade Association Logos (cont’d)
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.
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13. The “USGBC” Example
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. EcoFriendly
Building 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.”
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Credibility is Crucial to Most Customers
Creating a logo, sending in a check or answering some
online questions will only get you so far.
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14. Contact Information
Green Seal, Inc.
1001 Connecticut Ave, NW
Suite 827
Washington, DC 20036-5525
Tel: (336) 956-2211
Email: mpetruzzi@greenseal.org
Website: www.greenseal.org
Thank You!!
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