FTC "Green Guides" warn against making deceptive claims about recycled content

Submitted by: Phil Riebel 04/05/2013

In support of best practices in marketing claims, we have long warned our customers against using industry average data to make environmental claims about recycled fiber in coated fine papers.


April 3, 2013

The Environmental Quotient, Sappi Fine Paper North America

In support of  best practices in marketing claims, we have long warned our customers against using industry average data to make environmental claims about recycled fiber in coated fine papers.  Now, more than ever, we urge corporate marketers and advertisers to do their homework.

In October 2012, the US Federal Trade Commission (FTC) updated their “Guides for the use of Environmental Marketing Claims” more commonly referred to as the “Green Guides”.  In their summary document, highlighted on the cover page, readers will find this statement:

Claiming “Green, made with recycled content” may be deceptive if the environmental costs of using recycled content outweigh the environmental benefits of using it.

Clearly the federal government has seen enough evidence that in some cases recycled content can actually increase the environmental impact. And in fact, this is true for our paper mills in regard to greenhouse gas emissions.

At Sappi, we have studied the impact of using deinked market pulp (recycled fiber) as a substitute for our virgin kraft pulp made on site at our Somerset mill (Skowhegan, ME).  Recently published results show that adding 10% recycled fiber increases the carbon footprint by 16% as compared to a product made with 100% virgin fiber.  Meanwhile, the EPN’s “Paper Calculator” indicates that for coated freesheet paper (the type we manufacture) adding 10% recycled fiber decreases greenhouse gas emissions by 3%.*

Sappi’s integrated mills use over 80% renewable energy – far more than the industry average – resulting in a lower than average level of greenhouse gas emissions.  It is clear that the “Paper Calculator” does not accurately reflect the performance of our mills. 

Sappi has fully embraced transparency in reporting and we include a comprehensive set of key performance indicators in our regional sustainability report.  We have been long time supporters of the Environmental Paper Assessment Tool wherein users can study and compare actual mill data which is updated annually.  With access to so much current, mill specific data, there is no need to resort to using averages for making claims.  Worse yet, doing so could lead to deceptive claims.