United States Solid Waste and CDA/C™ cw 01
Environmental Protection Emergency Response EPA/530-bW-91
Agency (OS-305) October1991
Office of Solid Waste
&EPA Environmental
Fact Sheet
EPA To Develop Guidance on
The Use of the Terms "Recycled" and
"Recyclable" in Product Labeling and
Advertising
Recognizing the potential for accurate marketing claims to benefit the
environment, and the confusion caused by inconsistent use of
environmental marketing terms, the Environmental Protection Agency
(EPA) aims to provide voluntary guidance on specific terms and their use
to help educate consumers and advise marketers. The first terms
addressed will be related to recycling solid waste materials.
As a result of the guidance, use of recycled materials should increase
as consumer confidence in the information provided by marketers
increases.
Background
As the American public has come to understand that they may
contribute unknowingly to national or global environmental problems,
the public has increasingly expressed a desire to help protect the
environment. Many consumers demonstrate a growing willingness to
change their buying habits in ways that will reduce environmental
problems, and they continue to seek out products they believe are more
beneficial for the environment. As a result, a number of manufacturers
are promoting the environmental attributes of their products.
The lack of commonly understood meanings for terms used in
environmental marketing claims has confused consumers and
manufacturers,, The same claims are sometimes used by different
manufacturers and consumers to mean different things. In addition,
some labels promote a single attribute of a product, such as "recycled,"
while others make more generalized or vague claims, such as "safe for
the environment" or "environmentally friendly."
Recognizing the lack of uniform definitions for environmental
marketing terms, EPA—working with other federal agencies— intends
to provide guidance on those terms and on their use to help educate
consumers and advise marketers. The first terms addressed will be
related to recycling solid waste materials.
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Action
EPA is considering a number of options regarding voluntary national
guidance for use in product labeling and advertising to promote the use
of recycled and recyclable materials. Via a notice in the Federal
Register, the Agency is requesting comment and holding a public
meeting on the use of specific terms often used in promoting recycled
products and recyclable materials.
The Federal Trade Commission (FTC) held hearings in July 1991 to
determine whether to develop enforceable guidelines covering the use of
environmental marketing claims. In the interest of providing uniform
guidance, if FTC decides to develop guidelines in the future, EPA will
share with them information collected from this action. If FTC decides
not to develop guidelines, EPA will publish final recommendations as
guidance to industry and consumers.
Options for "Recycled Content" and "Recyclable" Marketing Claims
The notice discusses three options for "recycled content" claims and
four options for "recyclable" claims.
Recycled Content
The options are that:
— marketers clearly and prominently state the percentage of
recycled content by weight of recycled materials in the product;
— marketers promote recycled content only when a product meets a
specified minimum percentage of recycled material; or
— marketers use a combination of the above methods.
EPA prefers the first option.
Recyclable
The options are that:
— marketers promote the recyclability of a product only when the
product is recycled at a certain minimum percentage nationally
and the product prominently discloses the national recovery rate
for the material or product.
— marketers use only qualified claims that do not lead consumers
to assume that the product is recyclable everywhere and that
provide consumers with information that helps them recycle the
material.
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— marketers use a combination of qualified claims and disclosure
of the national recycling rate.
— marketers promote the recyclability of a product only when the
product is recycled at a certain minimum percentage nationally,
and that they use qualified claims and disclose the national
recycling rate of the product.
EPA's preferred option is that marketers use a combination of
qualified claims and disclosure of the national recycling rate to
advertise the recyclability of products.
Options for Use of the Recycling Emblem
The familiar recycling emblem (three chasing arrows) is commonly
used by marketers on products to show both recyclability and recycled
content. In some cases, it is used in conjunction with more generalized
claims, like "environmentally friendly." The Agency feels more guidance
on the proper use of the emblem is needed to increase the effectiveness
of its use for recycling, and to ensure consumers understand its
meaning. Three options for using the recycling emblem are discussed:
— to limit the use of the emblem to claims regarding the use of
recycled content and recyclability;
— to follow the American Paper Institute's guidance that uses
different versions of the emblem for recycled content and for
recyclable material; or
— to label the recycling emblem to indicate whether the product
contains recycled content or is recyclable or both.
The Agency prefers the first and last options, together.
Definitions
The notice proposes definitions for certain recycling terms to serve
as guidance for marketers and consumers. Along with the other terms,
it defines:
Recycled Content as the portion of a material's or
product's weight that is composed of pre- and post-consumer
materials.
Recyclables as products or materials that can be recovered from or
otherwise diverted from the solid waste stream for the purpose of
recycling.
The Agency is accepting comment on this notice for 90 days
following publication in the Federal Register. A public meeting will be
held in Washington, D.C. on November 13-14, 1991.
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Contact
For additional information or to order a copy of the Federal Register
notice, contact the RCRA Hotline, Monday-Friday, 8:30 a.m. to 7:30
p.m. EST. The national, toll-free number is (800) 424-9346; TDD (800)
553-7672 (hearing impaired): in Washington, D.C., the number is (703)
920-9810, TDD (703) 486-3323.
Copies of documents applicable to this guidance may be obtained by
writing: RCRA Information Center (RIC), U.S. Environmental Protection
Agency, Office of Solid Waste (OS-305), 401 M Street SW, Washington,
D.C. 20460.
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