Requests for Comments
   r PA is accepting comments on the October
2,1991, notice. Comments must be received
on or before December 31,1991. A public
meeting will be held on November 13-14,
1991, in Washington, DC.
 For More Information
  "or 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 (hear-
ing impaired). In Washington, DC, the num-
ber 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. Environmen-
tal Protection Agency, Office of Solid Waste
(OS-305), 401M Street SW., Washington, DC
20460.
                                      (
   • Follow the American Paper Institute's
     (API's) guidance that uses different
     versions of the emblem for recycled
     content and for recyclable material.

   • Label the recycling emblem to indicate
     whether the product contains recycled
     content or is recyclable or both.

   The Agency prefers a combination of the
first and last options.
                      AH "Recyclable" Emblem
  AH "Recycled Content" Emblem
 Definitions for Recycling Terms
  /PA also has proposed definitions for
certain recycling terms to serve as guidance
for marketers and consumers. Along with
other terms, these include:

   • Recycled Content—The portion of a
     material's or product's weight that is
     composed of pre- and post-consumer
     materials.

   • Recyclable — Products ormaterials
     that can be recovered from or other-
     wise diverted from the solid waste
     stream for the purpose of recycling.
          United States
          Environmental
          Protection Agency
                                                                                                                EPA/530-SW-91-072A
                                                                                                                October 1991
                                                                                                Office of Solid Waste (OS-305)
c/EPA Proposed
          Guidance on
          the Use of
          Environmental
          Marketing Terms
                                                                                                      Printed on Recycled Paper

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      "ver the past several years, the lack
  of commonly understood meanings for
  terms used in environmental marketing
  claims has confused many consumers
  and manufacturers alike. 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 claims, such as "safe
  for the environment" or "environmen-
  tally friendly."

      Recognizing the lack of uniform
  definitions for environmental marketing
  terms, the Environmental Protection
  Agency (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 ad-
  dressed will be related to recycling solid
  waste materials.
   ?A 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. EPA published a notice in the
federal Register on October 2,1991, requesting
comments on these options.
        The Federal Trade Commision (FTC)
  held hearings in July 1991 to determine
  whether to develop enforceable guidelines
  covering the use of environmental market-
  ing claims. In the interest of providing
  uniform guidance, if FTC decides to develop
  guidelines in the future, EPA will share with
  FTC the information collected from this
  notice. If FTC decides not to develop guide-
  lines, EPA will publish final recommenda-
''  tions as guidance to industry and consumers.

I  For "recycled content," the options are:
i!
i;      • Marketers clearly and prominently
I        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.

      • Marketers use a combination of the
        above methods.

      EPA prefers the first option.

   For "recyclable," the options are:

      • Marketers promote the recyclability of
        a product only when the product is
        recycled at a certain minimum percent-
        age nationally and the product promi-
        nently discloses the national recovery
        rate for the material or product.

      • Marketers use only qualified daims
        that do not lead consumers to assume
        that the product is recyclable every-
        where and that provide consumers
        with information that helps them
        recycle the material.
    • Marketers use a combination of quali-
      ified claims and disclosure of the
      national recycling rate.

    • Marketers promote the recyclability of
      a product only when the product is re-
      cycled at a certain minimum percent-
      age nationally. They must also 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.

    he familiar recycling emblem (three
I chasing arrows) is commonly used by mar-
 keters 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 recy-
] cling, and to ensure that consumers under-
• stand its meaning. EPA is considering three
) options for using the recycling emblem:
I
     • Limit  the use of the emblem to claims
      regarding the use of recycled content
      and recyclability.

                        (Continued on backpand)

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