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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