THE NATIONAL
ENVIRONMENTAL LABELING CONFERENCE
Sponsored by:
U.S. EPA, Region III
Hyatt Regency
Baltimore, Maryland
October 1-2, 1991
Printed on Recycled Paper
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Tim Mohin .
Frances Werner
Joel Makower .
Ruth Becker
Sandra Eberle
Lars E. Peterson
Michael Reilly
Eddie Powers
Manfred Eihoff
Graham Hardman
James Salzman
Honorable Hubert H. Humphrey III.
Tom Rattray
John Kamp
Carl Franke].
Lynn Elsasser
Robert Morgan
LIST OF ATTENDEES
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TABLE OF CONTENTS
INTRODUCTION
ACKNOWLEDGEMENTS
CONFERENCE SPEAKERS
PRESENTATIONS
Robert W. Dellinger
Ric Erdheim
Byron D. Sher
Ann W .lcox
Janet Steiger
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INTRODUCTION
Since 1990, consumers have expressed an increasing demand
for products that are less stressful on the environment.
Many products now bear information on their labels related
to their possible impact ranging from the vague “good for
the environment” to the more specific “contains at least
10% post-consumer waste”. There soon followed a variety
of governmental efforts to protect consumers from false
and misleading claims.
To facilitate communication among the many concerned
groups, U.S. EPA Region III sponsored the National
Environmental Labeling Conference on October 1-2, 1991.
The conference brought together more than 170
representatives of state and federal government, business
and foreign countries to discuss existing and potential
labeling strategies. This conference was preceeded by the
Second National Environmental Shopping Conference on
September 30, 1991 which was co—sponsored by Pennsylvania
Resources Council and U.S. EPA Region III. Both
conferences were held at the Hyatt Regency on the Inner
Harbor in Baltimore, Maryland. For more information on
the Environmental Shopping Conference, please contact the
Pennsylvania Resources Council at (215) 565—9131 or submit
a written request to P.O. Box 88, Media, PA. 19063.
ACKNOWLEDGEMENTS
U.S. EPA Region III would like to extend special thanks to
all the EPA staff who worked on the conference and to the
staff and volunteers of the Pennsylvania Resources
Council.
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CONFERENCE SPEAKERS
Ruth Becker
Executive Director
Pennsylvania Resources Council
P.O. Box 88
Media, PA 19063
Robert W. Dellinger
Deputy Director
Municipal and Industrial Solid Waste Division
U.S. Environmental Protection Agency
401 M Street SW
Washington, DC 20460
Sandra Eberle
Program Manager
U.S. Consumer Product Safety Commission
5401 Westbard Avenue
Washington, DC 20207
Manfred Eihoff
Attorney at Law
RAL German Institute for Quality Assurance and
Certification
e.v., Bonn, Germany
Lynn Elsasser
Vice President for Marketing
Green Seal, Inc.
1875 Connecticut Ave. NW
#300A
Washington, DC 20009
Ric Erdheirn
Office of Senator Frank Lautenberg
506 Hart Senate Office Building
Washington, DC 20510
Carl Frankel
Editor & Publisher
Green Market Alert
345 Wood Creek Road
Bethlehem, Connecticut 06751
Graham Hardman
Director of the Secretariat
Environmental Choice Program
107 Spark St. 2nd Floor
Ottowa, Ontario
Canada K1AOH3
Honorable Hubert H. Humphrey III
Minnesota Attorney General
102 State Capitol
St. Paul, MN 55155
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John Karnp
Vice President
American Association of Advertising Agencies
1899 L Street NW
Suite 700
Washington DC 20036
Joel Makower
Editor
The Green Consumer Letter
Tilden Press Inc.
1526 Connecticut Ave. NW
Washington DC 20036
‘rim Mohin
Chief, Program Implementation and Review Section
U.S. EPA, MD13
Research Triangle Park, North Carolina 27711
Robert Morgan
Director
Technical Committee Operations Division
American Society for Testing and Materials
1916 Race Street
Philadelphia, PA 19103
Lars Peterson
Senior Government Relations Representative
Food Marketing Institute
1750 K St. NW, Suite 700
Washington, DC 20006
Eddie Powers
Director, Government Relations
K-Mart
3100 W. Big Beaver Road
Tray, MI 48084
Tom Rattray
Associate Director
Corporate Packaging Development
Procter & Gamble Co.
Winton Hill Technical Center
6110 Center Hill Road
Cincinnati, Ohio 45224
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Michael Reilly
Manager of Environmental Programs
Wakefern Food Corporation
600 York St.
Elizabeth, New Jersey 07207
James Salzman
Environmental Consultant
Organization for Economic Cooperation and Development
42 Rue du Dragon
Apt. 31
75006 Paris
France
Byron D. Sher
California State Assemblyman
State Capitol Room 2136
Sacramento, CA 95814
Janet Steiger
Chairman
Federal Trade Commission
601 Pennsylvania Avenue NW
Washington, DC 20580
Frances Werner
Director
Planning and Analysis
Corporate Planning Department
Monsanto Company
800 N. Lindbergh B vd. Bid DiG
St. Louis, MO 63167
Ann Wilcox
Solid Waste Policy Analyst
MASSPIRG
29 Temple Place
Boston, MA 02111
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The following speakers declined to submit a copy of their
presentations. Please contact them directly for
additional information.
Dr. Kenneth Falci
Chief of Regulatory Affairs
U.S. Food and Drug Administration
200 C Street SW
Washington, DC 20204
Andrea Levine
Assistant Attorney General
Bureau of Consumer Frauds
New York Attorney Generals Office
120 Broadway, 3rd Floor
New York, NY 10271
Dr. Stanley Rhodes
President
Green Cross Certification Company
1611 Telegraph Ave.
Suite 1111
Oakland, CA 94612
John Schall
Co—Director, Solid Waste Group
Tellus Institute
89 Broad Street
14th Floor
Boston, MA 02110
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EPA’S EFFORTS ON ENVIRONMENTAL LABELING
Robert W. Dellinger, Deputy Director
Municipal and Industrial Solid Waste Division
U.S. Environmental Protection Agency
INTRODUCTION
We have all seen the proliferation of claims now being made in the marketplace that
tout the environmental attributes of products. Many companies are offering products in
highly concentrated forms, enabling their sale in “reduced packaging.” Others are
advertising their products as “environmentally friendly,” “recyclable,” “ozone friendly,” and
the like.
This tells me that consumers must be increasingly sensitive to environmental issues,
or manufacturers would not use the precious space on their packages for making
environmental claims. This is very good news because it means that environmental goals can
perhaps be achieved by proper environmental labeling messages and practices. We at EPA
want to seize this opportunity to help advance a number of our initiatives.
We believe that by providing reliable and meaningful information to consumers, we
can take advantage of their desire to do the “right thing” by making responsible
environmental choices. We believe strongly that well-conceived labeling programs can lead,
over time, to:
• reductions in air and water pollution
• significant reductions in municipal solid waste generated in the home
• enhanced markets for recovered materials
• increased supplies of recovered materials
• and, in general, to the promotion of the environmental ethic among all sectors
of society.
Unfortunately, there is a potential that we, as a nation, will fail to seize the
opportunity at hand. It is likely that consumers are becoming confused over the meaning of
terms used to describe various products. By making vague claims like “environmentally
friendly,” some are trying to take advantage of the “green” market, without taking the very
important step of educating the consumer. Conflicting State requirements may also make it
difficult, maybe even impossible, to market products nationally.
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EPA’S INITIATIVE
Information is the key to a properly functioning market and EPA wants to ensure that
consumers are equipped with accurate and meaningful information. We want to ensure that
responsible manufacturers are not at a competitive disadvantage because others are
improperly claiming environmental attributes. We also are seeking a market in which
businesses want to compete and will be able to compete on the basis of their products’
environmental characteristics.
Given this back drop, EPA believes that the solution is to issue clear Federal guidance
that will allow consumers to make informed choices based on accurate, meaningful
information. We need commonly accepted guidelines that will provide national consistency,
aid the competitive process, and provide guidance to the States.
National guidelines will serve an important environmental purpose -- accurate
information will stimulate consumer demand and encourage market response to products with
good environmental attributes.
Virtually everyonc recognizes the need for national guidelines. We first became
aware off how widespread the support was for national guidance in May of 1990. At that
time, we sponsored a focus meeting involving representatives of Federal, State, and local
government; the waste management industry; manufacturers and distributors; and public
interest groups. We were trying to define appropriate roles and responsibilities for all
involved in generating and managing municipal solid waste.
All of these groups, in their separate break-out sessions, called for the development of
national labeling guidelines. In response, we built a modest labeling project into our Fiscal
Year 1991 budget to look into the use of the terms “recycled” and “recyclable.”
More recently, EPA has been a participant with the Federal Trade Commission and
the U.S. Office of Consumer Affairs in the Federal Interagency Task Force on
Environmental Labeling. The purpose of the Task Force is to provide a coordinated and
cohesive national response to the issues of environmental labeling and “green” marketing.
Through a coordinated Federal effort, we hope to reduce consumer confusion and send a
unified message to both consumers and businesses.
Members of the Task Force are now active in a number of areas. First, EPA has
been considering a number of approaches for the use of the terms “recycled” and
“recyclable” and the “chasing arrows” symbol on products and packaging. Our intention
since May of 1990 has been to issue voluntary national guidance on the use of these and
other labeling terms.
Soon, probably this week, EPA will publish a notice in Federal Reaister requesting
comments on an array of options for the terms “recycled” and “recyclable” and the chasing
arrows symbol. We are recommending that the use of the term “recycled” be accompanied
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by a clear statement of the weight percentage of recycled materials in the product or
packaging.
We are also recommending that the term “recyclable” be qualified by the type of
material involved, the need to inquire about the availability of local recycling programs, and
disclosure of the national recycling rate for the commodity claimed to be recyclable. An
example of our preferred claim would be: “This bottle is recycled in communities where
collection facilities for colored glass bottles exist. For more information, contact your local
recycling coordinator. Glass bottles are recycled at a 20% rate nationally.”
With regard to the chasing-arrows symbol, we are recommending that the symbol be
used only for “recycled content” or “recyclable” claims, and not for claims unrelated to
recycling. We are also recommending that marketers clearly label the emblem as pertaining
to “Recycled Content” or “Recyclable” claims.
Lastly, we are recommending that marketers clearly differentiate between “recycled
content” and “recyclability” claims made about the product versus its packaging. We believe
this is necessary to reduce consumer confusion.
We will be conducting a public hearing on our notice. It is scheduled for November
13 and 14 at the Rosslyn - West Park Hotel in Arlington, VA. Details are provided in our
Federal Register notice. [ We have brought about two hundred copies with us for conference
attendees.] We are also providing a 90 day period for submittal of written comments on the
notice.
RELATED ACTIVITY
Additionally, in February of 1991, industry groups led by the National Food
Processors Association petitioned the Federal Trade Commission to develop industry guides
for the use of environmental terms. The FTC held hearings on July 17 and 18 to help them
determine whether the Commission should develop guides, as requested in the industry
petitions. They also requested information on how consumers respond to various marketing
claims.
Hank Habicht, our Deputy Administrator, testified at the FTC Hearing. In his
remarks, he stated:
1. Clear Federal guidance is needed to help clarify the information provided to
consumers and to increase consumer confidence in the validity of
environmental claims.
2. Environmental claims should be as specific as possible, should be substantive,
and should be supported by reliable evidence.
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3. Manufacturers should avoid the unqualified use of general claims such as
“environmentally friendly” and “safe in a landfill.” Our position is that they
are overly simplistic, vague, or irrelevant, and do not provide a meaningful
basis for comparing products.
4. Recycled content claims should include, at a minimum, the percentage of
recycled materials used; and
5. Environmental claims should distinguish between products and packaging.
Mr. Habicht stated his belief that accurate and meaningful information will stimulate
competition, provide a level playing field for manufacturers, benefit consumers, and, most
important of all, lead to benefits to the environment.
CLOSING
The ultimate fate of EPA’s efforts will necessarily be affected by the Federal Trade
Commission’s decision on whether to issue industry guides. We, of course, will share with
FTC the information that we receive in response to our Fedetal Register notice on “recycled”
and “recyclable.” We intend to continue the close working relationship that we have
developed with FTC and the U.S. Office of Consumer Affairs through the Interagency Task
Force. We have offered our technical assistance to FTC should it choose to issue industry
guides on environmental labeling. Additionally, in the event that FTC decides not to issue
industry guides, EPA intends to proceed with its own guidance. However, it is not our
intention to have two sets of guidance — it is our intention that the Federal government speak
with one voice through a single set of guidance on environmental terms.
Thank you.
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SPEECH BY RIC ERDHEIM October 1, 1991
EPA CONFERENCE ON ENVIRONMENTAL LABELING
ENVIRONMENTAL MARKETING CLAIMS ACT
My boss, Senator Frank Lautenberg, comes to the issue of
environmental claims on products and packages with a particular
interest. About 40 years ago, he co—founded a company you may
know, Automated Data Processing. He started out as ADP’s chief
salesman, so he has a keen interest in marketing and sales. He
knows firsthand that the way in which you market a product makes
a difference in whether or not the product sells.
Senator Lautenberg also has seen the power of information. Five
years ago the Congress passed the Right—to-Know law which Sen.
Lautenberg wrote. Now facilities must report on their emissions
of toxic pollutants.
When the first emissions were published in 1989, the results
were startling. The public was outraged that industry was
emitting 23 billion pounds of toxics into the environment. And
they demanded action.
But even more startling was the response of M erican industry. I
can’t tell you how many corporate officials told the Senator
that they had no idea about the level of their company’s
emissions. And when they found out they announced plans to cut
their toxic emissions. Voluntarily.
Accountability. It has revolutionized industry’s approach to
environmental issues. Just by disclosing information we have
demontrated the power of information. The Right-to--Know law
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conclusively demonstrates the ability of citizens to assert
their will when armed with accurate data to support their
arguements.
Finally, Senator Lautenberg believes that we need to focus our
efforts on preventing pollution from being generated. For the
last twenty years we’ve dealt with pollution by installing end-
of—the-pipe controls. Until recently, virtually all of our
regulatory efforts have been directed towards managing pollution
after it is produced.
But too often, end-of-the-pipe controls shift pollution from one
environmental medium to another. The safest way to protect the
American people and our environment from these pollutants is to
eliminate or reduce them before they are generated. Last year
the Congress enacted the Pollution Prevention Act which he wrote
to start a pollution prevention program.
That is why Sen. Lautenberg is so interested in this issue and
why he introduced S. 615, the Environmental Marketing Claims
Act. By making available accurate information about the
environmental attributes of consumer products and packages, we
can revolutionize the way manufacturers make their products and
package them. We can duplicate the success we’ve enjoyed with
the Right-to-Know program. And we can reduce the level of
pollution we generate.
I’m sure you realize the effect that environmental labeling can
have on consumers. Polls show that consumers would pay more for
“envi-onmentally safe” products and packages. Manufacturers are
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responding. According to Marketing Intelligence Service,
a company that gathers and analyzes new product information,
“environmentally friendly” products constituted 4.5% of all new
product introductions in 1989 and 9.2% in the first half of
1990. Back in 1985, green product made up only .5% of all new
products.
Today consumers are bombarded with product claiming to be
environmentally safe. Instead of environmental consumerism we
are getting environmental confusion. There are no standards by
which a consumer can judge these claims. And this puts
manufacturers who are making significant product or package
improvements at a disadvantage with those who aren’t making
these improvements. We need to establish a standard by which
consumers can measure these claims.
Many manufacturers want to respond to consumer demand for
environmentally preferable products. These companies are showing
great responsibility to their consumers and to their
communities. They want to play by a common set of rules. The
American people want to see firms invest in equipment and
processes to manufacture environmentally safe products and
packaging.
It is a basic role of government to establish common standards,
measures and definitions that provide cox on denominators by
which competition can take place fairly in the free market. A
free market relies on it and also depends on free and accurate
information.
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So we need to create a framework to protect consumers, to
protect industry and to protect the environment. We need to
provide incentives to manufacturers to make environmentally
preferable products and packages. We need to create a level-
playing field for manufacturers. We need to prevent claims by
those who fail to upgrade their products and packaging. And we
need to establish standards by which consumers can measure these
claims.
That’s what the Environmental Claims Marketing Act is intended
to do. It requires the EPA to establish detailed and enforceable
standards for environmental marketing claims for both products
and packages. It would establish an advisory committee including
members of industry and environmental and consumer groups to
advise EPA on the standards to be set. And it would establish a
petition process through which industry could ask EPA to
establish a standard for any unregulated claims a company may
want to make.
The bill is consistent with the recommendations of the Task
Force of State Attorneys General in its Green Report , and it has
the endorsement of that Task Force. The Task Force wants
standards which require that claims be specific, substantive and
supportable.
I want to answer a number of questions which are frequently
asked.
Why have we chosen EPA and not the FTC? EPA has the technical
expertise to establish standards. EPA is the agency responsible
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for the nation’s environmental policy. The claims are designed
to encourage consumers to buy certain products--these products
and the packages they’re in have environmental impacts. The
claims need to be consistent with the environmental policy EPA
is implementing. nd the FTC’S expertise is limited to truthful
advertising. Advertising can be truthful but not particularly
relevant to environmental attributes the nation wants to
promote.
Let me make clear that I am not opposed to FTC actions against
deceptive advertising. The FTC currently has 22 environmental
marketing investigations under way. The Commission is
investigating a variety of products including plastic disposable
diapers, trash bags, aerosol sprays and paper products. Claims
being reviewed include assertions that products are degradable,
CFC free and ozone friendly, environmentally safe and
environmentally friendly, recycled and recyclable. The
Environmental Marketing Claims Act does not negate the FTC’S
existing authority. So the FTC has an important role but a role
which is going to rely on EPA expertise and policy direction.
Senator Lautenberg wants to work with the FTC in defining the
Commission’s role in the bill.
Why products as well as packages? Because claims are being made
about the attributes of the product itself--ozone friendly,
biodegradable, nontoxic, chlorine free--these are just a few of
the claims you see about products in supermarkets today.
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Why specific standards? So that we establish a level-playing
field for industry. So that there is no confusion about what is
allowed. So that a consun er can rely on a claim that is made.
Does the bill require that claims be preapproved by EPA before
they can be used? Absolutely not. The bill provides that
companies which are making environmental claims must submit a
certification to EPA that the claims are qonsistent with the
Act. This provision is intended to aid in enforcement. But is
does not require any EPA action before a company can make the
claim.
Finally, does the bill preempt state laws? The bill does not.
This jE probably the toughest issue we have to face. Senator
Lautenberg understands the importance of preemption to industry.
Consumer products move in interstate co imuerce. At the same time,
states need to establish tougher standards to address local
problems. And the states often are innovators and take actions
which serve as forerunners to Federal action. So we’ll be
looking closely at this issue.
During this Congress, we will be considering the Environmental
Marketing Claims Act during the Environment Committee’s
deliberations on RCRA. A hearing was held on the bill on July
31. Markup on RCRA legislation could begin this fall.
I look forward to continuing to hear from all interested parties
in this important issue.
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REMARKS BY
ASSEMBLYMENBER BYRON 0. SHER
TO THE
U.S. ENVIRONMENTAL PROTECTION AGENCY CONFERENCE ON ENVIRONMENTAL
LABELING
October 1 1991
Hyatt Regency Qn T e Inner Harbor
Baltimore, N
I WANT TO BEGIN BY THANKING ELIZABETH RICH AND THE ORGANIZERS OF
THIS IMPORTANT CONFERENCE FOR INVITING ME TO SPEAK TO YOU TODAY.
I WOULD LIKE TO USE MY TIME TODAY TO PROVIDE YOU WITH SOME
BACKGROUND ON CALIFORNIA’S “TRUTH IN ENVIRONMENTAL ADVERTISING”
LAW, TO DESCRIBE THE LAW’S PROVISIONS, AND TO PROVIDE YOU WITH A
REVIEW OF KEY ISSUES AND CONTROVERSIES WHICH HAVE ARISEN SINCE THE
LAW’S ENACTMENT. I WILL ALSO TAKE TIME IN THE COURSE OF MY REMARKS
TO COl ’V4ENT Oil POTENTIAL FEDERAL PREEMPTION OF STATE LAWS SUCH AS
CALIFORNIA’S STATUTE AND ON EFFECTIVE ENFORCEMENT OF STATE LAWS IN
THIS AREA.
ODDLY ENOUGH, GIVEN THE ENORMOUS NUMBER OF CONSUMER PRODUCTS WHICH
CLAIM TO BE BENEFICIAL TO THE ENVIRONMENT, AND THE IMPORTANCE OF
CALIFORNIA AS A MARKETPLACE FOR SUCH PRODUCTS, THE DEBATE OVER
CALIFORNIA’S TRUTH IN ENVIRONMENTAL ADVERTISING LAW BEGAN RATHER
INAUSPICIOUSLY.
IN THE WINTER OF 1990, SEVERAL ENVIRONMENTAL ORGANIZATIONS (SIERRA
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CLUB, CALIFORNIANS AGAINST WASTE, CALIFORNIA PLANNING AND
CONSERVATION LEAGUE) SET UP A MEETING WITH ME TO DISCUSS THEIR
CONCERNS ABOUT THE EXPLOSION OF ENVIRONMENTAL CLAIMS BEING MADE BY
MANUFACTURERS OF CONSUMER PRODUCTS SOLO IN CALIFORNIA. THESE SAME
GROUPS HAD RECENTLY CONCLUDED A THREE-YEAR EFFORT WORKING WITH MY
OFFiCE TO PASS THE MOST COMPREHENSIVE INTEGRATED WASTE MANAGEMENT
LAW EVER ENACTED IN CALIFORNIA WHICH MANDATED THAT ONE-HALF OF THE
SOLID WASTE DISPOSED OF IN THE STATE BE REDUCED, RECYCLED OR
COMPOSTED BY THE TURN OF THE CENTURY.
THE STATE’S NEWLY-MINTED RECYCLING LAW, COUPLED WITH RESURGENT
CONSUMER INTEREST IN PROTECTING THE ENVIRONMENT, CAUSED THESE
GROUPS TO BECOME CONCERNED THAT MANUFACTURERS WERE SENDING
HALF.TRUE OR FLATLY FALSE ADVERTISING SIGNALS TO CONSUMERS ABOUT
THE ENVIRONMENTAL CHARACTERISTICS OF THEIR PRODUCTS. FOR EXAMPLE,
IF A CONSUMER PURCHASES A PRODUCT WHICH CLAIMS TO BE RECYCLA8LE”
BUT LEARNS AFTERWARDS THAT THERE IS NO RECYCLING LOCATION NEARBY
WHERE THE PRODUCT CAN BE RETURNED FOR RECYCLING, HE OR SHE MAY
BECOME IMPATIENT AND DISILLUSIONED WITH RECYCLING. ENVIRONMENTAL
GROUPS WERE ALARMED THAT, CONTRARY TO THE STATED OBJECTIVES OF
CONSUMER PRODUCT MANUFACTURERS TO EDUCATE AND INFORM CONSUMERS, THE
SiGNALS BEING SENT BY MANUFACTURERS TO CONSUMERS MIGHT ACTUALLY
SERVE TO FRUSTRATE AND DISCOURAGt CONSUMER INTEREST IN BUYiNG
ENVIRONMENTALLY FRIENDLY PRODUCTS AND IN PARTICIPATING IN PROGRAMS
TO REDUCE ENVIRONMENTAL DEGRADATION.
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IN THE MEETING THAI WINTER. THE SIERRA CLUB. CAW AND PCL PROPOSED
THAT I INTRODUCE LEGISLATION iN THE 1990 LEGISATIVE SESSION TO
ESTABLISH A STATE OPERATED ENVIRONMENTAL LABELING PROGRAM WHICH
WOULD MAKE AVAILABLE TO MANUFACTURERS A GOVERNMEHT SANCTIONED
“ENVIRONMENTAL CHOICE” LABEL TO BE PLACED ON THEIR PRODUCTS
PROVIDED THE MANUFACTURERS HAD COMPLIED WITH SPECIFIED
REQUIREMENTS, THiS PROGRAM WOULD BE ROUGHLY MODELED ON PROGRAMS
ALREADY IN EXISTENCE IN CANADA. WEST GERMANY AND SEVERAL OTHER
EUROPEAN COUNTRIES.
AS AN INTERESTiNG SIDELIGHT, A BILL MEETING THIS DESCRIPTION WA
INTRODUCED IN THE CALIFORNIA LEGISLATURE IN EARLY 1990.
UNFORTUNATELY, IT WAS jQITHE BILL I INTRODUCED AND IT HAS YET TO
BE ACTED UPON BY THE STATE LEGISLATURE. BUT THAT IS ANOTHER STORY.
IN THE MEETING THAT WINTER IN MY OFFICE, I EXPLAINEO TO THE
ENVIRONMENTAL GROUPS THAT I WAS NOT INCLINED TO CARRY LEGISLATION
WHICH ESTABLISHED A NEW GOVERNMENT PROGRAM AT A TIME WHEN BUDGETS
WERE EXTREMELY TIGHT AND WHERE THE PROGRAM MIGHT NOT ADDRESS THE
HEART OF THE CONCERNS I HAD OVER POTENTIAL ABUSES IN ENVIRONMENTAL
ADVERTISING. I SUGGESTED AS AN ALTERNATIVE THAT I WOULD BE
PREPARED TO CARRY LEGISLATION WHICH ESTABLISHED NEW SECTIONS TO
CALIFORNIA’S DECEPTIVE ADVERTISING STATUTES. THESE NEW SECTIONS
WOULD PROHIBIT MANUFACTURERS FROM MAKiNG REPRESENTATIONS ABOUT THE
SPECIFIC £NVIRONMENTAL CHARACTERISTICS OF THEIR PRODUCTS (E.G.,
OZONE FRIENDLY, BIODEGRADABLE, PHOTODEGRADABLE, RECYCLABLE AND
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RECYCLED) UNLESS THEY COMPLIED WITH STATUTORY STANDARDS FOR THE USE
OF THESE TERMS SET FORTH IN THE LAW. RECOGNIZING THAT SOME
CONSUMER PRODUCT ENVIRONMENTAL CLAIMS WERE NOT SPECIFIC IN NATURE
(E.G., ENVIRONMENTALLY FRIENDLY, ECO SAFE, EARTH FRIENDLY). I
SUGGESTED THAT AN ADDITIONAL SECTION OF LAW BE CREATED WHICH DID
NOT REGULATE THESE GENERAL TERMS PER SE, BUT INSTEAD REQUIRED
IIANUFACTURERS TO SUBMIT INFORMATION TO ThE ATTORNEY GENERAL’S
OFFICE (LATER CHANGED TO THE DEPARTMENT OF CONSUMER AFFAIRS) WHICH
SUPPORTED THE USE OF THE CLAIM.
THIS PROPOSAL, WITH SOME MODIFICATIONS ALONG THE LEGISLATIVE PATH
TO THE GOVERNOR’S DESK, BECAME ASSEMBLY BILL (AB) 3994 OF THE 1990
CALIFORNIA LEGISLATIVE SESSION.
AB 3994 PASSED BOTH HOUSES OF THE LEGISLATURE WITH LOPSIDED,
BIPARTISAN VOTES. ITS ONLY OPPOSITION WAS (RATHER PARADOXICALLY)
FROM THE CALIFORNIA DEPARTMENT OF CONSUMER AFFAIRS, WHICH OPPOSED
THE PROVISION OF THE BILL WHICH REQUIRED THE DEPARTMENT TO COLLECT
AND WAREHOUSE INFORMATION SUBMITTED BY CONSUMER PRODUCTS
MANUFACTURERS SUPPORTING GENERAL ENVIRONMENTAL CLAIMS (IN RESPONSE
TO THIS OBJECTION, WE AMENDED THE BILL TO SIMPLY REQUIRE
MANUFACTURERS TO MAINTAIN THE INFORMATION IN THIER OWN FILES AND
MAKE IT AVAILABLE TO THE PUBLIC UPON REQUEST). NOT ONE CONSUMER
PRODUCT MANUFACTURER OPPOSED THE BILL WHILE IT WAS PENDING BEFORE
THE LEGISLATURES 114 RETROSPECT, EVEN MORE CURiOUS WAS THE FACT
THAT THE STANDARDS SET IN THE BILL FOR SPECIFIC ENVIRONMENTAL
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CLAIMS (WHICH ARE BY MOST ACCOUNTS THE MOST CONTROVERSIAL
PROVISIONS OF THE BILL) WERE NOT QUESTIONED AND DID NOT CHANGE FROM
THE DATE THEY WERE AMENDED INTO THE BILL UNTIL THE DATE THE BILL
WAS SENT TO THE GOVERNOR.
ON AUGUST 21. 1990, AB 3994 WAS SENT TO THEN GOVERNOR GEORGE
DEUKMEJIAN ON A 68-1 VOTE OF THE 80-MEMBER ASSEMBLY. iT HAD NO
OPPOSiTION .
BUT THAT CHANGED QUICKLY ONCE THE BILL WAS ON THE GOVERNOR’S DESK.
WITHIN SEVERAL WEEKS OF THE BILL PASSING THE LEGISLATURE, CONSUMER
PRODUCTS MANUFACTURERS, LEAD BY THE AMERICAN PAPER INSTITUTE, THE
LEAGUE OF CALIFORNIA FOOD PROCESSORS AND THE WESTERN STATES
PETROLEUM ASSOCIATION, THE BURGER KING CORPORATION AND THE SIMPSON
PAPER COMPANY BARRAGED THE GOVERNOR’S OFFICE WITH LETTERS AND
TELEPHONE CALLS STRENUOUSLY URGING THAT HE VETO THE BILL. ONE CAN
ONLY ASSUME THAT THESE INTERESTS WERE ASLEEP AT THE SWITCHh WHILE
THE BILL WAS PENDING BEFORE THE LEGISLATURE AND WERE COUNTING ON
THE GENERALLY PRO-BUSINESS DEUKMEJIAN ADMINISTRATION TO PERFORM
THEIR DIRTY WORK AND VETO THE BILL.
SUPRJSED AND INITIALLY ANGERED AT THE ARROGANCE AND HIGH-HANDEDNESS
OF THESE SPECIAL INTEREST LOBBIES, THE ENVIRONMENTAL GROUPS MOUNTED
A MEDIA CAMPAIGN OF THEIR OWN TO COUNTERACT THE BEHIND-THE-SCENES
LOBBYING OF THE INTEREST GROUPS WHICH WERE URGING A VETO.
20
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CONCURRENT WITH THESE EFFORTS, I MET WITH AND WROTE TO THE GOVERNOR
AND HIS STAFF TO DISCUSS THE BILL’S PROVISIONS, TO RESPOND TO THE
ARGUMENTS BEING PRESENTED BY THE OPPONENTS AND TO OFFER TO AUTHOR
CLEANUP LEGISLATION TO ADDRESS ANY LEGITIMATE POINTS THE GOVERNOR
MIGHT BE CONCERNED ABOUT.
NOW, GOVERNOR DEUKMEJIAN IS A REPUBLICAN AND I AM A DEMOCRAT; HE
IS GENERALLY SUPPORTIVE OF THE BUSINESS COP ’1UNITY AND I HAVE
GENERALLY SUPPORTED STRONG ENVIRONMENTAL PROTECTION LAWS. HENCE,
OVER THE EIGHT YEARS THAT GOVERNOR DEUKMEJIAN HELD OFFICE, MORE
OFTEN THAN NOT I WAS IN DISAGREEMENT WITH HIS ENVIRONMENTAL
POLICIES. WHEN THE OPPOSITION EMERGED TO AB 3994, 1 WAS CONVINCED
THAT OUR CHANCES OF HAVING THE BILL BECOME LAW WERE SLIM. HOWEVER,
TO HIS CREDIT, AND TO THE GREAT SURPRISE AND DELIGHT OF MANY OF US,
ON SEPTEMBER 28, 1990, TWO DAYS BEFORE THE DEADLINE TO DO SO, THE
GOVERNOR SIGNED AB 3994 INTO LAW. HOWEVER, HE DID SO IN A RATHER
UNIQUE FASHION.
IN SIGNING THE BILL INTO LAW, THE GOVERNOR ISSUED A RARE MESSAGE TO
THE LEGISLATURE THAT OUTLINED HIS CONCERNS WITH THE BILL AND
REQUESTED CLEANUP LEGISLATION TO ADDRESS THESE CONCERNS. SIMPLY
STATED, HIS CONCERNS WERE THAT SOME OF THE STANDARDS FOR SPECIFIC
ENVIRONMENTAL CLAIMS WERE VAGUE AND NEEDED FURTHER REFINEMENT AND
THAT SOME PROVISION SHOULD BE MADE IN THE LAW FOR GOODS WHICH WERE
ALREADY IN THE STREMA OF COMMERCE WHEN THE BILL TOOK EFFECT. I
COMMITTED TO THE GOVERNOR TO AUTHOR CLEANUP LEGISLATION IN 1991 TO
21
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ADDRESS THESE TWO POINTS.
•IN MY VIEW, THE SIGNATURE OF AS 3994 INTO LAW, AND THE SIGNAL THAT
IT SENT TO CONSUMER PRODUCTS MANUFACTURERS, WAS A GREAT VICTORY FOR
CONSUMERS AND FOR THE ENVIRONMENT. It PUT CALIFORNIA STATE
GOVERNMENT ON RECORD THAT THE STATE WITH THE LARGEST SINGLE
CONSUMER MARKET IN THE COUNTRY AND THE SIXTH LARGEST ECONOMY IN THE
WORLD WAS SERIOUS ABOUT TRUTHFUL “GREEN ADVERTISING.” IT SENT THE
MESSAGE THAT IF YOU AS A MANUFACTURER WISH TO SELL YOUR PRODUCT IN
THE STATE AND MAKE ENVIRONMENTAL CLAIMS ABOUT THAT PRODUCT, YOU
MUST BE TRUTHFUL ABOUT THE ENVIRONMENTAL CLAIMS.
THE FINAL BILL, AS IT WAS SIGNED INTO LAW BY THE GOVERNOR, ADDED
SECTIONS TO THE DECEPTiVE ADVERTiSING STATUTES IN THE BUSINESS AND
PROFESSiONS CODE TO REQUIRE SPECIFIC CLAiMS OR REPRESENTATIONS MADE
ON CONSUMER PRODUCTS TO COMPLY WITH SPECIFIED STATUTORY STANDARDS.
FAILURE TO DO SO IS PUNISHABLE BY CRIMINAL MISDEMEANOR PENALTIES.
THE MEASURE DEFINES THE SPECIFIC TERMS ‘OZONE FRIENDLY”,
“BIODEGRADABLE”. nPHOTODEGR.ADABLEU, “RECYCLABLE’ 1 , AND “RECYCLED”
FOR USE IN CONSUMER PRODUCT LABELING AND ADVERTISING. AS 3994
FURTHER REQUIRES MANUFACTURERS OR DISTRIBUTORS WHICH MAKE GENERAL
ENVIRONMENTAL CLAIMS ABOUT THEIR PRODUCTS (E.G., ENVIRONMENTALLY
FRIENDLY”, ‘E.CO-FRIENDLY”) TO MAINTAIN WRITTEN JUSTIFICATION FOR
THE CLAIMS AND OTHER SPECIFIED INFORMATION. THE MEASURE IS
ENFORCED (AS WITH OTHER DECEPTIVE ADVERTISING STATUTES) BY DISTRICT
ATTORNEYS, THE ATTORNEY GENERAL AND THROUGH PRIVATE ATTORNEY
22
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GENERAL (I.E., “CITIZEN SUITS”) ACTIONS.
THIS MAY SEEM LIKE THE APPROPRIATE POINT IN MY REMARKS TO SAY
SOMETHING LIKE “AND THEY ALL LIVED HAPPILY EVER AFTER.” HOWEVER,
THE NEXT CHAPTER THE AR 3994 SAGA BEGAN IN DECEMBER OF LAST YEAR
WHEN I INTRODUCED THE CLEANUP LEGISLATIDN TO THE ORIGINAL LAW IN
ORDER TO FOLLOW THROUGH ON MY COItIITMENT TO GOVERNOR DEUKNEJIAN TO
MODIFY THE ORIGINAL STATUTE.
THE CLEANUP BILL, KNOWN AS ASSEMBLY BILL 144 WAS iNTRODUCED EARLY
IN THE SESSION WITH THE iNTENT THAT IT WOULD BE PASSED QUICKLY AS
API URGENCY MEASURE AND BECOME LAW BEFORE SUMMER. HOWEVER. ONCE THE
BILL WAS INTRODUCED, IT QUICKLY BECAME THE FOCAL POINT FOR
ENVIRONMENTAL AND INDUSTRY GROUPS, BOTH OF WHICH HAD THEIR bWN
IDEAS OF HOW TO IMPROVE THE LAW.
IN THE ORIGINAL VERSION OF AR 144, WE MODIFIED SEVERAL OF THE
SPECIFiC CLAIMS STANDARDS IN THE CURRENT LAW 10 MAKE THEM MORE
FLEXIBLE FOR INDUSTRY. THE BILL CHANGED THE STANDARDS FOR TERMS
SUCH AS “RECYCLABLE” AND “BIODE6RADABLE TO MAKE THEM EASIER FOR
CONSUMER PRODUCT MANUFACTURERS TO MEET. AFTER A GOOD DEAL OF
EFFORT 1 AR 144 PASSED THE STATE ASSEMBLY AND WAS ASSIGNED TO THE.
SENATE COP?IITTEE IN EARLY AUGUST. IN THAT CO1tI1TTEE, A COMPANY BY
TH NAME OF “KEYES FIBER” (MAKERS OF “CHINET’ PAPER PLATES) SOUGHT
AN AMENDMENT TO ALLOW THAT COMPANY TO CLAIM THAT ITS PRODUCTS WERE
MADE OF RECYCLED MATERIALS, EVEN THOUGH THEY CONTAINED NO
POSTCONSUMER RECYCLED MATERIALS. I RESISTED THIS AMENDMENT WHEN IT
W S OFFERED IN THE COMMITTEE AND THE BILL FAILED PASSAGE. WE WERE
GRANTED RECONSIDERATION BY THE COMMITTEE AND OlD IN FACT OFFER SOME
23
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MATTER SITS--EXCEPT THAT I HAVE NOW ADVISED THE ATTORNEY GENERAL,
WHO I HAD ASKED NOT TO PROSECUTE VIOLATORS PENDING THE DISPOSITION
OF AB 144, TO PROCEED “FULL SPEED AHEAD” TO ENFORCE THE LAW AS IT
WAS ENACTED. MEANWHILE, THERE HAS BEEN SOME INTEREST EXPRESSED BY
INDUSTRY GROUPS TO RESUSCITATE THE BILL, AND I INTEND TO PURSUE THE
MATTER WHEN THE LEGISLATURE RECONVENES NEXT JANUARY, ADDRESSING THE
TWO CONCERNS EXPRESSED BY GOVERNOR DEUKMEJIAN, AS WELL AS OTHER
ISSUES. IN THE MEANTIME, I EXPECT THERE TO BE SOME PROSECUTIONS
PRESSED BY LAW ENFORCEMENT AGENCIES OR CITIZEN GROUPS. ONE RECENT
CASE THAT HAS GENERATED A LOT OF INTEREST IS PROCTOR & GAMBLE’S ADS
THAT ITS PAMPERS DISPOSABLE DIAPERS ARE COMPOSTABLE, EVEN THOUGH
THERE ARE COMPOSTING FACILITIES FOR DIRTY DIAPERS IN CALIFORNIA.
AS A RESULT OF THE ADS, CONSUMERS iN LOS ANGELES BEGAN PLACING
DISPOSABLE DIAPERS OUT FOR COLLECTION IN THE CITY’S CURBSIDE
RECYCLING PROGRAM, AND THE CITY WAS FORCED TO PLACE STICKERS ON ITS
RECYCLING BINS STATING THAT DISPOSABLE DIAPERS ARE UNACCEPTABLE.
AT THE OUTSET OF MY REMARKS, I INDICATED THAT I WOULD TAKE A FEW
MINUTES TO COMMENT ON ENFORCEMENT AND FEDERAL PREEMPTION ISSUES.
WITH RESPECT TO ENFORCEMENT OF ENVIRONMENTAL TRUTH IN ADVERTISING
LAWS, IT IS FORTUITOUS THAT CALIFORNIA’S LAW WAS PLACED IN THE SAME
STATUTORY SECTIONS AS THOSE WHICH ADDRESS DECEPTiVE ADVERTISING
CLAIMS IN GENERAL. AS SUCH, THE LAW CAN BE ENFORCED BY THE STATE
ATTORNEY GENERAL, BY LOCAL DISTRICT ATTORNEYS, OR THROUGH WHAT ARE
CALLED “PRIVATE ATTORNEY GENERALN ACTIONS (I.E., CITIZENS SUITS).
IN MY VIEW, IT IS APPROPRIATE THAT THIS LAW, AS WITH OTHER
DECEPTIVE ADVERTISING LAWS, BE ENFORCEABLE BY CONSUMERS (WHO ARE
24
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DIRECTLY AFFECTED BY THE MARKETING CLAIMS OF CONSUMER PRODUCT
MANUFACTURERS). OFTEN, WHITE COLLAR CRIMES LIKE DECEPTIVE
ADVERTISING ARE LOW ON THE PRIORITY LIST OF LAW ENFORCEMENT
AGENCIES. THE PROSPECT OF PRIVATE ATTORNEY GENERAL ACTIONS BY
WATCHDOG CONSUMER GROUPS SHOULD SERVE TO DETER COMPANIES WHICH
MIGHT OTHERWISE HAVE A MARKETING INCENTIVE TO STRETCH THE TRUTH
ABOUT THE ENVIRONMENTAL BENEFITS OF THEIR PRODUCTS.
WITH RESPECT TO THE ISSUE OF FEDERAL PREEMPTION, CALIFORNIA’S LAW
EXPRESSLY DEFERS TO ANY DEFINITIONS IN TRADE RULES ADOPTED BY THE
FEDERAL TRADE COMMISSION, SO THAT ANY SPECIFIC ENViRONMENTAL CLAIMS
THAT MEET THE FEDERAL DEFINITION SHALL NOT BE SUBJECT TO
PROSECUTION. AS THE AUTHOR OF THE CALIFORNIA LAW, I PERSONALLY
SUPPORT THE IDEA OF UNIFORM NATIONAL STANDARDS iN THIS AREA. IT IS
INTERESTING TO NOTE, HOWEVER, THAT MANY OF THE COMPANIES AND
FEDERAL AGENCIES URGING THE FEDERAL GOVERNMENT TO STEP IN AND
PREEMPT THE STATES WERE SUPPORTERS OF THE REAGAN/BUSH “NEW
FEDERALISM’S POLICIES, WHICH SEEK TO DECENTRALIZE ENVIRONMENTAL
REGULATIONS IN THE FEDERAL BUREAUCRACY AND INSTEAD HAVE THE STATES
ASSUME REGULATORY JURISDICTION.
I WOULD HOPE THAT IF CONGRESS GRANTS THE FTC OR EPA THE AUTHORITY
TO PREEMPT THE STATES iN THIS AREA THE FEDERAL AGENCY IS ALSO
REQUIRED TO ESTABLISH TOUGH, LOCALLY ENFORCABLE STANDARDS FOR
TRUTHFUL ENVIRONMENTAL ADVERTISING. ALTERNATIVELY. I WOULD SUPPORT
THE FEDERAL GOVERNMENT’S ESTABLISHING BASELINE STANDARDS WHiLE
ALLOWING INDIVIDUAL STATES TO ENACT LAWS WHICH GO BEYOND THESE
25
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STANDARDS.
IN CLOSING, I WOULD SUGGEST THAT THOSE OF US IN PUBLIC OFFICE HAVE
AN OBLIGATiON TO PROVIDE MANUFACTURERS AND SELLERS WITH CLEAR,
EASILY UNDERSTANDABLE STANDARDS IN OUR TRUTH IN ENVIRONMENTAL
ADVERTISING LAWS. HOWEVER, WE ALSO HAVE A RESPONSIBILITYTO THE
CONSUMER WHO ON A DAILY BASIS IS BARRAGED WITH CONFUSING, AND OFTEN
MISLEADING CLAIMS BY CONSUMER PRODUCT MANUFACTURERS. I BELIEVE
THAT IF STANDARDS ARE SET FORTH CLEARLY IN THE LAW, AND IF
MANUFACTURERS ARE GIVEN A REASONABLE AMOUNT OF TIME TO COMPLY, BOTH
THE BUSiNESS COMMUNITY AND THE CONSUMER WILL BENEFIT. MARKETING OF
PRODUCTS WHICH ARE TRUTHFULLY ENVIRONMENTALLY BENIGN WILL ALSO
RESULT IN TANGIBLE ENVIRONMENTAL IMPROVEMENTS. THESE SHOULD BE THE
GUIDING PRINCIPLES IN OUR EFFORTS TO PROMOTE TRUTH IN GREEN
MARKETING.
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AMY WILCOX
MA$PIRG
MASSACHUSEI7S PUBLIC INTEREST RESEARCH GROUP
FACT SHEET: THE MASSACHUSETTS RECYCLING INITIATIVE
Massachusetts is facing a garbage crisis .
Every year, Massachusetts produces six and a half million tons of
solid waste -- more than a ton per person. We recycle less than ten
percent of that total, relying instead on burning and burying trash.
But landfills inevitably leak and contaminate drinking water
supplies. Incinerators are no better; they spew chemicals into the air
and Leave behind vast amounts of toxic ash which still must be
landfilled.
Packaging waste is out of control .
There is general agreement that reducing the amount of garbage we
throw out is the answer to this growing crisis and that throwaway
packaging, which makes up one-third of our total solid waste by weight
and half by volume, must be addressed. There is a growing recognition
of the need to require recycling standards for packaging. At least ten
states are working on bills modeled after our Recycling •Initiative.
The Recycling Initiative will prevent wasteful packaging and promote
increased recycling .
The primary purpose of the Recycling Initiative is to stimulate
innovations in packaging and recycling systems, and to do so with a
minimum of government involvement. It will encourage packagers to
reduce the amount of packaging they use, create a strong market demand
for recycled materials, and create incentives for packagers to push
comprehensive recycling programs in the state.
The Recycling Initiative would require that by July 1, 1996 all
packaging used in Massachusetts must be either:
* Reusable five or more times, or
* Made of 25% recycled materials (35% by 1999 and 50%
by 2002), or
* Made of materials that are being recycled at a 25%
rate in the state (35% by 1999 and 50% by 2002), or
* Reduced by 25% every five years, or
* Recycled at a 50% rate.
Practical decisions about how best to comply with these attainable
standards are left to those best able to make those decisions: the
affected industries themselves.
The Recycling Initiative would equalize the burden of solid waste
management, shifting some of the responsibility for reduction and
recycling onto those responsible for creating our trash problems in the
first place. No other solid waste proposal addresses so effectively
economic dimensions of recycling.
29 Temple Place, Boston MA 02111-1305 (617) 292-4800
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SUPPLEMENT TO REMARKS BY ANY WILCOX
THE ART
OF THE
POSSIBLE
The Feasibility of
Recycling Standards
For Packaging
SUMMARY VERSION
ROBERT F. STONE
Research Economist,
Center for Technology, Policy and Industrial Development,
Massachusetts Institute of Technology
NICHOLAS A. ASHFORD
Associate Professor of Technology and Policy,
Massachusetts Institute of Technology
GEOFFREY LOMAX
Research Scientist, National Environmental Law Center
FEBRUARY 1991
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THE ART
OF THE POSSIBLE
The Feasibility of Recycling
Standards for Packaging
SUMMARY VERSION
II4TRODUCr1ON:
Setting Recycling
Standards For Packaging
The average American discards, directly
and indirectly, an amount of waste equal in
weight to the Statue of Liberty every five
years. The economic, environmental and
public health consequences of burying and
burning these literal mountains of trash have
been well documented.
Throwaway packaging is not only the
symbol of our national solid waste crisis, it is a
leading contributor to the problem, comprising
one-third by weight of the municipal solid
waste stream.
But the findings in tins report demonstrate
that the technology needed to transform our
throw-away economy into one based on waste
reduction, reuse, recycling and sustainable use
of resources already exists. What packagers
and other manufacturers lack is a strong
enough incentive to reduce, reuse, and recycle
the materials needed to make their products.
Environmental and consumer groups in
many states are now proposing to provide that
incentive through mandatory recycling
standards for packaging. To comply with the
standards proposed in the Massachusetts
Recycling Initiative, product packaging must,
by 1996, be either:
(1) reusable live times: or,
(2) made of 50% recycled material by
weight; or,
(3) made of materials that are actually
being recycled at a rate of 35% statewide, and
at higher rates five and ten years later.
Our detailed analysis of each major
material used in packaging and offive
common products, summarized here,
demonstrates that recycling is truly, like
polLrzcs , “the art of the possible. ”
PART ONE:
MateriaLs Used In Packaging Can
Comply With Recycling Standards: A
Material-By-Material Analysis
In this section, we examine the broad
categories of materials most commonly used in
packaging — six types of plastics, paper,
glass, aluminum, and iron and steel — in light
of the latest advances in the recycling field.
For each material, we assess the current state
of recycling technology, the feasibility of
lIcction and separation of used materials,
and issues in packaging design.
In general, high recycling rates have
already been achieved nationally in the paper,
glass, aluminum, and iron and steel industries,
and ongoing efforts and innovations should
cause those rates to climb in the near future. In
addition, the plastics industry, which for years
has neglected recycling, is beginning to make
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major strides. The highlights of our findings
follow.
Plastics
Because they possess many qualities
attractive to consumers yet harmful to the
environment, plastics — now projected to
account for 10% by weight of mu aicipal solid
waste by the year 2000 — present the greatest
challenge to packagers and environmentalists.
But by designing for reuse, standardizing
plastic types (making more products out of the
same plastic type), improving recycling labels,
establishing better collection systems, and
incorporating recycled plastics into their
products, even plastics manufacturers can
comply with the proposed recycling standards.
Developments in the field of plastics
recycling are out of date almost before they
can be reported, while problems that were
insoluble yesterday become tomorrow’s
success stories. Following is a
soon-to-bc-obsolete sampling of the current
state of the art:
Reuse: Coca-Cola and Pepsi are
introducing reusable PET plastic soft drink
bottles that they expect to collect and refill up
to 25 times (which would be a 96% reduction
in waste). And General Electric recently
announced the development of a plastic
container that can be sterilized and refilled up
to 100 times and then recycled into other
products.
Recycling: Though only 1% of all plastic
is now recycled, 80% could be recycled using
existing technology. Some plastic resins have
achieved relatively high recycling rates: PET
plastic, used primarily in soft drink bottles, is
already being recycled at a 20% rate
nationally, and at rates as high as 80% in states
with bottle return laws. HDPE plastic, most
commonly seen in milk jugs, also promises
high co’lection and recycling rates. As
packaging standards increase demand for
recycled plastic, collection programs will
become more economically viable.
Recycled Content: In January, 1991. the
Food & Drug Administration (FDA) for the
first time approved the use of recycled plastics
in beverage containers (PET Coke bottles).
Proctor & Gamble sells Downy, Tide, Cheer
and other detergents in HDPE plastic bottles
containing about 30% recycled HDPE from
milk jugs, while Exxon has developed a
process to allow increased recycled HDPE
content. Plastic film, commonly used in bags
and wraps, poses particular collection and
recycling problems. But progress is even
being made here: Mobil is making trash bags
with up to 90% recycled LDPE, while Mirrex
Corporation is producing transparent PVC
packaging flim containing a minimum of 30%
recycled content.
Paper
Over half the 79 million tons of paper
produced in 1988 was used in packaging,
contributing heavily to the municipal solid
waste stream.
Recycling: Paper is already being recycled
nationwide at a rate of 26%, while rates for
some packaging uses are even higher (the
recycling rate of corrugated cardboard, for
example, is at 52%). The paper industry itself
has pledged to achieve an overall recycling
rate for all paper of 40% by 1995 (the
Massachusetts Recycling Initiative, in
comparison, anticipates a 35% rate by 1996).
Recycled Content: Many paper packaging
products today contain significant recycled
content. Corrugated cardboard is commonly
made with anywhere from 20% to 70%
recycled content. Also, innovations in inks
and coating allow recycled paper to be used in
higher grade products (such as boxes, paper
plates and cups) rather than lower grade uses
(tissues, newsprint).
Recent Developments: A plethora of new
recycling technologies and product designs
bodes well for achievement of recycling goals
as envisioned in the Massachusetts Recycling
Initiative. International Paper is running a pilot
program to test the feasibility of recycling
plastic. or wax-coated paperboard milk and
juice canons, an untapped source of
high-grade paper fiber. Chesapeake
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Corporation, in Virginia, has introduced a
super- efficient process for recycling
post-consumer newsprint, corrugated
cardboard and unsorted office paper in one
feed stream. This innovation cuts the cost of
traditional paper recycling processes by
one-third by reducing the number of steps
required from 21 to just eight.
Glass
About 12.9 million tons of glass were
discarded in 1986, approximately 90% of
which was container glass, the type used in
packaging.
Reuse: Reusable bottles are an
environmentally ideal container: reuse
accompLishes source reduction, and when the
bottle is no longer reusable it can be recycled
into new glass containers. One California firm
profitably collects and washes 9.3 million wine
bottles annually for resale to wineries, while
two northwestern breweries (0. Heileman and
Rainier) have made strong commitments to
refillable beer bottles.
Recycling and Recycled Content: Glass
is 100% recyclable: that is, one pound of
recycled glass makes one pound of new glass.
Approximately 25-30% of container glass is
estimated to be recycled currently (up from
just 15% in 1988), and the glass industry
intends to achieve a 50% national recycling
rate in the near future.
Aluminum, Iron and Steel
More than three-quarters of the aluminum
in municipal solid waste consists of aluminum
cans, while steel food and beverage cans
account for about a quarter of the 11 million
tons of ferrous scrap in the waste stream.
Recycling: Because of their high market
values, metals have historically been recovered
and recycled at high rates. The national
aluminum recycling rate is now 35%, while
aluminum cans are recycled at a rate of over
60%, In 1986, U.S. steel mills actually
consumed more scrap than virgin material,
and, overall. 66% 01 ferrous scrap is recycled.
High scrap values have always driven
post-consumer alum mum recycling, and
increased demand promises to raise recycling
rates for steel cans, which have been recovered
at 45% rates in curbside collection programs.
Recent Development: Magnetic
separation systems at waste processing
facilities will enhance steel recycling efforts by
efficiently separating ferrous materials from
the rest of the waste stream.
PART TWO:
Product Packaging Can Comply With
Recyclui.g Standards: Five Case Studies
How will developments in materials
conservation and recycling technologies
translate to the local supennarket or
department store? This section of the report
consists of five case studies of common
products, mast of which are often held up as
examples of why mand tory recycling
standards for packaging would be impractical.
To test the common wisdom about these
products, we interviewed dozens of people in
the packaging business: manufacturers,
packagers, distributors and retailers. We
explored current technology, the unique design
considerations necessitated by each product.
and the variety of options open to packagers
and retailers under the proposed recycling
standards. In each case, simple changes in
design or expanded use of recycling
technologies available today can guarantee
safe, effective and economical delivery ot’ the
products in question.
Milk
Milk packaging must be hygienic
(bacteria-free) and barrier resistant to moisture.
These criteria can be harmonized with
recycling standards for packaging in a variety
of ways:
Coated Paperboard Cartons: Paper is
very likely to meet the minimum statewide
recycling rates, while efforts are under way to
develop coated paperboard made with recycled
fiber (which would require FDA approval). As
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noted above, International Paper is conducting
a pilot program to assess the feasibility of
recycling post-consumer wax- and
plastic-coated paperboard from milk and juice
cartons.
Glass Bottles: Glass will meet the
proposed recycling rates; bottles can be made
of recycled glass; and refilling bottles many
times can make their unit cost competitive
with plastic and paperboard.
Plastic Jugs: HDPE (used now for milk
jugs) could achieve high recyc’ing rates with
more aggressive collection. Reusable piastic
jugs, such as those developed by General
Electric which can be sterilized and refilled
100 Limes and then recycled, offer another
possibility.
Shampoo
One of every seven plastic bottles sold in
Massachusetts is for hair or personal products,
and shampoo is almost exclusively sold in
plastic containers. Shampoo containers must
be barrier resistant, and should be
nonbreakable, lighiweigin, and squcezable.
Plastic shampoo bottles can comply with
recycling standards in various ways.
Single.Resin Plastics: Most shampoo
bottles are made of HDPE, which is being
recycled in a number of programs in
Massachusetts and around the country. PET,
which has achieved even higher recycling
rates, can also be used for shampoo.
Standardizing resin use — in other words,
making more products out of the same plastic
type — would aid in achieving aggressive
recycling goals.
Recycled Plastic: The technology to make
bottles from recycled plastic exists, and some
manufacturers believe they will actually be
cheaper to produce than virgin plastic bottles.
Three pompanies now make detergent bottles
with 25-35% post-consumer recycled HDPE,
and one of them (Plastipak, in Michigan) has
designed a 100% recycled PET bottle used by
Proctor & Gamble for Spic ‘n Span.
Reusable Plastic Bottles: The Boston
Food Co-op has refilled consumers’ shampoo
bottles for 20 years without any health, safety
or legal problems, while The Body Shop, a
California-based cosmetics store, encourages
consumers to refill bottles at the shop with a
$0.40 incentive.
Computer Equipment
Computer equipment is generally shipped
in corrugated cardboard boxes with styrofoam
cushioning material. The primary packaging
considerations are cushioning ability, fit, and
amenability to automated packaging processes.
Both the bbx and the cushioning material can
be produced in accordance with the proposed
recycling standards.
Corrugated Cardboard: These boxes are
already recycled at a rate of more than 50%,
and can include up to 70% recycled content.
Reusable Plastic Cushioning: Styrofoam
can be replaced with reusable polyethylene
cushioning materials. Dow Chemical’s
Ethofoam is more durable than styrofoam, can
be mused ten times, can be handled by
automated packaging machines, and is priced
competitively with styrofoam.
Paper Cushioning: EcoPak, of Kent,
Washington, is marketing a spring-loaded,
100% recyclable paper packing material that
expands upon impact and doesn’t settle during
shipping. Other innovative paper cushioning
products are also on the market.
Microwaved Food
Microwavable food is frequently cited as
an excessively packaged product. These
“convenience” foods are usually sold in an
outer box, a disposable plastic cooking tray,
and a plastic wrapping. The packaging must
keep food fresh and dry, and those elements
put into the oven must withstand extreme
temperature variations and not be made of
metal.
Paperboard Boxes: Paperboard will
comply with the proposed recycling standards
thanks to the high overall level of paper
recycling, while packagers like the
Virginia-based James River Paper Company
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are already working on coated paperboard with
recycled content.
Eliminate Disposable Cooking Trays:
Eliminating the plastic tray, which many
packagers already do, would reduce excess
packaging and avoid health threats posed by
plastic leaching into foods during cooking.
Trays can also be made of single-resin,
recyclable plastic.
Foods Wrapped in Plastic
Plastic film has become a popular flexible
packaging material because it is transparent.
barrier resistant, form fitting, and inexpensive.
But foods now wrapped in plastic cart be
packaged in a number of ways which comply
with the proposed recycling standards,
Reduction: Unnecessary second and third
layers of wrap — sometimes to delineate
“individual servings” or to provide an extra
“freshness seal” — are simply marketing
devices, and can be eliminated.
Substitution: Selling food in bulk,
packaging food in more durable plastic or in
other materials which can be reused or
recycled, and allowing consumers to use
reusable containers can also avoid unnecessary
uses of plastic film.
Recycled Content: Packages that use
plastic food wrapping in conjunction with
outer boxes, bags, trays or other material made
of recycled content would comply with
recycled content standards based ott the weight
0 the entire package. Shop ‘n Save
supermarkets in Maine now sell meat wrapped
in PVC film but sitting on molded, recycled
paperboard trays. And plastic film itself can be
made of recycled plastic: Mirrex Corporation
now produces PVC film with a 30% recycled
content.
Recycling: Advanced recycling
technologies are making possible the
separation and cleaning of post-consumer
plastic film, and successful collection and
recycling has been accomplished for LDPE
and HDPE grocery sacks, trash bags, and
cleaners’ bags.
CONCLUSION:
Mastering the Possibilities
There is an enormous potential for
reducing, recycling and redesigning product
packaging as a key component of a long-term
solution to the solid waste crisis. Our research,
however, has uncovered more than just
“potential.1’ The ground-breaking
technologies, innovative collection and
separation techniques, and advanced product
designs mentioned here demonstrate in striking
fashion the momentous changes already afoot.
Setting mandatory recycling standards for
packaging would ensure that all sectors of
industry take seriously their responsibility for
the solid waste challenges we all face.
Not all of the possibilities and options
described in this report may be desirable for
consumers or cost-effective for industry. But
those questions are for the free market to
decide. And that is one of the most attractive
features of the proposed recycling standards
discussed in this report. Decisions about how
best to comply with these standards would be
left to those best able to make such
determinations: the affected businesses
themselves.
The profusion of recent advances and
future possibilities in packaging design,
construction and recycling far exceed what the
common wisdom would have us believe. They
also contradict industry predictions that
mandatory recycling standards would lead to
wide-spread product bans and empty
supermarket shelves. The possibilities for
reduction, redesign, and recycling of product
packaging are certainly there; enacting
recycling standards for packaging may be the
only way to push the free market to master
those possibilities.
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SUPPLEMENT TO REMARKS BY AMY WILCOX
PACKAGE
DEAL
The Economic Impacts of
Recycling Standards for
Packaging in Massachusetts
SUMMARY VERSION
ROBERT F. STONE
Research EconomLc t ,
Center for Technology, Policy and Industrial Development,
Massachusetts Institute of Technology
NICHOLAS A. ASHFORD
Associate Professor of Technology and Policy,
Massachusetts Institute of Technology
MARCH 1991
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PACKAGE DEAL:
THE ECONOMIC IMPACTS OF RECYCLING STANDARDS FOR PACKAGING
IN MASSACHUSETrS
EXECUTIVE SUMMARY
This report examines the economics of recycling. It consists of three related parts. Part One compares
the costs of recycling with the costs of landfiiling and incineration for a representative ton of materials found in
municipal solid waste. In Part Two, we analyze the dynamics of recycling markets and determine that recycling
standards are the critical mechanism for remedying deficiencies in demand for recovered materials. Part Three
of the report evaluates the likely impacts of Massachusetts recycling standards for packaging (RSP), taking into
account both microecononiic and macroeconomic effects.
PART ONE: RECYCLING PAYS, BUT BY HOW MUCH?
It is widely recognized that the recycling of materials confers a net benefit to society, but just how large
is the social benefit? Casual estimates are typically based on the revenue from recycled materials plus the
avoided tipping fee for incinerating or landfilling of the (otherwise waste) materiaL However, tipping fees bear
no necessary relationship to the actual social costs of solid waste disposal, and the recycling of materials
imposes costs that must also be included in the calculation.
For the purposes of this analysis, we assume that current market conditions and prices for recycled
materials prevail. In fact, as we argue in Part Two, recycling standards for packaging arc required precisely in
order to realize this assumption, by maint iining viable markets for recycled materials.
The net social benefits of recycling can be derived from five elements:
(I) Revenues From Recvclers for Separated Materials : The current market values for separated and
processed paper, glass, plastics, steel, and aluminum, adjusted for the projected composition in the year
2000 of a typical ton of Massachusetts municipal solid waste, yield an estimated revenue of $49/ton.
PIus: (2) Avoided Subsidy to Virgin Materials : Since the use of recycled materials reduces the need for
virgin materials, the cost of government subsidies to producers of those materials—consisting of tax
benefits, below cost sale of natural resources, and wicompensated technical support--is avoided. The
magnitude of the subsidy is estimated to be approximately $3/ton.
Minus: (3) Costs of Collecting and Scyarptin Materials for Recvdlin The capital and operating costs needed
for the collection and separation of recycled materials--based on current garbage collection costs,
additional costs associated with collecting recyclables, and the experience of the Springfield Materials
Recycling Facility--is estimated to be $86/ton.
Plus: (4) Avoided Disposal Costs of Incineration (for that share of municipal solid waste that is incinerated) :
The Commonwealth predicts that, by 1992, the ratio of incineration to landfilling will be 70% to 30%.
Adding capital costs, Federal tax subsidies, the cost of remedial pollution control equipment, operating
costs, ash disposal costs, and the social cost of environmental harm and disamenities, and subtracting
revenues from the sale of electricity produced from solid waste combustion, yields a net cost of
$289/ton of waste incinerated in Massachusetts facilities. 70% of that figure provides the avoided
disposal cost of $202/ton.
Plus: (3) Avoided Disoosal Costs of Landfluing (for that share of municiDal solid waste that is landfillecfl :
Capital costs, operating costs, clean-up and post-closure care costs, additional costs of impending
landfill regulations, and the social cost of environmental harm and di menities come to $209/ton.
30% of that figure provides the avoided disposal cost of $63/ton.
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Based on the preceding estimates, we are now able to calculate the net social benefits of recycling, as
applied to packaging material.
Recycling Revenues: $49/ton
Recycling Costs: $86/ton
Net Recycling Revenue: $(-37)/ton
Avoided Subsidy to Virgin Material: $ 3/ton
Avoided Cost/Ton of Incineration $ 202/ton
(for the share of waste incinerated)
Avoided Costfron of Landfluing $ 63/ton
(for the share of waste landlilled)
Net Benefit of Recycling: S 231/ton
Appendix A of the report subjects the estimates cited above to a sensitivity analysis, in which each
variable influencing the net benefit of recycling is allowed to assume a range of possible values. This analysis
demonstrates how robust the $231/ton estimate is. With few exceptions, substituting the high and low values of
a variable in place of the baseline value still results in a net benefit of recycling of between $200 and $265.
PART TWO: WHY RECYCLING STANDARDS FOR PACKAGING ARE NECESSARY
This section answers the following two related questions:
(1) If the benefits of recycling are so substantial ($231/ton), wont private mwkets provide the desired
expansion of recycling activity (to its optimum level)?
(2) IThy we recycling standardr for packaging (RSP), or any other form of government intervention,
needed?
Market imoerfections plarue recycling efforts . For a market to operate efficiently, economic agents
must bear the full marginal social costs (and realize the full marginal social benefits) associated with their
actions. Imperfections in solid waste disposal markets prevent this condition from being realized.
Because the price for solid waste disposal does not reflect the environmental harm and disamenities
accompanying such activities soM waste generators are able to escape these costs. The other source of the
market failure arises from the way in which solid waste collection and disposal are financed, local government
typically finances market costs of collection and disposal from general tax revenues, making a household’s
mwginal tax burden of discarding an additional unit of trash effectively zero, even though the associated market
cost is not.
&asnple: Suppose a town contains 6000 households, each paying $400 a year in taxes to
collect and dispose of the 6000 pounds of solid waste it generates. The marginal cost to the
town of each additional pound of trash is 6.7 cents, but the cost borne by each household in tax
payments for each additional pound discarded is only 6.7/6000 cents, or approximately 1/1000
of a penny.
This discrepancy distorts incentives For individuals to reduce the amount of material they discard and
results in an inadequate amount of recycling from a social perspective.
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Government-mandated separation and collection of recyclable materials has fatal limitations . Until
recovered materials arc actually reused--until they are converted into new products and sold to new customers--
no meaningful recycling has been achieved. It is the inability of government-mandated waste separation and
collection programs to remedy deficiencies in demand for the recovered materials that will quickly cause them
to fail. Some cities have already discovered that no markets exist for their recyclables.
Existina demand-side policies are ineffective . Economic charges and tares (on household waste
disposal, packaging, or virgin materials) face insurmountable practical problems concerning accuracy, fairness,
effectiveness, and collection costs. State procurement constitutes too small a percentage of packaging sales to
remedy deficient private demand for recyclable materials. Unconditional product bans eliminate the possibility
of recycling the banned material or packaging and provide no additional demand for recovery of the material
that replaces it; historically, unconditional bans have been applied to isolated materials and packaging in a
relatively unsystematic manner, limiting their effect.
Recvclingstandards for nackaging are the mechanism critical to remedvin deficiencies in demand for
recovered materials . Since packaging is the largest single source of municipal solid waste (MSW), comprising
one-third of MSW, it is there where recycling standards would, in all likelihood, be most productively applied.
RSP will stimulate recycling demand for the major types of materials used in packaging--paper, glass, plastics,
steel, and aluminum. These materials account for 60% of MSW.
RSP should contain at least two provisions: that packaging consist of a given percentage of recycled
material, and, alternatively, that packaging be made of recyclable materials (those which achieve a specified
statewide recycling rate for all uses of the material). An important feature of the two provisions is their
synergy, which causes the demand for recovered packaging materials to ratchet up.
The function of 2overnment should not be to replace the market but to oraanizc and maintain a market
that is not independently sustainable . Mandatory separation and collection, education of consumers and
businesses, information clearinghouse functions, and state procurement take on added importance when
complemented by RSP. The combination of these activities can provide the stability in recycling markets that
private investors require and help develop a large-scale recycling infrastructure.
PART ThREE: ThE EFFECT OF RECYCLING STANDARDS FOR PACKAGING IN
MASSACHUS1 itS
Microeconornic Effects: The Benefits arid Costs of RSP
(1) Net Social Benefits of Increased Recycling of Packaging Material Due to RSP : Although less than
10% of Massachusetts’s 6.6 million annual tons of MSW is currently recycled, a larger proportion of packaging
discards (estimated at 213 million tons) is recycled: approximately 16% by weight, or 357,000 tons per year.
For purposes of analysis, we assume that an aggressive, but realisti; RSP program can and will
increase the recycling rate for discarded packaging to 50%. Not only have other countries met or exceeded this
level, but most packaging materials now used in the U.S. have already reached or are anticipated to reach 50%
rccyclin&
For all parksiging in Massachusetts to comply with RSP by consisting of 50% recycled materials would
require a total of 1.115 million tons of MSW to be recycled, or an increase of 758,000 tons per year from current
levels. (We argue below that, for economic reasons, most additional recycled material processing and
formulation will occur in-state.) Earlier, we calculated the net social benefit derived from recycling of
packaging material at $231/ton. Based on this figure, the net social benefit of RSP associated with the additional
7S OOO tons per year of recyckd MSWi apprawnatei y $175 million annually.
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(2) Ancillary Benefits of RSP : In addition to increasing the proportion of recyded materials in
packaging, an RSP program will promote packaging reduction and reuse, as well as recycling of packaging
materials from non-packaging uses. There is no reason these ancillary’ benefits might not exceed in magnitude
the aforementioned benefits from recycled packaging.
For example, businesses might choose to comply with RSP by using recydable packaging material--
those that are achieving a statewide recycling rate of 50% from aLl uses. If all packaging were to comply with
this criterion, half the 4 million tons of these materials discarded annually in Massachusetts would have to be
recycled; just 700,000 tons are estimated to be recycled currently. We previously estimated the impact of the
recycled content standard at 758,000 additional tons of recycling-, satisfying the recyclability standard (2 million
tons) would therefore require another 542,000 tons annually. Using $231/ion as the net social benefit of recycling
packaging materio4 the potential leveraged benefits of RSP due to the recyclability cnteiion are approximately an
additional $125 million per year.
Obviously, if some packaging complies with the recycled coutent standard and the remainder with the
recyclability standard, then the total social benefits will fall somewhere between $175 million and $3(X) million
annually.
(3) RSP Compliance Costs are the additional costs that firms incur to make their packaging meet
packaging recycling standards. We expect these compliance costs to be small for a number of reasons,
including:
‘some packaging is already in compliance with RSP;
• firms modify their packaging, on average, every two to three years, so that RSP compliance will be
part of the regular process of packaging revision;
• packagers will aggressively market their compliant packaging, reducing packaging buyers’ need to
spend resources seeking that information.
In addition. two by-products of RSP compliance will tend to minimize, or offset, RSP compliance costs
joint production efficiencies: the re-evaluation of production processes needed to achieve compliance
with RSP will allow some firms to introduce simultaneous productivity improvements at the same time;
• packaging and recycling innovations: government regulation with the characteristics of RSP has been
shown to stimulate the performance of industry.
(4) Administrative Costs of RSP indude government’s costs of developing, supervising, and enforcing
an RSP program, as well as the costs businesses incur to verify and demonstrate their compliance. Because of
its heavy reliance on market solutions, we anticipate that RSP will keep the government’s administrative costs to
a modest level. Competitors can be expected to challenge unwarranted exemption requests, while increased
recycling will reduce governmental costs associated with other environmental programs. Retailers, meanwhile,
will develop standard contract language requiring their suppliers to assume liability for any and all costs and
penalties arising from delivered packaging in violation of RSP.
(5) Possibility of Product Withdrawals or Shortages : Simply put, there will be no vacant shelves in
Massachusetts as the result of an RSP program. Although this prospect is raised by industry every time it is
faced with stringent regulation, the functioning of economic markets prevents product withdrawals or shortages.
Manufacturers of compliant packaging will rush in to fill the void left by non-compliant competitors, and
packaging entrepreneurs will develop novel packaging solutions that better incorporate the new realities of the
marketplace.
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Macrocconornic Effects on Massachusetts Employment and Economy
(1) General Caveats : The analysis of any policy requires tracing the long-run consequences of that
policy for all economic sectors, not merely Lhe immediate effects of the policy or the effects on only one
economic sector. For example, some manufacturers of non-compliant packaging will lose business and
employees. But those losses will be offset by the additional business and employment created for
manufacturers of recyclable or recycled-content packaging: recycling standards will result not in a loss of jobs,
but in a diversion of jobs.
It should also be understood that just because an economic agent is ‘affected by a policy or change in
economic activtty doesn’t necessarily mean that the impact is negative. The purpose of the recycling standards
is precisely to affects businesses and households by providing incentives to alter behavior in ways that promote
recycling.
(2) Real and Im liclt Tax Reductions : Every dollar an RSP program saves Massachusetts in solid
waste disposal costs directly translates into a dollar reduction in tax buMen for Massachusetts taxpayers.
Of the estimated $175 - $300 million net social benefit of an RSP program, approximately 42% is
associated with the avoided out-of-pocket costs and the remaining 58% is derived from the avoided imputed
costs of solid waste disposal. Thus, the net social benefits of an RSP progrwn translate into a tar reduction of $75
- $125 million annual y for Massachusetts businesses and households, and an additional implicit tar benefit of
$100 - $175 million (which may appear in such areas as reductions in environmental hazards and their
associated health and work-loss consequences).
These real and implicit tax reductions brought about by an RSP program will serve to stimulate the
Massachusetts economy and employment in Massachusetts. Tax reductions (without corresponding loss of
services) will attract both workers and industry to the state.
(3) Industry-Specific Effects : An RSP orogram will stimulate certain industries and cause others to
contract. The stimulated activities will be conducted primarily in Massachusetts, while the industries adversely
affected are primarily out-of-state. Although numerical projections of job gains and losses are necessarily
uncertain and subject to analytic abuse, we are confident in concluding that recycling standards will have a
positive effect on employment in Massachusetts. (Rough estimates of job gains are included, where relevant, in
footnotes to this report.)
Our reasoning with respect to each affected industry is as foUo
Because materials collection and sorting are much more labor intensive than Iandfafling and
incineration, the shift of economic activity to these local industries will create additional employment in
Massachusetts.
Only about 18,000 Massachusetts manufacturing jobs are packaging-related. These jobs will not be lost
as a result of recycling standards, but there will be some diversion of job activity to recycled-content or
recyclable parbi.ging .
The packaging industiy itsclf employs approximately 22,000 workers in Massachusetts. Some packagers
will be positively affected by RSP; some negatively. But these impacts are inherently off-setting: one packager’s
loss signals a competitors gain, with the net effect on Massachusetts employment smalL
Most importantly, however, the shift to recycled and recyclable pa ’ging will boost Massachusetts
employment in all materials processing and packaging-related businesses. The amount of economic activity in
Massachusetts involving vv in materials euraction and processing (such as forestry and mining) is extremely
small. Thus, any loss of economic activity in this area will have only a negilgible effect on the state economy.
Conversely, RSP-induced stimulation of recycled mmeriarfo?mulatiJJg widproce sing should have a substantial
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positive impact on employment. Because of the relatively high cost of transporting materials, additional
formulation and processing will, for the most part, happen locally. In-state packagers who quickly adapt to the
new market conditions will also enjoy competitive advantages.
(4) Other Effects and Considerations : The successful implementation of RSP in Massachusetts would
surely provide the impetus for adoption of this program in other slates. In addition, the pervasive benefits of
recycling standards will act to reduce materials and production costs throughout the economy, thereby
improving the competitiveness of Massachusetts and American industry. Finally, recycling standards for
packaging will provide the means for a successful transition from a throw-away society to one that respects and
values its resources.
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Federal Trade Commission
JANET . STLIGER
C A rm
FEDERAL TRLflE CD1 (ISS N
EPA NATIONAL ENVIRONH! L .1J.BELZHO CONFERENCE
BALTINORZ , MARYlaND
October 1 , 1991
The views expressed are those of the Chairman and do not
necessarily reflect those of the Federal Trade Cou miszion or the
other ComlTtisaiOflers.
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Good Afternoon, I appreciate the opportunity to join you
today to discuss the Greening” of the American Marketplace and
the FTC’s work in this area.
Our economy is driven by the powerful engine of competition
in which marketers are eager to respond to consumers’ choices
about the products they buy. Consumer choice drives marketers to
improve their products and to promote those improvements in
competition with each other. During the past three years, there
has been a powerful expression of concern by individual consumers
over how their purchasing decisions affect the environment of our
planet. It has been referred to by many as the “green
revolution.’
A iu1y 1991 study reported that 85% surveyed are “doing
something about the “solid waste problem.” This concern has
been translated into purchasing decisions. This same study
reported that 76% of those surveyed said that they would pay up
to 5% more for “environmentally sound” packaging, a response that
had jumped from 64% in 1989.2 Some marketers are now emphasizing
The views expressed are those of the Chairman and do
not necessarily reflect those of the Federal Trade Commission or
the other Commissioners.
Consumer Solid Waste. Awareness. Attitudes and Behavior
Study III , Gerstmart & Meyers, Inc. July 1991.
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more environmentally Sound products. During the first half of
1991, approximately 13% of all new products introduced made some
kind of environmental benefit claim. This compares to 11.4% of
all new product launches for 1990.
Green marketing is obviously no panacea for the nation’s
environmental concerns, and there is evidence that despite the
high level of consumer interest shown by the various surveys and
polls, green marketing is having a hard time effectively
responding to consumer demand for informative environmental
claims. One marketing expert testifying at our hearings has
graphically illustrated the problem. He said that only 14% of
consumers can remember seeing “green” advertising or labeling.
He further reported that in some focus groups an overwhelming
majority of consumers were skeptical of manufacturers’
environmental claims. 3 The recent Gerstrnan & Neyers survey
confirms this skepticism finding that only 15% of consumers find
environmental claims on packaging believable. The same survey
showed consumers want more, not less 1 information about products.
)lore than 95% of those surveyed agreed with the statement that
more infDrmation is needed about packaging materials.’
Walter Coddington, Persuasion Environmental Marketing,
Inc. (H.?. pp. 1D2—103, 105, Vol I).
‘ Gerstman & Meyers at page 9.
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A clear dilemma thus emerges. Survey data show that
surners want information about the environments], attributes of
tne products and packaging they buy. However, they mistrust many
marketing claims that they see in advertising. At the same time,
as we learned at the Commission hearings last July, many
marketers, large and small, are reluctant to make envirorunental
marketing claims because they fear law enforcement cti.on.
Confusion about green claims is simultaneously keeping useful
information from reaching consumers and leaving them distrustful
about the information they do receive.
Green benefits, to be fair, are not the easiest to convey in
creative marketing. One recent trade press article pointedly
asked advertisers to try using “polyethylene terephthalate” in a
gle. any of the issues that green marketing addresses are
nplex. We have only to look at the ongoing debate over whether
cloth diapers are better than disposable diapers or plastic bags
better than paper bags to understand this point. Some of the
most popular claims that have been made, such as “degradability”
or “ozone friendliness,” have been accompanied by charges that
they are themselves deceptive. When asked whether consumers
should choose paper or plastic begs at the grocery store, a
Ad Week “Try Using Polyethylene Terephthalat. in a
Jingle, (June 17, 1991) at 12.
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spokesperson of an envirorunenta l group said confidently, “it
depends. ,,6
So what is the FTC’s role in all of this? As you know, the
FTC is primarily a law enforcement agency. Its consumer
protection expertise lies in preventing deceptive practices,
thereby guaranteeing consumer freedom of choice. The FTC has
been involved in environmental marketing issues for many years.
The ConuTiiSSiOfl brought its first case challenging landfill
degradability claims for a plastic-coated milk carton in l973.
In the early ‘70’s it provided guidance for the soap and
detergent industry to facilitate labeling of phosphate content
and degradability of detergents. For the past two years we have
maintained a heavy caseload of envirorunental advertising
investigations, some of which have already been completed.e As
envirorunental claims in advertising and labeling increase, you
may rest assured so too will our environmental advertising
enforcement actions.
Nevertheless, there is a growing sentiment that in the area
of environmental claims more needs to be done. Specifically,
6 Nutrition Action Healthletter (April 1990) at 5.
Ex—Cell—O Corporation , 82 F.T.C. 36 (1973).
See, Zipatone, Inc. et al. , C-3336 (Final Consent
7/9/91); 3i ome Russell Cosmetics, USA. Inc., etal. , C—3341
(Final Consent (8/2/91); and A,ner .can Enviro ProductB. . Inc. , File
No. 902 3110 (Consent Accepted for Public Comment 8/30/91).
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there seems to be a strong feeling in most corners of the
Lrketplace that the Commission should issue some form of public
iidance on green marketing claims. It is my view on this
subject that I want to discuss w .th you today.
This July, in response to petitions filed by a coalition of
trade associations, as well as requests by the Nat .onal
Association of Consumer Agency Administrators, and the National
Association of Attorneys General, the Coniniss on held hearings on
green advertising. There were basically two issues the
Commission wanted to address during these hearings. The first
issue was whether there is a need for Commission guidance in the
area of environmental claims. The second issue was, assuming
there is a need for such guidance, what form should it take. 9
During two days of hearings, the Commission heard testimony
from forty witnesses. These included representatives of federal,
state and local government, trade associations, large and small
businesses, market researchers, environmental groups, advertising
agencies, certification groups and the Better Business Bureau.
In addition to this oral testimony, we received more than 100
written comments, many supported by numerous documents. The
Commission staff is currently preparing a recommendation to the
Commission based on the testimony and written comments. All of
the Commissioners will want to carefully review that
56 Fed. Reg. 24,968 (May 31, 1991).
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recommendation. At the same time I can tell you it is my belief,
based on the two days of testimony we heard, that the Commission
has an important role to play in providing guidance to companies
that wish to make claims about the environmental attributes of
their products, and that the Commission ought promptly to propose
guidelines for public comment. I believe we should try to rise
to the green claims challenge.
There are several things about the hearings that lead me to
this conclusion. First, in the absence of a national approach to
the green marketing problem, marketers told us they are being
confronted by a patchwork of differing and sometimes conflicting
state and local regulations. Second, there is near unanimity of
opinion that Federal Trade Commission guidelines could be useful
to both businesses and consumers and provide a helpful framework
for environmental claims. Third, most witnesses stressed the
need for a quick resolution of the problem.
Repeatedly during the hearings, representatives of industry
testified that in the absence of a federal policy, the potential
for inconsistent or conflicting state and local regulation of
environmental claims would put national advertising and marketing
legally at risk. A representative of one major national
manufacturer, for example, testified that the absence of national
guidelines and the emerging pattern of state-by-state regulation
may eliminate advertising and labeling as a source of
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environ.rnental information.’ 0 The representative of a national
rade association said that conflicting state standards “present
ignificant, if not insurmountable, barriers” 1 and a email
businessman who characterized himself as an “endangered species”
said simply that he would “dare not put” environmental, claims on
his products absent national standards.’ 2
One representative of the advertising community reported
that some advertisers were beginning to view envirorunental
claims, not as an opportun .ty, but as the “third rail of
advertising. Touch it and you die.” He also cited testimony by
small and large companies during the hearings that they had
either refrained from making environmental claims or were
rethinking continuing the claims they were already making. This
fitness noted that during the last quarter of 1990 there had been
nly 22 insertions of print ads that talked about the
environmental attribute of specific products. A trend he
characterized as “virtually nothing in terms of the noise level
in the marketplace.” 3
£0 L. Ross Love, Procter & Gamble (H.T. p. 227, Vol II).
Red Cavaney, American Paper Institute (H.T. pp. 254-
55, Vol II).
12 Hal Lightman, Independent Cosmetic Manufacturers and
Distributors (H.T. p. 202, Vol I).
13 Hal Shoup, American Association of Advertising
Agencies, (H.T. pp. 356—358, Vol I X).
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These trends are of concern, especially because the
testimony also indicates that consumers want truthful information
about the environmental impact of the products they buy and
because there is significant confusion about the environmental.
effect of the products consumers do buy. One witness, for
example, testified that surveys show that 70% of Americans still
believe that aerosol products contain CFCs despite the fact that
the use of CFCs in virtually all aerosols has been banned in the
United States since 1978.14
At the federal level, EPA’s Deputy Administrator, Hank
Habicht, told us that, “clear tederal guidance on environmental
labeling will help clarify the information provided to consumers,
and thus help markets operate more efficiently.” 13 His words
were echoed by Clayton Tong who testified on behalf of the United
States Office of Consumer Affairs, (USOCA).
At the state level, }linnesota Attorney General Hubert
Humphrey reiterated the position of 11 states Attorneys General
that a federal presence is needed. 6 Commissioner Thomas Jorling
of the New York Department of Environmental Conservation,
testified that he believed “the Commission working with EPA does
‘ Richard Bednarz, Chemical Specialties Manufactures
Association (H.T. pp. 193—194, Vol I).
13 EPA written Comments, July 17, 1991, p. 2.
16 Hubert H. Humphrey III, Attorney General of the State
of Minnesota, (H.T. p. 50, Vol I).
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have an appropriate role in establishing a broader national
amework for truth in advertising... . “ The statements of
these federal and state regulatory officials were shared by
environmental groups who testified before us. Dr. Richard
Denison, speaking for the Environmental Defense Fund, said that
“guidelines are critically important to clarify for industry how
the FTC believes consumers will respond to particu lar categories
of claims.” 8 And Jeanne Wirka of the Environmental Action
Foundation testified that her organization wanted the FTC “to
vigorously pursue enforcement actions and issue guidance against
misleading environmental claims. ,,19
Similarly, trade associations, representing some of the
country’s large and small corporations alike, urged the
rnmission to move forward on guidelines. Cal Collier, a former
... airman of the FTC, testifying for the National Food Processors
Association, characterized the need for national guidance, taking
the particular form of FTC guides, as “immediate and
compelling.” In sum, much of what I heard at the hearings
reinforced the words of General Humphrey, on behalf of a group of
11 state Attorneys General, “Never before have the business
‘ (H.T. p. 42, Vol I).
(H.T. p. 141, Vol I).
19 (H.T. p. 139, Vol I).
20 National Food Processors Association, written conui ent
p. 5.
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community, state regulators, and consumer activists, been so much
in agreement on any single point and that is for the need for
federal guidelines that will fit the national marketplace.” 2 ’
Of course, the Federal Trade Commission cannot base a
decision on whether to issue federal guidelines merely on the
idea’s popularity. We must undertake a close exanunation of the
likely impact on the business community and on consumers. That
is why, in publishing its notice announcing the hearing, the
Corrunission asked witnesses to address a series of ten probing
questions focusing on the need for guidelines, their feasibility
and potential costs, and the benefits to be derived from them.
Here again, I was impressed both by the reasons given for
supporting federal guidelines, and by the consistency of the
reasoning across diverse groups.
Perhaps most important, there was broad based support for
the idea that environmental marketing play an important role
in improving the environment. Richard Denison of the
Environmental Defense Fund observed that “consumers armed with
accurate and reliable information have a critical role to play in
shifting industrial systems and production toward more
environmentally defined products and processes.” 22
21 Hubert H. Humphrey, III (H.T. p. 34, Vol. I).
22 (H.T. p. 140, Vol I).
51
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Attorney General Humphrey, on behalf of the National
ociation of Attorneys General agreed, “Green marketing is
truly an area where all of us want to see more, not less,
information available to the public,” the statement said, “the
states do not seek to stamp out the green revolution.” 23
In summary, I believe our hearing record presents a
compelling body of testimony that federal guidelines could make
an important contribution to promoting truthful advertising of
product attr .butes responsive to consumer concern for the
environment.
I have no illusions that consensus for a guidelines approach
n be read to show support for any particular guidelines that
ght be written. Consumer groups and industry come at the
problem differently, and do not necessarily agree on what a
guideline should say. I only want to assure you that any
Commission project would be conducted in the full sunshine of
public review and debate. That, after all, is what our public
hearings were all about and what, as a public agency, the FTC is
all about.
There are other difficulties with any endeavor to draft
guidelines. Drafting guidelines on environmental claimB will be
23 (H.T. pp. 33—34, Vol I).
52
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difficult because it is a rapidly developing technological area.
Any FTC guidelines would have to walk the line between being too
strict, and thus unlikely to accommodate future developments, and
too weak, thus permitting claims that may be misleading.
In addition to the changing nature of the technology there
are also concerns that the Commission has less dat on how
consumers actually interpret environmental claims than we would
like to have in an ideal world. In that regard, much has
remained the same since as long ago as 1973, when the FTC
promulgated guidelines on laundry detergents. Nearly two decades
ago there were also problems of consumer perception. For
example, the Commission learned that there was not much
information on how the average consumer interprets the term
biodegradable, except that a significant number of people vaguely
believe that being biodegradable is somehow good for the
environment. The Commission faces similar problems today in
determining consumer perception.
A related issue is industry’s perception of the problem.
One of the common threads in FTC cases against deceptive or
misleading green marketing claims is that, in many instances
marketers have rushed to propose solutions to environmental
concerns without fully conveying either the problem or the
usefulness of the product to a solution. For example, enhancing
the degradability of trash bags or disposable diapers intuitively
53
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seems like a good idea to respond to consumer concerns about the
environmental attributes of plastic versus paper products. It is
only when one considers that in the United States, much of our
plastic and paper waste winds up in landfills, and that landfills
are managed in a way that actually retards degradability, that
you can see the advertising promise may be illusory.
Moreover, there has been concern that if the FTC promulgates
environmental marketing guidelines, it will inevitably be drawn
into setting environmental policy, rather than protecting
consumers from deception, the role that Congress intended the FTC
to play. In my opinion, the FTC is not and should not, be
engaged in setting environmental policy. That is a matter
appropriately left to the EPA and Congress. But many of the
witnesses during the July hearings seemed to understand that
there are separate communication issues in marketing that the FTC
could and should address.
Finally, there have been concerns, echoed by several of the
witnesses at our hearing, that, because FTC guidelines would not
preempt or legally displace different state laws, FTC guidelines
would have Little practical effect on the problem of potentially
inconsistent or conflicting state laws or regulations. This
concern seemed to be the focus of much of the industry ’s
testimony and the Commissions’s questions during the hearings.
54
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These are all important concerns and none of them have been
fully answered. But. again, I believe that the hearings provide a
strong basis for going forward; the testimony I heard at the
hearings suggest that the greatest risk of stifling information
stems from the lack of guidance. Moreover, the proposal for
guidelines made by both the State Attorneys General and industry,
in general, strive for approaches that avoid rigid definitions
most likely to lock in todays technology, leaving a potential
defect of rendering guidelines obsolete in the future.
Gu .delines would not be the only answer to the problem that
we face. As a law enforcement agency, we will continue
vigorously to pursue cases of deceptive and false advertising of
environmental claims. Likewise, you. can anticipate that any
guidelines would draw heavily from the principles —- both legal
and economic -- that are represented in the Commission general
case law and enforcement actions.
In conclusion, I want to leave you with my view that green
market .ng guidefines are a unique opportunity for business,
government, and public interest groups to build on a broad
consensus to develop an approach that can serve the interest of
consumers and the environment. To be sure, there are difficult
challenges to be faced, and the success of any FTC effort, if
undertaken, is certainly not assured. The key to success in
forging federal policy in environmental advertising r.quiree a
55
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partnership between government, industry, and consumer groups,
h presents a unique opportunity for cooperation. The result
could be the development and promotion of more environmentally
sound products within the proven success record of the free
market system. Thank you.
56
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EPA Life Cycle Assessment Task Force -
Market Based Pollution Prevention
Timothy J Mohin
-------
kg u ]
[ 1 Definition
U SETAC Workshop, Vermont, August, 1990
— Determine state of the art
— Define three stages of LCA
-------
Components of a Life Cycle Analysis (LCA)
Impacts
Inventory
Improvements
I
LCA
-------
Three l’s
D Inventory
— Boundary definition
Criteria definition for an LCA
o Impact
— Which are the important criteria
— Methods of evaluating criteria (scoring/weighting)
o Improvements
— Results oriented actions product improvements
— product labelling
— product certification
— education/product design
— regulatory programs
-------
Soap Manufacturing Module
Tallow —p
Sodium Hydroxide—p
Catalyst —p
Energy —+
Additives —*
(e.g., pigments)
Air Emissions
Liquid Wastes
Solid Wastes
Coproducts
—* Bar Soap
Inputs
Outputs
-p
-p
-p
-p
Soap
Manufacturing
Process
-------
Coproducts
Nuclear Steam
as _ Electricity
Coal L:: ion
Hydroelectric
Air
Solid
Waste
Sodium
Hydroiide
Coproducis
Coproducts
Ta low
Paper
Energy
V
Waste Water
Solid Waste
(Bar R,rnnariti
Packaging)
V
Surface
Water
Ground
Water
62
-------
Sumoitfied Life Cycle Anelyss fo Ba Soao
tnergy Ar vlutso’u
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63
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I I Joint effort among tour EPA offices
— Office of Air Quality, Planning, and Standards (OAQPS)
— Office of Solid Waste (OSW)
— Office of Research and Development (ORD)
— Office of Policy, Planning, and Evaluation (OPPE)
Li 2% project combined with an ORD project
LI Total funding 850K over 3 years (FY9O-92)
LI Work on project began August, 1990 (Battelle)
-------
Goals & Objectives I
D GOAL: To make LCA an effective tool for providing
information on products that will lead to a shift in the market
profile
o Develop a comprehensive LCA method to facilitate use and
understanding
O Develop a streamlined approach to increase use and
effectiveness and lower costs
O Develop a screening method to prioritize LCAs of products
O Provide the lifecycle methodology to consumers, industrial
designers, manufacturers, and regulators
O Emphasis on lifecycle method development rather than
labelling
-------
ii Establish a Technical Advisory Panel (second meeting April 2, 1991)
— Academic, industry. PIF GS, State agencies and other Federal agencies
— Possible NACEPT locus group
LI Analyze the existing lilecycle programs
— Foreign countries, Franklin, Tellus
D Develop an inventory assessment methodolgy
— Identification of loadings, assumptions and uncertainties
— Identification and validation of types and locations of data
0 Develop a hazard assessment method (impact assessment)
— Goal: determine the health and environmental implications of the loadings
identified in the inventory
— Identify possible methods
— Conduct a workshop
— Develop best method
Tasks
-------
D Evaluate a communications strategy options
— Short-term: status reports, getting the work out
— Long-term: results oriented, target consumers, manufacturers, etc.
— Methods vs. audience matrix to evaluate effectiveness
o Screening analysis
— To determine whether to use a detailed or streamlined LCA
O Develop a stream-lined method
— Goal: practical yet credible lifecycle method
— Simplified approach to data gathering and manipulation
— Assumptions and decision rules to replace missing data
o Screen and select product groups for testing
— Representative product groups - cover many effect areas
— Available substitutes
o Analyze and refine method
— Adjust the criteria and weighting system
-------
Products I
LI Method for product lifecycle analysis
— Comprehensive method
— Inventory
— Hazard Assessment
— Screening method
— Stream-lined method
— Case studies of product groups
— Communications vehicles
• ttT
-------
Procedural LCA Approaches I
D Federal program
— Canada, Germany, Japan, etc.
D Private programs
— Green Cross, Green Seal
0 Federal/private coop
— E.G., industry supported review panel with Federal guidelines
and joint membership
rc* nyc
-------
[ Policy Consideration]
0 Federal guidelines for environmental claims
— EPA/FTC/US Office of Consumer Affairs task force on environmental
claims
— recycled content
— recyclable
— lifecycle???
O Legislative initiatives
— Lautenberg bill S. 3818
— Federal guidelines for lifecycle claims
— EPA Pollution prevention bill
— Quasi-governmental reviewfcertification board
0 Bottom line: unclear where this work will “fit”
•(* C
-------
Two Classes of LCA Use
Internal
LCA assessment results remain
internal and are used to design or
redesign a product or package.
Criteria for accuracy need not be
very stringent. (A best guess is
better than ignoring environmental
issues .)
LCA science has advanced to allow
useful predictions. Scientific
consensus is not necessary.
LCA assessment results are
public to promote a product
package as having a lower
environmental impact than a
competitor’s.
Criteria for accuracy must be very
stringent. (False or misleading
claims can not be allowed.)
LCA science is not yet advanced to
the leyel of certain proof. Recently
published LCAs have met with a
wide range of scientific criticism.
External
made
or
-------
FRANCES WERNER
MONSANTO COMPANY
IS PR0D CT LIFECYCLE METHODOLOGY
APPROPRIATE FOR CONSUMER LABELING ?
BACEGROUND
Product lifecycle assessments (LCA’s) have been done for
approximately 20 years with a recent serge in interest in the
last 18 months worldwide. The science of lifecycle assessments
is in its infancy with the 1989 SETAC (Society of Environmental
Toxicology and Chemistry) conference focusing on the INVENTORY
portion of LCA’s. Future conferences are.planned to determine
the IMPACT of the waste inventories as veil as the DATA QUALITY
within the inventory. LCA’B are expensive ($100,000-S250,000 for
a typical study) and involve an extraordinary amount of time and
effort. They cannot be done quickly or with the lack of proper
expertise.
ASE LCA’ S A PEAS IBLE BOURCZ P0k LABELING I PQkXATION?
Against the backdrop of the early stages of the science of LCA’s,
it seems inappropriate to begin discussions of the possible uses
for labeling from the assessments. However, the overriding
interest in a holistic approach makes the concept very appealing
to many groups. The “ideal case” of having a simple number which
would allow consumers to discriminate between product choices on
the basis of waste produced has merit. But the difficulties of
having a “simple number” can be demonstrated with several
examples.
Figure 1 lists two products, A and B. The data are actual data
for two interchangeable products that a consumer could use, An
examination of solid waste shows that Product A is superior to
Product B. However, an examination of raw materialB used shows
that “B” is superior. Adding both raw material and solid waste
shows that “A” is still superior. The addition of process waste
still gives the edge to Product A.
However, when energy is added to the information, Product B has
lover energy usage. Neither scientists nor consumers can add
“Btu’s” to kgs of waste to come up with a meaningful comparison.
Conversion of Btu’s to kilograms confirms that Product B is
superior in energy consumption. However, the final totals show
that Product A is better overall. One theoretical option would
be to label Product A with the number “228” and Product B with
“235.8” to allow consumers to see the relative position of the
products. But the conclusions would be faulty!!
72
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FIGURE 1
PRODUCT LIFECYCLE ASSESSMENT
KG WASTE/1000 L PRODUCT
PRODUCT A PRODUCT B
SOLID
WASTE 33 63
MATERIALS 39.2 33.8
SW + RM 72.2 96.8
RM +SW
PROCESS 75.4 115.2
ENERGY, BTU 2270 2210
ENERGY, KG 156 139
TOTAL WASTE 228 235.8
73
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LIMITATIONS of LCA’s
Figure 2 shows other issues which are not dealt with in this
analysis. There are several examples of inventory information
which require either resolution by the scientific community or
a value judgment by the group preparing the label system. For
example, should consumers have information on water consumption
rolled into their number? Certainly consumers in California may
have a different opinion than those in Michigan. But what about
waste that is treated? Should products be docked” for making
wastes that are degradable? LCA’s measure that pollution from
the source, not the ultimate fate of the pollutants. What if
products can decompose to CO, and water, or other organic matter
after composting? Isn’t thai better than a product which has
waste which cannot be treated? Do consumers want to know about
toxic waste or all waste? Product B has 9 pounds of waste which
includes table salt and salt used on your driveway in winter.
Product A has more metal ions released than Product B, for
example. Do these have an impact? What does the consumer care
about waste reported in kg/bOO liter units? LCA’s report data
in units that do not make sense for the consumer application.
POTENTIALS POR APPLICATIONS
There are several possibilities for some usage of LCA informa-
tion. However, the consumer labeling evolution must deal with
several key issues (Figure 3). First of all, what’s the purpose
of the labeling? Concerned parties should decide this answer,
then make sure that the vehicle for measurement is going to meet
this need. Several types of labeling proposals could include:
— Total waste a customer can control
- Total waste and energy generated by the product
- Total waste and energy release to the environment
— Specific ingredients that may have health issues
The most appropriate usage of labeling to begin with should be
HELPING CONSUMERS MAXE INTELLIGENT CHOICES ABOUT DISPOSAL. Thus,
labels should be made utilizing meaningful units for the
customer. In most cases, this would be on the appropriate unit
size that the customer is purchasing. It is also recommended
that since U.S. customers are still Nmetric ignorant,u labeling
in pounds may make the most sense. But information from LCA’s
can be misconstrued if the total picture is not presented.
Instead of clouding the picture with upstream data from manu-
facture and raw materials, downstream application from LCA’s
may make the most sense. In fact, a limitation to using only
disposal and recycling waste data may be prudent as a starting
point.
74
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FIGURE 2
DIFFICULT INVENTORY QUESTIONS:
VALUE JUDGMENT IN CONSUMER LABELING
“WATER CONSUMPTION?
PRODUCT A 2,3rn 3
PRODUCT B l78m 3
“WASTE GENERATED VS. WASTE RELEASED?
PRODUCT B HAD 2x
MORE BIODEGRADABLE
“NATURAL WASTE PRODUCTS COUNT?
CO 2 . ORGANIC CARBON
TOXICS VS. NON-TOXICS?
PRODUCT B HAS 9 LBS WASTE
SODIUM CHLORIDE + CALCIUM
CHLORIDE
“WRONG UNITS?
KG WASTE/bOO LITERS PRODUCT
NOT MEANINGFUL TO CUSTOMERS
75
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FIGURE 3
SUGGESTIONS
CONSUMER LABELING EVOLUTION
FIRST STEPS:
HELP CONSUMER MAKE CHOICES
ABOUT DISPOSAL
LABEL IN MEANINGFUL UNITS
TO THE CUSTOMER
UTILIZE DOWNSTREAM PRODUCT
LIFE CYCLE INFORMATION
ON DISPOSAL/RECYCLE
ONLY
LCA METHODOLOGY IS IN ITS
INFANCY; PRESSURE FOR
LABELS SHOULD NOT OUTPACE
THE SCIENCE
76
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DEI4ONSTRATION 07 DOWNSTRZAJ( SOLID WASTE CONCEPT
Let’s revisit Products A and B. Remember that the earlier data
showed that the total waste numbers for the products were 228
and 235.8, respectively. Based upon those numbers from the
product lifecycle, a customer would probably choose Product A.
An examination of Figure 4 shows an alternative presentation of
the data on the two products from a downstream solid waste
perspective. If Product A is pitched into municipal trash, it
will contribute 0.06 pounds of waste to the environment that’s
unlikely to degrade. However, Product A is NOT RECYCLABLE. The
technology is being developed, but it is not available in the
United States. Product B, on the other hand, will contribute
0.11 pounds of waste if pitched into municipal waste streams.
However, if it is recycled, it will only contribute to 0.01
pounds of waste.
Nov the consumer can make an intelligent decision. If the
consumer can recycle Product B, it is a better choice. However,
if the consumer does not plan to recycle Product B, Product A
is the superior choice. This type of presentation of data gets
to the heart of the MISUSE of WA data. .ith.r Product A nor B
is clearly the “winner.” But the ultimate aoat/bansf it to the
environment will be influenced by the choices th. customer makes.
But even this suggestion has limitations. It is easy to suggeBt
that limiting the analysis for solid waste makes BeflBS. And it
certainly does in this case where solid waste is dominant. How-
ever, let’s look at another case for two products, C and p
(Figure 5) where the results are not as straight forward.hl) One
product is a solid waste product which is primarily paper, while
the ether involves a cleaning step to be able to reuse the
product. Nov the consumer is faced with a new set of choices.
If the consumer is merely going to throw the product away, then
Product C will make less solid waste. However, Product D is
superior if the product will be reused. Now, let’s add
complexity by showing that as composting becomes available to
consumers, it makes Product C look much better (Figure 6). In
addition, what if we include the water pollution produced during
the cleaning of Product D as well as the energy required? Nov
Product D has a waste produced of 0.05 pounds. Product C now
emerges as the product of choice.
(1) Complete data not available, so numbers have been rounded by
author to demonstrate concept.
77
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PRODUCT A
PRODUCT B
FICIJR
-------
PRODUCT C
FIGURE 5
PRODUCT D
-------
PRODUCT C
FIGURE
PRODUCT D
-------
BWO(ARY
These examples are real data from existing LCA’s. They show that
many types of data are available and can change the final answer.
Product Lif.cycl. 1 MsSBaaSDt$ should nsvsr bs us.d as a simpis
number for consumer labels because there is far too much
complexity behind the final output which can lead the uninformed
to wrong answers. However, LCA methodology on the disposal!
recycling side may have merit to show consumers their choices and
the consequences of their choices. There will likely be multiple
answers for every product, because there are multiple disposal
and recycling choices that can be made. The critical decision on
labeling must include the r.solution of th. purpos. of any labsi.
The importance of LCA methodology can ultimately only be answered
by that purpose. Finally, remember that LCA’s are only in their
infancy. Let’s not expect reasonable solutions when there have
been less than 100 completed worldwide to date, and publication
with an acceptable level of detail of less than a dozen.
81
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Shopping Is a Polluting Activity
by Joel Makower, Editor, The Green Consumer Letter
October 1, 1991
Talking Points
* Let’s start with the essentials: Nothing you can buy will ever be good for the earth. The
most we can hope for is to buy products that generate the least amount of pollution and
use resources most wisely.
* Consumer information on environmental topics is a muddle at best. In fact, a lot of
what’s going on may well be counterproductive.
* consumers don’t know what to believe
* retailers don’t know what to believe
* regulators are scrutinizing everything
* we don’t even know if green claims increase sales
* To illustrate the muddle, take a look at the polls. While consumers repeatedly tell
pollsters that they are environmentally concerned and would like to do the right thing,
they also indicate that they don’t necessarily practice what they preach. And when you
look at other polls, you can easily see why:
* A 1991 survey by Decision Research: only 7% believe companies are taking
appropriate steps to protect the environment. Fully 58% were unable to name a single
company they consider “environmentally conscious.”
82
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Shopping Is a Polluting Activity
* Another poll found that Americans rank corporate environmental crimes as
more serious than insider trading, antitrust violation, and worker health and safety
abuses. Three-fourths of those surveyed said executives should be held personally
liable for their companies’ environmental offenses.
* Other polls show people don’t know what “biodegradable,” “recyclable” or
other terms mean
* My experience traveling around country is that seemingly well-informed
people — reporters, even some environmentalists — still believe that aerosols contain
CFCs, or that some materials will effectively biodegrade in landfills. It simply points
out that all the gbod efforts of writers, environmental groups, and government agencies
can’t hold a candle to the power of a couple good product ad campaigns.
* So, it’s no wonder consumers aren’t shopping green. They don’t know who to believe.
They don’t know what kinds of claims they can rely on.
* I’m concerned that Green Consumerism is evolving hot on the heels of the Oat Bran
Era. You no doubt recall what happened: manufacturers all but force-fed a single
ingredient on an all-too-eager public, only to have the rug pulled out from under us by
the reality of medical science. There is no doubt in my mind that the next time a magic-
bullet cholesterol-reducing substance is discovered — however valid its claims —
Americans are going to be far less wiliing to take the plunge.
* So, it’s the repsponsibility of manufacturers to provide genuine education on Green
Consumerism that transcends slogans and quick fixes.
83
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Shopp ngIs a PollutmgActivity_
* We’ve got to admit to ourselves that this is tough stuff. To understand, for example,
the environmental impact of something so simple as a soda bottle or a bleached coffee
filter requires digesting a fair amount of technical data, not to mention comprehending
the often elusive maneuverings of companies, politicians, and environmentalists.
* It’s vital that we make consumers understand that “going green” involves to
fundamental things: minimizing waste and maximizing resources. When you do those
two things — reduce waste and maximize resources — it doesn’t matter whether you are
running a business or simply shopping for groceries — you can’t help but get a better
return on your investment over the long run. So, “going green” can be as economical as
it is ecologkal.
t Manufacturers have to supplement their product information with good, green
information. For example, although it may seem simple to us, most people don’t yet
grasp the fundamentals of recycling — what’s recyclable, how to do it, and so on. Labels
should help disseminate this information. If a product is truly recyclable, then exlain
how to do it — “Remove the plastic top, which cannot easily be recycled. Then rinse out
the bottle and place it in a bin with other PET plastics, such as those from soda
bottles....”
84
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ShoppthglsaPoUutfngActivfty-
* It’s also important to put things in perspective. For example, for all the debate over
paper bags versus plastic bags, or glass versus aluminum containers, the environmental
differences are obliterated by the energy and pollution impact of a consumer driving
just one mile and back to the supermarket. In other words, the environmental impact of
the purchases made at the grocery can pale by the impact of getting to the store and
home again. So, we’ve got to make sure to tackle the significant things as well as the
symbolic ones.
* Finally, companies have to get their own houses in order. The challenge is to integrate
these green ideals into your corporate culture on a day-to-day basis — not simply to do
a few symbolic and well-publicized things every third week in April around Earth Day.
* facilities management — greening lights, water, energy use, transportation,
packaging, etc.
* pressuring suppliers — using marketplace clout to encourage other
companies to adopt more environmentally responsible practices. Ace Hardware
example.
* adopt a simple but specific environmental policy around which everyone
can rally
* Use advertising dollars to help teach, not just to build credibility. Polls show that
people don’t believe those ads anyway. If you were to believe some oil companies’ ads,
you’d be led to think that they were in the principal business of saving porpoises and
whales. Do companies really believe this will work? Apparently, companies do. But
companies have to first establish credible products and corporate behavior before their
ads can be heard.
85
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Shopping Is a PollutingActivity-
* J think the public can handle imperfect answers, and solutions that aren’t necessarily
aimed at the lowest common denominator. People can adjust to uncertainty and
change, as long as they are aware of the process.
* So, when companies start being honest with consumers and stop taking advantage of
their genuine concern for the earth — I think the products will sell themselves.
86
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RUTH BECKER
PENNSYLVANIA RESOURCES COUNCIL
LABELING: CONSUMER PROTECTION OR CONFUSION
My perspective on labeling is based primarily on
extensive contact with ecologically aware consumers. As
some of you already know, the Environmental Shopping
Program was launched by Pennsylvania Resources Council
about five years ago. Aimed at educating people about how
to shop in a way which is less demanditig on our
environment. The program has reached over 50,000 people
and is growing every day. Most of my comments and insights
will be based on experience gained from working with such
environmental shoppers across the United States and in
Europe. In addition, I have also had substantial contact
with industry during my two years on CONEG’S former source
reduction council.
The first thing we need to look at when asking
whether labeling is protection or confusion is what we
mean by labeling. If we’re talking “Green Hype”,
motivated by Green Profiteering, or course it’s confusing.
It’s meant to be. Its intention is not information. It’s
sales.
On the other hand, a national symbol that has
standardized meaning and criteria could be a source of
assistance to both buyers and manufacturers. The only way
a market system works properly is when the consumer has
enough information to make informed decisions. And
consumers want and are entitled to specific information on
all products and packaging from food to cleaners, from
paints to pesticides. If a consumer goes to a salad bar,
he or she shouldn’t have to ask if sulfites have been
used. If you heard Pat Imperato testify at the forum on
labeling yesterday, you heard a demand for less hype on
the container and more information on what is in the
product. Others properly objected to the use of a
recycling symbol on a container if it was not recyclable
within the community.
But what is equally clear is that labeling is not
enough. Education is a necessity if any labeling effort
is to be truly effective. It is also evident that
educational materials and services for consumers won’t be
trusted unless those preparing them don’t have an ax to
grind. We cannot depend on the current void in consumer
education being filled by manufacturers. Because they
have a vested interest, much of what they say the consumer
does not believe. In fact, right now the American
consumer believes little of what government says, even
a,
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less of what business claims and nothing of what
advertising touts. We need only look across the Atlantic
to get a glimpse of what this can mean.
The British consumers are furious. They are
demanding immediate government action and boycotting
products. In store vandalism has increased.
The American buyer really accepts only two sources of
information - the environmental group and the
environmental journalist. This means that environmental
labeling consumer education programs could probably be
handled most effectively by non-profitgroups like PRC who
don’t have a vested interest and already have credibility
in the eyes of the consumer. They could be funded to
prepare and provide educational materials both for schools
and the general public.
Now, there are things no label can do.
I question whether it can be a source of protection
because protection for the buyer lies in self education
and protection for the manufacturers comes from ethical
business conduct. No label is ever going to relieve
informed consumers of the need to keep informed to make
intelligent shopping decisions.
No label — no matter how good it is, is ever going to
assess whether you need a product. No label is ever going
to change the fact that “buying green” is no substitute
for the change in behavior we all need to make to protect
the environment. And herein lies the danger of the
environmental labeling — that it can be construed as
“doing enough” for the environment.
But regardless of the risk, in a democracy citizens
have the right to know how the products they buy affects
their health, their children’s health and the environment.
The environmental label, properly designed and implemented
can be a useful tool, but it cannot be a be-all, end-all
in itself. As Pogo said, “I’ve met the enemy and it is
us”. Much of the solution lie in changing our lifestyle
and only we can make that choice.
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Presentation by Sandra Eberle, Office of the Executive Director
U.S. Consumer Product Safety Commission before the Environmental
Labeling Conference Panel on Labeling: Consumer Protection VS.
Confusion, October 1, 1991.
The views expressed are Ms. Eberle’s and do not necessarily
represent the official position of the Commission.
Good afternoon, it is a pleasure to be here in Baltimore to
address this new task that many would have product labeling
fulfill -- helping us all protect the environment.
I am reminded of the words of a song — SIGN, SIGN,
EVERYWHERE A SIGN, DO THIS, DON’T DO THAT, CAN’T YOU READ THE
SIGN!
Yes, product labeling is a sign that is being used to
influence consumer behavior, our behavior, in many ways. Today I
want to discuss with you
(1) some of the characteristics of labeling that the
Commission’s Human Factors’ staff conclude impact the likelihood
that a label will influence behavior, and
(2) the Commission’s interest in assuring that health and
safety messages on the label are not obscured by these other
envirorunentally important messages.
First — what are the characteristics of a labeling message
that don’t cause confusion {as our title today highlights}? What
characteristics make the label effective at changing behavior?
The Consumer Product Safety Commission relies on product
labeling as part of the strategic defense system against injury
from products ranging from lawn mowers to children’s toys. The
CPSC’s Human Factors staff has concluded that the primary factors
that influence the effectiveness of labeling are:
1) the perceived hazard of the product;
2) the products’ familiarity; and
3) the ease of complying with the warning.
These factors are all interrelated. If a product is
perceived to be hazardous, labeling instructions are more likely
to be noticed and the recommended actions taken. The more
familiar the product or situation, the less likely that labeling
instructions will be noticed or followed. Labeling instructions
t1 t require the consumer to expend only modest effort to comply
are more likely to be followed than those requiring repeated
effort or lots of time.
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Recent proposals would provide information on environmental
concerns - everything from whether the manufacture of a product
or component involved an “ozone depleting chemical” to a
direction to the buyer to encourage the development of recycling
facilities in their local area. This certainly is a fine thing.
Consumers want information which is factual and reliable. They
want to judge the comparative “safety” (safe for them and for the
planet) of products.
The majority of Americans consider themselves
environmentalists, and will find this plethora of new information
useful and necessary, or will they?
Will they read and understand the i ew labels? And how well
will the new “green” labels coexist with health and safety
labeling?
CPSC’s interest results from its regulation of the labeling
of most of the products likely to bear “green” labeling, and from
the need to ensure that the environmental issues do not
overshadow or conflict with health and safety labeling.
Warnings about health hazards and risk of fire or explosion
required by the Commission now fight for prominence and
conspicuousness with the “product promotion” portion of the
label.
It seems that most of the “positive” messages — “ozone
friendly”, “recyclable”, “ Contains no CFC’s” — are treated as
advertising messages and placed on the front panel, again often
more prominently than the health and safety messages. This can
lead to problems.
Environmental labeling has indirectly caused at least one
serious safety problem. Aerosol spray string, a novelty item,
was reformulated to remove the CFC propellent, and the resulting
products prominently labeled as “ozone safe” and “safe for the
environment.” The reformulated product was highly flammable, and
several accidents occurred before CPSC obtained a recall and
reformulation to a less flammable propellent.
CPSC compliance staff has encountered several other
aerosols that require “DANGER Extremely Flammable” on the label,
but also have disclaimers like “Safe for the Environment.” These
statements may violate regulations against the deceptive use of
disclaimers, 16 C.F.R. 1500.122, which precludes the use of
wording that implies safety on the labels of hazardous products.
The Commission can take action against products where the
“green” labeling has the potential to mislead or deceive
consumers into thinking they are buying a “safe” product.
Over 250,000 acute injuries resulting from household
chemical products are treated in hospital emergency rooms each
year. These injuries include accidental ingestions, chemical
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burns and other acute injuries associated with household
chemicals. Over 900,000 accidental ingestion exposures involving
children under age five were reported to Poison Control Centers
in 1989; in 1988 there were 42 deaths of children under age five
from accidental ingestion of household chemicals.
Consumers are interested in using their purchasing power to
protect the environment. Accurate labeling can help them do
that. But a purchasing decision is a complex one that must
balance many “needs” — including cost, the appropriateness of the
article for the task, and the safety of the product in use.
If the prominence of environmental labeling causes
consumers not to notice a safety warning label, then increased
injuries and deaths may be the result. If changes are made in a
familiar product that make it more environmentally appropriate,
but more hazardous for the consumer to use, “green” claims should
not be allowed to detract from the hazard warnings.
The Environmental Protection Agency’s current position is
that the front panel (principle display panel) should be used for
the ozone depletion warning statements required by the new Clean
Air Act. The placement of the full text of that label on the
front panel presents the potential for interference with health
and safety labeling for hazardous consumer products.
The label reads as follows: “Warning: Contains [ name of
substance), a substance which harms public health and environment
by destroying ozone in the upper atmosphere.”
It will require the thoughtful analysis and full
cooperation of business, government, consumer and environmental
interests to implement environmental labeling in a way that truly
improves the safety and health of the American public.
Thank you. I will be pleased to answer any questions you
may have.
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Remarks by Lars E. Peterson
Senior Government Relations Representative
Food Marketing Institute
National Environmental Labeling Conference, October 1, 1991
Workshop: In—Store Labeling — What’s In—Store for the Consumer?
Thank you for the opportunity to be here today. My name is Lars
Peterson and I am Senior Government Relations Representative for the Food
Marketing Institute. FMI is a trade association representing the retail and
wholesale grocery industry. We have 1,500 members; one half of them are
single store owners, two—thirds operate ten or fewer stores, and one third
have eleven or more stores. Our members operate a total of approximately
19,000 stores, which account for half of the nation’s grocery sales.
What is the role, what should be the ‘role, of the retailer in the
environmental area, and what is happening regarding in—store labeling?
The grocery industry recognizes that supermarkets are a very visible
part of the product/package supply chain. We see that we have a
responsibility to play a constructive role in the solid waste issue — a
problem we all share. We all have to change our habits and ways of doing
things — as individuals as businesses, coum unities.
A fundamental premise of the grocery industry is that we see ourselves
as the purchasing agent for the consumer. This perspective is the first tenet
set forth in FMI’s mission statement. This is only natural. Consumers visit
grocery stores an average of 2.3 times a week. Retailers hear about
suggestions and complaints — what consumers like and want or do not like —
and try to respond.
The fact is, the environment has become a consumer issue. Shoppers
want to be responsible environmentally SO they want to know about the
environmental impact of the things they buy — what is recyclable, what
products and packages contain recycled materials, what can be reused, is a
paper, plastic or canvas grocery bag best?
And what does this mean? Like other consumer issues, it means that
consumers have a right to accurate and usable information and that industry —
manufacturers and retailers — has an obligation to provide it. With usable,
clear information consumers will be empowered to make sound environmental
purchasing decisions.
So, what’s in store? More environmental information, more involvement at the
couinunity level.
FMI maintains a compendium of environmental programs that our members are
undertaking. It is called our Member Company Environmental Directory and it
is updated every few months as we learn of new programs.
Several stores are shelf labeling environmental information — telling
shoppers such things as what is recyclable in the store or community or
what is source reduced.
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Other shelf signing programs provide general environmental information,
for example, about the SPI plastic coding symbols or about specific
materials.
Cents—off programs offering a discount to shoppers who take their
shopping bags back to the store for reuse.
Brochures and general information programs about community
environmental activities, in other words, the store acting as a source
for useful community information about recycling centers, collection
programs, etc.
These kinds of efforts show how the setting — the point of purchase —
presents a unique opportunity for the public to gain environmental information.
It is important to keep in mind that local conditions are not always
the same, and this means there is not total unanimity within the grocery
industry on environmental programing. In some areas, for example, in—store
plastic and paper grocery bag collection programs for recycling work very
well. In other areas a lack of space makes such programs impossible.
If you would like a copy of the Directory, please let me know. I would
be happy to send it to you.
In addition to in—store programs designed for the shopper, retailers
are looking at the operations side of their business to see where in—store and
office waste can be reduced and recycled more, and they are educating their
employees on the solid waste issue. They are also working with local
communities to advance comprehensive solid waste planning, and with
manufacturers and suppliers to encourage source reduction and recyclability.
Now, all this sounds just terrific, but let me douse it with some cold
reality. Is there a potential for confusion in this new arena of
environmentalism? Yes, not only is there a potential, there is confusion.
Polls show the public wants to be environmentally responsible but that it is
confused. Are products really recyclable if there is no collection system in
a community? What does “environmentally friendly!” mean on a label?
With the realization that being environmentally correct is not as
straight forward as first thought, and in light of some manufacturers being
taken to task for using terms like “biodegradable,” some manufacturers and
retailers have backed off from environmental programs. Not only do they want
to avoid legal problems, but there is a recognition that if environmental
labels and claims cannot be understood or turn out to be hollow, there is the
risk that cynicism will turn the consumer off — even to valid and useful
environmental messages.
That is why we need the Federal Trade Commission to issue guidelines
for the use of environmental claims. I was happy to hear Commission Chairman
Janet Steiger in her luncheon speech to us today voice her perBOnal support
for the Commission issuing guidelines. They are critically needed for
eliminating the ambiguity and uncertainty that presently exists. Guidelines
would create a level playing field for marketers so that there will be less
chance of consumers being confused and turned off.
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The national grocery distribution system is a vast, integrated
mechanism. One of the needs for guidelines is to establish uniformity. A
patchwork of different states’ definitions of environmental terms would impose
such significant labeling problems that manufacturers would likely stop making
claims, or wholesalers —— many of which are multi—state suppliers —— would
stop carrying items with claims.
But let me again complicate things. While we need uniformity, national
guidelines cannot be so rigid that they stifle local initiatives or cannot
acconm odate local conditions.
If national guidelines prescribe that a packaging material cannot be
labeled as “recyclable” unless it has achieved a 25 percent recycling rate
(this has been proposed), then the grocery stores in a coimnunity that is just
starting a curbside collection program cannot put up shelf tags in the stores
informing shoppers about the packaging materials that are now being collected
for recycling!
This would be a classic Catch—22. Grocers could not shelf label
recyclable items exactly when the public needs the information, when the
community’s recycling rate is zero. They would have to wait until a 25
percent rate has been achieve, when the lesson has already been learned. What
a wasted educational opportunity this would be! Needless to say, FMI is
making sure that the retailer’s unique perspective is kept in mind at the
Federal Trade Coission as well as in Congress.
This concludes my remarks, which are meant as an overview of how the
food distribution industry — and grocery retailing in particular — is
responding to the solid waste problem facing our nation. My fellow panelists
will now provide some company—level perspectives on what the industry is doing.
Thank you for the opportunity to be with you today.
Food Marketing Institute
Suite 700
1750 K Street, N.W.
Washington, D.C. 20006
202—452—8444
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U.S. EPA CONFERENCE ON ENVIRONMENTAL LABELING
IN-STORE LABELING - WHAT’S IN-STORE FOR THE CONSUMER
MICHAEL REILLY - MANAGER OF ENVIRONMENTAL AFFAIRS
WAKEFERN FOOD CORPORATION
Good afternoon everyone, its a pleasure to be here. First,
I would like to thank the Pennsylvania Resources Council for
inviting Wakefern to this important conference and giving us the
opportunity to share our views on in-store enviro labaling.
WFC/ShopRite is the largest retail owned cooperative in the
United States. We operate 180 supermarkets in Connecticut,
Delaware, Massachusetts, New Jersey, New York and Pennsylvania.
We serve over 3 million customers each week. The environmental
affairs department that I m responsible for was formed in June of
1991. It came about because of a need our Board of Directors saw
in taking a consistent and comprehensive approach to
environmental issues facing their companies. The Board
established an Environmental Committee which is comprised of
Board Members (ShopRite owners) and WFC Staff. This committee
reviews, evaluates and recommends all environmental programs and
presents them to the Full Board of Directors for their
endorsement and recommendation, for implementation. This
afternoon I would like to share with you our reasons for not
implementing enviro labeling at the shelf, what we think as
retailers our roles should be in regards to this area and the
enviro programs we have implemented and finally, how we stand on
uniform labeling standards.
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As we began establishing environmental objectives for our
companies, our most important criterias were that they were
factual, educational and did not add to the confusion that our
customers were already dealing with in regards to environmental
issues. When we explored the possibility of ijt plementing some
shelf labeling, the programs did not meet the criteria we had set
for ourselves. For example, if we were to place signs that
showed a particular product was recyclable, the first thing we
would need to do is clarify where its .recyclable. One store
serves numerous communities. What may be recyclable in one
community may not be recyclable in a neighboring town. What
happens when a community stops recycling a material. No, the
shelf is not the appropriate place or time for the customer to be
making an environmental choice. The majority of customers don’t
have the time to read enviro shelf labels and make an informed
decision at the point. The most important information for our
customer is the shelf tag, informing the customer of the
product’s price, unit value and any added 5avings they may be
offered on an item. Adding more information, environmental or
nutritional, on signs, tags or shelf talkers would just confuse
customers further.
Our company believes that all environmental issues must be
addressed with educational and factual information. One or two
word pronouncements such as, reduce, reuse, recycle, reusable,
recyclable, biodegradable, ozone friendly, etc. really benefit no
one. We believe that our customerB want more information and a
better, understanding of what the environmental issues are and
what they can do so they can make an informed decision on not
only the products they purchase but also other things they can do
that ars •nvtronn%entally responsible.
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To begin th is educational process we created a series of
full page ads in our market area newspapers as well as our
customer circulars which addressed different environmental topics
such as, waste reduction, recycling and energy conservation. In
these ads we briefly discuss the problem, explain some things
that ShopRite has done and then suggest what the reader may do to
help. We also have available in our stores Environmental
Consumer Brochures that customers can take home and read at their
convenience. This yearns series inclu sd “Seasons Greetings”,
holiday ideas that respect our earth, “Outdoor Environmental
Actions”, tips to help us enjoy and preserve our parks and
beaches and “Reduce, Re n.se, Recycle”, which is an excellent
brochure develope by th’e Food Marketing Institute and which we
added a few points spec fic to our market area. Customers are
asked to question themselves on their purchases. Is the product
durable or reusable, or is it recyclable in my community? Is the
packaging reusable or refillable, or is it recyclable in my
community? Are mamifact rers’ claims in line with the best
scientific evidence? Are claims clear and specific? Are claims
being made for the pro ct its packaging or both? Does the
manufacturer provide a if ull address or an “800” telephone number
to answer product or pa aging questions? Ask yourself if you
are opting for speed a convenience or acting just out of habit,
instead of buying a practical alternative that is better for our
environment. Think twi a before making a purchase. The other
program we introduced thus past year is our bag reuse program
that asks our customers to use a permanent canvas or mesh bag or
reuse their paper or plastic bag. Two cents is refunded to the
customer for every bag that is reused - no matter what type it
is.
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must be implemented. Our industry through 11 national trade
associations, along with the Attorneys General from 11 states and
the E.P.A. have endoresed the idea of national guidelines and
presented their various petitions this past July to the F.T.C.
All parties agreed that claims must be specific and inform
consumers rather then confuse them. If national labeling
standards are not adopted, I’m afraid that the opportunity to
present clear factual environmental information on product
packaging will be lost. national manufacturers and distributors
will not be able to provide specific product packaging for one
particular state or individual community.
In summary, I would like to say that retailers can play an
extensive role in helping a community resolve its solid waste and
other environmental problems. However, it must be done
cooperatively and with all parties understanding what the issues
are. As retailers we can voice your concerns to manufacturers
and all work in partnership to try to resolve them. Your local
supermarkets can be a clearing house for clear, factual
environmental information. I’m very proud to be part of an
industry that has demonstrated that we are very serious about
helping resolve our environmental problems. There are no magic
wand answers to these often complicated problems. But as our
ShopRite Environmental Logo states, “Together we can make a
difference”.
Thank you for your time and interest.
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For the first full. year of the program, over 5.2 million bags
were reused clearly telling us that our customers are willing to
help reduce waste in their communities. This past year we also
funded a Municipal Compost Management Course developed by the
Cornell University Waste Management Institute. The Food Industry
feels composting of organic waste can be a major component in a
communities overall solid waste management program. The course
addresses the basic science of composting, how to properly site a
location and finally how all segments f a communtty n r1 to work
together to make composting of organic wastes succeed in their
community. The course work is completed at home, the waste
institute grades the work and a certificate is awarded on
completion. Our initiatives go beyond solid waste. Through full
page ads our organization had a Call for Action printed in the
major newspapers in our market area. We asked our customers to
ask the President and Congress to put in place a “real” National
Energy Policy with conservation and increased fuel standards for
automobiles. Thousands of customers mailed in their ballots,
many included personal letters besides. Again, another example
of consumers willing to act to improve our environment.
These types of programs are very effective I What else can
be done for our customers? The product package can be a valuable
tool in presenting clear, factual, environmental education for
the consumers. The problem lies in that we have a national food
distribution system and the enviro claims that products make may
be regulated at the state or local level. If product packaging i
going to be effectively used, national uniform labeling standard
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EDDIE G. POWERS
U.S. EPA NATIONAL ENVIRONMENTAL
LABELING CONFERENCE
OCTOBER L 1991
GOOD AFTERNOON AND THANK YOU FOR JOINING US. IT IS A PLEASURE TO
PARTICIPATE ON THIS PANEL.
IN THE NEXT FEW MINUTES, I WOULD LIKE TO PROVIDE YOU WITH BACKGROUND
INFORMATION ON KMART ENVIRONMENTAL PROGRAMS. THIS WILL GIVE YOU AN IDEA ABOUT
OUR PHILOSOPHY ON THE ENVIRONMENTAL PACKAGING & LABELING. LET’S BEGIN THE
DISCUSSION OVER ONE OF THE MOST IMPORTANT ISSUES OF THE ‘90’s.
MANY CONSUMER EXPERTS BELIEVE THIS DECADE WILL BE THE EARTH DECADE.
A 1991 GOLIN/HARRIS AND ANGUS STUDY REPORTED THAT 76% OF RESPONDENTS WOULD
PAY 101. MORE FOR A “GREEN” GROCERY PRODUCT. A 1991 GERSTMAN—MEYERS SURVEY
FOUND THAT 83% OF PARTICIPANTS CHANGED BRANDS AS A RESULT OF ENVIRONMENTAL
CONCERNS; ALMOST EIGHT OUT OF 10 ALSO SAID THAT A COMPANY’S ENVIRONMENTAL
RECORD AND IMAGE INFLUENCED THEIR PURCHASING DECISIONS.
IN FACT, THE GORDON S. BLACK CORPORATION BROKE ENVIRONMENTALISTS INTO FIVE
CATEGORIES. THEY ARE:
ROCK & RECYCLE . SMALL TOWN FOLKS, 18 TO 34 YEARS OLD WITH NO CHILDREN,
FORTY PERCENT WITH INCOMES OVER $30,000. THEY USE PAPER TOWELS AND PLASTIC
WRAP BUT ARE WILLING TO CHANGE. (IN FAVOR OF MANDATORY RECYCLING AND OTHER
ENVIRONMENTAL MEASURES WHICH WILL DIRECTLY AFFECT THEIR COMMUNITIES.)
BACH & BACKPACKERS . SUBURBAN MIDDLE—AGED PROFESSIONALS, WELL EDUCATED
WITH INCOMES OVER $30,000. THEY SPEND THE MOST TIME OUTDOORS — HIKING,
FISHING, CAMPING. THEY VOTE AND BUY PRODUCTS BASED ON ENVIRONMENTAL
CONCERNS. (THEY USE THE LEAST AMOUNT OF PAPER TOWELS, PESTICIDES, CHEMICALS,
AEROSOLS AND PLASTIC FOAM CUPS.)
SEDANS & SKEPTICISM . GENERALLY RETIRED PERSONS — AGE 46 AND ABOVE, WITH A
RANGE OF INCOMES FROM $15,000 TO $50,000. ABOUT SEVENTY PERCENT DO SOME
RECYCLING; TWO—THIRDS USE PUMP SPRAYS VS. AEROSOLS; HALF AVOID PLASTIC FOAM
PRODUCTS.
POP & PAYCHECKS . THIS GROUP CONTAINS THE SMALLEST PERCENTAGE OF PERSONS
EARNING MORE THAN $30,000 AND THE CHANGES THEY HAKE MUST BE AFFORDABLE .
MOSTLY CITY PEOPLE AND BLUE COLLAR WORKERS. THEY FAVOR MANDATORY RECYCLING.
MOST AVOID AEROSOLS AND PLASTIC FOAM GOODS.
DON’T WORRY BE HAPPY . MOSTLY MALES, 18 TO 34 YEARS OF AGE LIVING IN THE
SOUTH, THESE INDIVIDUALS DO NOT WISH TO COMPROMISE CONVENIENCE OR COST FOR
ENVIRONMENTAL CONCERNS. (THEY ARE THE LEAST LIKELY GROUP TO EXERCISE OR SPEND
TIME OUTDOORS. IN SPITE OF THIS ATTITUDE THEY DO SUPPORT MANDATORY RECYCLING.)
MANY OF THESE ARE KMART TARGET CUSTOMERS.
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‘7—
VIRTUALLY ALL OF OUR CUSTOMERS ARE AWARE OF THE PROBLEMS OF THE
ENVIRONMENT. THUS, ALL BUSINESSES NEED TO BE COMMITTED TO HELPING THE
ENVIRONMENT TO BE SUCCESSFUL. IF BUSINESS DOES NOT RESPOND, OUR CUSTOMERS
WILL. THEY TAKE THEIR BUSINESS TO OUR COMPETITORS.
IT WAS OBVIOUS TO US WE COULD HAVE A POSITIVE IMPACT ON OUR ENVIRONMENT
THROUGH OUR PROGRAMS, EMPLOYEES, VENDORS AND CUSTOMERS.
IN LATE 1989 WE BEGAN A PROGRAM IN COOPERATION WITH OUR VENDORS, THAT HILL
HAVE LONG TERM CONSISTENCY AND COMMITMENT. AS A PART OF THIS ENVIRONMENTAL
PROGRAM, WE DEVELOPED A MISSION STATEMENT: KMART CORPORATION IS COMMITTED TO
PROVIDING A HEALTHIER ENVIRONMENT FOR AMERICA .
WE DEVELOPED THREE OBJECTiVES FOR OUR ENVIRONMENTAL ACTION PLAN. THEY ARE:
1. TO EDUCATE EMPLOYEES AND CUSTOMERS ABOUT PRODUCTS KMART SELLS AND
THEIR EFFORTS ON THE ENVIRONMENT.
2. TO IDENTIFY AND MODIFY, WHERE POSSIBLE, PRODUCTS SO THAT THEY HAVE
A POSITIVE IMPACT ON WASTE DISPOSAL.
3. TO PROMOTE THE SALE OF ENVIRONMENTALLY RESPONSIBLE CONSUMER
PRODUCTS.
ONCE WE HAD CAREFULLY RESEARCHED THE ENVIRONMENT AND KMART’S ROLE, WE
KICKED OFF OUR PROGRAM AT STORE LEVEL IN MARCH OF LAST YEAR.
SIGNS, BANNERS, AND ENVIRONMENTAL TIPS PASSOIJTS WERE DEVELOPED FOR STORES
TO INFORM OUR CUSTOMERS OF OUR PROGRAM. PRIOR TO STORE LEVEL ACTIVITIES,
BUYERS MEETINGS WERE HELD AND OUR CEO, JOE ANTONINI, GAVE A PRESENTATION ABOUT
THE ENVIRONMENT AND ITS IMPORTANCE TO KMART. HE DEVELOPED A VIDEO TAPE TO
INFORM OUR EMPLOYEES AND VENDORS ABOUT OUR ROLE IN THE ENVIRONMENT.
TO MAKE THIS PROGRAM AN EFFORT THAT ALL DEPARTMENTS OF THE COMPANY CAN
SUPPORT, WE HAVE INITIATED A COMMITTEE OF ASSOCIATES FROM MARKETING, PUBLIC
AFFAIRS, SALES, LEGAL, CORPORATE SAFETY, AND OTHER AREAS. THAT OPENS
COMMUNICATION CHANNELS BETWEEN THE COMMITTEE, THE BUYERS AND THE VENDORS ABOUT
THE ENVIRONMENT. OUR COMMITTEE HELPS TO INITIATE OR REVIEW ALL KMART
ENVIRONMENTAL PROGRAMS, AS WELL AS REVIEWING HOW ENVIRONMENTAL ORGANIZATIONS
IMPACT OUR CUSTOMERS AND COMPANY.
AT THIS TIME I WOULD LIKE TO INTRODUCE A VIDEO THAT WILL HELP EXPLAIN OUR
PROGRAM.
VIDEO
WE BELIEVE OUR VIDEO SHOWS WE ARE COMMITTED TO BEING MORE ENVIRONMENTALLY
SENSITIVE. WE WANT EVERYONE TO BE A PART OF THIS COMMITMENT TO THE
ENVIRONMENT.
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THE INCREASING INTEREST IN ENVIRONMENTAL CONSEQUE!NCES OF PURñ SPlG
DECISIONS HAS NOT BEEN LOST ON THE RETAILING COMMUNITY. A QUICK TRiP DOWN THE
AISLE AT THE LOCAL KMART STORE MAKES THIS CLEAR. MANY COMPANIES NON CLAIM
THAT THEIR PRODUCTS PROVIDE BENEFIT TO THE ENVIRONMENT OR J RE UES’S HARMFuL TO
THE ENVIRONMENT THAN OTHER COMPETING PRODUCTS. THIS MARKETING S PRATEGYI HICH
INCLUDES PACKAGING AND LABELING IS “GREEN MARKETING”. IT CAN BE NFORMAir1VE
TO CONSCIENTIOUS CONSUMERS WHEN USED HONESTLY. UNFORTUMATEtY, A1flflEMPTS TO
TAKE ADVANTAGE OF THE CONSUMER INTEREST IN THE ENVIRONMENT ARE LEADING TO A
NUMBER OF ENVIRONMENTAL CLAIMS THAT ARE TRIVIAL, CONFUSING SAND EVEN
MISLEADING. RETAILERS AND THEIR VENDORS MUST WORK TOGETHER TO PREVENT
MISLEADING CLAIMS. CERTAINLY THE GROWING INTEREST IN THE IMPACT DF LI’FE
CYCLING WILL HAVE A DIRECT BENEFIT.
A GRATIFYING PROJECT MENTIONED IN THE VIDEO IS THE CON5ORTIUJP WE HAVE
FORMED WITH MICHIGAN STATE UNIVERSITY AND COALITION TECHNQLOGIES A
TECHNOLOGY—RICH MICHIGAN CORPORATION, TO DEVELOP USEFUL PRODUCTS ‘OUT F DUR
TRASH. KMART’S PART IN THIS GROUP WILL BE TO FURNISH USED TIRES, PLASTIC,
ETC. WHATEVER RAW MATERIALS (SOLID WASTE) ARE NEEDED FOR 1THE R EARCH
EFFORT. HE WILL FURNISH INPUT INTO THE DEVELOPMENT PROCESS 1HR 1L!JDH OUR BUYING
DEPARTMENTS. WE WILL HELP IDENTIFY AND TARGET MINORITY COMPANIES FOR
PRODUCTION AFTER PRODUCTS ARE READY FOR MANUFACTURING AND E WILL REVThEW
PRODUCTS TO DETERMINE IF WE WANT TO BUY FOR OUR USE OR SALES.
KMART LOOKS ON THESE EFFORTS AS A NATURAL THING TO DO. MHO ETTE ) WORK
WITH TOWARD DEVELOPMENT OF NEW PRODUCTS THAN THOSE WHO DEAL 4’IITH CUSTOMERS ON
A DAILY BASIS. MORE IMPORTANTLY, FROM THE ENVIRONMENTAL POINT F VIE3’ IT IS
THE RIGHT THING TO DO.
ONE OF THE FIRST RESEARCH PRODUCTS MADE FROM MIXED WASTE PLASTIC FOR
KMART, AS MENTIONED IN THE VIDEO, WAS A PALLET USED TO DISPLAY PI’ND TR NS ORT
MERCHANDISE, IS ALREADY BEING USED IN MANY OF OUR STORES AS A REPLACEtdE N1 FOR
TYPICAL WOODEN PLATFORMS. OTHER RETAIL COMPANIES ALSO ARE INTERESTED I THE
PALLET, TIRE SHREADING AND PLASTIC RECYCLING.
THERE ARE ALREADY MANY INTERESTING THINGS HAPPENING ON THE : CHM4D1SING
FRONT. KHART HAS BEEN APPROACHED BY MANY OF OUR VENDORS WISHI TO DO JOINT
PROMOTIONS WITH US. AND WE ARE ALREADY SELLING A VARIETY OF PRODUCTS WHiCH
ARE ENVIRONMENTALLY SAFE. HE ARE TESTING A PROGRAM WHICH DISPLA S PRODUCTS
THAT ARE PERCEIVED TO BE ENVIRONMENTALLY SENSITIVE IN A WECIAL 9I MART CARES”
PRODUCT CENTER.
—- THE CLAIM OF THESE PRODUCTS ARE SUPPORTED BY MA II T. CTURiE S INFORMATION
& ACCOUNTABILITY
—— AT RANDOM TESTING
—— MANUFACTURERS ACCOUNTABILITY
—- HE ALSO ENCOURAGE EXPERIMENTATION THROUGH *JR Bll NC OFTI E
WE HAVE DEVELOPED A NEWSLETTER THAT KEEPS ‘.OL R BUY ERS 11 FDATED N N E W
PROCESSES AND PRODUCTS. THIS IS BEING DONE ‘ON 3MONT+tL ’ BASI S. OUR BUYERS
WILL TAKE ADVANTAGE OF THIS INFORMATION TO HO 4 &1 H EJS I ID DE LfDP
CROSS—MERCHANDISING PROMOTIONS.
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THE KMART AND EXIDE BATTERY RECYCLING PROGRAM WAS A MERCHANDISING AND
MARKETING PROGRAM WITH VERY SUCCESSFUL RESULTS. OVER 2 MILLION BATTERIES WERE
TURNED IN DURING 1990 AND A HIGH SINGLE DIGIT INCREASE IN EXIDE BATTERIES WAS
SEEN. KMART AND EXIDE ALSO RECEIVED OUTSTANDING MEDIA COVERAGE ON THIS JOINT
ENVIRONMENTAL EFFORT.
AS MENTIONED IN THE VIDEO, IN 1991 THIS PROGRAM MADE AVAILABLE $100,000 IN
CONTRIBUTIONS TO NATIONAL NONPROFIT ENVIRONMENTAL PROGRAMS. ONE OF THESE
GROUPS, KEEP AMERICA BEAUTIFUL (KAB) WAS THE FOCUS OF OUR COMMUNITY SERVICE
PROGRAM THIS PAST APRIL DURING EARTH WEEK. STORE MANAGERS SELECTED AN
ELEMENTARY CLASSROOM AND ADDRESSED THEM ON THE ENVIRONMENT, UTILIZING SPECIAL
EDUCATIONAL MATERIALS DEVELOPED BY KAB.
WE ARE LOOKING INTO DEVELOPING SIMILAR GRASSROOTS PROGRAMS WITH OTHER
NONPROFIT ORGANIZATIONS.
HOWEVER, FOR OUR ENVIRONMENTAL EFFORTS TO BE CREDIBLE WE NEED TO DEVELOP
STANDARD DEFINITIONS AND TERMS. IT’S IMPORTANT FOR US TO DEVELOP TO HELP OUR
CUSTOMERS AND OURSELVES——WHETHER MERCHANDISE LABELING OR RESEARCH PROJECTS ARE
IMPLEMENTED. THE INTERNATIONAL MASS RETAIL ASSOCIATION AND THE NATIONAL
RETAIL FEDERATION, TWO OF THE RETAIL ASSOCIATIONS WE BELONG TO ON THE FEDERAL
LEVEL, ARE PETITIONING THE FEDERAL TRADE COMMISSION TO HELP DEVELOP THESE
CONSOLIDATED DEFINITIONS AND CRITERIA ON THE ENVIRONMENT. THESE DEFINITIONS
WILL ASSIST BUSINESS IN DEVELOPING ENVIRONMENTAL POLICIES. WE ARE COMMITTED
TO WORKING WITH GOVERNMENTAL BODIES TO PROVIDE FAIR ENVIRONMENTAL RULES,
REGULATIONS AND LAWS WHERE NEEDED.
WE AT KNART REALIZE THIS IS A LONG—TERM COMMITMENT AND WE ARE NOT GOING TO
ACCOMPLISH EVERYTHING OVERNIGHT. WE ALSO REALIZE IT WILL TAKE AN
INDUSTRY—WIDE EFFORT TO EXPLAIN WHAT RETAILING’S ROLE IS AND WHAT IS
REALISTIC. TO THAT END, HE WILL REMAIN ACTIVE WORKING WITH OUR EMPLOYEES,
CUSTOMERS, VENDORS AND GOVERNMENTAL BODIES TO DEVELOP AN INDUSTRY—WIDE MISSION
AND STRATEGY. THE ENVIRONMENTAL ISSUE IS HERE TO STAY AND WILL REQUIRE ALL
OUR EFFORTS.
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“ Blue Angel” a label of orientation for consumer. trade. industry
and administration
by Manfrad Eihoff,
attorney at law, head of the legal department of PAL German
Institute for Quality Assurance and Certification e. V., Bonn,
Germany
U.S EPA Conference on Environmental Labelling, Oktober 1—2, 1991
Baltimore, Maryland
First of all I would like to thank the management in the name of
my institute that we, the authorized office for issuing the “Blue
Angel” in Germany, may report about our experience in handling
the “Blue Angel”.
Before going into details on the sublect I would like to make a
few remarks about the institute PAL :
PAL German Institute for Quality Assurance and Certification e.V.
is a private institution in form of a registered society. PAL was
founded in 1925. According to its constitution, the goal of PAL
is the propagation of the quality idea and in this connection the
regulation of the organization of the distinguished quality marks
in the economy, including agriculture. PAL is engaged in the pro-
motion of “quality associations”, attends to them, as well as to
circles of the economy. PAL accepts quality marks and their
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guidelines. Furthermore it produces and administers marking sy-
stems, for example “RAL-TESTATE” (dealing with product info) etc.
Quality assurance by quality mark is the main object of the dif-
ferent tasks of RAL, as the guarantee of quality has a special
significance for the quality of a product and quality of perfor-
mance.
In order to achieve this, RAL has produced an instrument that
helps economy, consumers, commerce and the state to find an ori-
entation for reliable quality of product and performance. There
are quality marks in all different areas (construction, food and
custom-goods). At this time there are 142 quality marks. Admit-
tance to this quality — associations are open to every one — also
to any foreign manufacturers, if they comply with the technical
requirements of corresponding quality assurance.
This short exposition will have to suffice as the time alloted to
me for my lecture is limited .
In 1978, according to an agreement with the German Federal
Environmental Agency (UBA), RAL was authorized to confer the en-
vironmental label “Blue Angel” in keeping with existing regula-
tions with manufacturers in conformity with contracts of environ-
mental label users.
The environmental label was introduced in the Federal Republic of
Germany in 1977 by the Federal Minister of Interior, who was at
that time competent for environmental protection, and the Mini-
sters for Environmental Protection of the Federal States. The
original goals of the programme were to reduce pollution in the
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environment by means of technological innovation, to provide ac-
curate information in guiding consumer devices, and to create art
economic incentive for producing products that are environmen-
tally sound. Labelled products should be exceptionally beneficial
for the environment in comparison with other products serving the
same purpose, without signifcantly impairing their primary func-
tion of safety.
The programme started with retreaded tires, returnable bottles,
low waste hairsprays, deodorants and shaving foams, glass collec-
tion bin compaign, sanitary crepe papers made from recycled pa-
per, low—noise lawn mowers.
The environmental label in the Federal Republic of Germany is
called “Blue Angel”. The designation “Blue Angel” is not an off i-
cial name which is obviously deviced from the blue figure with
its outstretched arms in the center of the label. It is the syin-
bol of the United Nations Environmental Programme (UNEP) together
with the word “Umweltzejchen” (environmental label) above, the
explanatory phrase, starting with “well...” (“because...”) below,
and the words “Jury Umweltzeichen” (Environmental Label Jury).
Permission to use the U. N. logo was granted by the United Na-
tions within the scope of the environmental labelling scheme and
for environment-related public relation works undertaken by the
Federal Government, the Federal States and the communities.
The environmental label is the property of the Federal Minister
for the Environment, Nature Conservation and Nuclear Safety and
therefore he is obliged to protect the “Blue Angel” label. In the
performance of this task, RAL supports the Minister by preventing
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the misuse of the “Blue Angel” by a party with a RAL-contract,
for example: Using it for a product not included in their PAL
contracts, or for advertising purposes.
Before I speak about the various stages of award procedure, the
participants and the development of the special criteria for get-
ting the “Blue Angel”, I would like to tell you about the
philosophy of the “Blue Angel” :
The environmental label is itself a market-oriented instrument of
environmental policy. It fits into the competition incentives for
products with the best possible environment-related properties.
The environmental label should enc’.ourage the industry to produce
products friendly to the environment and should be a signal for
the consumers to purchase sucb products. The environmental label
is one of the so called “soft ii truments” ‘of environmental po-
licy, as it is a voluntary product identification. It cannot
establish binding requirements or industry wide standards. It re-
lies instead on information and motivation, on conviction and the
environment-conscious thinking and acting of manufacturers and
consumers alike.
And that is in my opinion the main point, as this “Blue Angel-Sy-
stem” is in the meantime so successful and there is no need for
having governmental regulations. Legal regulations cannot be as
flexible as voluntary guidelines. Since terthnologies and stan-
dards change in product categories with time, sometimes as a re-
suit of the “Blue Angel”, the basic criteria are only valid for a
period of three years and in principle, once the basic criteria
have become the industry norm, the criteria should be raised
I
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again or the basic criteria will not be prolonged for three more
years as the basic criteria has served its purpose. For example:
Environmental compatible buses and trucks, low-noise vacuum clea-
ners and auto gas installations have been cancelled. Depending on
changes in product norms, particular criteria may also be eliini-
nated. Thus the CFC-free requirement for hairsprays, deodorants,
and shaving foams has been eliminated since so many of these pro-
ducts are now CFC—free.
In connection with these remarks let me tell you that a product
can only be called “environmental friendly” in a relative sense,
because entirely environmentally sound products do not exist. As
the original inscription of the environmental label
(“environment-friendly because ...) has been misunderstood by
some groups in the society - in particular, it was sometimes mis-
takenly understood to denote a product as having no harmful ef-
fects at all on the environment - the original inscription was
replaced in 1988 with a neutral statement (“environmental label
because...”). Regarding this point I want to emphasize that this
change was not based on a court decision.
As to the requirements and criteria on which the environmental
label is awarded. I would say the following :
The criteria that a product must fulfill in order to obtain the
environmental label are outlined in the “Basic criteria for the
award of the environmental label”. It can only be awarded to
products with a high degree of environmental soundness, compared
with other products fulfilling the same function. The assessment
considers the product in its entirety, taking into account all
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aspects of environmental protection, including the economical use
of raw materials. Heretofore an environmental label test chart
has been used, in which the necessary requirements were stated.
A product is judged on two aspects :
a)
the various “phases” in the life of a product cycle (for example
from manufacture to use and consumption to disposal), in the
sense of the “cradle-to-grave principle” and
b)
the environmental damage caused by the product on the various en-
vironmental sectors (for example, hazardous substances, emissions
into air, water and soil, waste aspects).
The “Basic criteria for the award of environmental labels” de-
inand, that these aspects, too, are to be considered. Therefore
they are always taken into account when developing the “award
criteria”. Nevertheless, the environmental aspects will always
have priority, because it is an environmental label. The conside-
ration of safety and fitness for use will therefore on the whole
be oriented on minimum or average requirements, like those speci-
fied in technical guidelines or standards. Health protection is
considered likewise, as environmental protection and health pro-
tection are in most cases inseparable. Proposals for the “award
criteria” can be done by anyone, manufacturers, consumers and
their associations or environmental groups. They can submit new
proposals to the Federal Environmental Agency (UBA). In practice,
however, most proposals come from manufacturers. These new pro-
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posals are investigated by the UBA, whether they are significant
for the environment. After consideration, the proposals are
brought, with a votum by the USA, into the Environmental Label
Jury for decision. Should the Jury decide in a positive way, the
UBA get orders to stipulate, what kind of criteria are required
for a new environmental label. Further details about this I will
tell you later on.
Three bodies administer the “Blue Angel” yrogramme :
- Federal Environmental Agency
- Environmental Label Jury
— P.AL German Institute for Quality Assurance and Certification
e.V,
The Federal Environmental Agency is the government’s environmen-
tal protection agency, providing support to the Federal Minister
of Environment, Nature Conservation and Nuclear Safety. The
Environmental Label Jury is a 14 member non-governmental body. It
is independent and takes its decisions on the basis of regulated
standing orders. Members of this Jury are representatives from
the German protestant church, environmental organizations,
consumer associations, the Federation of German Industry, the
Confederation of German Trade Unions, the federal states -
extended by the new federal states - and a journalist. Further-
more, no voting representatives are the Federal Environmental
Agency, the Federal Ministry for the Environment, Nature Conser-
vation and Nuclear Safety and RAL. The jury members are appointed
by the Federal Minister for Environment, Nature Conservation and
Nuclear Safety. They do not get a salary for their work.
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The decision-making process comprises the following two steps:
Step 1 :
a)
collection and reviews of applications by the Federal Environ-
mental Agency,
b)
forwarding to the Environmental Label Jury, which, twice a year
makes a preselection of those product groups warranting closer
scrutiny.
C)
organisation of expert hearings by RAL for the preperation of
the final decision by the Jury. In expert hearings, all factual
matters in connection with the possible labelling of the relevant
product group are discussed, based on the proposed “award crite-
ria” submitted by the Federal Environmental Agency. In order to
maintain a balance of news, experts are invited from the Federa-
tion of German Industrie (representing manufactures supplies and
the suppliers) and the Association of Consumer Organizations re-
presenting consumer and environmental associations, and trade
unions. Each group may appoint up to four representatives. The
Federal Environmental Agency and RAL can invite other experts to
these hearings, if it is necessary for the subject-matter. The
expert hearings are not conducted in public, so that all factual
questions may be discussed openly and without being unduly influ-
enced by anyone. The results of the expert hearings are minuted
by RAL, who send the minutes to the participants of the hearing.
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The minutes on the expert hearings serve the Environmental Label
Jury as basis for their decision making.
Twice a year the Environmental Label Jury decides on the product
groups that may be given the environmental label and furthermore
it decides about prolonging, changing or striking off existing
“award criteria”.
Voting of the Environmental Label Jury takes place, on principle,
on the majority principle. The decisions of the Jury are regu-
larly published in a press bulletin of the Federal Ministry for
Environment, Nature Conservation and Nuclear Safety.
After that RAL and the Federal Environmental Agency draw up the
“award criteria” for the “Blue Angel”, on which the applicants
can get the label.
Step 2
If a manufacturer is interested in getting the “Blue Angel” he
has to send his application to PAL, for approval. If the docu-
ments are in order PAL forwards the application to the Federal
Environmental Agency and the Federal State in which the product
is manufactured. Even though the product may meet the award cri-
teria, the label still will not be granted if the manufacturer
has a poor record of environmental protection. In the case that
Federal Environmental Agency and the Federal State don’t have any
objections against the application, a contract on the use of the
environmental label is completed between PAL and the applicant.
The environmental label may only be used on the product itself
and for advertising this product after such a contract has been
completed — and not while it is being processed.
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The costs for the applicant are :
A one-time fee of DM 300,-- is charged for a product’s initial
application. The annual contract fee is based on the estimated
annual turnover of the product identified with the environmental
label. The annual contributions at this time are:
Annual turnover in Mio Annual Contribution in DM
up to 0.5 350,00
from 0.5 to 2.0 700,00
from 2.0 to 5.0 1.400,00
from 5.0 to 10.0 2.750,00
over 10 3.980,00
In addition to this every label user is required to contribute to
an “advertising fund”. The contributions payable into the adver-
tising fund amount to 20% of the annual contribution paid to RAL.
The advertising fund is used to finance public relations work in
connection with the environmental label. The “Environmental Label
System” is, as I told you, voluntary and is avaible to foreign
manufacturers subject to the same conditions applicable to German
companies. Therefore it is not surprising that approximately 13%
of all contracts completed with RAL on the use of the label were
signed by foreign companies, for example, Austria, Belgium,
Deflmark, Finland, France, Great Britain, Italy, Lichtenstein,
Netherlands, Spain, Sweden, Switzerland.
As I told you, the “Environmental Label System” started 13 years
ago with 6 product groups. Nowadays contracts for the use of the
environmental label with PAL can be concluded for individual pro-
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ducts on the basis of 71 “award criteria”. Up till now 3672 inVi—
dual products have been awarded an environmental label. Cor-
responding contracts permitting the use of the environmental la-
bel have been concluded with a total of over 770 firms.
These are the facts of the procedure of the “Blue Angel Pro-
gramme”. It took a long time until the “Blue Angel” was accepted
by the industry and the consumers. In the beginning it was an
indeficit system for RAL, but had its breakthrough with the in-
troducing of the “Blue Angel” for lacquers. Today the “Blue An-
gel” is a self financing system. With the increasing environmen-
tal thinking of the society it now has its steady place as well
as in the future. The environmental label is the only secure la-
bel in a number of selfmade “Environmental-Logos”. The “Blue An-
gel” is the leading system and an example for other national sy-
stems for the environment as in Canada, Japan and Austria. Simi-
lar thinking takes place in Great Britain, the Netherlands,
France and in the Nordic Countries.
Talking about the ECO-Label would mean a second speach. Therefore
I only want to say that the Federal Republic of Germany has cho-
sen detergents as a pilot for an ECO-Label. The talks about esta-
blishing an ECO-Labe]. by the commission which is definitely much
more complicated, because of the different attitudes in the EEC-
Countries, still continue. Therefore the Blue Angel will defini-
tely carry on with its successful way and increase its acceptance
in the public. For example 85% of the people in the Federal Repu-
blic of Germany know the “Blue Angel”.
I thank you very much for your attention.
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LABPI1JNG: A GLOBAL CONCERN
Presentation to
U.S. EPA NATIONAL ENVIRONMENTAL LABVLIJNG CONFERENCE
October 1, 1991
HYATI’ REGENCY, BALTIMORE
by
Graham Hardman, Director,
Environmental Choice Program
Environment Canada
Introduction
The title of this session conference is particularly a propos as one of my colleagues on
this panel, Jim, and I have just attended a conference held in Greece for representatives
of national environmental labelling programs. Environmental labelling is, indeed, a
concern for many countries including, I am delighted to say, ones that used to be
behind the Iron Curtain and those that are sometimes referred to as LDCs, lesser
developed countries, as
well as the European Community, some of its members, India, Chile, Czechoslovakia
and many more.
Today it will be my pleasure to brief you on Canada’s Environmental Choice Program.
Normally I would give what amounts to a crash course, ECP 101. Today, however, you
will be spared this because of time limitations so I will cut out some of the detail.
Instead, [ would like to give you a quick overview of the Program and a progress report,
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noting some of the interesting issues that have arisen especially on the international
scene.
First, a bit of background. Polls tell us that consumers are increasingly seeking products
that have lower impacts on our natural environment. At the same time they are in
danger of becoming confused by a proliferation of symbols and advertising claims.
This is exactly where Canada’s Environmental Choice Program fits. It is a practical
initiative of our federal government, designed to raise cbnsumer awareness so as to
change consumer behaviour. The Program deals directly with the environmental
potential of changing individual purchasing decisions and actions in the stores -- where
it counts.
Canada was the second country in the world to instal such a program. It was
announced in June 1988 at the Changing Atmospheres Conference in Toronto, ten years
after Germany’s Blue Angel program got under way.
A similar approach to ours has been adopted in New Zealand, the Nordic Countries and
by Green Seal here in the United States. As I said earlier, many other countries are
struggling with the political and practical realities of setting up labelling programs.
Let us turn to an overview of the Program.
LOGO SLIDE
The goal of the Environmental Choice Program is to ease the burden on the
environment, not through regulation, nor through taxation, but simply through the
operations of the marketplace. It uses the “carrot” of compliance with voluntary
guidelines rather than the “stick” of regulations.
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Our focus is on the consumer and the growing demand for products that ease the
burden on the environment. We seek to harness this shift in consumer preferences, this
“green purchasing power”, to pull industry towards the production of goods that are
environmentally less harmful.
The other side of the equation, therefore, is industry, always eager to supply
consumer demands including, these days, those for environmentally sounder products.
But who identifies environmentally sounder products? Consumers are sometimes
sceptical about environmental claims respecting things they buy. Therefore there is a
need for unbiased, credible information regarding which products would make good
environmental choices.
Our government, through the Environmental Choice Program, has filled the gap. Both
consumers and producers need this information. By providing it we can put the supply-
demand equation to work for a healthier world through EMPOWERING the CONSUMER
to make an INFORMED CHOICE.
** Products and services are identified as being a good environmental choice through
our symbol, the EcoLogo. It is licensed for use on products and services that meet
environmental criteria that we establish. This means that, when making their buying
decisions, consumers can rely upon the integrity of our easily recognizable symbol.
Through this voluntary program we aim to steer consumers towards the use, and
suppliers towards the supply, of products and services that meet our Program objectives.
These cover:
** The reduction, re-use and recycling of waste;
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• The management of renewable primary resources (to increase availability
for future generations);
• The management of non-renewable resources (to minimize our
dependence on them);
• The development of transportation systems which minimize energy
consumption, land use, and harmful emissions;
• The management of energy generation (to reduce consumption and
maximize the use of renewable energy soihces);
• The protection of ecosystems and species diversity.
Let’s now look at credibility. Clearly, if we expect to motivate business to provide
environmentally less harmful products and services, three prerequisites must be met:
• the EcoLogo must have meaning for consumers;
• it must be relied upon as having integrity; and
• it must be credible.
** The EcoLogo’s meaning for consumers is partly a function of how well we market
the Program; of that, more later. Regarding the EcoLogo’s integrity and credibility, I
believe that the EcoLogo has six points in its favour:
1. It is backed up by guidelines that set the criteria that must be met for licensing.
Note three things: (1) the criteria are designed to promote incremental change at
the margin, (2) they are technically or scientifically based; and (3) they are
specific to each product category. Anyone can find out our criteria - they are
not secret.
2. The guidelines are developed by an independent Board and, it should be noted,
involve a great deal of consultation.
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3. The Board requires a product to deliver an environmental benefit, taking into
account its entire life cycle. Do understand, however, that our criteria may reflect
only some of the life-cycle components.
4. We use the Canadian Standards Association, an independent organization, well-
experienced in the setting of standards and testing of products.
5. The fifth aid to the credibility of the EcoLogo is a final check on the quality of
the guidelines through a 60-day period of public review built into their
development. This is the Program’s opportunity To hear from environmentalists,
industrialists, consumers and anyone else with ideas on how to improve the
substance of any guideline.
6. Of course, a guideline can be based only on the best information available at the
time of its development. So, as new information appears or as technology
evolves to allow the setting of more stringent criteria, the guidelines will be
upgraded to be stronger.
We want to set criteria that produce environmental benefits, but this is pointless
unless the criteria are achievable by industiy. Setting criteria that are unattainable
obviously would not result in less harmful products or services. This, in turn, would not
lead to a decrease in the burden on the environment.
** It would be useful briefly to review the roles of the five main participants in the
Program.
Since it is a government program, the Minister is ultimately responsible for the Program
under CEPA (the Canadian Environmental Protection Act). En this capacity he also
appoints the Chairperson and the members of the Board and approves the final
guidelines before pnblicatiori in the Canada Gazette.
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The 15-member, independent, volunteer Board is responsible for the overall
effectiveness of the Program. This covers the development of policies on the Program’s
design and operation. The Board also determines the product categories and approves
the environmental criteria. Of course, it also monitors the implementation of the
guidelines and the operation of the licensing and certification activities.
The chair of the Board is Pat Delbridge, a well-known environmental and public policy
consultant. Its members are experts in such fields as environmental assessment, law,
business, scientific research, and manufacturing.
Environment Canada must get the credit for setting up this Program and funds it. It
also provides strong support on environmental, technical and policy issues and, of
course, is our liaison with the Minister. Funding needs should reduce as licence
revenue increases.
The Secretariat is part of Environment Canada and our staff manages the Program on a
day-to-day basis. This includes marketing and ensuring that environmental and technical
issues are dealt with properly. We co-ordinate the work of the Technical Agency with
the Program and are the Program’s main point of contact with the public.
Our Technical Agency is currently the Canadian Standards Association. It is under
contract to do the detailed work on the preparation of our guidelines, under Program
supervision. Its staff work with an excellent volunteer technical committee made up of
technical and environmental experts. This committee, in turn, forms task forces when
necessary to cover special product categories.
The CSA also is contracted to act as our independent testing and certification agency.
The CSA has to see that the licensed products meet our criteria not only upon initial
licensing but also on a surprise basis during the life of the contract.
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Today I will not describe the guideline development process in detail. We have just
decided to revise it and it makes no sense to give you information that will be out of
date before too long.
Nevertheless, it would be useful to outline some of the basic assumptions underlying
the process; these will be changed:
The Program should be rooted in public need. We have dealt with this so far by
encouraging business and the public to send us suggestions for environmentally
better products and services.
It should be consultative. We want to involve all types of stakeholder -.
industry, governments, environmentalists and the public -. in developing the
environmental criteria.
Criteria must be scientifically or technically based. As such they should be
subjected to outside scientific or technical review. We have been using an
excellent volunteer technical committee to do this.
Public input into proposed criteria is invaluable. A sixty-day public review
period has enabled us to receive useful information from those who have not
participated in the more formal parts of the process.
The guidelines must be kept current. They will not be of much use if
developments outstrip them for too long.
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Final guidelines have been issued for eighteen product categories: re-refined
lubricating oil; cloth diapers; water-based and oil based paints; zinc-air batteries; heat-
recovery ventilators; cellulose insulation; products from recycled plastic; three recycled
paper categories: fine paper, newsprint, and miscellaneous products; composting
systems for residential use; ethanol-blended gasoline; reusable shopping bags; energy-
efficient light bulbs; water-conserving products; and non-rechargeable batteries.
We have over 80 licensees with more than 500 products with the logo on them.
Guidelines for compost and energy-efficient appliances rill be published soon. Well-
known names are licensees: du Pont, Water Pik, Esso, Noranda, major retailers and
small companies.
Still in process are different types of detergents, dry cleaning, paint removers, compost,
energy-efficient appliances and many others.
We want to have our products in different types of locations -- hardware stores,
decorating shops, grocery outlets, stationery stores -- so that all types of consumer will
see and y EcoLogo products.
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* Now for some particularly good news! Until now we have been described as
Canada’s best-kept environmental secret. We have not had enough products on the
shelves to make mass marketing worthwhile. This has now changed: the Environmental
Choice Program is now being promoted more aggressively.
The TV advertisements, which started at the beginning of September, are designed only
to promote the EcoLogo, to ensure that it will be more recognisable. The print ads
appearing in two national magazines, Macleans and l’A tualite, will emphasize the
EcoLogo’s credibility and integrity and explain what is behind it. Also, I hope it is
reasonable to expect to see our campaign reinforced by advertising by our licensees. We
expect that awareness of the Environmental Choice Program and the EcoLogo will
increase substantially over the next few months.
** Let me next note some of the challenges we have had to deal with, the opportunities
that are ahead and some lessons learned.
The chille.nges have been particularly interesting because there has been almost no one
else in the world to consult. The Germans have been most helpful in areas in which
they have experience, but our process and approach is different from theirs, so it has
been very much a learn-as-we-go experience.
Let me pick a couple of areas to illustrate the point. Take the life-cycle review that we
do as part of our product assessment. In looking at a potential product category we
review its life-cycle to determine where the environmental gains can be made. We do
not, at this stage, expect to set criteria for all stages of the life-cycle -- it is far too
complex; we pick the one or two where the greatest gains can be made.
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Even now, as many of you know and have learned today, the science is still being
developed. Thus in some areas difficult judgements are required weighing one
environmental factor against another.
Indeed, we have avoided the issue completely for the time being on fluid food
containers. Who can provide the definite reading on which is better for the
environment: reusable/refillable, recyclable, or certain one-use containers, and made of
which material, steel, aluminum, plastic, glass, or laminate?
Another challenge has been to ensure that our criteria are not so high that they are
unattainable nor so low that they are meaningless. Our approach, as I have noted, is to
use an extensive consultative process. We have also tried to ensure that a “threshold”
level of between ten and twenty percent of an industry can meet the criteria when first
promulgated. This seems to have worked so far but we are looking at ways to improve
the process and are making the threshold percentage more flexible, depending upon the
product category.
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We have also faced some interesting criticisms. For example we have been criticised a
little bit for having standards that are too loose. This would be bad except that the
same standards also have been criticised as being too tight. Our defence is that we aim
to set standards that are achievable by some members of an industry in the early days
of a guideline. There should then be enough of an incentive for others to comply in
order to compete. The standards will be raised every three years or so as to ensure that
environmental gains will still be made.
Let me illustrate the point. In our fine paper guidelines, in specifying criteria for post-
consumer recycled waste content we had to recognize that the infrastructure to collect
waste paper was not fully in place. So, as more paper can be collected, our criteria will
be tightened. The trick is for us to be ahead of the changes so that we can provide an
incentive.
Regarding the future corporate structure of the Program, since its inception it has been
a candidate to be spun off in some form. This is the subject of discussion now within
the Department and we hope to see a decision made fairly soon.
This presentation has been a little parochial so far, so now it is time to cover off a
couple of the points that have arisen on the international scene.
The first concerns information exchange. As long there have been only a couple of
programs this has been manageable. We have spent many hours giving information to
those looking at setting up similar schemes -. and this has helped . But, as more and
more programs begin to take shape, the nature of the information that we will all need
will change.
For example, take product lifecycles: the application of lifecycle reviews in determining
environmental criteria is still developing, so countries can save time, money, arid grief
by exchanging information in this area.
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The trick will be to do this (a) without tying up limited resources in unnecessary data-
gathering and distribution exercises; (b) without having to depend on international
bureaucracies with mandates that don’t fit with ours; and (c) while recognising that we
do not all have the same needs. Some solutions were discussed in Greece and we will
be working on them over the next few months.
Another area is harmonization of criteria among labelling programs. If this means that
all labelling programs should now use the same criteria for a given product category, I
would find it difficult to advocate harmonization at this point .
Another point of interest relates to the licensing of imported products. Our Program
does not restrict licences to domestic producers; this would not be desirable and, in any
case, would be almost impossible to do. However, if we license a producer from a
country that has stringent environmental regulations than ours, are we in effect
exporting pollution?
Conversely, if we try to restrict imports from such countries on environmental grounds,
are we guilty of what some call environmental imperialism? We are working on a
sensible permanent solution to this and, in the meantime, have been doing our best to
ensure that foreign licensees have high environmental standards.
So that covers my remarks for today. As you can imagine, it has been a stimulating
experience for the past two years, demanding and most rewarding. I have enjoyed
working on this program and working with such supportive and bright people in the
Department and on the Advisory Board. I look forward to the next era as we become
better known and as we adopt some of the excellent ideas we have been given, and
adapt to the changing times.
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The International Aspects of Environmental Labelling Programmes
Jim Salzman, OECD’
Introduction
The international growth of environmental labelling programmes over the last few years
has been truly dramatic. Just three years ago, only Germany was issuing labels. By the end
of 1992, as many as 21 countries could have products with environmental labels on their
market shelves. This growth has been global, as well. Programmes will soon be issuing labels
in the Americas, Europe, Asia, Australia and New Zealand. These programmes offer an
exciting new instrument for environmental protection from the demand side, and, at the request
of its Member countries, the OECD Environment Directorate has been examining national
environmental labelling programmes for the last two years. 2 The findings have recently been
derestricted by Member countries and published in the book, Environmental Labelling in OECD
Countries . This book represents the most comprehensive assessment of labelling programmes
to date. This paper is drawn from OECD research and addresses the following questions: why
have labelling programmes become so popular in the OECD, how much do environmental
labels cost for business, how axe programmes financed, and what are the opportunities for
harmonisation?
The rise of eco-labelling
The idea of environmental labelling, of putting labels on products in order to inform
consumers of their environmental impacts, is a relatively recent phenomenon. Today we accept
as a matter of course the government’s requirements to label products with consumer
information such as the carcinogenicity of cigarettes, nutritional content of foods, or toxicity
of chemicals. These regulations axe important because they permit the consumer to make an
informed judgment regarding the product’s effect on his health. It is quite different, however,
for the government or the manufacturer to label a product solely on the basis of its effect on
the environment (e.g. I ozone.friendlyH) rather than on its immediate impact on the consumer.
The widespread desire to be informed of the environmental aspects of a product represents a
real change in consumer tastes and may be attributed to the recent rise in environmental
consciousness. Indeed, while one can point to examples of environmental labels in the 1970s
describing appliances’ energy consumption and “organically-grown” foods, even here, the
emphasis was often more on how the product directly affected the consumer rather than how
the consumer indirectly benefitted by a cleaner environment. While an appliance’s energy use
does reflect its demand for natural resources, it is also a direct index of the appliance’s cost
of use; and organically-grown food (grown without pesticides or chemical fertilizers) is as
much a health issue as an environmental one.
1 The views presented In this paper are solely those of the author and not necessarily those of the OECD or
its Member countries. A 1ication for permission to reproduce or translate all or pan of this article should be
made to Director of Information, OECD, 2 rue AncW-Pascal, 75775 PARIS CEDEX 16, France.
The Organisation for Economic Cooperation and Development (OECD) Is an international diplomatic
organisation which grew out of the institution originally charged with achnirustration of the Maishall Plan after
World War II. The OECD is based in Paris and has 24 Member goveri nents. These include all of Western
Europe, Australia, New Zealand, Japan, Iceland, Turkey, “o” 1 . and the United States.
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The international Aspects of Environmental Labelling Programmes
Jim Salzman, OECD’
Introduction
The international growth of environmental labelling programmes over the last few years
has been tnily dramatic. Just three years ago, only Germany was issuing labels. By the end
of 1992, as many as 21 countries could have products with environmental labels on their
market shelves. This growth has been global, as well. Programmes will soon be issuing labels
in the Americas, Europe, Asia, Australia and New Zealand. These programmes offer an
exciting new instrument for environmental protection from the demand side, and, at the request
of its Member countries, the OECD Environment Directorate has been examining national
environmental labelling programmes for the last two years. 2 The fmdings have recently been
derestricted by Member countries and published in the book, Environmental Label1in in OECD
Countries , This book represents the most comprehensive assessment of labelling programmes
to date. This paper is drawn from OECD research and addresses the following questions: why
have labelling programmes become so popular in the OECD, how much do environmental
labels cost for business, how are programmes financed, and what are the opportunities for
harmonisation?
The rise of eco-labelling
The idea of environmental labelling, of putting labels on products in order to inform
consumers of their environmental impacts, is a relatively recent phenomenon. Today we accept
as a matter of course the government’s requirements to label products with consumer
information such as the carcinogenicity of cigarettes, nutritional content of foods, or toxicity
of chemicals. These regulations are important because they permit the consumer to make an
informed judgment regarding the product’s effect on his health. it is quite different, however,
for the government or the manufacturer to label a product solely on the basis of its effect on
the environment (e.g. “ozone-friendly”) rather than on its immediate impact on the consumer.
The widespread desire to be informed of the environmental aspects of a product represents a
real change in consumer tastes and may be attributed to the recent rise in environmental
consciousness. Indeed, while one can point to examples of environmental labels in the 1970s
describing appliances’ energy consumption and “organically-grown” foods, even here, the
emphasis was often more on how the product directly affected the consumer rather than how
the consumer indirectly benefitted by a cleaner environment. While an appliance’s energy use
does reflect its demand for natural resources, it is also a direct mdcx of the appliance’s cost
of use; and organically-grown food (grown without pesticides or chemical fertilizers) is as
much a health issue as an environmental one.
‘The views presez ed in this paper are solely those of the author and not necessarily those of the OECD or
Us Member cosnuies. Application for permission to reproduce or translate all or part of this article should be
made to: Director of Information, OECD, 2 rue Andre-Pascal, 75775 PARIS CEDEX 16, France.
The Organisation for Economic Cooperation and Development (OECD) is an international diplomatic
organisatlon which grew out of the institution originally diarged with administration of ttr Mamhall Plan afteT
World War I I. The OECD is based in Paris and has 24 Member goverm et1ts. These indud all of Western
Europe, Australia, New Zealand, Japan, Iceland, Turkey, Canada. and tbe United States.
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The difference today is that consumers want to act to protect the environment, and are
willing to use their purchases as an environmental protection tool. Manufacturers are well
aware of this trend, and have sought to identify their products with the increasingly-common
“phosphate-free” and “biodegradable” labels as a prominent part of their marketing strategies.
And it works.’ Recent polls throughout the OECD area have clearly demonstrated consumers’
willingness to pay a premium for “environmentally-friendly” goods. In a nationwide poll in
Canada, for example, 80% of those polled stated they were willing to pay up to 10% more for
environmentally less harmful products. Public opinion polls in Austria and Sweden show
similar results. The British paperback, The Green Consumer’s Guide , published in September,
1988, topped the bestseller’s list for 9 months and has sold over 300 000 copies, It is being
introduced in 10 foreign editions.
One reason for the tremendous success of these shopping guides is that, while the
consumer can judge for himself the validity of manufacturer claims concerning longer-lasting
sponges or brighter-cleaning laundry powder, the consumer may find it difficult to assess the
validity of manufacturer’s claims regarding environmental impact. In the search for means to
better inform concerned consumers and to improve the state of our natural surroundings, a
number of governments and private organizations have thus turned to environmental labels in
guiding the marketplace toward environmental protection.
The Federal Republic of Germany issued its first environmental label in 1978. The
programme now has over 3 600 labelled products in 64 product categories. Canada and Japan
commenced their programmes in 1988. Norway, Sweden, Finland (in a harmonized Nordic
Council Programme), Austria, Portugal, and France intend to start issuing labels in 1991.
Programmes are now under consideration in the European Community, Netherlands, Australia,
and New Zealand. By 1992, as many as 21 OECD countries could have products with
environmental labels on their market shelves. 4
Depending on one’s perspective, environmental labelling can accomplish a number of goals,
including:
i. Improving the sales or image of a labelled product
This goal is actually a necessity, for if the use of environmental labels does not increase
sales or improve the product’s or company’s public image, then the labelling programme is
doomed to failure. As a voluntary market-based instrument, environmental labelling will only
be effective if it is accepted and used by manufacturers as a marketing tool. And this will only
occur if consumers accept and respect the objectivity and goals of environmental labels.
ii. Raising the awareness of consumers
A re nt study In the United States concluded that “green” products constituted 0.5% of all new products
Introduc *d in 1985. In the first half of 1990, 9.2% of Ill new products were maik.etod “green,” mi i ncrease of
almost twentyfold.
sourne: Green Marketing Alert , October 1990.
This refers only to government-sponsored labelling prognenmes. Retailers, manufacturers, and
nongoveirsnental organisatlons have established their own labelling systems In a number of cuunhies, but most
do not attempt to be as comprehensive as the existing government-sponsored prognunmes.
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iii. Providing accurate information
ii’. Directing manufacturers to account for the environmental impact of their products
if the entire life cycle of a product is considered in awarding labels, then manufacturers
vying for the label should have an incentive to reduce depletion of natural resources, reduce
the burden on waste disposal, and reduce the accumulation of polluting substances. In short,
if the criteria for obtaining an enviionmental label are set at high standards throughout the
product’s life, then manufacturers will be encouraged to produce increasingly more
environmentally benign products, perhaps moving closer to state-of-the-art cleaner production
processes. Moreover, even if some products will not qualify for the label, they may have to
raise their environmental qualities just to stay competitive. Eventually, programmes should
encourage manufacturers to incorporate environmental concerns into their entire product
development process, much as product quality has now become an integral aspect of
manufacturer decision-making.
v, Protecting the environment
Directing consumers to favour less environmental]y harmful products in their purchases
should reduce the net environmental impact. This is, after all, the ultimate benefit of labelling
programmes.
While all these goals are present in a labelling programme’s aspirations, individual
programmes stress particular goals over others. Thus, for instance, one programme might place
particular emphasis on labelling’s role as an economic instrument while another programme
would stress the consumer information aspect.
Label costs
For American businesses wishing to sell their products in foreign markets,
environmental labels may provide a useful marketing tool. Provided the product satisfies the
label requirements, the costs to put the label on the product or its packaging is quite small
compared to other advertising media. In order to make the label available to small and medium
sized enterprises (often the very firms with innovative products which could benefit from the
label), the fees for the use of the label are kept down. All programmes, except the Japanese,
charge a one-time application or certification fee to cover application costs. As Figure 1
illustrates, there is a wide range of application fees among national programmes, from none in
Japan, to $190 in Germany, to $1 727 in Sweden. 5 The application fees in Sweden, NoTway,
and Finland are intentionally set at a similar price to prevent manufacturers who wish to
introduce their product into the harmonized Nordic system from choosing among national
programmes on the basis of initial cost. The Canadian and French application fees are variable,
depending upon the complexity of the manufacturing process and the number of plant sites
requiring visits. The Canadian fee also includes a charge for surprise testing by the technical
agency. In all programmes, the testing costs associated with a product’s application for a label
are paid by the manufacturer.
‘The exchange rates are those of September 5th 1990.
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Programmes also charge an annual contract fee for the use of the label (Austria charges
a biennial fee). With the exception of Japan, the annual fees are determined by the volume of
product sales. As Figures I and 2 demonstrate, 6 for a product with low sales, depending on
The nation, the fees may range from $259 in Canada to $1 382 in Sweden. The fee for a
product with high sales may range from $700 in Japan to $26 000 in Norway. Unlike all of
the other programmes, Japan charges an annual fee based on product price, irrespective of total
sales. In many cases the Japanese programme will have the least expensive charges,
particularly because it has no application fee.
The German programme levies an annual 20% surcharge of the contract fee for label
publicity costs. The other programmes presumably incorporate promotional costs into the
annual contract fee. Despite the differences in fees among countries, however, all of them are
relatively inexpensive when compared to conventional forms of marketing such as radio,
newspaper and television advertisements.
urns in the figures aie accurate as olMay 1991.
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FIgure 1. The costs of using an environmental label. MI amounts In table are In U.S.
dollars, currency exchange rates u on the 5th September, 1990.
Annual Product Total annual contract fee for use of label
Sales
Germany’ Norway Austria 2 Sweden Canada
$100 000 $267 $400 $450 $1 382 $259
250 000 267 1 000 1350 1382 1 294
500 000 532 2 000 1 350 4 145 2 155
1 000 000 532 4 000 2 700 6 460 2 155
2000000 1066 8000 2700 9520 4310
3500000 2094 14000 2700 9520 4310
5000000 2094 20000 4050 9520 4310
6 500 000 3 030 26 000 4 050 9 520 4 310
•nd above
One-time $190 $1 641 $ 1 727 $6904-
application fee
Japan: Product Price Annual Fee
$0 - $7 $278
7-70 417
70-700 556
above 700 700
The German programme levies an annual promotional charge of 20% of the contract costs. The
table figures include this fee.
2 The Austrian contract fee covei 2yeaz . The fee includes the application fee (approximately
25% of the total).
The application fee depends upon the complexity of the manufacturing process and the number
of plant sites requiring inspection.
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Figure 2. National programme lee structures (In local currency):
Germany (DM): Certification fee: 300; annual advertising fee: 20% of annual fee; annual
fee: 350 for product sales up to 500,000; 700 for sales up to 2 000 000; 1 400 for sales
up to
5000000; 2750forsalesupto 10000000: 3980forallsalesabove 10000000.
Sweden (SKr): Certification fee: 10 000; annual fee: 4 000 for product sales up to 500
000; 8000forsalesupto 1 500000; I4000forsalesupto2 500000; 24000forsales
upto
5000000; 38000forsalesupto8000000; S6000forsalesupto 17000000; 78000
for all sales above 17 000 000.
Norway (NKr): Certification fee: 10 000; annual fee: 0.4% of product sales, with
minimum fee of 2 400.
Austria (Sch): Biennial fee: 5 000 for product sales up to 2 000 000; 15 000 for sales
upto 10000000; 30000forsa IesuptoS0000000; 4S000forsalesupto50000000.
Canada (CS): Certification fee: 800+ (depending upon the complexity of the
manufacturing process and the number of plant sites requiring inspection); annual fee: 300
for product sales up to tOO 000; 750 for product sales up to 250 000; 1 500 for product
sales up to 500 000;
2 500 for product sales up to 1 000 000; 5 000 for product sales ov& 1 000 000.
Japan (‘1): Annual fee: 40 000 for product price up to 1 000; 60 000 for price up to 10
000; 80 000 for price up to 100 000: 100 000 for price above 100 000.
Approximately 25% of the bknnial fee is comidered as a certification fee. This is forfeited
if the applicant product does not qualify for the label.
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Programme financing
The idea of a labelling programme paying for itself seems veiy attractive. It helps
ensure independence, efficient management of resources, and does not draw on the
government’s budget. While a number of national programmes have stated that they intend to
become self-financing within two to five years after commencing, these claims must be viewed
with some caution. None of the existing programmes are self-financing. While Germany’s
certification and contract fees do pay for the costs of the programme’s administration (by the
non-governmental certification organisation, RAL), the initial screening of product category
proposals and much of the product research (a very resource-intensive activity) are performed
by the government, which is financed by the taxpayer. The Japanese programme is entirely
government-funded. Neither the German nor the Japanese programmes have any intention of
becoming self-financing. The Canadian programme, originally hoping for total self-sufficiency
wnhin 2-5 years, is also government funded at this time. It should become increasingly self-
sufficient as product license fees grow.
Figure 3. The initial goveriiment..borne costs to establish labelling programmes.
Country Funding (USS) Funding (local currency)
Austria $721 370 Sch 8 000 000 (for 3 fiscal years)
France $283 983 FF 1 500 000
Norway $98 457 (fiscal 1989) NKr 600 000 (for fiscal 1989)
$656 383 (fiscal 1990) NKr 4 000 000 (for fiscal 1990)
Sweden $967 185 SKr 5 600 000 (provided as a loan)
indeed, self-financing could be poor strategy, because there may exist a basic conflict
between self-financing and an effective environmental labelling programme. There are three
ways to raise additional funds for a programme outside of government grants: the application
fees must be high, a large number of different products must be labelled, or the labelled
products must have a high sales volume. A high application fee, however, may make the label
inaccessible to small and medium-sized enterprises (often the very firms with innovative
products which could most benefit from the label). Expanding the number of products labelled
may compromise the goal of high threshold criteria, and favouring products with high sales
volume may run contrary to the goal of selecting products with a small market share. If the
experiences to date are any guide, partial government funding is necessary, at least in the short
term, to ensure a comprehensive labelling programme.
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The Nordic programmes, which all have a stated goal of self-sufficiency, do not rely on
any government personnel. As a result, their overall budget requirements should be even
higher than the German or Canadian programmes because none of the personnel costs will be
absorbed by government payrolls. This larger budget necessitates larger revenues, hence higher
fees, which are evident in figure 1. Over time, programmes’ fee structures should change since
it is not yet clear what a fair market price for the label should be.
Harmonisation
To date, while there has been a good deal of discussion over harmonising labelling
programmes, there has been little progress. In large part this is due to the fact that only three
programmes are actually issuing labels. Given the increasingly international aspects of trade,
the rise of “green consumers” throughout the OECD, and concerns over non-tariff barriers to
trade, however, the haimonisation of national labelling programmes will remain an important
issue. With the basic similarity of labelling programmes to date, limited harmonisation of
programmes might be possible in the short term. Indeed, by the end of 1992, the Nordic
Council harmonised programme will encompass four countries and the European Community
environmental label, if adopted, will include another twelve. Nonetheless, the there exist
significant obstacles to achieve harmonisation.
Two basic factors weigh in favour of harmonisation: consumer confusion and economic
efficiency. If the European Community’s plan for an environmental label does not come to
pass, one might expect to see three or more different national environmental labels on a
European nation’s market TheIf. The consumer cannot realistically be expected to know the
various national criteria for products and thus be able to gauge the relative worth of one
country’s label versus another. In this setting, it is only natural for the consumer to favour his
country’s national label. Knowing this, the manufacturers will apply separately for each
country’s label, as well. Presently, outside of the Nordic Council programmes, to obtain a label
a manufacturer must apply separately to every country’s programme, submit the product and
the required tests, and pay the certification and contract fees. This is economically inefficient
if the national criteria for products are similar.
The two models harmonisation might follow would be a supra-national decision-making
process and mutual recognition. The supra-national plan would give an international body the
power to approve product groups and criteria, and the actual certification and awarding of
labels could take place, for example, at the national level. In the Nordic Council, for example,
product categories and criteria are developed at the national level and then forwarded, after
consultation with member countries’ labelling programmes, to the Nordic Council Coordinating
Body on Environmental Labelling. Each labelling country has two representatives on the body,
and consensus must be reached for approval. Once the product has been approved,
manufacturers may apply for labels in countries where they wish to sell their goods. The
proposed European Commission’s plan is similar, with decision-making power vested in an EC
body and criteria originally developed by the European Environment Agency. The EC plan
also has an appeal process in case a country wishes to challenge another country’s decision to
award a label.
No programmes presently contemplate mutual recognition of labels. Such a system
would be one of reciprocity, where country X would automatically award labels to products
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which had qualified for labels in country Y, and vice versa. This is analogous to technical
certification and product safety programmes which recognise the validity of results from
standardised tests.
Both of these harmonisation options pose significant problems. For mutual recognition
to have any appeal, the countries’ criteria must be very similar. It makes no sense for country
X to award its national labels to products from country Y if country Y’s criteria are set at a
much lower level, And national criteria may well be set at different levels. The environmental
label should be awarded to goods with higher than average environmental standards in their
product category. Since this is a relative measure, the particular product criteria will depend
upon the national market for that good, which may vary from country to country. For
example, the criteria for scrap paper content in recycled fine paper is 50% in Japan and
Canada, and 100% in Gennany. The criteria may also be set differently because the severity
of environmental problems vary from nation to nation. Thus a country with an efficient water
treatment system may place more emphasis on the bulk filler of detergents rather than their
phosphate content.
This concern over differing national criteria is also relevant to a supra-national system.
Given different composition of product markets and the varying environmental concerns in
countries, the final product criteria established in a supra-national system may be either too
high or too low from a member country’s perspective. Hence a number of countries have
expressed concerns that harmonisation could lead to a general lowering of standards. Other
countries have expressed concern that programmes will favour national industries in the
awarding of labels and that the bureaucratic apparatus necessary to handle such a programme
may pro/c unwieldy. The ongoing negotiations within the European Community to approve
a Community-wide label for the Single Market in 1993 have had to confront directly such
concerns. In accounting for national favouritism in the awarding of labels, for example. the
Commission has proposed an appeals process to challenge the improper awarding of a label.
The problems associated with harmonised labelling programmes warrant serious
consideration, but they should not be taken as an indictment of harmonisation. After all,
despite differences in structure, the existing programmes do share the same basic principles and
goals; and industry groups and a number of countries have voiced strong support for further
harmonisation. Indeed, it is not a foregone conclusion that harmonisation will lead to a general
lowering of standards, nor is it inevitable that countries will manipulate a harmonised label as
a tool to favour local industries. The initial guidance toward the course of harmonisation will
come from the Nordic Council programme’s experience. If the European Commission’s
labelling plan meets with success, then it too will provide a powerful impetus for increasing
harmonisation efforts.
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“LABEUNG: ENVIRONMENTAL FRIEND OR FOE?”
Remarks of
Minnesota Attorney General
Hubert Humphrey Ill
EPA National Environmental Labeling Conference
Baltimore, Maryland
October 2, 1991
Thank you very much for allowing me to join you at what is truly an
impressive conference. I have had the privilege of attending a number of
outstanding seminars on these environmental labeling issues. But I can tell you
that the program for these three days takes the cake. By the time you leave this
afternoon, you will have heard from a virtual “who’s who” of the people
influencing the most important marketing development of the decade.
Ed Erickson, the EPA, and the Pennsylvania Resources Council aH deserve our
hearty congratulations for having assembled such an outstanding program.
The only problem with such an all-star line-up is that it leaves me feeling a
little like Johnny Carson on the Tonight Show , when Ed McMahon turns to him
and says: “Well, there you have it! We now know absolutely everything yone
could ever want to know about environmental labeling! one could possibly
have thing further to say on the subject!”
And, so I debated a little about how to use my time this morning.
You certainly don’t need the kind of pep talk I found myself giving a year or
two ado, when business leaders and public officials alike had to be convinced
that the green. revolution was more than a passing fad. After this week’s
presentations, any of you who weren’t already “green revolutionaries” are surely
ready to run out and enlist by now.
Nor do I propose to talk with you about the nuts and bolts of today’s hottest
environmental labeling issues. After all, how much can I add about the current
state of federal regulatory efforts, when you’ve already heard from Janet Steiger,
from senior officials of the EPA, and from Seriator Lautenberg’s key staffer? How
much more do you need to know about state initiatives, when you’ve already
heard from a distinguished panel representing four of the most active states?
And, what insights can I add on environmental seats of approval, when you will
soon hear from representatives of Green Seal, Green Cross and ASTM?
Rather than a sermon, then, or a lecture, I’d like to take a few minutes this
morning to share some thoughts that are, perhaps, more in the nature of a
benediction: to acknowledge just how far we have already come, and to share
some thoughts about where we are going.
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This conference marks an appropriate time for us to pause briefly catch our
collective breath, and take stock of how much we have achieved in only a couple
of years. Actually, events are racing so swiftly that we probably don’t have the
luxury of catching our breath -- it’s all we can do just to keep up -- but let’s look
for a moment at the profound changes that have already taken place.
It was only two years ago that my wife carrie home with a package of those
now-notorious so-called “degradable” trash bags. (You know who I mean.) And,
the Humphrey household was briefly proud of itself for taking one small step to
better the environment - - that is, we were proud until we began thinking about just
where those trash bags would really end up, and about the fact that when we put
them in the trash, they headed off to landfills and incinerators where they would
never have a chance to degrade.
I had been reading about the emerging trend in Europe to market products
on the basis of their environmental impacts. And we knew the phenomenon was
headed toward our shores. But, it was the irritation of having been bamboozled
myself that first brought home to me what a few alert environmentalists had
already begun pointing out without safeguards to ensure that green claims are
accurate, consistent, and forthright, the green revolution could easily be
subverted.
By late 1989, I was sounding an alarm among my friends in the business
community, and with my colleagues, urging that we do our level best to get ahead
of the curve, and to see that this once-in-a-lifetime opportunity was not
squandered.
By the end of 1989, we had formed the Task Force of Attorneys General that
has been mentioned by some of the previous speakers. Acting in our traditional
law enforcement role, we began investigating suspicious product claims and
advertisements.
In this, our traditional role, we have already concluded cases involving
several manufacturers of those plastic bags with the trashy claims, as well as a
case involving so-called “degradable” plastic diapers.
Most recently, we have reached settlements with a major manufacturer of
hair-care products (Alberta-Culver), for claims about the effect of its aerosol
sprays on the atmosphere, and with the manufacturers of cardboard “juice
boxes” for what we felt were misleading claims about the extent to which the
boxes are currently recyclable. The many cases still under investigation include
issues of degradability, air pollution, composting, energy saving, and source
reduction.
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But, it did not take our Task Force long to realize that case-by-case
enforcement is, at best, a stop-gap solution. The real solution, we believe, must
take the form of federal standards and definitions, from both the FTC and the
EPA.
The first step must be the prompt adoption of FTC guides, hopefully along
the lines we proposed in our Green Report , in which we summarized the lessons
we learned in our public hearings and investigations. FTC guides offer the speed
and flexibility that are so critical in this arena.
Farther down the road, we look to Congress to enact the LautenberglSikorski
legislation, under which the EPA would promulgate substantive rules, specifically
defining each of the critical terms of environmental labeling. Unlike FTC guides,
the eventual EPA rules would have the full force and effect of law.
In practice, we see the two federal agencies working in tandem, with the
guides and definitions being developed coliaboratively by the staffs of the two
agencies, with input from our Task Force.
In the meantime, our Task Force is holding the line with case-by-case
litigation. So far, we are hanging on, and we haven’t lost the opportunity to make
green marketing a permanent part of environmental protection. But, in all
honesty, I’m not sure how much longer we can hold things together with the
hit-or-miss approach of occasional lawsuits and settlements.
The situation today is a little like what happens when the traffic lights go out
at a major intersection. Federal standards are the traffic lights — the rules of the
road, if you will — that we need for commerce to flow smoothly. Unfortunately,
through most of the 1980s, Washington suffered a major power failure. Power is
being restored, but for now, the traffic lights are still down.
You know what happens when traffic signals go out. For a while, drivers can
rely on each others’ sense of fair play and common courtesy to keep traffic
moving. Before long, though, traffic jams up. Drivers get angry and reckless.
They start to cut each other off and to drive off the road.
That’s about where we are today in environmental labeling. And our Task
Force is a little like the Good Samaritan who steps into the middle of the
intersection and starts directing traffic to keep things moving in an orderly fashion.
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I don’t know how much longer we can keep it up. I urge my friends at the
FTC and the EPA to get those federal rules of the road and traffic signals hooked
up and operating. I can tell you that the drivers are getting surly, and I am
reminded that in some parts of the country, freeway commuters are known to
shoot one another. So the time for action is definitely now.
That’s why the announcement by Chairman Steiger yesterday, that she will
support the adoption of FTC guides, and expects them to be completed within six
to twelve months, represents a major milestone. This is the signal our Task Force
and the business community have been waiting for. Of course, 1 would still hope
that by keeping this issue a top priority, the Commission can shorten even the six
to twelve month timeline suggested by the Chairman.
All the evidence says that we have not lost the opportunity to make every
consumer a frontline environmental activist. The latest Gerstmann and Meyers
poll shows that the percentage of consumers who prefer environmentally superior
products has actually inched up, in the last year, by one percent, to eighty-three
percent. In addition, seventy-nine percent of consumers say they are influenced
not only by the environmental merits of the product , but also by the environmental
reputation of the companies that make and sell the product.
Unfortunately, the same polling data shows that consumers’ desire to “do the
right thing” is still far ahead of their understanding of how to achieve that goal.
The fact remains that, on many of these issues, consumers are confused and
cling to perceptions that are simplistic or, in some cases, just plain wrong.
We shouldn’t be surprised by this type of oversimplification, when we
consider how complicated the issues are, and how quickly the technology is
moving. Add to this the use of terms that are vague, ambiguous and confusing,
along with the reckless use of misleading claims by some marketers, and you
have a real recipe for consumer frustration. That frustration, too, is beginning to
appear in survey results that show consumers growing skeptical of advertisers
claims, and looking for greater regulation by government.
Many businesses are just as frustrated, as they try to chart a course through
this whirlwind of change. Trying to design tomorrow’s products and to anticipate
changing customer expectations is challenge enough. When you factor in
uncertainty about federal regulations, and the knowledge that, without a federal
framework, states and cities may move off in different directions, you can
understand why some businesses feel they are caught up in something like the
game of croquet in Alice in Wonderland , where the rules changed arbitrarily at
every step of the way.
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Amid all this confusion, ft would be easy to miss the real story of the last two
years. That story, suggest, is extraordinarily positive. The green revolution has
stumbled here and there, and it will undoubtedly continue to go off course from
time to time, but that should not obscure the extraordinary changes taking place
every day. Everywhere we look, we see profound changes. Exciting changes. It
would be hard to find another arena in which we have come so far, so fast, on so
many fronts.
We have seen changes in products. Changes in packages. Changes in
marketing techniques. And, changes in our solid waste disposal system. But the
most profound changes are the changes in our attitudes and perceptions. It is
these changes that are the true cause for celebration.
The critical change, of course, was the sudden emergence of the willingness
on the part of ordinary consumers, to shop with the environment in mind. Just
where this commitment came from, we still don’t know. But we know it’s here,
and we know it’s real. And that’s an exciting change.
Second, took how much we have already learned. The business community
has learned how important this revolution is, and has moved to meet it in a
thousand ways. One tracking service tells us that, during the first half of this year,
an astounding forty-four percent of all new household products featured
environmental claims of one sort or another.
As this number suggests, in the space of just a couple of years, the entire
business community has mobilized to respond to consumers’ new preferences.
That’s an exciting change.
Third, in the same short period of time, we have achieved a near-consensus
about the need for some form of regulation to ensure that this unique opportunity
is not undermined by meaningless and dishonest claims. We are quickly
developing the will to put those regulations in place. And, those are exciting
changes.
Public perceptions and attitudes are evolving with the same astounding
speed in dealing with the specific issues of environmental marketing.
Consider degradability. Two years ago, “degradability was perhaps the
single buzzword uppermost in the minds of consumers. They weren’t sure just
what it meant. But, they had a vague notion that degradability was a magic bullet
that would somehow make environmentally troublesome products disappear.
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How far we have come! In less than two years, the public has largely
awakened to the fact that degradability is of no environmental benefit, and may
even be harmful. for the vast majority of our trash that ends up in sanitary landfills.
We are well on the way to understanding that degradability has a place, but only
in limited applications.
For products that end up as litter in our lakes and oceans, or for specialty
products destined for composting facilities where they will truly degrade, there
may be important benefits. But, after only a couple of years, the public has
figured out that we cannot simply degrade our way out of our solid waste
problems.
Second, look at the issue of recyclability. Here, the public has been
victimized by products promoted as “recyclable” when the recycling has been
theoretical, at best. Some products and packages that suffer from an
environmental stigma have been especially quick to claim that they are
“recyclable” when, in fact, the only recycling being done was in a few isolated
pilot programs, usually subsidized by the manufacturers.
The predictable result, of course, has been that consumers simply toss the
products into their local recycling stream, where they promptly contaminate the
materials that actually are being recycled in that community.
Look what progress we’ve made. With pressure from our Task Force and
others, manufacturers are changing their advertising to make clear that their
products are recyclable only in limited areas, and have begun offering 800
numbers and other resources to help promote the expansion of recycling.
Even more important is the fact that the growth of our recycling infrastructure
has been explosive. Although the economic viability of recycling some materials
is still unproven, we are moving quickly toward universal access to convenient
recycling for a growing list of materials.
Consider, too, how far we have come on the emerging issue of
compostability. The movement toward composting -- admittedly still in its
infancy -- is gathering speedy quickly. For example, in Minnesota we now ban all
yard trimmings and leaves from our landfills, and are either leaving them on our
lawns, composting them at home, or diverting them to commercial yard-waste
composting facilities.
More challenging is the effort to bring on-line full-scale facilities for
composting general municipal solid waste. Even here, events are racing forward.
With encouragement from the state, and with support from private corporations,
pilot facilities are already operating, and half a dozen municipal facilities are in the
planning or construction stages in Minnesota alone.
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Each of these changes is exciting in its own right. Together, they represent
an astounding metamorphasis in the way we do business. And, it has all taken
place in the blink of an eye, by historical standards.
As exciting and hopeful as these changes are, I believe they are but
symptoms of a larger shift in our public ethic. Just as, a generation ago, we
changed our attitude toward littering; just as we are changing our attitudes about
smoking and drinking; (believe we are in the process of changing our attitudes
toward consumption that is environmentally irresponsible.
If we can maintain the momentum of this green revolution just a little longer, I
believe we will soon reach a point of no return - a critical mass — beyond which
the change in our attitudes will be irreversible.
If we can achieve such a change, it wiU have significance far beyond issues of
degradability, recyclability, compostabikty, or other issues of the moment. Those
are passing problems, and in a few years we will have laid them to rest.
The true promise of the green revolution, is that it holds the potential for a
paradgm shift — a shift to an enduring public ethic that demands responsible,
sustainable consumption. An ethic that expects products to be designed,
produced, and disposed of to minimize their environmental impacts.
We can detect the first signs of such a shift in the phenomenon of source
reduction, which will be the next, and most important, of all the trends of
environmental marketing.
Today, the term “source reduction” is virtually unknown among consumers.
But, it is just over the horizon. And, it has vast implications for the way we do
business.
Packaging Will be first to come under scrutiny. To take two small examples,
consider the way the recording industry packages its compact discs, in that
awkward cardboard package known as the “long box,” that we all promptly
discard once we get our new disc home. Or, consider the way in which many
deodorants are packaged: not only in the plastic dispenser stick, but also
surrounded by an unnecessary, bulky cardboard overwrap.
As the public looks with an increasingly skeptical eye at packaging materials,
needless waste will soon be viewed with the same scorn we now apply to
someone who tosses trash out the window of a car. In fact, I am willing to predict
this morning that, within two years, both of the packages I mentioned — the long
box for compact discs, and the cardboard box surrounding deodorant
sticks — will be history, and will have disappeared from our shelves.
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From excess packaging, public scrutiny will move on to products
themselves. Consumers will increasingly ask whether it makes sense to use
flashlight batteries that are discarded after a few hours, or a throwaway camera,
or a throwaway plastic razor, or a throwaway cigarette lighter. Increasingly, they
will question the throwaway mentality that today drives so much of our
consumption.
To underscore just how fundamental this change will be, I encourage you, as
you fly home from Baltimore, or the next time you are on an airplane, to notice the
way an airline meal is served today. Notice the polystyrene coffee cup, the clear
plastic drink cup, the plastic cutlery, the tray liner, the individual containers for
salt, pepper, butter, salad dressing, breadsticks, peanuts, and so on.
Think about the throwaway mentality they reflect, and what it means for our
environment. Because that mentaUty is about to change. The writing is already
on the wall. And, when we begin to look at our product choices with different
eyes when we begin to consider the cradle-to-grave environmental implications
of our product choices, then the changes we see will be exciting indeed. And
when we put those changes into practice, we will truly be able to say that the
green revolution has succeeded.
Thank you very much.
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—E c u
Environmental Labeling
Torn Rattray, Procter & Gamble
EPA Enviionmentai Labeling Conference
October 2, 1991, Baltimore, MD
Good morning. It is a pleasure to be here and talk to you about environmental labeling. It’s a very
hot and dynamic topic these days.
Fm glad you all came, but actually, I always want to talk to the people who didn’t come, the one’s
who don’t think there’s anything wrong, environmental issues are a passing fad like pet rocks, or
for some reason they won’t be affected. But, they didn’t show up (they never do), so I ask you to
carry the message to them.
I assume that we’re here today because in one form or another we’ve got a problem.
Our basic problem at P&G is that our customers want to know all sons of things about the
environmental qualities of our products and packages, and we’re finding it increasingly difficult to
tell them. In fact, arc having a very hard time making some sense out of the growing maze of state
environmental labeling regulations and legislation.
You may not know that almost everything we produce is made at a few national locations 1 and we
often don’t even own the product after it leaves our warehouse. We literally do not know, and
cannot control where our products are ultimately sold. So, we have to do nationally acceptable
labeling. Unfortunately, we have temporarily removed some of our environmental infonnation
until their fate is clarified.
I’ve got to tell you that this is a very unfortunate situation. People want to know what they’re
buying. We want to tell them. And state after state is trying to facilitate this process. But instead
of getting easier, we’re approaching grid lock.
Therefore, we strongly support a unified national plan for environmental labeling, and have played
an active role in the NFPA petition to the FTC for national labeling guidelines.
However, before I get to the details of that, I’d like to look at a few labeling basics.
This is a very controversial area, for a number of reasons. in my observation of the debates
around environmental labeling, I find that there are two philosophies being espoused. In addition,
there are endless arguments about what ‘truth’ means, and the use of logos or seals.
First, let’s look at the philosophies. The first I would call information/education. It’s simply
telling people what the product or package is- like a net weight or ingredient statement.
The second I would call a Reward for Achievement. This philosophy says that producers can only
label those items that have achieved some fairly high standard for their particular product or
package.
A good way to think about it is when you go shopping. The average supermarket has about
30,000 items. Using the informational/educational approach, I would expect that many if not most
of the items there would have some sort of environmental information on them over time. Using
the second approach, only a few items would be labeled.
We have become advocates of the information/education approach. Thousands and thousands of
people call our 800 numbers every month asking all kinds of things about many, many products.
People want to know what they’re buying. Some of the questions, like “Can I water my garden
with the wash water from Camay soap?”, we’ll never put on the label. But others, like recycled
content or compatibility with recycling systems are of very broad interest.
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- 1 f PRO CTER & ‘MB IE CQ \’P’ ’
Environmental Labeling
EPA Environmental Labeling Conference
October 2, 1991, Baltimore, Ml)
I’d also like to touch on the subject of seals or logos. As you know, there are at least two
organizations in the U.S. that are offering their services to producers to certify that their products
or processes are ‘erwironrnentally okay. Once this certification is confirmed, the label can carry the
organization’s seal.
The theory is that consumers will see the seal, know that the product is environmentally okay, and
prefer it. However, we have strong reservations about this. First, let me show you some of the
good-guy seals you can find in today’s supermarket. Each one of these is supposed to signify
some sort of goodness about the particular product or package. Incidentally, you can find the two
environmental seals I mentioned if you know what to look for. You can also find three recycling
symbols, and a number of others that all mean that the product or package is somehow better than
the avenge bear.
We conclude, as does almost everyone who gets involved in this area, that to make major changes
in our resource utilization/disposal systems everyone will have to be involved, including the
general public. Therefore, we’re very concerned that yet another seal system that supposedly does
the thinking for the public will, in fact, let them off the hook - Jet them simply pick up a ‘good-
guy’ seal package once in a while and otherwise not change their habits. Remember, Americans
arc the people that drink Diet Coke with their Haagen-Daz ice cream - we want it all.
So, we’re not in favor of seals or logos as substitutes for telling people the truth about what they’re
buying. A logo may be useful to flag the part of the package that carries the environmental
information, but not as a substitute for the information ,
So, now Let’s look at truth. What is environmental truth? There are a few things that everyone
agrees about, and many things that will be researched and debated for a long time to come.
One of the givens of environmental truth is that less packaging going to disposal is good. There
are several ways to reduce the packaging to disposal, and Ill get into these in a minute, but
essentially everyone agrees that less disposed packaging is good.
The second is that reducing toxic disposal is also good.
That’s it. End of truth. At least, end of uncontroversial nth. Everything else is being debated.
I’d like to deal with these in reverse order.
The primary target for environmental packaging toxic reduction is heavy metals. As you probably
know, CONEG drafted a model heavy metals reduction bill for packaging in 1969. It is now the
law in 10 states, and will probably be law in another ten or so by the end of 1992. It says you
must reduce the levels of lead, mercury, cadmium, and hexavalent chromium to 100 parts per
million per component over a 3 year period. This has been P&G policy and practice for at least 15
years, and is being accomplished across the packaging industry with little disruption.
The question of reducing packaging to disposal is abit more complex.
We’re all familiar with the EPA hierarchy of waste management options. I have become a strong
believer in the value of source Suction, and have been with the CONEG Source Reduction
Council since it’s inception. By the way, it has resumed operation and is doing some very exciting
projects.
CONEG defined source Suction thusly:
Source Reduction - The elimination of packaging or reduction of the weight, volume
and/or toxicity of packaging.
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Environmental Labelin g
EPA Environmental Labeling Conference
October 2, 1991, Baltimore, MD
In addition, they produced a set of guidelines for packagers to help them understand how to
achieve source reduction. These are as follows:
CONEG Preferred Packaging Guidelines
1. No Package
2. Minimal Packaging
3. Refillable/Reusable Packaging
4. Recyclable, Recycled Content Packaging
When we first think about total package elimination, a lot of people think that nothing would be
packaged if it didn’t need to. But that’s not true for basketballs, or a sauce pans. They’re sold in
boxes, and without. So are a good number of other things. In other words, there is potential to
eliminate some packages entirely. In addition, there are major reductions possible through material
optimization, concentrates, refills, combination products, and larger sizes.
Here are a couple of examples. We are now producing 8 Enviropacs in Canada, for a variety of
products. These are plastic pouches that ace to refill the original plastic bottle. They represent 70
to 85% less packaging for the same amount of end product. In the U.S., we put the Downy fabric
softener refill concentrate in a carton because it was strongly consumer preferred to the pouch.
This is a 75% reduction in packaging for the same amount of dilute Downy.
Here’s how we label these:
“75% Less Packaging”
‘tess packaging to throw away.”
Both are clear, simple statements. Both are intuitively obvious to the public. Incidentally, so far
there’s. little indication that putting down the precise % reduction has much impact on the public.
It’s obvious that both of them represent a heckova lot less packaging, and that’s what’s important.
The American favorite is recycling. As you may know, in 1988 we announced the development of
a 100% recycled plastic bottle for Spic & Span Pine cleaner. And in May, 1989, we announced
that we could now put 20 to 30% of recycled plastic in owHDPE bottles for a variety of laundry
products.
Here’s how we label these:
“Bottle made from 100% recycled plastic.”
or
“Bottle contains at least 25% recycled plastic.”
These have been incredibly well received by the public. When we first started labeling the Spic
and Span bottle the level of voluntary testimonials went up over 100 times the normal. I mean,
when’s the last time you wrote anybody about a floor cleaner? The public really wants to know
about these things, and appreciates ii when you tell them.
Lasfly, we’re now up to about 80% of our cartons being made with recycled fiber, usually close to
100% recycled content. Until recently, we were using the standard API labehng format for all of
our fiber packages. Now we’re having to change due to state specific regulations.
This brings us to the most controversial category - recyclabiity. We’ve got the message and are
working hard on a number of fronts to get as many of our packages included in municipal
recycling programs as possible. Until recently, we’ve been making a conditional statement for ow
glass, steel, aluminum, PET and HDPE packages.
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J ‘ Ri :1 R C
Environmental Labeling
EPA Environmental Labeling Conference
October 2, 1991, Baltimore, MD
“This (can, bottle,) may be recycled where (steel, aluminum, plastic) recycling
facilities exist. Support recycling in your community.”
Today, we’ve stopped.. There’s simply no way we can tell people about recyclability without
running afoul of someone’s regulation. Once again, people want to know. I got a call last week
from a woman in central Arkansas wanting to start recycling of almost everything - plastic. cans,
glass - you name it. The public wants to recycle. We need to tell them in as many ways as we can
how they should think about it, what can be done.
So, as I said, we’re strong supporters of national guidelines for environmental labeling, and a
process to manage those guidelines. As a result, we were active participants in the process that led
to the petition to the FTC by 11 trade associations. Ron Smithies has given you the background on
the NAt), and how it works, so I’d like to take a few minutes to tell you what the petition is asking
for, what we think the right answer is.
First, the petition asks for guidelines, not hard and fast rules at this point. The whole
environmental arena is extremely dynamic. A few years ago it was big news if you took the
CFC’s out of your foam packages. Today, it’s old news. I fully expect that in the next few years
that the recycability of all common package forms will also be old news. Everyone will know it
because everyone will be doing it.
So to get started we are hopeful that we can all at least agree on the principles that should be used.
We need a system that lets producers and the public change and mature as we move toward more
environmentally benign products and packages. In addition, the system proposed to the FTC lets
whole new technologies like life cycle analysis be readily added as it becomes mature and relevant
to consumer products.
And as Ron told you, the NAD/BBB already has in place a well tested and experienced mechanism
to resolve conflicts. They use the same case-by-case method that the FTC favors, and any number
of entities can start the process.
Let’s start with the toughie - recyclability. The petition clearly recognizes that unqualified
statements can be deceptive and should be avoided. It further recognizes that access to collection is
the key quality for a package to be considered recyclable. Some packages, such as glass bottles or
tin cans, are recycled widely. However, the access to such systems will be vastly different in rural
Montana than suburban Cincinnati, for instance. Similarly, milk and soft drink bottles are already
collected in several thousand towns, so it is reasonable to expect that they could, or should be
collected broadly. Therefore, a qualified recyclability statement for them would be reasonable.
However, a child’s plastic toy would be scrap almost everywhere, and a recyclability statement for
that would not be reasonable.
The guidelines for recycled content arc less controversial. First of all, they state that recycled
content labels should apply to the primary package, unless otherwise clearly stated. This has not
been a problem.
They also say that they should either state the recycled content level, or be “substantially” all of the
product or package material. What is “substantially”? It depends on the circumstances. Some
mattrials, like clear glass, are essentially mono-materials. Others like papers or plastic have
colorants, surface treatments, stabilizers, and other modifiers to help the recycled material perform
acceptably. The NAD process lets each of these be determined on a case-by-case basis.
As I’m sure you know, there are endless debates about ‘what counts’ when you keep score on
recycled materials. The petition treats it simply. Everything that would have gone to the dump that
now winds up in a product or package counts - regardless of the source,
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t1 ( ROCTER C \\1 1( C’ ’ ip ‘‘.
Environmental Labeling
EPA Environmental Labeling Conference
October 2, 1991, Baltimore, MD
Time doesn’t permit me to go into this much detail for all of the-other items in the petition, but I’d
Like to hit them lightly. They treat source reduction much as P&G does - factual statements of
reduction, with supporting documentation to establish the claim. The standard of comparison is
always the immediate preceding product or package, unless clearly stated otherwise.
Compostability claims need to be qualified, with supporting evidence available that all elements of
the product or package will either be biologically broken down to soil-like elements, or screened
out of the compost end-product by a MSW composting process.
Refillable/Reusable claims should only be made when there is an actual system to refill or reuse
them. These can be at-home refills like our Downy Fabric softener, or distributor or’manufacturer
refill systems like the old beer and soft drink systems, or milk crates.
Terms like “Friendly”, “Green”, or “Safe” should not be used: They simply are not specific
enough. Remembers people want to know what they’re buying. They want the facts - not the
producer’s conclusions.
“Ozone Safe” is very tricky. It’s much safer to say that you contain no CFC’s than to document
that what you do have poses no threat to the ozone..
So that’s the petition to the FTC. rye spent a lot of time on it because it rep esents a very
concerted attempt to put together a set of principles of reasonableness that producers should use.
To me it also represents something else that’s very important. It’s a good way to break the log-
jam. It’s ironic in a way, almost everyone wants environmental labeling to happen some way. But
in our respective zeals, we’ve almost brought it to a complete stop. This is the wrong answer for
everyone, particularly the group we’re all trying to serve - the American public.
Do 7 ou remember two years ago all the controversy about the SN codes for plastic bottle resins?
We vegotten past that - and it’s working.
Towns are now telling their residents to turn in their l’s and 2’s. So I take heart that we can work
through our current controversies.
I believe this because we all have the same objective - to minimize the impact on the environment
For us the key interaction takes place here - at the checkout stand. Our customers axe telling us
again and again that they are worried about the environment and warn to know what they’re
buying. We want to tell them, and to continue to give them the very best products and packages
we know how.
It’s going to take all of us, working together to figure Out how to do this best. The issues are too
big and too complex to leave to our normal adversarial instincts. P&G is committed to
collaborating with state and federal government 1 public interest groups, and the American public at
large to develop strategies and plans for long term, self sustaining systems of integrated waste
management, and we hope you are as well.
Thank you very much.
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ADVERTISING AND ENVIRONMENTAL CLAIMS
Reniarks of JOHN F. KAMP
Vice President, American Association of Advertising Agencies
at
US EPA National Environmental Labeling Conference
October 2, 1991
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Thank you for inviting me to appear today on behalf of the
American Association of Advertising Agencies.
As many of you know, I have great faith in the good sense of
the American people to make good decisions so long as they
have unrestricted access to information. Similarly, I believe
in the power of advertising, not only to sell products and
services -- but also to stimulate competition, to lower
prices, and enable marketers to bring new, improved products
to consumers.
I know that many of you share these convictions, and thus I am
pleased that you asked me today to discuss how advertising
itself can become a part of the solution to many of the
environmental issues that confront us.
The A.A.A.A. is the national trade association for the
advertising industry. Our more than 700 members create and
place over 80% of all national advertising and over 50% of
local and regional advertising.
We stand today at a point of great opportunity for industry
because of the currency of the environmental issue and
consumers’ desires to be part of the solution rather than the
problem.
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Many consumers are thinking about the environment. They are
concerned. They are worried about the future. They are
looking for ways to help.
Consider for a few moments the results of a major study by the
J. Walter Thompson advertising agency, the Greenwatch Report.
The J. Walter Thompson study found that more than 4 of 5 U.s.
consumers feel that protection of the environment is a very
serious problem.
Although still concerned with pollution, consumers are
increasingly paying attention to the disposal of hazardous
waste and the build up of solid waste. That is, they are
worried about the accumulation of garbage, trash. They are
worried about all the trash we create.
Although they dont consider themselves experts, more than 60%
take personal responsibility for environmental problems. More
than a third hold the government responsible.
Most important for us here today, U.S. consumers have
expressed a willingness to pay more for environmentally
friendly products and to pay higher taxes for tough
environmental controls.
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Consumers are willing to do these during a recession marked by
sluggish consumer spending, and at a time when incumbent
politicians have been called home for merely mentioning
increased taxes.
With no experience in politics, I’ll pass on the appropriate
political response, but I know that no savvy manufacturer or
marketer would lightly ignore such an expression of consumer
sentiment.
But consumers are not hearing about green products as much and
as often as they should.
Recently in a presentation on this subject at the Federal
Trade Commission, Paul Nulcahy, the marketing chief of the
Cambell Soup Company showed a number of print and television
ads highlighting the environmental aspects of products. Many
were hard hitting; all were effective at getting across the
message that there was something that consumers could do to
improve the environment.
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Unfortunately, only three of the television spots were
examples of domestic U.S. advertising -- even though most of
the products were available in America. A study by the
Opinion Research Organization backs up Paul Mulcahy’s informal
finding that the United States falls well behind Europeans and
other major consuming countries in the development of
effective environmental advertising.
To date, the most effective environmental advertising in the
United States has come in two forms.
First, general public service campaigns typified by the famous
tear in the eye of a Native American who urged us to Keep
America Beautiful. By the way, that campaign was created by
one of our member agencies. The Marsteller advertising agency
launched that nationwide anti—pollution effort over 20 years
ago.
Second, institutional campaigns typified by the energy
conservation messages sponsored by public utility companies.
Product advertising clearly lags behind in these efforts.
I do not pretend to know all the reasons for this, but I know
one very important reason and it brings us all here in this
room. Currently, manufacturers face a crazy quilt of
advertising restrictions dealing with environmental claims.
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Many of these definitions are designed by state agencies with
scientific or technical expertise in solid waste management
but no understanding of the value and potential of
advertising. Others are the result of lawsuits brought by
state Attorneys General with insufficient regard for the
problems caused by inconsistent action in other states.
Moreover, none of these regulators have either the national
jurisdiction of Federal Trade Commission nor the
sophisticated expertise necessary to develop regulations that
would unleash the power of product marketers to enable
consumers to become a part of the solution to environmental
problems.
Regardless of the good intentions of many state and local
regulators, the net result has been a disaster for marketers
of national products who have attempted to communicate to
consumers about the environmental aspects of their products.
Let me just give you one example that came up in our office
recently. It involved a member that would otherwise be
invisible to you because no federal or state regulator ever
heard of the situation, much less brought a case. But the
mere threat of legal action squelched what we would all agree
would have been an environmentally positive consumer
communication.
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A small direct marketing agency member located in Ohio called
with a question about the use of a small note at the bottom of
mailing pieces stating correctly that they were printed on
recycled paper. Until then he had accepted his paper
supplier’s guarantee that the paper was recycled. He did not
know his supplier’s definition of the term recycled, much less
the percentage of the paper’s content of so—called
post—consumer and pre-consumer waste. He had heard that both
California and Rhode Island had passed laws limiting the use
of the term recycled and was particularly concerned about
proposed definitions by other regional, state and municipal
bodies.
After consultation with our office, review of several
statutes, consultation with his various suppliers arid
consideration of other complications, he determined that he
could not afford the time and expense involved to stay in
compliance in every jurisdiction.
Thus, he decided that his direct mail pieces would no longer
contain a line noting that they were printed on recycled
paper.
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In an attempt to deal with this dilemma, the American
Association of Advertising Agencies joined with 10 other
associations on February 14 of this year in the joint industry
petition to the Federal Trade Commission. That petition
specifically requests that the FTC develop guidelines for
environmental claims in advertising, and provides several
examples of what those guidelines might entail.
Some FTC Commissioners have expressed a preference for
accomplishing the same end by announcing a succession of case
decisions that would give clear guidance to marketers. In
fact, one such case was handed down by the FTC in a disposable
diaper case late last September. Regardless of the regulatory
means chosen by the agency, my association considers it
paramount that the Federal Trade Commission become the prime
regulator of environmental claims throughout the United
States.
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The FTC guidance must give renewed incentive to the
manufacturers of products with positive environmental
attributes to advertise those goods nationally.The FTC
guidance must enable manufactures to develop new products with
better attributes by giving those manufactures an ability to
tell consumers that the products are available. The FTC
guidance must be so pervasive, persuasive , and clear that the
FTC totally inhabits the area of environmental claims
throughout the nation.
The FTC guidance must, as a practical matter, eliminate the
inconsistent regulation and adjudication that is crippling
national environmental marketers in the United States.
In the meantime, as the representative from the Better
Business Bureau will fully explain, we have asked all of our
more than 700 agencies nationwide to comply with the
guidelines set forth in the joint industry petition and to
fully participate with the BBB in its use of the petition to
guide its case decisions.
Thank you for your attention on this long third day of
presentations. As always, I will be glad to answer any
questions now, or to pursue these issues with you later at
your convenience.
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INDUSTRY’S RESPONSE TO GREEN CONSUMERISM:
WHAT IT HAS DONE, WHAT MORE IT CAN DO
Remarks of CARL FRANKEL
Editor and Publisher, Green MarketAlert
at
US EPA National Environmental Labeling Conference
October 2, 1991
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I appreciate the opportunity to address this group
today. In my remarks, I will focus on some of the specifics
of mainstream business’s response to green consumerism. I
will then turn to additional steps which industry might
consider taking.
I have divided my discussion of businesses’ response to
green consumerism into five sections: (1) the energy level
of the response; (2) the psychological tenor of the
response; (3) the functional orientation of the response;
(4) the depth of the response; and (5) . areen product
performance as reflected in the marketplace.
Eneray L evel . Overall, industry has responded to green
consumerism very energetically. The movement has triggered
activity at many levels and across many functions throughout
corporate America. In a business study entitled “Businesses’
Strategic Response to Green Consumerism” which I wrote a
year ago for a New York City-based research company called
FIND/SVP, I surveyed major U.S. corporations and came up
with the following indicators of corporate “energy levels.”
Executives were asked to rate the importance of green
consumerism for their businesses two years ago and
presently, on a scale of 1 to 10, with 10 for most
important. Responses indicated that two years before, the
average score, or “energy level,” had been 4.63. For the
present, the score was 8.02. When asked what the importance
would be in ten years, the rating came in at a still higher
8.27.
Psychological Tenor . To date, the response of business
and industry to green consumerism has been largely reactive.
That is, it has been driven largely by consumer demand and
by regulation, most of which has come from the state and
local levels.
One refrain that we at Green MarketAlert continually
hear from consumer goods companies is that they are, in
essence, finely-tuned mechanisms for responding to consumer
demand. If demand is there, they develop and market product.
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If it’s not there, they don’t. But that image tells only one
side of the story. If the history of American marketing
teaches anything at all, it’s that industry can and does
create demand. Perhaps you can’t sell ice to Eskimos, but
where there’s some demand, savvy marketing can always turn
the volume up. It’s perhaps a bit misleading for the majors
to present themselves as basically Pavlovian in nature --
they have more free will than that. In my opinion, their
response to green consumerism could be more pro-active than
it has been.
There’s also been some defensiveness in the corporate
response. This is inevitable and indeed necessary when
you’re under attack, but some of the defensive strategies
have to my mind been problematic.
Let’s take, for example, the strategy that has the
following universal formulation: “Why is everybody picking
on our product taseptic packaging, plastic, disposable
diapers, etc.) when it only constitutes a tiny percentage
[ .1%, 2%, 6%, etc.] of the solid waste stream?” On the
surface, this may appear to be a powerful argument —— but
what if one took the same physical material and described it
in terms of tonnage rather than as a percentage of the total
solid waste stream? In that case, a quite different
impression would be created. The problem with this argument
is that it involves image-making more than it does truth-
seeking. As such, it does not improve the overall quality of
the critically important dialogue about environmental issues
that is currently taking place -— and our environmental
future depends on this debate’s being conducted at the
highest possible level.
Environmental image advertising too often provides
additional examples of how the corporate response is
sometimes problematic. I daresay we have all seen ads which
take a corporation’s environmental good deed —- say,
rerouting a pipeline to preserve a species habitat —— and
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turn it into a symbol of that corporation’s environmental
commitment.
The standard environmentalists’ objection to these ads
is that they are hypocritical, that corporations don’t
really care about the environment. I do not share that
perception. Corporations are complex organisms with often
conflicting goals. They are dominated by the profit motive,
yet the great majority also evince genuine concern about
environmental and social issues. Greed and caring live side—
by—side in corporations, just as they do in people. My
problem with this sort of advertising is that it selects Qfl
corporate face and presents it as the only corporate
persona. This is why such advertisements are misleading.
I don’t hold individual corporations responsible for
this so much as a corporate culture which has been with us
for much of this century. In an article I wrote for the
National Association of Professional Environmental
Communicators, I called this the “John Wayne” model of
corporate identity. This name is appropriate because the
model is characterized by an unyielding sense of one’s own
infallibility as well as by a felt need to project
decisiveness and unswervable self—assurance. Self-
questioning and the admission of fallibility are not part of
this model. However, I believe that we are currently in an
interregnum, that a new myth of corporate identity which
allows for a more flexible type of communication is
emerging.
As a footnote to my remarks about the psychological
tenor of the corporate response, I should also note that
corporations have also done much that’s first—rate. One can
see the glass as half—full or half—empty. In these last
remarks, I’ve been directing my attention to the empty half
of the glass.
Functional Orientation . A recently published study by
the management consulting firm Booz Allen & Hamilton
indicates the functional areas into which businesses have
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been putting their energy. The Booz Allen study segmented
businesses into environmental “leaders” and “non-leaders”
based on what Booz Allen called the “apparent progress made
in installing ... comprehensive risk management program(s).”
The study then examined the extent to which leaders and non-
leaders had developed programs to manage potential
environment-related risks in specific functional areas. I
will not burden you with the details of the study’s
findings. However, for the purposes of this discussion, two
findings were particularly significant.. First, contrary to
the widespread public perception, green consumerism—related
marketing and public relations programs are actually less
widespread among both leaders and non-leaders than programs
in less visible areas such as R&D/product development. This
suggests that the response of mainstream business and
industry to green consumerism may be more across-the-board
than some cynics might be inclined to believe.
Second, it’s in the area of marketing where the widest
discrepancy between leaders and non-leaders emerges. This
tells us that, while green consumerism is generating
activity across the board, it’s in the area of marketing
that leaders are responding most aggressively.
The Depth of the Response . In its few years of
existence, the green products industry has evolved into two
distinct segments —- “mainstream” and “environmentally and
socially responsible” businesses, respectively. In saying
this, I don’t mean to suggest that mainstream businesses are
neither socially nor environmentally responsible. I use
“socially and environmentally responsible” as a term of art
to describe a fundamental shift in corporate values that
characterizes many young, often small, “eco-preneurial”
companies.
Businesses have three basic agendas. The first is
economic —- turning a profit. The second is product—oriented
—- producing a high-quality product. The third is more
values—related —— behaving in an environmentally and
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socially responsible manner. In the traditional business
configuration, the economic agenda is paramount -- it is the
economic agenda, for instance, which provides much of the
incentive to produce high-quality products. In the “socially
and environmentally responsible” company, the three agendas
are parallel —— genuinely parallel, and not just public
relations-parallel.
While mainstream businesses have done a great deal over
the last few years to get greener, one thing they have not
by and large done is shift their philosophical underpinnings
from “economic agenda-first” to “values parity.”
At the same time, however, there has been a quite
extensive implementation of programs across the board to
address environmental issues.
From a “socially/environmentally responsible” point of
view, what we have is an image of symptom after symptom
being addressed —— but not the “disease.” Green issues are
being addressed extensively, but not holistically.
Benchmarks . Now let’s briefly consider the extent to
which green products have made their mark on supermarket
shelves. If we look at tdeep_green products, i.e., at
products which build their very identities around their
claimed environmental virtues, market share is modest at
best. Deep-green bath tissues and towels have only 2% of the
market -- and they are a relative success story.
Biodegradable and compostable diapers have less than 2% of
the market. Household cleaners have 2% —- and that’s if you
count products which some deep-green product suppliers
suggest aren’t really all that green.
There are exceptions to the general rule that deep—
green products’ share of market comes in at 2% or less.
Unbleached coffee filters, for instance, have a 12% market
share. In addition, selected deep-green companies are having
a transformative effect on their industries that goes beyond
their market share —- Anita Roddick’s The Body Shop and
Earth’s Best baby foods are two prominent examples.
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It’s also important to note that these modest market
share figures do not accurately reflect green consumerism’s
overall market impact. While these figures are only for
“deep-green” products, the lion’s share of the market
activity is coining from the “greening up” of established
product lines. Procter & Gamble’s Downy Refill, for
instance, which is perhaps the quintessential “greened-up
product,” now accounts for about 40% of all Downy sales.
This product “greening-up,” which has been spearheaded by
the major consumer goods companies, has led to noteworthy
source reduction gains as well as to other significant
environmental improvements.
It’s also worth noting that these same majors have
without exception shied away from developing and marketing
“deep-green” products in the U.S. There are excellent
business reasons for their having done so, including: (1)
the risk that existing products will be cannibalized; and
(2) the “slippery slope” danger that these products will
invite closer scrutiny of existing product lines. Still, the
blunt fact is that the majors have cast a cold eye on deep-
green products and have chosen to green up their established
product lines instead.
I would like to conclude my discussion of the nature of
mainstream business’s response to green consumerism with
several summary points.
(1) The response has been energetic -- but reactive.
(2) The response has touched on virtually all key
functional areas —- but it hasn’t generally led to drastic
overhauls of the underlying corporate culture. The machines
are being re-tooled but they’re basically the same old
engine.
(3) Long-established and not necessarily constructive
modes of communication are still being relied on to deliver
corporate environmental messages.
(4) In terms of product, green consumerism has caused
companies to dedicate significant resources to improving
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their product/packaging combinations. However, it has not
inspired those same companies to develop deep-green
products. We have greener products but we do not have, as it
were, “greenly-inspired products.”
Let me now close by suggesting some additional steps
that mainstream businesses might consider taking.
First, the majors might give thought to updating
habitual modes of communication so that they are more in
tune with the emerging myth of corporate identity that
permits statements of imperfection and that leaves room for
complexity. Such a strategy would increase credibility and
upgrade the overall quality of the dialogue.
Second, the majors might consider responding more pro-
actively to green consumerism. Conceptually, this would
involve abandoning the model of “business-as-machine-for-
responding-to—consumer—demand” and replacing it with the
model of “business-as-machine-for—shaping-consumer—demand.”
Specifically, this could involve such measures as the
development and marketing of deep-green products. I
understand that there are many compelling arguments against
doing so. Still, aggressive entry into the deep-green
products marketplace by one of the majors would signal
consumers and others that the environment is not only to be
upgraded in significance, but that it is to be treated as a
matter of the highest significance. Such a step would in
addition help to mobilize the millions of consumers who are
waiting for one of the majors to come forward with a loud,
no-bets-hedged declaration of environmental commitment.
Finally, it would also allow that same major to lay claim to
a true leadership position in the green marketplace of the
‘gOs —- and as several studies have shown, that leadership
position is a vacuum that is waiting to be filled.
Thank you.
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PUBLICATIONS ON GREEN CONSUMERISM BY CARL FRANKEL
ARTI CLES
Green Marketing: Leading the Eco-Pack -- Natural Foods
Merchandiser, April 1991
Thinking Like an Earthworm -- Buzzworm magazine, May/June
1991
When Myths Collide: Corporate Identity and the Emerging
Green Myth -- NAPEC Quarterly, June 1991
The Hot Pursuit of Irrelevancy —- Buzzworm magazine,
July/August 1991
BUSINESS STUDIES
The Green Consumer —- FIND/SVP (New York, NY), 1990
Businesses’ Response to Green Consumerism -- FIND/SVP (New
York, NY), 1990
OTHER PUBLICATIONS
Green MarketAlert —- a monthly newsletter tracking the
business impacts of green consumerism
345 Wood Creek Road, Bethlehem, CT 06751
Tel: 203/266-7209 Fax: 203/266-5049
The newsletter that analyzes the business impacts
green consumerism
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JSE4
LYNN ELSASSER
a’ THIRD PARTY CERTIFICATION
0
FILLING THE LABELING GAP
QUESTIONS & ANSWERS
What Is Green Seal?
Green Seal is a national, independent, nonprofit, environmental labeling and
educational organization. It issues environmental seals of approval to consumer
products that meet strict environmental standards. Green Seal has the support of a
broad cross section of the leaders of major national consumer and environmental
groups. The renowned Underwriters Laboratories Inc. is responsible for the majority of
Green Seal’s product testing and factory inspection.
Why was the Green Seal developed?
American consumers are looking for help in reducing their impacts on the Earth,
particularly through purchasing environmentally responsible goods. Green Seal was
developed to give consumers clear, expert advice about which products are less
harmful to the environment.
Green Seal offers unbiased environmental analyses to enable consumers to TM vote with
their walletsu for the Earth. When enough people choose products bearing the Green
Seal, manufacturers will increasingly alter their product lines to meet this consumer
demand for environmentally responsible products.
Who runs Green Seal?
Green Seal Is led by President and Chief Executive Officer Denis Hayes and
Executive Vice President and Chief Operating Officer Norman L. Dean. Author and
environmentalist, Hayes is best known as Executive Director of the first Earth Day in
1970 and as International Chairman of Earth Day 1990. A long-time environmental
researcher, manager, and attorney, Dean most recently served as Director of
Environmental Quality at the National Wildlife Federation.
Green Seal’s diverse and distinguished Board of Directors is composed of business-
people, public figures, and leaders of major national environmental, consumer, and
other public interest organizations.
How does Green Seal maintain Its Independence?
Green Seal is the only national, nonprofit, independent, environmental labeling
organization. It has no financial interest in the success or failure of any consumer
products. Its standards are developed in an open process with the active participation
of the public, and overseen by the Environmental Standards Council, composed of
noted scientists and other experts. Most product testing is conducted by Underwriters
Laboratories Inc., known for nearly a century for s reliability and independence.
Green Seal staff and board members must sign a detailed Code of Conduct that
prohibits financial conflicts of interest.
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2
Why do manufacturers want the Green Seal?
Independent research found that 4 out of 5 consumers are more likely to purchase a
product with the Green Seal when choosing between products of equal quality and
price. Also, in a Gallup survey conducted for Advertising Age, consumers said that
Green Seal would have more impact on their purchase decisions than government
guidelines.
Green Seal is the independent, authoritative, credible source for the environmental
product information that consumers seek. Products bearing the Green Seal will enjoy
a strong marketing advantage with the growing numbers of consumers concerned
about the environmental impacts of their purchases.
How will consumers learn about the Green Seal?
Television and print public service announcements will generate awareness and
educate consumers about the Green Seal. Green Seal’s educational campaign also
includes distribution of fact sheets, brochures, and outreach to the media.
In addition, Green Seal will publish a consumer-oriented description of the standard
for each product category, a list of certified products, and an explanation of the
environmental impacts reduced by using products bearing the Green Seal. These will
be widely distributed to retailers, businesses, and schools, among others.
Will products bearing the Green Seal be “Environmentally Friendly?”
No product is environmentally friendly. All consumer products have some impact on
the environment. Green Seal’s objective is to identify those products that are less
harmful to the environment than others in their category.
How does the labeling process work?
Environmental standards are set on a category-by-category basis. Industry and the
public are invited to suggest product categories for review. Once Green Seal selects a
category, an Environmental Impact Evaluation of the product is conducted. It identifies
the characteristics of the product and the points in the manufacturing process that
cause significant environmental harm. Based on this information, an environmental
standard is developed that focuses on those factors that provide significant
opportunities to reduce or eliminate pollution or other impacts on the Earth.
In some cases, advisory panels composed of representatives from business,
government, academia, and the public interest community may be formed to assist in
the development of specific standards.
The proposed standards are released for public comment. Manufacturers, trade
associations, environmental and consumer groups, government officials, and the
public are encouraged to comment on the proposal. After reviewing the comments,
Green Seal releases a final standard and notifies appropriate manufacturers.
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The Environmental Standards Council, composed of independent scientists,
academicians, and other experts, acts as an appeals board for manufacturers and
others who disagree with Green Seal’s technical judgments.
What environmental impacts do Green Seal’s standards address?
Green Seal’s standards seek to reduce significant environmental impacts of products.
Depending on the product, a Green Seal standard will address one or more of the
following impacts: toxic chemical pollution; energy consumption; depletion and
pollution of water resources; harm to fish, wildlife, and natural areas; waste of natural
resources; destruction of the Earth’s atmosphere (including its protective ozone layer);
and global warming.
Will the standards be revIsed?
Green Seal’s environmental standards are reviewed at least every three years.
Periodic review and revision ensures that criteria keep up with changing technologies
and consumer needs. The Green Seal process gives companies continuing
incentives and opportunities to improve products and benefit the Earth.
Does Green Seal evaluate companies as a whole?
Green Seal evaluates only the environmental impacts of specific consumer products,
not the environmental practices of companies as a whole. Green Seal does not
evaluate unrelated corporate behavior.
Who tests and certifies the products?
Underwriters Laboratories Inc. (UL) is Green Seal’s primary testing and factory
inspection contractor. For the majority of product categories, UL will test products to
determine whether they meet Green Seal’s environmental standards. UL will also be
responsible for conducting follow-up inspections at the manufacturer’s facility to
determine continued compliance with Green Seal standards. Where UL has
expertise, it will also assist Green Seal in the development of product standards.
in many cases, product testing may require a manufacturer to share sensitive or
confidential information. For almost a century, UL has handled such documents
responsibly and earned the confidence of industry.
What are the guidelines for use of the Green Seal?
When awarded the Green Seal, manufacturers may use it on the product, its
packaging, as well as in product specific advertising and promotional materials. A
company cannot, however, use the Green Seal for general corporate advertising.
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Do manufacturers pay a fee for the Green Seal?
Manufacturers pay a testing fee when they apply for the Green Seal. If the product
meets Green Seal’s standard, the company pays an annual fee for monitoring
continuing compliance. The fees reflect the actual costs to both Green Seal and UL for
time and materials. The amount will vary with the specific product category and the
manufacturing plant.
What if a product does not meet the Green Seal standard?
Should a product fail to meet Green Seal’s standard, the manufacturer will be
informed of the reasons, encouraged to make the changes necessary to meet the
standard, and to reapply for the Green Seal. Results of all tests are kept strictly
confidential.
How are manufacturers represented In the Green Seal process?
At present, business people, but not consumer products manufacturers, sit on Green
Seal’s Board. Manufacturers are represented on an Advisory Committee and are
strongly encouraged to get involved in the standard setting process by commenting on
proposed standards. Green Seal actively solicits comments from the business
community, among others.
How Is Green Seal funded?
Start-up costs for Green Seal are being provided by foundations and individual
donors. Eventually, Green Seal will be self-sustaining.
How can the public get Involved?
Green Seal’s process is open to the public. Individuals are invited to participate by
suggesting product categories and by commenting on proposed standards. Advice is
formally solicited from manufacturers, trade associations, environmental and
consumer organizations, government officials, and others.
In addition, Green Seal maintains a list of individuals who are interested in the
progress of the labeling program and in receiving educational materials. To be
included, individuals should write to Green Seal. Ultimately, of course, the most
important way for consumers to get involved is to buy and use products bearing the
Green Seal.
How can I contact Green Seal for more Information?
Call or write our Washington office: Suite 300-A, 1875 Connecticut Avenue, NW,
Washington, DC 20009-5818. Phone: 202-986-0520, Fax: 202-328-8087.
PrIn d on 10% rocyded poet.cov tnh1er w ie paper
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Green Seal
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Why Environmental Labeling?
• 4 out of 5 People Want to Buy “Green”
• Last Year, 10% of New Products Were “Green”
• $8.8 Billion in “Green” Sales by 1995
• Success of Environmental Guides and
Magazines
• Market is Flooded with Environmental Hype
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Green Seal Program
• Consumer Education
• Product Certification
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Consumer Education Programs
• Public Service Ads
• TV & radio
• Print
• USA Weekend Sunday Column
• 34 million readers
• Fact Sheets
• “How To” Brochures
• Point of Purchase Info
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What Consumers Believe
Please rate the following on how much impact they would have on
your purchasing decisions.
• Denis Hayes Green Seal
• No phosphate detergent label
o Federal Government Guidelines
• “Concentrated Laundry Detergent”
• Recycled Plastic Detergent Bottle Label
[ .. Recycled Plastic Detergent Bottle TV Ad
Graph shows those who answered “great impact”
Source: Gallup Poll, Advertising Age, 1/29/9 1
35%
30%
25%
20%
15%
10%
5%
0%
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Benefits to Manufacturers
• Independent, Third party certification
• Consumer education campaign
• Use of the Green Seal on product, its package,
and in advertising and promotion
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Environmental Goals
• Reduce toxics
• Improve energy efticiency
• Protect water quality & quantity
• Halt damage to natural areas
• Eliminate waste of resources
• Protect atmosphere
• Save fish & wildlife
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AN ALLIANCE FOR THE EARTH
1
Product Selection
& Study
r
2
Standard Setting
UI
Manufacturers
The Public
3
Product
Submission
4
Product Testing &
Factory Inspection
L 1Lj/
UI
5
Green Seal
Award
6
Monitoring for
Continued
Compliance
• ..
UI
Green Seal
0
Green Seal
Green Seal Manufacturers
Green Seal
THE GREEN SEAL ENVIROF4
NTAL LABELING PROCESS
-------
Proposed Standards Issued
• Toilet tissue
• Facial tissue
• Re-refined motor oil
-------
Categories Under Review
• Light Bulbs
• Stationery
• Copy Paper
• Coffee Filters
• Showerheads
• Aerators
• Toilets
• House paints
-------
How Green Seal is Different
• Open, public process
• Leadership includes environmental & consumer
leaders, and business people
• Multiple environmental criteria
• Financially Independent
• Non-profit
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ROBERT 3. MORGAN
THIRD PARTY CERTIFICATION — FILLING THE LABELING GAP
U.S. EPA CONFERENCE ON ENVIRONMENTAL
LABELING
OCTOBER 1-2, 1991
BALTIMORE, MD
OVERVIEW
OF
ASTM AND Co
MMITTEE D1O ON
PACKAGING’S
NEW
ACTIVITY:
ENVIRONMENTAL
LABELING
FOR
PACKAGING
AND PACKAGING
MATERIALS .
ROBERT J. MORGAN
DIRECTOR, TECHNICAL COMMITTEE OPERATIONS
DIVISION
As MANY OF YOU ARE AWARE, ASTM (THE AMERICAN
SOCIETY FOR TESTING AND MATERIALS) IS ONE OF
THE LARGEST VOLUNTARY STANDARDS DEVELOPMENT
SYSTEMS IN THE WORLD. ASTM’s MISSION IS TO
183
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DEVELOP VOLUNTARY FULL CONSENSUS STANDARDS
FOR PRODUCTS, MATERIALS, SYSTEMS, AND
SERVICES AS WELL AS TO PROMOTE RELATED
KNOWLEDGE.
ALTHOUGH ASTM HAS A STAFF OF OVER 200 IN
PHILADELPHIA, IT IS THE ASTM VOLUNTEER
MEMBERSHIP THAT MAKES ASTM WHAT IT IS.
ANYONE WITH AN INTEREST IN THE DEVELOPMENT
OF A PARTICULAR STANDARD IS WELCOME TO
PARTICIPATE IN THE STANDARDS DEVELOPMENT
PROCESS. CURRENTLY THERE ARE OVER 34,000
MEMBERS IN ASTM. 20,000 OF THESE SERVE ON
STANDARDS WRITING TECHNICAL COMMITTEES.
THEY REPRESENT INDUSTRY, GOVERNMENT,
ACADEMIA, REGULATORY AGENCIES, TESTING
LABORATORIES, CONSUMERS, AND ENVIRONMENTAL
184
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ORGANIZATIONS. ASTM STANDARDS ARE DEVELOPED
VOLUNTARILY AND USED VOLUNTARILY. THEY
BECOME MANDATORY ONLY WHEN ADOPTED OR
REFERENCED BY A GOVERNMENT AGENCY OR USED IN
CONTRACTUAL AGREEMENTS.
ASTM HAS 134 STANDARDS WRITING TECHNICAL
COMMITTEES. ASTM TECHNICAL COMMITTEE
STRUCTURE IS MADE UP OF MAIN COMMITTEES,
SUBCOMMITTEES, AND TASK GROUPS. THESE
TECHNICAL COMMITTEES DEVELOP STANDARDS IN
SUBJECT AREAS RANGING FROM MATERIALS , SUCH
AS PAINT, STEEL, CONCRETE, PETROLEUM,
PLASTICS; ENVIRONMENTAL CONCERNS , SUCH AS
WASTE MANAGEMENT, ANALYSIS OF ATMOSPHERES,
WATER, RECYCLING AND DEGRADABILITY OF
VARIOUS PRODUCTS, AS WELL AS SERVICES AREAS
185
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SUCH AS HEALTH CARE SERVICES, EMERGENCY
MEDICAL SERVICES, SEARCH AND RESCUE, ETC..
THE LIST OF TECHNICAL COMMITTEES IS TOO
NUMEROUS TO MENTION.
ASTM CURRENTLY PUBLISHES 8500 STANDARDS IN
A 68 VOLUME ANNUAL BOOK OF ASTM STANDARDS .
THE WORD “STANDARD” IS USED
DOCUMENT THAT HAS PASSED
RIGOROUS ASTM CONSENSUS DUE
FOLLOWING THE REGULATIONS
TECHNICAL
TO IDENTIFY A
THROUGH THE
PROCESS SYSTEM
GOVERNING ASTM
COMMITTEES . ASTM IS NOT AN
ACCREDITING AGENCY; HOWEVER, MANY AGENCIES
USE ASTM STANDARDS IN THEIR CERTIFYING AND
ACCREDITING PROCESSES.
As I
MENTIONED
EARLIER,
ASTM
HAS 134
186
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TECHNICAL COMMITTEES, ONE OF WHICH IS
COMMITTEE D1O ON PACKAGING. D1O STARTED ITS
STANDARDS DEVELOPMENT ACTIVITY 77 YEARS AGO
AND HAS DEVELOPED STANDARDS RELATING TO
VARIOUS AREAS OF PACKAGING INCLUDING PAPER
AND PAPERBOARD PRODUCTS, LABELING, CHILD
RESISTANT PACKAGING, AND CONSUMER PACKAGES.
LAST YEAR COMMITTEE D1O DISCUSSED THE NEED
FOR ENVIRONMENTAL LABELING STANDARDS. ASTM
WAS ALSO CONTACTED BY THE COUNCIL OF
PLASTICS AND PACKAGING IN THE ENVIRONMENT
(COPPE), AND OTHER ORGANIZATIONS AND
COMPANIES, TO EXPLORE THE ESTABLISHMENT OF
A NEW ACTIVITY IN THIS AREA. IT WAS
SUGGESTED THAT STANDARDS WOULD BE BENEFICIAL
FOR ENVIRONMENTAL LABELING, WHICH PROVIDE
187
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CONSUMER
CRITERIA,
IMPORTANT
INTERNATI
LABELING,
THROUGH A
INFORMATION EXPLAINING CHOICES,
PACKAGING FUNCTIONS, ETC.. IT IS
TO DEVELOP NATIONAL AND
ONAL STANDARDS FOR ENVIRONMENTAL
AND IT IS BENEFICIAL TO DO THIS
CREDIBLE CONSENSUS ORGANIZATION.
AFTER ASTM RECEIVED THIS REQUEST, THE
ORGANIZATIONAL PROCESS BEGAN. ASTM STAFF
CONTACTED INDIVIDUALS, COMPANIES, AND
ORGANIZATIONS INVOLVED IN THE FIELD TO
ASSESS THE LEVEL OF INTEREST AND THE NEED
FOR THE PROPOSED ACTIVITY. SINCE THE
RESPONSE OF THIS PARTICULAR ACTIVITY WAS
POSITIVE, ASTM CALLED A PLANNING MEETING IN
APRIL IN CONJUNCTION WITH THE COMMITTEE D1O
MEETING IN COLUMBUS, OHIO.
188
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THERE WERE 75 INDIVIDUALS AT THE PLANNING
MEETING WHO UNANIMOUSLY AGREED TO PROCEED
WITH THIS STANDARDIZATION EFFORT UNDER THE
AUSPICES OF ASTM.
THE PARTICIPANTS DISCUSSED AN APPROPRIATE
TITLE FOR THIS ACTIVITY AND AGREED 0N
“ENVIRONMENTAL LABELING FOR PACKAGING
AND PACKAGING MATERIALS”
IN JULY, TWO AD HOC WORKING GROUPS MET TO
ADDRESS TERMINOLOGY AND A SCOPE STATEMENT.
THE AD HOC WORKING GROUP ON SCOPE
DEVELOPMENT PROPOSED THE FOLLOWING SCOPE AND
ACTIVITIES OF THE GROUP:
189
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“THE PROMOTION OF KNOWLEDGE AND THE
DEVELOPMENT OF STANDARDS (TEST METHODS,
SPECIFICATIONS, PRACTICES, GUIDES,
CLASSIFICATIONS, AND TERMINOLOGY) FOR
LABELING OF PACKAGING WHICH RESPONSIBLY
COMMUNICATES ENVIRONMENTAL ATTRIBUTES TO
THE CONSUMER. THIS WILL INCLUDE
CONSIDERATION OF THE DISPOSABILITY AND
RESOURCE ASPECTS OF THE PRODUCTION AND
USE OF THE PACKAGING.”
THE WORK OF THIS GROUP WILL BE
COORDINATED WITH OTHER ASTM COMMITTEES
AND OUTSIDE ORGANIZATIONS HAVING RELATED
INTERESTS.
PROPOSED ACTIVITIES OF THIS GROUP MAY
INCLUDE:
190
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- DEVELOPING TERMS AND DEFINITIONS
- DEVELOPING STANDARDS TO BE UTILIZED TO
SUPPORT LABEL CLAIMS
- CLARIFYING THE USE AND APPLICATION OF
LIFE CYCLE ANALYSIS IN
THE PROCESS
- EXPLORING THE USE AND APPLICATION OF
ENVIRONMENTAL EMBLEMS/SYMBOLS
THE AD HOC WORKING GROUP ON TERMINOLOGY
DETERMINED THE INITIAL FOCUS ON THE GROUP
AND SET PRIORITIES.
IT WAS THE CONSENSUS OF THE
STANDARD BE DEVELOPED ON
LABELING AND THAT THE STANDARD
AND DEFINITIONS PERTAINING TO
GROUP THAT A
ENVIRONMENTAL
INCLUDE TERMS
ENVIRONMENTAL
191
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LABELING FOR PACKAGING AND PACKAGING
MATERIALS
THE GROUP DISCUSSED TERMS THAT NEED TO BE
DEFINED AND AGREED ON 13 TERMS THAT ARE THE
GROUP’S INITIAL PRIORITY. THESE TERMS ARE:
SOURCE REDUCTION, RECYCLABLE, REFILLABLE,
REUSABLE, RECYCLED, POST CONSUMER MATERIAL,
RECYCLED CONTENT, COMPACTION RATIO, PRE-
CONSUMER, RETURNABLE, BIODEGRADABLE,
DEGRADABLE, AND COMPOSTABLE. THE GROUP ALSO
DEFINED SEVEN OF THESE TERMS AT ITS MEETING.
AT THE NEXT ORGANIZATIONAL MEETING WHICH IS
BEING HELD SEPTEMBER 29-OCTOBER 3 IN
CONJUNCTION WITH THE COMMITTEE D1O MEETING,
THE PARTICIPANTS WILL REVIEW THE TITLE,
192
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SCOPE, TERMINOLOGY, AND DIRECTION OF THE
COMMITTEE. THE PARTICIPANTS WILL VOTE ON
ACCEPTING THE TITLE AND SCOPE AS WELL AS
MODIFYING SOME OF THE TERMINOLOGY. THE
PARTICIPANTS WILL ALSO IDENTIFY SPECIFIC
AREAS FROM THE LIST OF PROPOSED ACTIVITIES,
AND THEY WILL FORM LOGICAL WORKING GROUPS SO
THEY CAN ADDRESS EACH AREA IN DETAIL.
ALTHOUGH THIS NEW ASTtI VOLUNTARY STANDARDS
DEVELOPMENT ACTIVITY ON ENVIRONMENTAL
LABELING FOR PACKAGING AND PACKAGING
MATERIALS IS IN ITS ORGANIZATIONAL STAGE,
MUCH PROGRESS HAS BEEN MADE TO DATE. I
WOULD LIKE TO INVITE YOU OR AN INTERESTED
PARTY THAT YOU KNOW TO PARTICIPATE BECAUSE
IT IS THE MEMBERS WHO DEVELOP THE FULL
193
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VOLUNTARY CONSENSUS STANDARDS IN ASTM!
3 94
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ATTENDEES, SPEAKERS AND FACILITATORS
Georgianna Allsopp Kevin Bank
Federal Trade Commission Federal Trade Commission
Washington DC Washington DC
Liz Barrett Denina Bautti.
Mary Kay Cosmetics PA House of Representatives
Dallas TX Harrisburg PA
Steven Becker Dr. Stanley Becker
Bryn Mawr College Springfield PA
Broomall PA
Ruth Becker Daniel Blank
PA Resources Council U.S. EPA
Media PA Washington DC
Dana 1. Blanton Cathy F. Bowen
American Paper Institute Penn State University
Washington DC University Park PA
Ginger Bucher Mark D. Burd
City of York County of Butler
York PA Butler PA
Marjorie 3. Clarke Irene S. Cohrs-Johnsofl
City University of New York Passaic County Planning Board
New York NY Paterson NJ
Steve Connolley Carolyn Cox
PA Resources Council Federal Trade Commission
Media PA Washington DC
Brenda Cude John J. Culligan
University of Illinois L & F Products
Urbana IL Montvale NJ
Sherri. Curley Rosemary Dashi.ell-Young
U.S. EPA, Region III The Coca-Cola Company
Philadelphia PA Atlanta GA
Robert Dellinger Richard Denison
U.S. EPA Env. Defense Fund
Washington DC Washington DC
Roy E. Denmark, Jr. Michael Dershowitz
U.S. EPA, Region iii Federal Trade Commission
Philadelphia PA Washington DC
William 3. Dixon Janice M. Donlori
U.S. EPA, Region III U.S. EPA, Region III
Philadelphia PA Philadelphia PA
Jim A. Dotson Tim Draeger
Mobay Corporation Degradable Plastics Council
New Tripoli PA St. Louis MO
Pamela Driver Cindy Drucker
Foodservice & Packaging Inst. Webster Industries
Washington, DC Peabody MA
195
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Andrew Duchornay Dana Duxbury
U.S. EPA, Region III Dana Duxbury & Associates
Philadelphia PA Andover MA
Manfred Eihoff Mark Eisen
RAL Deutsches Institut The Home Depot
Germany Atlanta GA
Lynn Elsasser Ric Erdheim
Green Seal, Inc. Office of Sen. Lautenberg
Washington DC Washington DC
Edwin B. Erickson Deborah L. Eschenbacher
U.S. EPA, Region III Indianapolis Clean City Comm.
Philadelphia PA Indianapolis IN
Matthew D. Ewadinger Kathryn Fahnline
GBB Federal Trade Commission
Mechanicsburg PA Washington DC
Dr. Kenneth Falci Jean M. Frane
US Food & Drug Administration U.S. EPA
Washington DC Washington DC
Carl Frankel Dan Frantz
Green Market Alert PA Resources Council
Bethlehem CT Media PA
Douglas Gibboney Lena Gill
Pennsylvania Glass Recycling The Scientific Consulting Group
Harrisburg PA Rockville MD
Sheryl Gillilan Joan Goodis
SCC Corporation U.S. EPA, Region III
Salt Lake City UT Philadelphia PA
Alison B. Graham Margaret N. Gray
PA Resources Council Killian & Gephart
Media PA Harrisburg PA
Naomi Greer Dennis Griesing
Aseptic Packaging Council Soap and Detergent Association
Washington DC New York NY
Maureen Hall Greg Harder
PA Resources Council PA Dept. of Env. Protection
Media PA Harrisburg PA
Graham C. Hardman Patrick Hayes
Environmental Choice Prog. Procter & Gamble
Canada Cincinnati OH
Dirk Hewindt Diane Hicks
Colgate Palmolive Co U.S. EPA
New York NY Washington DC
Thomas B. Hilton Joel Hirschhorn
Drackett Company Hirschhorn & Associates
Cincinnati OH Washington DC
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Jeanne H. Hogarth Hannah Holmes
Cornell Cooperative Extension Garbage Magazine
Ithaca NY Portland ME
Hon. Hubert Humphrey Patricia Imperato
State of Minnesota PA Resources Council
St. Paul MN Media PA
Linda M. Ingrain Carol Johnson
PA Bureau of State Parks National Polystyrene Recycling Co
Reading PA Washington DC
John Kamp Richard J. Kampf
Amer. Assn. of Ad Agencies U.S. EPA, Region III
Washington DC Philadelphia PA
Richard Kashmanian Richard Keller
U.S. EPA Northeast MD Waste Disposal Auth.
Washington DC Baltimore MD
Marcia Kelley Hollister Knowlton
LWV of the Richmond Metro. Area PA Environmental Council
Richmond VA Philadelphia PA
Donna Kotsch David Labovitz
U.S. EPA, Region III Ashdun Industries, Inc.
Philadelphia PA Marblehead MA
Pat Lane Jay Layman
League of Women Voters of Maryland Killian & Gephart
Baltimore MD Harrisburg PA
Lisa A. Levenberg Bob Levering
Cosmetic, Toiletry & Frag. Assn. Direct Marketing Association
Washington DC Washington DC
Andrea Levine Catherine A. Libertz
NY Attorney General’s Office U.S. EPA, Region III
New York NY Philadelphia PA
Nancy Lilienthal Virginia Lipscomb
INFORM, inc. Maryland Dept. of Environment
New York NY Baltimore MD
Evelyn MacKnight William MacLeod
U.S. EPA U.S. EPA
Washington DC Washington DC
Joel Makower Theresa Martella
Tilden Press, Inc. U.S. EPA, Region III
Washington DC Philadelphia PA
D. Craig Martin Peter G. Mayberry
E. Bruce Harrison Co. INDA, Assn. of Nonwovens Fabric
New York NY Washington DC
Jim McCabe John MeCaul].
The Clorox Company Californians Against Waste
Pleasanton CA Sacramento CA
I 07
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Virginia McCoy Soonya W. McDavid
National Soft Drink Association National Paints & Coatings Assn.
Washington DC Washington DC
Mike McGrath Robert 3. McManus, Esq.
Edison Electric Institute Baker & Hostetler
Washington DC Washington DC
Lennie Medcalf Robyn Meeker
Faultless Starch/Bon Ami Co. U.S. EPA
Kansas City MI Seattle WA
William Miller, CAE Robin Mitchell
Mid-Atlantic Food Dealers Assn. U.S. EPA, Region IV
Baltimore MD Atlanta GA
Tim Mohin Robert.Morgan
U.S. EPA ASTM
Research Triangle Park NC Philadelphia PA
R. Steve Morrow Nancy Moucha
The Coca—Cola Company Dorf & Stanton Communications
Atlanta GA New York NY
Ginny Nelson-Wulf Janet Fox Neltner
REACH Indiana Recycling Coalition
Lincolnshire IL Indianapolis IN
Linda Norris Leslie Noss
Frederick Co. Recycling Office City of York
Frederick MD York PA
June M. Nylin Elizabeth Olenbush
Fingerhut Corporation Steel Can Recycling Institute
Minnetonka MN Pittsburgh PA
Gregory Ondich Richard H. Parry
U.S. EPA DowBrands
Washington DC Indianapolis IN
Sherri Passick Kate M. Perry
L & F Products U.S. EPA
Montvale NJ Washington DC
Jenny Peters Judith Peters
SAIC Eastman Kodak
Falls Church VA Washington DC
Lars E. Peterson Herman R. Phillips, Jr.
Food Marketing Institute U.S. EPA
Washington DC New York NY
Tammy Posten Eddie Powers
Flexible Packaging Association K—Mart
Washington DC Troy MI
Dr. J.B. Pratt Sandie Preiss
Pratt Foods Sweetheart Cup
Shawnee OK Owings Mills MD
1 flO
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Richard Pritzlaff Ann Rapoport
Arnold MD PA Resources Council
Media PA
Mara Rastovsky Tom Rattray
Colgate—Palmolive Proctor & Gamble
New York NY Cincinnati OH
Michael Reilly Stanley P. Rhodes, Ph.D.
Wakefern Food Corporation Green Cross Cert. Co.
Elizabeth NJ Oakland CA
Elizabeth L. Rich Patrick Rita
PA Resources Council Stateside Associates
Media PA Arlington VA
Allen Rosenfeld Dr. Alexander Ross
Public Voice for Food & Health U.S. EPA
Washington DC Washington DC
Carole Rubley Myles Salmon
ERM,Inc. Leavenworth KS
Exton PA
James Salzmari Keith Scarborough
OECD Assn of National Advertisers
France Washington DC
John Schall Sharon A. Schiliro
Tellus Institute National Wildlife Federation
Boston MA Vienna VA
Susan Schueler Lori Scozzafava
Maryland Environmental Services MD Dept of Environment
Annapolis MD Baltimore MD
Howard Seltzer Susanne Shank
U.S. Office of Consumer Affairs Franklin Associates, Ltd.
Washington DC McLean VA
Rep. Byron Sher Carol Singer
California State Assembly U.S. EPA
Sacramento CA Washington DC
Lillian B. Smith Ronald Smithies
U.S. EPA, Region iii Better Business Bureaus Inc.
Philadelphia PA New York NY
Sharon Stahl Janet Steiger
U.S. EPA Federal Trade Commission
Washington DC Washington DC
Melinda Sweet H.E. Swift
Lever Brothers Company Procter & Gamble Company
New York NY Cincinnati OH
Michael Taylor Theresa M. Termine
Maryland Environmental Services Can Manufacturers Institute
Annapolis MD Washington DC
1 00
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Bryan N. Thomlison Janet E. Tosi
Church & Dwight Co. , Inc. Hill and Knowlton, Inc.
Princeton NJ Waltham MA
Cheryl Tumola Lorraine Urbiet
LWV of Pennsylvania U.S. EPA, Region III
Wayne PA Philadelphia PA
Andrew R. Uricheck Cynthia Valena
U.S. EPA, Region III Painesville OH
Philadelphia PA
Thomas Voltaggio Debra Wagner
U.S. EPA, Region III Maryland Environmental Services
Philadelphia PA Annapolis lID
Kathryn D. Wagner Richard Webster
Pew Charitable Trusts State Advert.sing Coalition
Philadelphia PA Washington DC
Carol Weisner Donald S. Welsh
U.S. EPA U.S. EPA, Region III
Washington DC Philadelphia PA
Christine Wendy Frances Werner
Helene Curtis, Inc. Monsanto Company
Chicago IL St. Louis MO
James B. White Roberta F. Wiernik
U.S. EPA LWV of New Castle
Research Triangle Park NC Chappaqua NY
Ann Wilcox Julie Winters
MASS PIRG U.S. EPA
Boston MA Washington DC
Lynda Wynn Sandra Young
U.S. EPA U.S. EPA
Washington DC Washington DC
Arthur Zadrozny
ARCO Chemical Co.
Newtown Square PA
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