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May 22, 2023: Call to Action: Include Textile Reuse and Recycling in FTC Recycling Conversation
We applaud the Federal Trade Commission (FTC) for commencing a comprehensive review of the Green Guides which have been a valuable resource for brands, marketers, retailers, and consumers since they were first introduced over 30 years ago. As you focus on the topic of recycling, we urge you to include textiles reuse and recycling in this discussion.
Much has changed in technology, consumer awareness, and interest since the Guides were updated in 2012. Recycling has become more prevalent throughout the US, but there is growing confusion about textiles which, among other items, include footwear, apparel and accessories. Unlike most other household recyclables, textiles can be reused, repaired in addition to recycled. But there are questions surrounding what textiles should be reused, repaired or recycled, if they are actually recyclable, and how to recycle them. Addressing these issues are critical and timely.
The US’s own Environmental Protection Agency (EPA) estimates that the average American throws away 70 pounds of clothing and other textiles every year. With only an estimated 15% being reused or downcycled, less than 1% of that is actually recycled, and 85% finds its way to landfills where much of it does not degrade.
Recycling clothes at their end of life is a challenge because footwear, accessories and apparel often contain a mix of synthetic and organic fibers, which require different recycling methods. Additionally, there is a confusion around distinguishing between the terms reuse and recycling, as well as how pre- and post- consumer recycling are handled, and how they are marketed. The good news is that consumers, brands, non-profits and states are increasingly concerned and are seeking solutions. Individuals are looking for ways to reuse and then recycle items, after they are past the point of repair; brands are facilitating take-back programs; for profit and non-profit enterprises are collecting and sorting items; and states are considering and adopting various regimes for addressing textile waste. The economic and job opportunity for increased textile recycling in the U.S. is meaningful: a recent study from Global Market Insights projects the textile recycling market valuation to surpass $8.5 billion by 2033, and thredUP predicts the global resale market will reach $350 billion by 2027.
However, as these entities work to weave together a comprehensive solution, it is important that the marketing of these approaches be in-line with the FTC’s expressed intent of the Green Guides: to “explain how reasonable consumers likely interpret each such claim, describe the basic elements necessary to substantiate it, and present options for qualifying it to avoid deception.”
The December 14th 2022 published Notice on soliciting comments on the Green Guides expressly stated a focus on recycling. Many of the comments submitted did provide insights and suggestions on the broad topic of recycling and also weighed-in on textile recycling specifically. We appreciate the FTC is holding a workshop focusing on recycling on May 23rd, but to not include textiles in this conversation with stakeholders and advocates is a missed opportunity.
We encourage the FTC to provide an additional workshop focused on textiles to appropriately acknowledge this pressing reuse and recycling topic.
It is imperative that textiles be part of your approach to considering recycling. We hope you will focus on textiles in future events. We look forward to a robust debate and discussion amongst all stakeholders - brands, advocacy organizations, scientific and policy experts, and consumers- and we stand ready to work with you in these endeavors.
Sincerely,
Amendi * America’s Best Cleaners (ABC) * American Circular Textiles (ACT) * American Apparel and Footwear Association (AAFA)
Arrive Recommerce, Inc * Collective Fashion Justice * Custom Collaborative * Debrand * Everlane * Fashionphile * Jewelers Vigilance Committee * Mara Hoffman
New Standards Institute * Onward LLC * Recurate * Reformation * Scrap NYC * Sortile * Supercircle * Sustainable Brooklyn * The Fashion Connection * thredUP * Upwest
May 6, 2021
Federal Trade Commission
600 Pennsylvania Avenue, NW
Washington, DC 20580
Telephone: (202) 326-2222
Dear Commissioners:
The Federal Trade Commission (FTC)’s Green Guides have been a valuable resource for brands, marketers, retailers, and consumers since they were first issued in 1996. These Guides, “outline general principles that apply to all environmental marketing claims and provide guidance regarding many specific environmental benefit claims…[and]…explain how reasonable consumers likely interpret each such claim, describe the basic elements necessary to substantiate it, and present options for qualifying it to avoid deception.”[1] For businesses, they provide practical advice and examples on how to accurately and responsibly make environmental claims on products without being deceptive. There is also benefit for consumers who increasingly want to align their values with their shopping behavior. However, the Guides have not been updated since 2012. We write to urge the FTC to undertake a comprehensive review of the Green Guides.
Much has changed in technology and consumer awareness in these past nine years since the updated Guides were released in 2012. Due to the rise in the use of smartphones to access websites and utilize QR codes when shopping in brick and mortar stores, and a pandemic-fueled increase in online shopping, consumers are accustomed to looking for detailed information on the environmental claims made by the brands they are shopping. The information consumers seek must be truthful, reasonable, and useful to the average consumer.
In addition to a review of the existing guidance, consideration should be given to examining the use of words such as “sustainability” and “organic” in marketing claims. When the Guides were last reviewed in 2012, the FTC decided not to act in these areas. In the past nine years, there has been an exponential growth in sustainability claims by businesses. But, without guardrails on this term, or data to substantiate these claims, there is risk the term becomes meaningless, or even detrimental to efforts to promote healthy environmental practices.
The United States is not alone in promulgating rules on fair and safe environmental claims. In the UK, the Advertising Standards Authority (ASA) is tasked with ensuring advertisers do not engage in “greenwashing”, or making unsubstantiated or broad environmental claims. And the European Union is advancing the Sustainable Products Initiative which seeks to improve customer communication on sustainability through mandated labeling and other practices.
We do not presuppose the outcome of an FTC review. We look forward to a robust debate and discussion amongst all stakeholders - brands, advocacy organizations, scientific and policy experts, and importantly, consumers.
With a new Administration and Congress, the time is right for the FTC to undertake a comprehensive review of the Green Guides with the full participation of businesses and consumers.
We, the undersigned, stand ready to work with you on this timely and critical undertaking.
Sincerely,
Amendi * ASKET * TIDAL * Reformation * Jewelers Vigilance Committee * The Conservatory, Founder, Brian Bolke * Mimi Prober * Wearable Collections * Secteur 6, Amit Hooda, Co-founder and CEO * Senza Tempo Fashion, Kristen Fanarakis, Founder * Hudson Hemp/Our Treaty * Thousand Fell * The New Standard Institute * The OR Foundation * Fashion Revolution, Founder, Orsola de
Castro * Conscious Fashion Campaign * PoliticallyInFashion* Circular Services Group * Sustainable Brooklyn * Fashion Mingle * The Center for the Advancement of Garment Making, Founder, Caroline Priebe * Fashion Engineering LLC * Swap Society * Chicago Fair Trade * The co-lab * New York University Stern School of Business Social Impact and Sustainability
Association (SISA) * Elizabeth Cline, Journalist and Author * Dana Thomas, Journalist and Author * Liz Segran, Journalist and Author * Nick Wooster, Fashion Consultant * Thomasine Dolan Dow, Independent Sustainability Consultant * Flora Gil, Design Consultant * Tabea Soriano, Sustainability and
Strategy Consultant * Malinda Salter, Salter Textile Consulting * Garik Himebaugh, Founder, Eco-Stylist.com * Haley Lieberman, CEO and Founder, Shop Tomorrows * Eleanor Turner, Founder, The Big Favorite * Aditi Mayer, Journalist and Activist
[1] https://www.ftc.gov/sites/default/files/attachments/press-releases/ftc-issuesrevisedgreenguides/greenguidesstatement.pdf
July 16, 2021
PoliticallyInFashion and Amendi Applaud the Federal Trade Commission’s
Announcement to Review the Green Guides.
In May 2021, PoliticallyInFashionand Amendi led a coalition letter to the Federal Trade Commission (FTC) urging them to undertake a comprehensive review of the Green Guides. They were joined by over 40 signers representing outstanding fashion brands, thought leaders and advocacy groups. The Green Guides outline general principles for making environmental marketing claims and how reasonable consumers are likely to interpret these claims. The FTC has just announced they will undertake a review in 2022.
“The Green Guides have been a valuable resource for brands, marketers, retailers, and consumers since they were first issued in 1992 but they have not been updated since 2012,” said Hilary Jochmans, Founder of PoliticallyInFashion, a community for everyone in fashion to engage in legislative and regulatory issues critical to the industry. “Much has changed in technology and consumer awareness in these past nine years since the Guides were revised. With a new Administration and Congress, the time is right for the FTC to undergo a review of this critical document.”
“We believe that regulation is key to catalyzing real change in the fashion industry.” said Corey Page Spencer, co-founder of AMENDI: a Swedish-American brand that creates traceable and transparent denimwear from certified organic and deadstock materials. “When we joined PoliticallyInFashion in the pursuit to have the Green Guides updated it spoke to exactly who we are as a brand, and what we believe the future of fashion will become: responsible to the earth and humane to people.”
Consumers increasingly want to align their values with their shopping behavior. Companies who are proud of their efforts to operate in an environmentally responsible manner want to be able to promote their endeavors. But, these statements must be truthful, reasonable, and useful to the average consumer.
The signers of the letter stand ready to work with the FTC and look forward to a robust debate and discussion amongst all stakeholders – brands, advocacy organizations, scientific and policy experts, and importantly, consumers.
“As countries around the globe promulgate regulations to prevent greenwashing and promote accurate and transparent environmental claims, we urge the FTC to encourage full participation of businesses and consumers in the US to develop regulations that will be the global gold standard” said Jochmans and Spencer.
More information on the Green Guides, including the letter to the FTC, can be found at: https://politicallyinfashion.com
A link to the FTC’s announcement be found at: https://www.federalregister.gov/documents/2021/07/02/2021-13724/regulatory-review-schedule
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Contact: Hilary F. Jochmans
Hilary@PoliticallyInFashion.com
@PoliticallyInFashion
Contact: Corey Page Spencer
@amendiofficial
They are a resource to help businesses avoid making deceptive environmental claims. The Guides were originally created in 1992 by the Federal Trade Commission (FTC), an agency empowered by federal law to prohibit unfair or deceptive acts in business. They are to assist businesses in making lawful environmental marketing claims and the public in understanding and appreciating these statements. The FTC can bring an enforcement action if they see an environmental claim that is inconsistent with the Guides, unfair and deceptive.
These Guides apply to marketers, manufacturers, auditors, wholesale and retail sellers and is particularly impactful to the fashion industry and are for the benefit of all consumers.
Consumers increasingly want to align their values with their shopping behavior. Companies who are proud of their efforts to operate in an environmentally responsible manner want to be able to promote their endeavors. But, these statements must be truthful, reasonable, and useful to the average consumer. The Green Guides outline a dozen common environmental claims with examples of permissible statements.
*General Environmental Benefit Claims *Carbon Offsets *Certification and Seals of Approval *Compostable *Degradable *Free of Claims *Non-toxic claims *Ozone Safe and Ozone Friendly *Recyclable *Recycled Content *Renewable Energy Claims *Renewable Materials Claims
Benefit Claims:
§ Marketers should not make broad, unqualified general environmental benefit claims like "green" or "eco-friendly." Broad claims are difficult to substantiate, if not impossible.
Recyclable:
§ Marketers should qualify recyclable claims when recycling facilities are not available to at least 60 percent of the consumers or communities where a product is sold.
Sustainability Claims
Organic/Natural Claims
The Green Guides have not been updated since 2012. Much has changed in technology and consumer awareness in these past 9 years. With a new Administration and Congress, the time is right for the FTC to undergo a review of this critical document.
Contact Hilary@PoliticallyInFashion.com to learn more.
Businesses should review The Green Guides to see how they work for their companies. Where do they see need for improvement? Should the FTC look at Sustainability, Organic and Natural environmental claims? Has consumer understanding changed perception of claims? Could technology be utilized more effectively to substantiate environmental claims? The industry needs to tell their elected officials what works for their business and their customers. We are here to help you.
PoliticallyInFashion, along with UpWest and ACT, lead 'Call to Action' to the FTC urging the inclusion of textiles, footwear and accessories in recycling conversation as part of the review of the Green Guides!