FTC releases proposed "Green Guides" revisions

Last month, the Federal Trade Commission (FTC) released the long-anticipated proposed revisions to its Guides for the Use of Environmental Marketing Claims—the so-called "Green Guides." These proposed revisions aim to respond to changes in the marketplace and to address the proliferation of environmental claims in all types of marketing by providing guidance on the types of claims the Commission would consider unfair or deceptive in violation of Section 5 of the FTC Act, 15 U.S.C. § 45. Although the Guides will not be finalized before next year, they are of immediate relevance in that they provide a glimpse into the Commission's current thinking on environmental marketing claims and potential related enforcement actions.

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