Toy Association Addresses Members’ Priorities in Latest Comments on FTC's “Green Guides”

June 14, 2023 | The Toy Association™ submitted comments that address members’ priorities related to the Federal Trade Commission's (FTC) "Green Guides," which are currently under review by the agency. As previously reported, The Toy Association gathered feedback from members regarding the use of the term “recyclable” in advertising claims. Toy manufacturers that label or market toys, games, or other products as environmentally friendly may be impacted by changes to the guidelines.

In its feedback, The Toy Association asked for regulatory requirements to come at a reasonable cost to companies and for the FTC to not adopt overly prescriptive recommendations that would make it impossible or difficult for companies to advertise the environmental attributes of their products. The comments underscored that businesses will also have to comply with state and local environmental and consumer-deception requirements in addition to those outlined in the federal Green Guides.

Previously, The Toy Association submitted comments to the FTC expressing a need for agency guidance to help companies comply with the guides and suggested incorporating QR codes on product packaging for consumers to access information about a product’s sustainability at the point of sale.

The request for the latest round of public comments came in conjunction with a public FTC workshop, which took place May 23. The session brought together a range of experts to analyze the term “recyclable” and address the current state of recycling practices and recycling-related advertising in the U.S., consumer perception of current and emerging recycling-related claims, and any additional updates or changes needed to the Green Guides related to recycling claims.

First issued in 1992, the Green Guides were created to prevent marketers from making environmental marketing claims that are deceptive to consumers; the FTC seeks to update the guides based on increasing consumer interest in buying such products. The Green Guides were revised in 1996, 1998, and, most recently, in 2012.

For more information on The Toy Association’s advocacy initiatives related to environmental issues or to join the Environmental Sustainability Committee, contact The Toy Association’s Jennifer Gibbons.