Toy Association Submits Comments on FTC ‘Green Guides’

April 25, 2023 | The Toy Association submitted comments on April 24 on the Federal Trade Commission's (FTC) “Green Guides,” which are currently under review and will be soon be updated by the agency. Toy manufacturers that label or market toys, games, or other products as environmentally friendly may be impacted by changes to these guides.

“The Toy Association believes there is an ongoing need for the Green Guides to help achieve transparency, consistency, and ultimately increased consumer confidence when choosing from the growing volume of products marketed as environmentally friendly,” said Jennifer Gibbons, senior vice president of government affairs at The Toy Association. “We look forward to participating in this review process to develop guidance that creates predictability and consistency in the marketplace without limiting companies’ abilities to communicate environmental initiatives in nondeceptive ways.”

In its comments, the Association encouraged the FTC to provide guidance to help companies comply with the guides and navigate any changes, such as providing resources like webinars or one-on-one consultations. The Toy Association also suggested incorporating QR codes or digital IDs on product packaging for consumers to access more detailed information about the product’s sustainability at the point of sale.

Now that the comment period is closed, the FTC will take a fresh look at its Green Guides and analyze the continued need for them, their economic impact, their interaction with other environmental regulations, and how they relate to consumer perception of “green” claims. The agency is also looking for guidance on carbon offset and renewable energy claims and defining terms such as “recyclable,” “recycled content,” “compostable,” “sustainable,” and more.

The Green Guides were created to help marketers avoid 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 first issued in 1992 and were revised in 1996, 1998, and, most recently, in 2012.

Members may reach out to The Toy Association’s Jennifer Gibbons with any questions on this topic.