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

May 23, 2023 | The Toy Association™ is preparing to submit comments that address members’ priorities related to the Federal Trade Commission's (FTC) "Green Guides," which are currently under review by the agency. This specific set of comments will address 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 and are encouraged to contact The Toy Association by June 10 so that their concerns can be included in the Association’s comments. Feedback may be sent directly to Jennifer Gibbons, senior vice president of government affairs at The Toy Association.

On behalf of members’ interests, The Toy Association has previously submitted comments expressing the significant undue cost the guides have imposed on businesses to make modifications, especially smaller manufacturers.

The request for additional public comments by the FTC comes in conjunction with a public FTC workshop, which took place earlier today. 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.

“We support the FTC reviewing the Guides with the intent to provide flexibility for businesses to promote environmentally friendly products and practices and improve clarity for consumers,” said Gibbons. “As consumer interest in purchasing more environmentally conscious products continues to grow, the Green Guides have served as an essential tool in ensuring marketplace transparency without impeding on companies from communicating their environmental initiatives in non-deceptive ways.”

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 first issued in 1992 and 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.