The Association of Plastic Recyclers

APR Statement on Federal Trade Commission Potential Updates to Green Guides for the Use of Environmental Marketing Claims

Steve Alexander, APR President & CEO, issued the following comments on the FTC action regarding Green Guides:

"The Association of Plastic Recyclers (APR) supports updating the Federal Trade Commission (FTC) Green Guides for the Use of Environmental Claims. The FTC's goal in updating the Green Guides should be to help consumers seeking to reduce waste make informed choices about the products and packaging they buy, and to ensure that companies make accurate marketing claims about the sustainability of their products.

APR strongly urges the FTC to provide clear guidance on the terms "recyclable" and "recycled content" in the updated Green Guides. In considering these definitions, the FTC's Green Guides should continue to reflect the facts on the ground and current consumer understanding of these terms, while also leaving room for the innovation and investment that is vital to the success of the industry.

Specifically, the FTC should continue to be clear that unqualified "recyclable" claims on packaging are only allowed when a substantial majority of consumers or communities have access to recycling facilities where the item is sold. At the same time, APR recommends that the Green Guides reflect ongoing investment and research by differentiating between those products that could be recyclable at scale and are on the path to meeting performance requirements, and those products that are not recyclable at scale and have no pathway to get there.

For "recycled content" claims, the Green Guides should reflect consumer understanding of the recycling process.The FTC should make clear that marketers can only make unqualified claims of recycled content if the entire product or package on which the claim is displayed (excluding minor, incidental components) is made from post-consumer recycled material - products made from material used by households or individuals and placed in recycling bins or as part of a consumer recycling program. The FTC should not allow unqualified claims that products are recycled if they are made from "post-industrial" material – manufacturing scraps or byproduct – or if the claim is based on "mass balance" calculation.

APR looks forward to submitting comments to the FTC and to actively participating as a stakeholder in the important Green Guides development process." 


Contact: Kara Pochiro,
APR Communications Director
This email address is being protected from spambots. You need JavaScript enabled to view it.

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The Association of Plastic Recyclers (APR) is The Voice of Plastics Recycling." As the international trade association representing the plastics recycling industry, membership includes independent recycling companies of all sizes, processing numerous resins, as well as consumer product companies, equipment manufacturers, testing laboratories, organizations, and others committed to the success of plastics recycling. APR advocates the recycling of all plastics. Visit www.PlasticsRecyling.org for more information

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