How to spot greenwashing on a label

The word covers a range of behavior, from fuzzy language to outright false claims. Much of it sits in a gray area: a leaf on the box, the word "pure," a shade of green.

The main federal reference is the Federal Trade Commission's Guides for the Use of Environmental Marketing Claims, known as the Green Guides. The FTC says they were issued to help marketers make sure their claims are true and substantiated. They cover general principles, how consumers are likely to interpret particular claims, and how marketers can qualify claims to avoid deceiving people. The current version was issued in October 2012.

The Guides are not a law in themselves. They state the FTC's current views, and by their own terms they do not bind the FTC or the public. But the Commission can take action under the FTC Act if a marketer makes an environmental claim that is inconsistent with them, and in that case it has to prove the claim is unfair or deceptive. The Guides apply to words, symbols, logos, depictions and product brand names alike.

Start with the broad ones. The Green Guides say unqualified general environmental benefit claims are difficult to interpret and likely convey that a product has specific and far-reaching environmental benefits, and may convey that it has no negative environmental impact. Because it is highly unlikely that a marketer can substantiate all of that, the FTC says marketers should not make unqualified general environmental benefit claims.

The fix the FTC describes is qualification: clear and prominent language that limits the claim to a specific benefit. "Eco-friendly" alone tells you nothing. "Bottle made from recycled plastic" tells you one thing you can weigh.

Then there are the words the Green Guides leave alone. When the FTC issued the 2012 revision, it said the Guides do not address the terms "sustainable," "natural" and "organic." Organic claims on products derived from agricultural products are covered by the USDA National Organic Program. Natural is covered by almost nobody: the FDA says it has not established a formal definition of the term for food. Our guide to organic vs natural vs non-GMO has the detail.

A seal is a claim too. The Green Guides say it is deceptive to misrepresent that a product has been endorsed or certified by an independent third party. Their own example is a paint advertised with a "GreenLogo" seal that the manufacturer awarded to itself. Unless the company clearly says it awarded the seal to its own product and limits what the seal means, the FTC considers that deceptive.

The Guides flag a second problem: seals that do not say what they are for. An environmental seal that does not convey the basis for the certification likely implies a general environmental benefit, which the marketer almost certainly cannot prove. The FTC's advice to marketers is not to use them. Membership badges fall in the same trap. In another FTC example, a seal from an association the company merely belongs to, which never evaluated the product, would be deceptive.

Real certifications behave differently. They name the standard, and they can be traced. A certified organic food names its certifier on the package after the words "Certified organic by." A GOTS label must include the logo, the label grade, a reference to the certification body and a certification number, which is why a claim on an organic t-shirt can be checked. The labels directory lists what each common seal covers and who issues it.

Often nothing. A specific free-of claim can be the most useful line on a label. But the Green Guides describe two ways a truthful one can still deceive. The first is when the product contains or uses substances that pose the same or similar environmental risks as the one that is absent. The second is when the substance has never been associated with that product category in the first place.

The second is the one to watch for in the shampoo aisle. A long list of things a product is free of is only meaningful if products of that kind normally contain them. When you compare bottles on a page like organic shampoo and hair care, read the ingredient list for what is in the bottle, not the front panel for what is not.

Then there is the broadest free-of claim of all, "free of chemicals." It cannot be true of any physical product, because every ingredient, water included, is a chemical. A claim that names the substance is one you can check.

Non-toxic gets its own section in the Green Guides. The FTC says a non-toxic claim likely conveys that a product is non-toxic both for humans and for the environment generally, so a marketer needs competent and reliable scientific evidence for both, or needs to qualify the claim. On all-purpose cleaners, we look for a named program and a full ingredient list instead of the word.