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8 Tips to acing green guideline claims

Advice for accurately communicating the sustainability benefits of your packaging materials to meet Greener Package Guidelines to Sustainability Claims.

Sustainable packaging suppliers, we’ve been reviewing your Greener Package Product Database submissions for a couple of months now. We applaud you early adapters for taking the plunge and allowing us to analyze your claims and the data used to support them.

You are the true pioneers! And, as pioneers, you have taken the slings and arrows that will help those who follow in your footsteps to obtain faster and less time-consuming approvals. To be honest, at least 90% of the first three months’ submissions were initially rejected. Significantly, it wasn’t that the products weren’t worthy of approval. It was simply that the information provided didn’t clearly make the case for approval.

Here are the eight most common submission problems, and what you can do to avoid them. These tips can also be useful to consumer packaged goods companies that wish to accurately communicate their product packaging’s sustainability benefits on shelf.

1. Be specific in your claims. Virtually every claim we’ve seen has described the product in question as being “sustainable” or the “most sustainable.” This claim is problematic for two reasons. First, it is too general to be accepted under Federal Trade Commission (FTC) guidelines. While we are all tempted to simply use terms like “sustainable,” “recyclable,” “compostable,” and “biodegradable,” the FTC considers them to be too general, and in many cases misleading and therefore illegal.

Second, it does not explain why we should believe it. The FTC also requires that you explain what specific benefit you are claiming, compared to which competitive product(s), and the relative or absolute difference(s) between the two.

Let’s say that your new polypropylene CD case has been lightweighted by 22% versus your previous versions and versus the industry-standard product. You might be tempted to say it’s “the most sustainable CD case on the market.” Instead, what you can say is: “Improved sustainability versus other products because it uses 22% less material and creates 22% less waste.” (If you had data about reduced energy consumption or greenhouse gas generation, you could claim that, too.)

By the way, you can put the qualifying part of the statement (“because it uses…”) in a footnote. You should also use footnotes or a web link to offer proof that your claim is valid, which takes us to….

2. Provide proof from third parties (research, suppliers, etc.). Neither comparative nor sustainability claims can be made in a vacuum. We need pictures, statistics, and other supporting evidence that tells us what the product in question is being compared against and what the differences are. This doesn’t mean that you need to supply us with a full-fledged life-cycle analysis (although if you have it, that would be nice). We are interested in the rationale behind the specific claim that you are making.

Please note that when it comes to heavy metals testing, we will only accept lab test results from a third party. Sustainable forestry claims also require certification from third parties such as the Forest Stewardship Council or the Sustainable Forestry Initiative. A letter from your paper supplier stating that their wood is certified will not suffice.

3. Check to see that compliance certificates are up-to-date. This is an easy one. Before uploading the sustainable forestry certifications and heavy metals lab test results, please make sure that they have not expired. The sustainable forestry certifications explicitly have an expiration date for the particular source; please make sure that they haven’t expired. Lab test results do not have expiration dates. However, the tests are dated and are only for a specific product. If the chemical makeup of the product has changed in any way, shape, or form, be sure to provide updated lab tests.

4. Provide supporting documentation for heavy metals limits. We have found this one to be really tricky. Many claims were rejected based on lack of supporting documentation. Specifically, either lab test results from a third party were not provided, or the lab test results did not state the detectable limit they used when performing the testing. This last part is confusing, as CONEG standards state that any materials added to the basic package (inks, dyes, etc.) must not contain any heavy metals (i.e., heavy metals must be nondetectable.)

We have stated in our latest version of the Greener Package Guidelines to Sustainability Claims that the detectable limit for the basic package cannot exceed five parts per million. This means that the independent lab test results should a.) state what the detectable limit is; and b.) this limit should not exceed 5 ppm.

5. Be aware of your state’s renewable energy resources. There have been many questions on this issue. Most businesses do not know if their state provides them with indirect use of energy from renewable resources, or specifically what percentage of the energy provided actually is from renewable resources. To make things a little easier, we have added a link on the Greener Package database to U.S. Environmental Protection Agency data indicating the renewable energy generation per state.

What if you have multiple facilities in multiple states? Create a weighted average by taking the production from each plant, as a percentage of total production. Multiply this percentage by the percentage of renewable energy available in the state where that plant operates. Do this for each plant, and add up the results.

Example: Let's say your company produces 1,000 units of product X across two plants. Plant 1 is in State A, where 50% of the energy is considered renewable. Plant 2 is in State B, where 25% of the energy is renewable. Plant 1 produces 400 units, or 40% of the total. Plant 2 produces 600 units, or 60% of the total. For Plant 1, multiply the percentage of total units (40%) times the renewable energy level for State A (50%), for a total of 20%. For Plant 2, multiply the percentage of total units (60%) times the renewable energy level for State B (25%), for a total of 15%. Adding up the results from the two states (20% + 15%) provides a weighted average total of 35%.

6. Be clear with recycling, biodegradation, and compostability claims. Claims relating to these three aspects of sustainability are probably the most contentious in terms of theory versus reality. In general, the potential for a product to be recycled, biodegraded, or composted does not provide enough support to claim recyclability, biodegradability, or compostability. Even the presence of ASTM standards does not meet FTC standards of proof, as these standards do not in fact guarantee that the physical infrastructure exists to turn potential into reality.

Let’s start with recycling. To make a simple claim of “recyclable,” a product must be currently accepted or collected for recycling in at least 60% of U.S. communities. If the recycling level does not meet this definition of common availability, you must either specifically state where it can be recycled, or only use the claim in areas where it is convenient for consumers to do so. So, you could claim “Recyclable in CA, WA, MI, and WV,” or you could use the general term “Recyclable” in those particular states, and nowhere else.

Composting presents a similar situation. There is really no such claim as “compostable.” If a product is compostable in backyard/home systems or piles, say so: But please make sure you have appropriate proof from ASTM and an organization such as the Biodegradable Products Institute (BPI).

If a product is compostable but not in a home or backyard system, you would have to claim, “Can be composted in an industrial composting facility.” Because industrial composting facilities are few and far between, you would either have to be specific about the locations where industrial composting is conveniently available, or could only use the general claim in those areas where the availability criteria is met.

The issue of biodegradability is very similar to composting. A general claim of “biodegradable” or “100% biodegradable” is most likely unacceptable without accompanying support such as “… in home composters.” Third-party data to support the claim must also be provided or made available to anyone who might read or hear about the claim.

7. Be specific with source-reduction claims. As with all of the examples mentioned above, if you are going to claim source reduction, please be specific. “Uses less material” or “creates less waste” won’t cut it. “Uses 19% less paper than our previous product,” or “Produced using 36% less energy than XYZ Co.’s product” are acceptable ways to claim source-reduction benefits.

8. Ensure statistical differences of 15% or more. To claim that your product is better along some measurable dimension, it must not be just better, it must be statistically better. This means that the statistical probability that there is indeed a difference must be at least 90%. The rule of thumb we use to gauge statistical significance is a relative difference of 15% or more.

For example, if your process reduces greenhouse gas generation by 8% versus a competitive process, you cannot claim improvement or a difference. The laws of probability indicate that in actuality, greenhouse gas generation for both processes is the same. (And you thought that freshman stats class was worthless!)

However, if the difference is at least 15%, you can claim a difference. You’re free to simply say “less greenhouse generated than…” or you can claim “15% less greenhouse gas generated than…” or even “significantly less greenhouse gas generated than….” Don’t forget to also indicate the source of this information – e.g. EPA Study XXXX or 2010 Life Cycle Assessment Study Conducted by XYZ Associates (available on our Web site or on request).

Summary
The best way to ensure that your submission is quickly reviewed and approved is to make sure that a sustainability claim is:

• Specific in terms of what is being measured and what products this measurement is being compared against.

• Based upon credible internal or third-party data that is available to the public.

• Statistically significant when claiming superiority

• Within FTC, EPA, and other federal guidelines and mandates.

* Bob Lilienfeld, editor of The ULS (Use Less Stuff) Report and a consultant for Packaging Knowledge Group (PKG), and Tanja Carroll, project manager at Environmental Packaging Intl. (EPI), are third-party reviewers approved by GreenerPackage.com to review packaging material suppliers’ submissions to the Greener Package Product Database. Audited claims must comply with the
Greener Package Guidelines to Sustainability Claims for approval.

* indicates an article that was submitted directly to this Web site by the supplier, and was not handled by the Greener Package editorial staff.

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