Summary of CRS Comments on Proposed Revisions to the FTC Green Guides

Summary of comments on the Federal Trade Commission (FTC)’s recently released proposed update to its Guides for the Use of Environmental Marketing Claims (“Green Guides”). CRS will be submitting comments, and we have developed a summary of the key points we will be making to the Commission. Overall, we are very supportive of the proposed update and find that it reinforces many of the consumer-protection practices required by Green-e certification, but there are a few areas where we suggest further consideration and clarification.