Advocacy Groups Submit Comment Letter Calling on FTC to Tackle Corporate Greenwashing

WASHINGTON, DC — A coalition of advocacy groups has submitted a comment letter to the Federal Trade Commission, asking the agency to revise its “Green Guides” to better manage corporate and fossil fuel greenwashing. The public comment period ended today, April 24. 

• Read the letter here

The “Green Guides” provide guidance to companies on how to make environmental claims in advertising and marketing. During the comment period, the agency specifically asked for feedback on carbon offsets, renewable energy, and climate change, among other issues. In their comments to the FTC, the groups emphasize that strong guidelines are necessary to prevent greenwashing, ensure that consumers can make informed choices about the products they’re buying, and bring much needed transparency to issues surrounding the energy transition. 

“Our organizations represent millions of U.S. residents who are gravely concerned about climate change. When making purchases, they expect accurate information from companies about how those companies are meaningfully reducing greenhouse gas emissions. Unfortunately, companies are increasingly marketing products and services as climate-friendly with deceptive claims and omissions relating to carbon offsets,” reads the comment letter.

The Advocacy groups that signed the letter included Action for the Climate Emergency, Amazon Watch, Americans for Financial Reform Education Fund, Greenpeace USA, Institute for Agriculture and Trade Policy, Public Citizen, and the Sierra Club.

The groups specifically called on the FTC to:

• Bring the Green Guides into alignment with international standards addressing greenwashing
• Recognize that the term “natural gas” is inherently misleading 
• Clarify how “net zero” claims need to be substantiated
• Tighten rules around the marketing of “carbon offsets” and the use of offsets to justify sustainability claims
• Restrict the amount fossil fuel companies can advertise their investments in clean energy to correspond with the amount of money those companies are actually investing
• Stop companies from using vague and generic environmentally friendly terms like “clean,” “sustainable,” “natural,” or “renewable” to describe fossil fuels
• Strengthen enforcement of the guidelines to ensure that companies are held accountable for any misleading claims.

The Green Guides were last updated in 2012, and the FTC is expected to issue a revised version by the end of this year. 

Quotes from advocacy groups: 

“Companies are making increasingly bold climate action claims, frequently based on heavy use of carbon offsets. Yet offsets rarely, if ever, live up to their climate and forest protection promises, and often drive land grabbing from Indigenous peoples in places like the Amazon rainforest. It’s high time regulators like the FTC protect consumers from this corporate climate deception," said Moira Birss, Climate Finance Director at Amazon Watch.

“It's time for the FTC to use its Green Guides to establish strong binding standards that stop greenwashing. In the face of widespread public support for climate action, companies are distorting the facts about their role in the climate crisis and falsely casting themselves as allies. Phrases like net zero and carbon offsets have been used to mislead the public into believing that companies will stop polluting, even when it isn’t the case. What the public needs to know is the total emissions of companies and their supply chains. The FTC can help us get the honesty and transparency we deserve when it comes to the health of our air, water, and planet,” said Anusha Narayanan, project lead at Greenpeace USA.

“Americans who care about the health of our planet and communities try to do their best as consumers to reward environmentally responsible business practices. But when companies make deceptive marketing claims about ‘carbon neutrality’ and other alleged climate benefits of their products, it frustrates consumers, who have to sift through the greenwashing,” said Ben Cushing, Campaign Director of Sierra Club’s Fossil-Free Finance Campaign. “We need the Federal Trade Commission to protect consumers from this climate deception — including requiring companies to explain their reliance on dubious carbon offsets when making claims about reduced emissions.” 

“Food companies are increasingly making unsubstantiated climate claims, from “climate neutral” to “net zero”, that are not supported by science or independent standards. Many of these corporate claims are based on purchasing highly questionable carbon offsets to address their continued pollution. These types of deceptive marketing claims are not what consumers expect. The FTC needs to catch up to what is happening in the marketplace and set clear guidelines for credible corporate climate claims,” said Ben Lilliston, Director of Climate Strategies at the Institute for Agriculture and Trade Policy.

See additional quotes from organizations including Clean Creatives, ClientEarth, Action for the Climate Emergency, and Gas Leaks here.

BACKGROUND

A recent study from Brown University concluded that the five largest oil companies have spent over $3.6 billion on “reputation building” advertising over the last 30 years. As a report by ClientEarth concluded, the vast majority of that advertising “routinely misrepresented the sustainability of [fossil fuel] activities” in an effort to mislead consumers. Another study by Harvard researchers in 2022 found that 72 percent of social media posts by oil and gas companies engaged in some form of greenwashing.