Environmental Claims Need a Specific Subject

Look for the Specific Benefit

The FTC’s Green Guides summary advises against broad, unqualified environmental-benefit claims such as “green” or “eco-friendly.” It explains that qualifications should identify specific benefits clearly and prominently, and that broad claims can be difficult to substantiate.

When reading skincare marketing, first locate the subject. Is the statement about the bottle, one ingredient’s sourcing, a manufacturing activity, or the entire product? Keep any explanation or qualification with the claim.

Sources: Federal Trade Commission: Environmental Claims: Summary of the Green Guides

A Seal Also Has a Scope

The FTC explains that environmental certifications and seals should make their basis clear. Having third-party certification does not remove a marketer’s responsibility to substantiate the express and implied claims it makes.

For the reader, the next step is to find the standard behind the mark and the attributes it actually evaluates. A small symbol should lead to a specific explanation, rather than a broader assumption.

Sources: Federal Trade Commission: Environmental Claims: Summary of the Green Guides

TSB perspective

How TSB Approaches Sourcing Language

For a “sustainably sourced” ingredient claim, TSB’s standards call for a defined ingredient and source, stated criteria or a named standard, and relevant supplier and traceability records connected to the submitted product.

Such a finding would not establish that the entire product, brand, or supply chain is sustainable. Packaging and other environmental representations are not automatically eligible for TSB review merely because this article discusses them. Eligibility follows the current published program scope.

Sources: The Skincare Bureau: Our Standards

Questions to ask

Questions That Keep the Claim Specific

To understand the representation, ask:

• What part of the product or activity is being described?
• What environmental benefit is actually stated?
• What criteria, comparison, or qualification accompanies it?
• Where can I read the supporting explanation or certification scope?