FTC Issues Long-Awaited Revised "Green Guides"
Client Alert | 1 min read | 10.01.12
Today the Federal Trade Commission (FTC) issued its latest revisions to the Guides for the Use of Environmental Marketing Claims, 16 CFR Part 260, commonly referred to as the "Green Guides." These long-awaited changes to the Green Guides follow proposed revisions published in October 2010 and trail fourteen years after the FTC's last revision of the Green Guides in 1998. Information about the changes, including the FTC's press release, the Federal Register Notice, and a summary of the proposed changes, is available on the FTC's website here.
The Revised Green Guides differ from the 2010 proposed revisions in some respects, accounting for the many comments the FTC received about those proposed revisions. The Revised Green Guides amend the FTC's environmental marketing claims guidance last published in 1998 including specific new guidance regarding general environmental benefit claims; certificates and seals of approval; the use of "free of" and non-toxic labels; and compostable, degradable, recyclable, and refillable claims. The guides also address claims made about carbon offsets, renewable energy, renewable materials, and source reduction.
For more information about the Revised Green Guides, as well as a forthcoming substantive analysis of the revisions, please contact Crowell & Moring.
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On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement.
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