Sustainable Action Leadership

Are You Being Bamboozled? A Guide on How to Avoid Mislabeling

This Brochure is a Collaboration of:

Dr. Gwendolyn Hustvedt, Texas State University‐San Marcos
and
Coral Rose, Eco‐Innovations Sustainable Textile Services

How to Avoid Mislabeling of Bamboo Textile Products

Download here: Bamboo.FTC.How.To.Avoid.Mislabeling.10.09

You Can Have Your Bamboo and Eat it Too--"Rayon Made From Organic Bamboo"

by Coral Rose

The FTC recently charged four textile companies with making false unsubstantiated “green” claims. According to the FTC these companies were deceptively labeling and advertising textile related items as made of ‘bamboo’ fiber, when they are made of rayon, and must legally be labeled "Rayon made from bamboo."

The question has again been raised......

"Can bamboo(technically "Rayon from bamboo") textiles be certified organic to the USDA National Organic Program (NOP)?" 

The last time this question was posed a few years ago, I was informed that bamboo was considered a product of a forest and therefore could possibly be eligible for FSC Certification.

Given the existing controversy that is still running wild in the textile market, I decided to again reach out to the USDA NOP for clarification. I received the following response:

According to Joan Shaffer, Office of Public Affairs at the USDA National Organic Program (NOP) “Bamboo” as a raw material for textiles is available for Organic Certification according to the USDA NOP.

“The organic standards cover agricultural products from livestock and crop.  Bamboo is a crop.”  Please see the explanations for textiles in this (Labeling of Textiles Under National Organic Program (NOP) Regulations) fact sheet.” 

“Below is an excerpt from the “Preamble” on “nonedible fibers products” in the organic standards.” 

“(6) Nonedible Fibers Products in the NOP. Some commenters asked the NOP to clarify the certification status of fibers such as cotton and flax. The final rule allows for certification of organically produced fibers such as cotton and flax. However, the processing of these fibers is not covered by the final rule. Therefore, goods that utilize organic fibers in their manufacture may only be labeled as a "made with..." product; e.g., a cotton shirt labeled "made with organic cotton."   USDA-AMS Office of Public Affairs

 The proper labeling in accordance with the FTC would be:

“Rayon(or Viscose) made from organic bamboo”

*Note that it is the bamboo itself as the CROP (raw material) that is allowed to be certified as organic to the USDA NOP Standard, and that the processing of the fiber and or garment is NOT considered in the process of certification to the USDA NOP Standard.

While this may sound a bit absurd (and about as clean as coal) that rayon can indeed be considered an organic textile, it is the bamboo itself as the raw material that is being certified as organic.

***See August 1, 2009 Post below: Labeling of Textiles: National Organic Program (NOP)

First Clean Coal, Now Organic Bamboo? by Coral Rose

FTC Mulches False Bamboo Textile Claims by Coral Rose

FTC Charges Companies with 'Bamboo-zling' Consumers with False Product Claims

Bamboo-based Textiles, Actually Made of Rayon, Are Not Antimicrobial, Made in an Environmentally Friendly Manner, or Biodegradable

Note from Coral Rose: After much hard work and effort, THE FTC is to be congratulated on bringing integrity back to the Eco-Textile Market.

Press Release 8/11/09:

The Federal Trade Commission has charged four sellers of clothing and other textile products with deceptively labeling and advertising these items as made of bamboo fiber, when they are made of rayon. The complaints also charge the companies with making false and unsubstantiated “green” claims that their clothing and textile products are manufactured using an environmentally friendly process, that they retain the natural antimicrobial properties of the bamboo plant, and that they are biodegradable.

“With the tremendous expansion of green claims in today’s marketplace, it is particularly important for the FTC to address deceptive environmental claims, so that consumers can trust that the products they buy have the environmentally friendly attributes they want,” said David Vladeck, Director of the FTC’s Bureau of Consumer Protection. “When companies sell products woven from man-made fibers, such as rayon, it is important that they accurately label and advertise those products – both with respect to the fibers they use and to the qualities those fibers possess.”

FTC ALERT: HAVE YOU BEEN BAMBOOZLED BY BAMBOO FABRICS

FTC BUSINESS ALERT: HOW TO AVOID BAMBOOZLING YOUR CUSTOMERS

For the entire Press Release  Use this FTC Website link

Labeling of Textiles: National Organic Program (NOP)

Original Post 8.08

Labeling of Textiles: National Organic Program (NOP)

USDA regulates the term “organic” as it applies to agricultural products through its
National Organic Program (NOP) regulation, 7 CFR Part 205.(LINK HERE)

● Raw natural fibers, such as cotton, wool ,flax, etc., are agricultural products and
are covered under the NOP crop/livestock production standards. Off-farm treatment of
raw organic fibers are not covered under the NOP crop/livestock production standards. 

● Although the NOP has no specific fiber or textile processing and manufacturing
standards, it may be possible for fi bers grown and certified to NOP crop/livestock standards
to be processed and manufactured into textile and other products which meet NOP
standards. 

Labeling for Certified Handling/Processing/ Manufacturing Operations 

Only textile products certified to the NOP production AND processing standards are eligible to be labeled
“100 percent organic” and “organic.” 

100 percent organic 

● 100 percent organic fiber content.

● Only organic processing aids.

● USDA Organic seal may be displayed on final product, in marketing materials, and in retail
displays—in proximity to certified products only.

● All operations producing, handling, processing and manufacturing the final product must be
certified. 

Organic 

● Minimum of 95 percent organic fiber content.

● 5 percent nonorganic substances, as listed in Section 205.605 of the NOP regulation.

● No non-organic fibers.

● USDA Organic seal may be displayed on final product, in marketing materials, and in retail
displays—in proximity to certified products only.

● All operations producing, handling, processing,and manufacturing the final product must be certified. 

Other Uses of the Word “Organic” in Textile Product Labeling 

The NOP does not restrict the use of the term “made with organic …” in the labeling of textile products to
only those products manufactured in certified organic facilities or containing a minimum of 70 percent
organic fibers. However, all fibers identified in these textile products as “organic” must be produced and
certified to NOP standards. 

Labels on textile products from non-certified handling/processing/manufacturing operations: 

● May identify specific fibers as being organic if certified to the NOP crop/livestock standards.

● May state the percentage of organic fibers contained in the final product.

● May not use the USDA Organic seal.

● May not imply or lead the consumer to believe that the final product is certified organic 

Other Labeling Laws 

● NOP label requirements are in addition to those required by the Federal Trade
Commission’s (FTC) Textile and Wool Acts.

● Information on FTC labeling requirements for textiles can be found at the following websites:

Threading Your Way Through the Labeling Requirements of The Textile and Wool Acts

Calling it Cotton

USDA regulates the term “organic” as it applies to agricultural products through its
National Organic Program (NOP) regulation, 7 CFR Part 205.(LINK HERE)

● Raw natural fibers, such as cotton, wool ,flax, etc., are agricultural products and
are covered under the NOP crop/livestock production standards. Off-farm treatment of
raw organic fibers are not covered under the NOP crop/livestock production standards. 

● Although the NOP has no specific fiber or textile processing and manufacturing
standards, it may be possible for fi bers grown and certified to NOP crop/livestock standards
to be processed and manufactured into textile and other products which meet NOP
standards. 

Labeling for Certified Handling/Processing/ Manufacturing Operations 

Only textile products certified to the NOP production AND processing standards are eligible to be labeled
“100 percent organic” and “organic.” 

100 percent organic 

● 100 percent organic fiber content.

● Only organic processing aids.

● USDA Organic seal may be displayed on final product, in marketing materials, and in retail
displays—in proximity to certified products only.

● All operations producing, handling, processing and manufacturing the final product must be
certified. 

Organic 

● Minimum of 95 percent organic fiber content.

● 5 percent nonorganic substances, as listed in Section 205.605 of the NOP regulation.

● No non-organic fibers.

● USDA Organic seal may be displayed on final product, in marketing materials, and in retail
displays—in proximity to certified products only.

● All operations producing, handling, processing,and manufacturing the final product must be certified. 

Other Uses of the Word “Organic” in Textile Product Labeling 

The NOP does not restrict the use of the term “made with organic …” in the labeling of textile products to
only those products manufactured in certified organic facilities or containing a minimum of 70 percent
organic fibers. However, all fibers identified in these textile products as “organic” must be produced and
certified to NOP standards. 

Labels on textile products from non-certified handling/processing/manufacturing operations: 

● May identify specific fibers as being organic if certified to the NOP crop/livestock standards.

● May state the percentage of organic fibers contained in the final product.

● May not use the USDA Organic seal.

● May not imply or lead the consumer to believe that the final product is certified organic 

Other Labeling Laws 

● NOP label requirements are in addition to those required by the Federal Trade
Commission’s (FTC) Textile and Wool Acts.

● Information on FTC labeling requirements for textiles can be found at the following websites:

Threading Your Way Through the Labeling Requirements of The Textile and Wool Acts

Calling it Cotton

How Green Is Your Wardrobe?

Orginal Post on EcoTextile News click here

MATLOCK – [08.07.08] A new on-line calculator which allows consumers to calculate the environmental impact of their clothing has been launched by Colour Connections Ltd – the same company which developed the ground-breaking textile eco-metrics (click here or see this blogs 7.18.08 post) for manufacturers and clothing brands.

The new ‘Household Textile Environmental Impact Calculator’ differs from textile eco-metrics in that it's aimed specifically at shoppers instead of the textile industry. Using a series of drop-down menus and a set of complex mathematics hidden behind its user friendly interface allows consumers to assess the environmental impact of the choices they make when they buy, care and dispose of household textiles and clothing.

All users have to do is choose from a list of common clothing items in terms of how many items they buy and how they are disposed in a twelve month period. Then users are asked how these items are washed, dried and ironed in a typical week. After pressing the 'calculate' button, users score a rating in terms of 'Environmental Damage Units' or EDU’s. The EDU value is an environmental measure which is scientifically arrived at based on water and energy use, the use of non-renewable resources and pollution.

The overall EDU score for each item of clothing depends on each individual consumer’s buying preferences, how they care for their garments and ultimately how they dispose of them.

“You may be surprised at how much impact your personal or family clothing preferences have on the environment,” said Phil Patterson, managing director of Colour Connections. “Doing one fewer tumble drying cycle per week saves 170 EDU’s, which is enough to make the fabric for 50 pairs of underpants.”

CLICK HERE to see how your wardrobe stacks up.

Copyright © 2008 Mowbray Communications Ltd 

Labeling of Textiles: National Organic Program (NOP)

USDA regulates the term “organic” as it applies to agricultural products through its
National Organic Program (NOP) regulation, 7 CFR Part 205.(LINK HERE)

● Raw natural fibers, such as cotton, wool ,flax, etc., are agricultural products and
are covered under the NOP crop/livestock production standards. Off-farm treatment of
raw organic fibers are not covered under the NOP crop/livestock production standards. 

● Although the NOP has no specific fiber or textile processing and manufacturing
standards, it may be possible for fi bers grown and certified to NOP crop/livestock standards
to be processed and manufactured into textile and other products which meet NOP
standards. 

Labeling for Certified Handling/Processing/ Manufacturing Operations 

Only textile products certified to the NOP production AND processing standards are eligible to be labeled
“100 percent organic” and “organic.” 

100 percent organic 

● 100 percent organic fiber content.

● Only organic processing aids.

● USDA Organic seal may be displayed on final product, in marketing materials, and in retail
displays—in proximity to certified products only.

● All operations producing, handling, processing and manufacturing the final product must be
certified. 

Organic 

● Minimum of 95 percent organic fiber content.

● 5 percent nonorganic substances, as listed in Section 205.605 of the NOP regulation.

● No non-organic fibers.

● USDA Organic seal may be displayed on final product, in marketing materials, and in retail
displays—in proximity to certified products only.

● All operations producing, handling, processing,and manufacturing the final product must be certified. 

Other Uses of the Word “Organic” in Textile Product Labeling 

The NOP does not restrict the use of the term “made with organic …” in the labeling of textile products to
only those products manufactured in certified organic facilities or containing a minimum of 70 percent
organic fibers. However, all fibers identified in these textile products as “organic” must be produced and
certified to NOP standards. 

Labels on textile products from non-certified handling/processing/manufacturing operations: 

● May identify specific fibers as being organic if certified to the NOP crop/livestock standards.

● May state the percentage of organic fibers contained in the final product.

● May not use the USDA Organic seal.

● May not imply or lead the consumer to believe that the final product is certified organic 

Other Labeling Laws 

● NOP label requirements are in addition to those required by the Federal Trade
Commission’s (FTC) Textile and Wool Acts.

● Information on FTC labeling requirements for textiles can be found at the following websites:

Threading Your Way Through the Labeling Requirements of The Textile and Wool Acts

Calling it Cotton

How Green Is Your Brand?

Posted here New York Times
How Green Is Your Brand?

Sustainable brands. A term soon to join the lexicon of perfect oxymorons, like jumbo shrimp and plastic glasses, but for now the title of a four-day annual conference in Monterey, Calif., referred to by those in the know as “SB08.”

The corporate-logo-covered banner at the conference entrance was straight out of NASCAR, as SB08 had garnered sponsorship from the likes of the Gap, Hewlett Packard, Advanced Micro Devices, Clorox, General Electric, Deloitte and Sun Microsystems, as well as smaller companies like Lunar Design, Mohawk Fine Papers, Seventh Generation and Fetzer Vineyards. Conference presenters touched on topics from safer fish to smarter supply chains, consumer attitudes to crowd-sourcing. This breadth of participation is something to applaud; many of these companies wouldn’t have seen the merit of attending, let alone sponsoring, a sustainability conference in years past.

One bit of information that was driven home by speakers again and again (though it offers a blinding glimpse of the obvious): most people say they want to do the right thing when making purchasing decisions but not all people actually do. Similar gems were offered, i.e., consumers make decisions based on price and convenience.

Now, no one needs to attend a conference to learn that. Do they? During many of the presentations, I was disheartened by the degree to which eco-aspects have to be separated and called out, rather than be built-in, integral and inherent to a product, service or philosophy. It would be great to see more products and services serve a true environmental need rather than see so many emerge from companies jumping on a savvy marketing opportunity.

I also wonder why so much sustainable stuff, from shoes to canned goods, still isn’t really allowed a true design sensibility; is some degree of (whole) grain of hippie-ness really necessary? Take the rugged footwear of one SB08 presenter, Keen: do they really need something called a vegan sandal? Even their own vice president of marketing admitted that Keen’s shoes didn’t match the dress she was wearing while presenting at the conference that day..

But wait, back to the positive stuff: the fact that companies like Dow Chemical willingly participated illustrates that the fear of even approaching the idea of sustainable design and strategy is evaporating. It is heartening to see that all manner of companies are paying serious attention to things like supply chain, packaging, distribution, authenticity and transparency in thoughtful ways.

Not to say that greenwashing (in which consumers are misled regarding the environmental practices of a company or the environmental benefits of a product or service) has gone away, because it sure hasn’t — though it was fascinating to learn in one study that 83 percent of consumers are unfamiliar with the term. When oil companies re-brand themselves as green companies, when hotels slap on sea-foam green paint (non-toxic, at least) and market themselves as “eco,” when car models are erroneously marketed as less carbon-emitting than they really are, that’s greenwashing.

So, sure, there was a little greenwashing going on at SB08 (gathering large groups of people from around the county in one remote location is a little less than green). But what I came away with after hearing about these companies’ myriad sustainable missions, goals and platforms is:

(1) Finally! Glad they are paying attention.

(2) Wow. The green envelope needs to be pushed further. A lot further.

Some 2,670 new green products were introduced in 2006; the number has almost doubled since then.

Huh?

Making more stuff — no matter how green that stuff is — will not really help combat global warming or reduce our collective carbon footprint. Companies need to produce things and need to make money by selling them — understood — but to me, the idea of simply creating more (albeit greener) product is pretty much on par with lowering gas prices as a solution to skyrocketing oil costs. When will we consider behavior? When we will commit to innovation?

Sustainable solution? That’s no oxymoron.

To read the complete article click on the link at the top of the post.

Federal Trade Commission-FTC Guidelines

What message can I communicate to my customers in regards to Environmental Claims?

Here are the FTC Guidelines/Resources

Click onto the document that you wish to reference:

• Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts

• Environmental Marketing Claims

• RULES AND REGULATIONS UNDER THE TEXTILE FIBER PRODUCTS IDENTIFICATION ACT     

• Part 260 -- GUIDES FOR THE USE OF ENVIRONMENTAL MARKETING CLAIMS

 

Concern Over Recycled Polyester: As Reported by EcoTextileNews

Source:  EcoTextileNews  Concern over recycled polyester

TAIPEI – [13.05.08] Textile industry sources in Taiwan have revealed to our new sister publication – The Textile Dyer – that some suppliers of polyester fabrics made from recycled bottles have been taking things a little bit too literally, and have put financial gain ahead of environmental common sense.

Clothing retailers and brands could be in for a nasty surprise when they find out that some of the bottles used to make their textiles have never actually been used as drinking bottles by consumers.

One reliable industry insider, who refused to be named, has claimed that the demand for used bottles, from which recycled polyester fibre is made, is now outstripping supply in some areas and certain cynical suppliers are now buying NEW, unused bottles directly from bottle producing companies to make polyester textile fibre that can be called recycled.

Retailers and brands that can fully trace their supply routes are likely to be able to put a stop to this practice but those who buy fabrics and garments on trust, with little knowledge of where they come from, may find themselves exposed to accusations of greenwash and subsequent brand damage.

A related issue involves the dyeing of the recycled polyester fibres which are claimed by some dyers to be less consistent than virgin polyester. This is resulting in increased levels of re-dyeing which of course has massive environmental impacts of its own.

The demand for recycled polyester is growing rapidly and although as the commercial scale of production gathers pace, there is growing concern that dyeing consistency in some qualities is limited.

If you have any comments on the consistency of recycled polyester compared to virgin fibre please e-mail: editor@ecotextile.com

 

Navigating Organic~Eco Labels; Smart Solutions for Sustainable Business

 

by Coral Rose

The terms “eco, green, sustainable and organic” are being used openly and interchangeably in the market with the term ‘certified organic.’ Inappropriate use of environmental labels has caused confusion in the apparel market. To be sold in the US as certified organic cotton, all textile fiber must be certified organic in accordance with the USDA NOP (National Organic Program) program (or) for Europe the EU organic certifications EU 2092/91. Currently that is the legal requirement for certified organic cotton.

This is NOT business as usual, nor is this a trend, this is an entirely new business model, one where you need to know your supply chain clear back to the farm or fiber production facility. Where does your fiber come from? What is the country of origin? Bottom line: There needs to be Supply Chain Transparency back to the farmer and to the seed.

One reason that there is confusion in the apparel market is that the NOP Organic Standards were originally created for food.

So why is cotton included? The USDA considers cotton a food product until it leaves the gin. Upon completion of the ginning process, where the seed and fiber are separated, cotton consists of 60% seed and 40% fiber. Cotton seed enters the food chain. Cottonseed oil is found in many processed snack foods, among them chips, cookies, crackers and salad dressings. Cotton seed is fed to livestock, dairy cattle and poultry as a high protein supplement. The remaining fiber is baled and shipped to textile mills to be spun into yarn for fabric.

The Global Organic Textile Standards (GOTS)has been submitted for trademark rights. GOTS has offered the world the first globally accepted standard for certified organic fibers. (As early as Fall 2008, we may see the USDA NOP adopt GOTS as the USDA NOP official standard for fiber. )

The GOTS standard for organic textiles covers the production, processing, manufacturing, packaging, labelling, exportation, importation and distribution of all natural fibres. The final products may include, but are not limited to fibre products, yarns, fabrics and clothes.

“The aim of the standard is to define requirements to ensure organic status of textiles, from harvesting of the raw materials, through environmentally and socially responsible manufacturing up to labelling in order to provide a credible assurance to the end consumer.” The standard provides for a subdivision into two label-grades. “ according to GOTS.

a) "organic" or "organic in conversion" 95% or more of the fibres must be of certified organic (or in conversion) origin. The remaining balance up to 5% may be made of non-organic fibres including defined regenerated and synthetic fibres. Blending (= mixing the same fibre in organic and conventional quality in one product) is not permitted.

b) "made with x % organic materials" or " made with x % organic in conversion materials" 70% - 95% or more of the fibres must be of certified organic (or in conversion) origin. The remaining balance up to 30% may be made of non-organic fibres. Regenerated and synthetic fibres are limited to 10% (resp. 25% in the US). Again blending is not permitted.

There is concern in the organic food and apparel market with standards that seek to certify blends and or low percentages of organic fiber content. If USDA/NOP recognizes GOTS as the US Standard for apparel, these minimal standards could go away as quickly as they appeared.

Your label claims CANNOT be deceptive according to the Federal Trade Commission (FTC) Environmental Marketing Guides.

“It is deceptive to misrepresent, directly or by implication, that a product, package or service offers a general environmental benefit.” Additionally, claims should be adequately qualified to avoid consumer deception.

FTC is an Independent Agency, appointed by the President. Its goal is to enforce consumer protection and antitrust laws AND the FTC has jurisdiction over environmental claims and Textile Labeling.

FTC’s GREEN GUIDES(link)  

The Green Guides do not set performance standards or grant eco-labels but require that labels and communications:

• Tell the truth
• Have substantiation
• Are based on consumer perceptions and require claims controls so they are not misleading
• Have clear qualifications & disclosures
• Specify whether claims apply to the product, the package, or both
• Do no overstate the product attributes

General Environmental Claims:

• Qualify: identify specific "green" attribute
• Third Party Certifications must be independent from advertiser
• Certification does not insulate advertiser - Avoid broad claims unless it is based on LCA (Life Cycle Assessment) and sustainable product standard addressing multiple environmental impacts      across the supply chain and social equity.

Symbols

• Avoid unqualified symbols, e.g. generic recyclable
• Use disclosures to qualify claims. Recyclable e.g. for this bottle may not exist in your area.

Bottom line; Before you label-Educate yourself!!!!!!