Sustainable Action Leadership

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!!!!!!

 

Organic Cotton Fact Check: Chemicals in Cotton

Since first posting this series in March of 2008, we have supported the industry in setting the record straight.
Several organizations have removed the incorrect and outdated information from their websites, as well as other blogs are now reporting on these facts.

This has become one of this blogs most searched-for pieces. Therefore.....here it is again....corrected facts on the chemicals in cotton. Read carefully and report the facts.
It takes 2.86 ounces of chemicals to grow a pound of US cotton...NOT 5 ounces or a 1/3 pound.


The definition of organic agriculture (including cotton) is:  “Organic production is based on a system of farming that maintains and replenishes soil fertility without the use of toxic and persistent pesticides and fertilizers. Organically produced foods also must be produced without the use of antibiotics, synthetic hormones, genetic engineering and other excluded practices, sewage sludge, or irradiation. National organic standards require that organic growers and handlers be certified by third-party state or private agencies or other organizations that are accredited by USDA.”

Though often misunderstood to refer only to insecticides, the term pesticide also applies to herbicides, fungicides, and various other substances used to control pests. Under United States law, a pesticide is also any substance or mixture of substances intended for use as a plant regulator, defoliant, or desiccant.

What is a fertilizer, and isn't it a pesticide? No, fertilizers are not the same as pesticides. "The USDA definition of pesticides is quite broad, but it does have some exclusions: Fertilizers, nutrients, and other substances used to promote plant survival and health are not considered plant growth regulators and thus are not pesticides."

A fertilizer is any substance that is added to soil in order to increase its productivity. Fertilizers can be of biological origin (eg composts), or they can be synthetic (artificial fertilizer). Fertilizers are substance that improves the ability of soil to produce crops, they are considered plant nutrients, substances that feed the plants.

Corrected facts on the growing of conventional cotton and it's comparison to organic cotton from previous post:

0.08637 ounces of pesticides are used to grow a pound of cotton fiber in the US.

*Utilizing  fertilizer data provided by the USDA, there are 2.7731 ounces of fertilizers used to grow a pound of cotton fiber. (144.03 pounds per acre x 16=2,304.48 ounces divided by the 831 pounds per acre yield =2.7731

This calculates to 2.8595 ounces of pesticides and fertilizers to grow a pound of cotton, far less than the 5 ounces per pound, that was the outdated previously reported statistic. Also note that 97% of the chemicals are fertilizers, while 3% are pesticides.

*Please note: It is not known what fraction of the fertilizers as reported by USDA are organic-approved versus organic-disallowed. Thus it is impossible to sum pesticides and fertilizers and get total synthetic chemicals applied. It is reasonable to expect that most of the USDA reported pesticides currently applied to cotton are synthetic chemicals.There are NOP approved fertilizers used on conventional cotton production. It is a known fact that NOT all fertilizers are synthetic chemicals since dairy, chicken and feedlot manure is commonly applied to cotton. Cotton fields respond well to manure and cotton tolerates the salts prevalent in cattle manure. 

"Organic Cotton Fact Check" in perspective;

Most organizations in the organic cotton business, take a single purchase, seasonal or annual purchases to document the amount of savings in purchasing organic cotton vs. conventional cotton, a practice I strongly encourage as long as you are using correct facts.

As an example an organization that is using the outdated information is reporting for every 100,000 pounds of organic cotton purchased, they are saving 31,250 pounds of pesticides and fertilizers from the planet.

Using the above current USDA information that same 100,000 pounds of organic cotton purchased would be saving 8,637 ounces or 540 pounds of pesticides and 17, 312 pounds of fertilizers. A total of 17,852 pounds per 100,00 pounds of cotton fiber versus the previously reported 31,250, a difference of 13,398 pounds or 43% less than previously reported. Since we cannot distinguish synthetic from organic fertilizers in the USDA data, it is noted that this calculation is on the high end of the scale.

Facts:
According to the Federal Trade Commission (FTC) Environmental Marketing Guides.

“Your label claims CANNOT be deceptive.” “It is deceptive to misrepresent, directly or by implication, that a product, package or service offers a general environmental benefit.”

According to PAN-UK; "The figure of 1/3 pounds pesticides per pound of cotton is completely wrong. That would be the end of the world if so much pesticide was used in the world."

You should distinguish between pesticides and fertilizers in your marketing materials. Fertilizers make up 97% of the inputs to cotton, while pesticides are at 3%.  Noted environmental and health impacts of fertilizers include but are not limited to: runoff into streams; possible contamination of water as well as eutrophication, and penetration to underground water tables again with possible contamination.

Therefore the previous usage of 1/3 pounds of pesticides in a t-shirt and or pound of cotton would be incorrect, if used you would be overstating by over 40%.

The information noted by the resources in this four part series is considered correct as of this date.

Green-tegrity Fact Check: Should a Garment With 5% Organic Cotton Be Considered Organic?

Should a garment with 5% Organic Cotton Be Considered Organic?

 According to the National Organic Program (NOP) the answer is NO, as noted in a previous post.

Q. FTC regulations allow special fiber content claims to be made at the 5% threshold level. Can I label my clothing “made with organic cotton” if they only have 5% organic cotton?

A. No. The NOP regulations require at least 70% certified organic content for products to be labeled as “made with organic."

Ecorazzi recently ran a piece on the Greenwashing of a Banana Republic T-Shirt. (pictured on this post) per Ecorazzi;  “They are made from 87% cotton, 8% spandex, and 5% organic cotton. A source has revealed to us that these shirts “come in plastic bags that most of the stores just throw away because they can’t recycle.” Are we seeing here a classic case of greenwashing?”  “On the other, labeling something ‘eco-friendly’, even though 95% of it is not, seems a bit of a reach”

So why would anyone want to use 5% organic cotton in a garment? I didn’t understand it either, so I asked several people I know that are blending 5% organic cotton in garments (clients of mine, brands and retailers.)

It seems that during the last six to eight months, there has been a proliferation of misinformation in the market regarding the supply of organic cotton. It seems that many brands and retailers are under the impression and have been told,  that there might or could be a shortage so it would be wise to use a 5% blend and at the same time they are under the impression that it would enhance the credibility of the garment to use a voluntary 5% Blended Standard. ( Which now, according to the NOP is invalid in the US.) Another reason cited for using a 5% blend has been that 70-100% organic cotton is cost prohibitive. I can assure you, that if Wal-Mart is buying 70-100% organic cottons that it is not cost prohibitive-while organic cotton can cost on average 10-15% more-a blend of 5% would therefore be almost mute.

In speaking with a large producer/supplier this week at the All Things Organic Show in Chicago, it is not true that there might be a shortage, infact, I was told that there is actually quite a bit of organic cotton available and this source cited the fact that so many brands and manufactures have been blending 5% as one of the reasons. The unintended result could be adverse effects on producers and farmers, effecting their livelihoods if they are unable to sell the cotton or if they have to sell at a loss.

There is also concern that the 5% fiber blend (such as that noted by Ecorazzi in the article) will undermine the organic food market and the great work done there for many years in the organic food industry.

Perhaps what the organic cotton industry needs is a David Bronner (see previous post) to take a stand against claims that seek to undermine the integrity of the organic label in textiles?

Dr. Bronner's Hits Back with Green-tegrity

I spoke at a seminar this week at All Things Organic with David Bronner, President of Dr. Bronners. David is an example of exemplary integrity to the organic industry.

SAN FRANCISCO, April 28 PRNewswire-USNewswire

"Offending Companies Claim "Organic" or "Organics" on Labels But Main
Cleansing Ingredients Are Based on Conventional Agricultural and/or
Petrochemical Material.

The family owned Dr. Bronner's Magic Soaps filed a lawsuit in California Superior Court today against numerous personal care brands to force them to stop making misleading organic labeling claims. Dr. Bronner's and the Organic Consumers Association (OCA) had warned offending brands that they
faced litigation unless they committed to either drop their organic claims or reformulate away from main ingredients made from conventional agricultural and/or petrochemical material without any certified organic
material. OCA has played the leading role in exposing and educating consumers about deceptive organic branding. 

David Bronner, President of Dr. Bronner's Magic Soaps says, "We have been deeply disappointed and frustrated by companies in the 'natural' personal care space who have been screwing over organic consumers, engaging in misleading organic branding and label call-outs, on products that were
not natural in the first place, let alone organic." Dr. Bronner's has determined, based on extensive surveys, that organic consumers expect that cleansing ingredients in branded and labeled soaps, shampoos and body washes that are labeled Organic", "Organics" or "Made with Organic" will be from organic as distinct from conventional agricultural material, produced without synthetic fertilizers, herbicides or pesticides, and free of petrochemical compounds.

For example: The major cleansing ingredient in Jason "Pure, Natural & Organic" liquid soaps, body washes and shampoos is Sodium Myreth Sulfate, which involves ethoxylating a conventional non-organic fatty chain with the carcinogenic petrochemical Ethylene Oxide, which produces caricinogenic 1,4-Dioxane as a contaminant. The major cleansing ingredient in Avalon "Organics" soaps, bodywashes and shampoos, Cocamidopropyl Betaine, contains conventional non-organic agricultural material combined with the petrochemical Amdiopropyl Betaine. Nature's Gate "Organics" main cleansers are Disodium Laureth Sulfosuccinate (ethoxylated) and Cocamidopropyl Betaine. Kiss My Face "Obsessively Organic" cleansers are Olefin Sulfonate (a pure petrochemical) and Cocamidopropyl Betaine.

Organic consumers have a right to expect that the personal care products they purchase with organic branding or label claims, contain cleansing ingredients made from organic agricultural material, not
conventional or petrochemical material, and thus have absolutely no petrochemical contaminants that could pose any concern. 

Dr. Bronner's products, in contrast to the brands noted above, contain cleansing and moisturizing ingredients made only from certified organic oils, made without any use of petrochemicals, and contain no petrochemical preservatives. The misleading organic noise created by culprit companies' branding and labeling practices, interferes with organic consumers ability to distinguish personal care whose main ingredients are in fact made with certified organic, not conventional or petrochemical, material, free of
synthetic preservatives. 

The  Lawsuit Also Names Estee Lauder, Stella McCartney's CARE, Ecocert and OASIS. 

Ecocert is a French-based certifier with a standard that allows not only cleansing ingredients made from conventional versus organic agriculture, but also allows inclusion, in the cleansing ingredients contained in products labeled as ":Made with Organic" ingredients, of certain petrochemicals such as Amidopropyl Betaine in Cocamidopropyl Betaine. Even worse, despite Ecocert's own regulations prohibiting the
labeling as "Organic" of a product containing less than 100% organic content, Ecocert in practice engages in "creative misinterpretation" of its own rules in order to accommodate clients engaging in organic mislabeling.

For instance, Ecocert certifies the Ikove brand's cleansing products to contain less than 50% organic content, noted in small text on the back of the product, where all cleansing ingredients are non-organic including Cocamidopropyl Betaine which contains petroleum compounds. Yet the product is labeled "Organic" Amazonian Avocado Bath & Shower Gel. Another instance is Stella McCartney's "100% Organic" CARE line certified by Ecocert that labels products as "100% Organic" that are not 100% Organic alongside ones that are; the labels of products that are not 100% organic simply insert the word "Active" before "Ingredients." In allowing such labeling, Ecocert simply ignores the requirements of its own certification standards.

Furthermore, the primary organic content in most Ecocert certified products comes from "Flower Waters" in which up to 80% of the "organic" content consists merely of just regular tap water that Ecocert counts as "organic."

Explicitly relying on the weak Ecocert standard as precedent, the new Organic and Sustainable Industry Standard ("OASIS")-a standard indeed developed exclusively by certain members of the industry, primarily Estee Lauder, with no consumer input--will permit certification of products outright as "Organic" (rather than as "Made with Organic" ingredients) even if such products contain hydrogenated and sulfated cleansing ingredients such as Sodium Lauryl Sulfate made from conventional agricultural material grown with synthetic fertilizers, herbicides and pesticides, and preserved with synthetic petrochemical preservatives such as Ethylhexylglycerin and Phenoxyethanol. [Reference: OASIS Standard section 6.2 and Anti-Microbial List] The organic content is required to only be 85%, which in water and detergent-based personal care products, means organic water extracts and aloe vera will greenwash conventional synthetic cleansing ingredients and preservatives.

.The OASIS standard is not merely useless but deliberately misleading to organic consumers looking for a reliable indicator of true "organic" product integrity in personal care. Organic consumers expect that cleansing ingredients in products labeled "Organic" be made from organic not conventional agriculture, to not be hydrogenated or sulfated, and to be free from synthetic petrochemical preservatives. Surprisingly, companies represented on the OASIS board, such as Hain (Jason "Pure, Natural & Organic"; Avalon "Organics") and Cosway (Head "Organics",) produce liquid soap, bodywash and shampoo products with petrochemicals in their cleansers even though use of petrochemicals in this way is not permitted even under the very permissible OASIS standard these companies have themselves developed and endorsed. 

Organic Cotton Final Fact Check... Part IV of IV

The definition of organic agriculture (including cotton) is:  “Organic production is based on a system of farming that maintains and replenishes soil fertility without the use of toxic and persistent pesticides and fertilizers. Organically produced foods also must be produced without the use of antibiotics, synthetic hormones, genetic engineering and other excluded practices, sewage sludge, or irradiation. National organic standards require that organic growers and handlers be certified by third-party state or private agencies or other organizations that are accredited by USDA.” ( FOR DEFINITIONS: SEE THIS BLOGS MORE RECENT 8/6/08 POST-USDA PDF-for pesticides used in cotton use this post as resource. Coral Rose 8/7/08)

Though often misunderstood to refer only to insecticides, the term pesticide also applies to herbicides, fungicides, and various other substances used to control pests. Under United States law, a pesticide is also any substance or mixture of substances intended for use as a plant regulator, defoliant, or desiccant.

What is a fertilizer, and isn't it a pesticide? No, fertilizers are not the same as pesticides. "The USDA definition of pesticides is quite broad, but it does have some exclusions: Fertilizers, nutrients, and other substances used to promote plant survival and health are not considered plant growth regulators and thus are not pesticides."

A fertilizer is any substance that is added to soil in order to increase its productivity. Fertilizers can be of biological origin (eg composts), or they can be synthetic (artificial fertilizer). Fertilizers are substance that improves the ability of soil to produce crops, they are considered plant nutrients, substances that feed the plants.

Corrected facts on the growing of conventional cotton and it's comparison to organic cotton from previous post:

In total, all nine states applied 55,738 pounds of pesticides divided by the total 12,425 planted acreage equals 4.4859 pounds applied per acre of cotton. 4.4859 pounds equals 71.774 ounces applied per acre. For the documented year, the yield per acre was 831 pounds of cotton fiber per acre. 71.774 ounces divided into 831 pounds of cotton fiber per acre equals:0.08637 ounces of pesticides are used to grow a pound of cotton fiber in the US.

*Utilizing  fertilizer data provided by the USDA, there are 2.7731 ounces of fertilizers used to grow a pound of cotton fiber. (144.03 pounds per acre x 16=2,304.48 ounces divided by the 831 pounds per acre yield =2.7731

This calculates to 2.8595 ounces of pesticides and fertilizers to grow a pound of cotton, far less than the 5 ounces per pound, that was the outdated previously reported statistic.

*Please note: It is not known what fraction of the fertilizers as reported by USDA are organic-approved versus organic-disallowed. Thus it is impossible to sum pesticides and fertilizers and get total synthetic chemicals applied. It is reasonable to expect that most of the USDA reported pesticides currently applied to cotton are synthetic chemicals.There are NOP approved fertilizers used on conventional cotton production. It is a known fact that NOT all fertilizers are synthetic chemicals since dairy, chicken and feedlot manure is commonly applied to cotton. Cotton fields respond well to manure and cotton tolerates the salts prevalent in cattle manure. 

"Organic Cotton Fact Check" in perspective;

Most organizations in the organic cotton business, take a single purchase, seasonal or annual purchases to document the amount of savings in purchasing organic cotton vs. conventional cotton, a practice I strongly encourage as long as you are using correct facts.

As an example an organization that is using the outdated information is reporting for every 100,000 pounds of organic cotton purchased, they are saving 31,250 pounds of pesticides and fertilizers from the planet.

Using the above current USDA information that same 100,000 pounds of organic cotton purchased would be saving 8,637 ounces or 540 pounds of pesticides and 17, 312 pounds of fertilizers. A total of 17,852 pounds per 100,00 pounds of cotton fiber versus the previously reported 31,250, a difference of 13,398 pounds or 43% less than previously reported. Since we cannot distinguish synthetic from organic fertilizers in the USDA data, it is noted that this calculation is on the high end of the scale.

Facts:
According to the Federal Trade Commission (FTC) Environmental Marketing Guides.

“Your label claims CANNOT be deceptive.” “It is deceptive to misrepresent, directly or by implication, that a product, package or service offers a general environmental benefit.”

According to PAN-UK; "The figure of 1/3 pounds pesticides per pound of cotton is completely wrong. That would be the end of the world if so much pesticide was used in the world."

You should distinguish between pesticides and fertilizers in your marketing materials. Fertilizers make up 97% of the inputs to cotton, while pesticides are at 3%.  Noted environmental and health impacts of fertilizers include but are not limited to: runoff into streams; possible contamination of water as well as eutrophication, and penetration to underground water tables again with possible contamination.

Therefore the previous usage of 1/3 pounds of pesticides in a t-shirt and or pound of cotton would be incorrect. The information noted by the resources in this four part series is considered correct as of this date.

 

.

 

Organic Cotton Fact Check...Part II of IV

So, just what does all this mean? Simply put, all of us have a responsibility to present the facts to our consumers.

Not only is it our responsibility but all environmental claims are regulated by the FTC.

Ideally, we should all be asking the  #1 question; "Where does my cotton come from?" The next step? Tracking those raw materials and their impacts to that particular region--and then reporting the specifics for that region and season.

Note this previous post:

Navigating Organic~Eco Labels; Smart Solutions for Sustainable Business

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)is premiering the new GOTS Logo at BioFach in Nurenberg, Germany this week.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, this will become the minimum standard for which all apparel must be certified.

FTC’s GREEN GUIDES
(click here)

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.

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 or biodegradable
• Use disclosures to qualify claims. Recyclable e.g. for this bottle may not exist in your area.

Bottom line;

Before you label, print marketing materials before you address crowds of influential people including the press----check your facts and educate yourself, that is what I am doing.

We want to maintain the integrity of the organic industry and we certainly DO NOT WANT to misinform or misrepresent any industry that is working towards sustainability .

 

Have You Been Bamboozled by Bamboo?

By Coral Rose

BAMBOO IS NOT A FIBER.

BAMBOO IS NOT LEGALLY RECOGNIZED AS A FIBER BY THE FTC.

Bamboo is not, in and of itself, recognized as a fiber in the US or EU.  What is referred to as bamboo fiber in the market is actually viscose/rayon.

All viscose or rayon fiber from Bamboo (as a source) that is imported into the US must carry a legal fiber content label declaration of viscose or rayon. All bamboo imported into the EU must use of the legal content declaration viscose; the EU does not permit the use of the word rayon.

According to the FTC, you can label your garments; "Rayon from Bamboo"

As one of the fastest growing plants in the world, bamboo grows to its maximum height in about 3 months and reaches maturity in 3-4 years.  It spreads rapidly across large areas. Because of relatively quick growing time and the ability to be grown without fertilizers or pesticides, the fiber is currently being marketed as an ‘eco-green-sustainable fiber.’ There are also claims that viscose or rayon from bamboo is biodegradable and anti-microbial. There are potential risks associated with using bamboo as a polymer source for rayon since there is currently a lack of transparency in the supply chain. It is not always clear which type of bamboo is used for fiber, where it is grown, how it is cultivated, harvested etc. To date there are no known organic certification of bamboo. 

The process to make viscose or rayon fiber from bamboo is the same process used to produce viscose/ rayon from any other plant source. The cellulose is extracted from the bamboo, and then the cellulose is mixed with chemicals to convert the plant pulp into textile quality fiber. This process can be very polluting unless it is carefully controlled, which can be influenced by the age and condition of the equipment as well as whether there is any by-product recycling or effluent treatment.  

There is only one case of manufacturing a regenerated cellulose fiber-where the chemicals used in the process are completely recycled  with a recovery rate of 99.5%, this is known as a closed loop system. The fiber made using this closed looped process is Lenzings TENCEL ® Lyocell. More accurately described Lyocell is a solvent spun fiber in which the cellulose is directly dissolved keeping the cellulose much closer to that found in nature. TENCEL® Lyocell,  also carries the Oeko Tex 100 certification and FSC certification ( http://www.fsc.org/en/) Currently organic standards are not in place for certifying regenerated fibers using trees as a source e.g. Eucalyptus, or Beechwood.  FSC certification for TENCEL® Lyocell is for the forest and for the pulp, they also have been awarded the European-Eco flower label. (www.Lenzing.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)is premiering the new GOTS Logo at BioFach in Nurenberg, Germany this week.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 

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!!!!!!

 

The Green Claim Game........Part III of III

 

The Federal Trade Commission is planning to host a public workshop on January 8, 2008 to examine the emerging market for carbon offsets (i.e., greenhouse gas emission reduction products) and renewable energy certificates, and related advertising claims. The workshop will focus on consumer protection issues in these markets, such as consumer perception of carbon offset and REC advertising claims and substantiation for such claims.

Excerpts from the current FTC Guidelines for the use of Recycled Content and Recyclable:

FTC-GUIDES FOR THE USE OF ENVIRONMENTAL MARKETING CLAIMS

Recycled content: A recycled content claim may be made only for materials that have been recovered or otherwise diverted from the solid waste stream, either during the manufacturing process (pre-consumer), or after consumer use (post-consumer). To the extent the source of recycled content includes pre-consumer material, the manufacturer or advertiser must have substantiation for concluding that the pre-consumer material would otherwise have entered the solid waste stream. In asserting a recycled content claim, distinctions may be made between pre-consumer and post-consumer materials. Where such distinctions are asserted, any express or implied claim about the specific pre-consumer or post-consumer content of a product or package must be substantiated.

It is deceptive to misrepresent, directly or by implication, that a product or package is made of recycled material, which includes recycled raw material, as well as used, reconditioned and remanufactured components. Unqualified claims of recycled content may be made if the entire product or package, excluding minor, incidental components, is made from recycled material. For products or packages that are only partially made of recycled material, a recycled claim should be adequately qualified to avoid consumer deception about the amount, by weight, of recycled content in the finished product or package.

Additionally, for products that contain used, reconditioned or remanufactured components, a recycled claim should be adequately qualified to avoid consumer deception about the nature of such components. No such qualification would be necessary in cases where it would be clear to consumers from the context that a product's recycled content consists of used, reconditioned or remanufactured components.

Recyclable: It is deceptive to misrepresent, directly or by implication, that a product or package is recyclable. A product or package should not be marketed as recyclable unless it can be collected, separated or otherwise recovered from the solid waste stream for reuse, or in the manufacture or assembly of another package or product, through an established recycling program.  Claims of recyclability should be qualified to the extent necessary to avoid consumer deception about any limited availability of recycling programs and collection sites. If an incidental component significantly limits the ability to recycle a product or package, a claim of recyclability would be deceptive. A product or package that is made from recyclable material, but, because of its shape, size or some other attribute, is not accepted in recycling programs for such material, should not be marketed as recyclable.

GUIDES FOR THE USE OF ENVIRONMENTAL MARKETING CLAIMS

 

The Green Claim Game........Part II of III

While the USDA/NOP is the federal agengy in charge of regulating organic claims, claims appearing on the labeling and or advertising of organic and or any products claiming environmental benefits are also regulated by the Federal Trade Commission (FTC) Here is an excerpt from the FTC guides, drafted in 1992, but still in use today, until they are updated sometime next year, check out the guidelines for such terms as Biodegradable and Compostable---which by the way have been showing up in droves in the apparel industry.........and now at your local mall.................a link to the Guides is provided at the end of this post. Post III will look at Recycled/Recycled Content.

FTC-GUIDES FOR THE USE OF ENVIRONMENTAL MARKETING CLAIMS

General environmental benefit claims: It is deceptive to misrepresent, directly or by implication, that a product, package or service offers a general environmental benefit. Unqualified general claims of environmental benefit are difficult to interpret, and depending on their context, may convey a wide range of meanings to consumers. In many cases, such claims may convey that the product, package or service has specific and far-reaching environmental benefits. Example:

A brand name like "Eco-Safe" would be deceptive if, in the context of the product so named, it leads consumers to believe that the product has environmental benefits which cannot be substantiated by the manufacturer. The claim would not be deceptive if "Eco-Safe" were followed by clear and prominent qualifying language limiting the safety representation to a particular product attribute for which it could be substantiated, and provided that no other deceptive implications were created by the context.

Degradable/biodegradable/photodegradable: It is deceptive to misrepresent, directly or by implication, that a product or package is degradable, biodegradable or photodegradable. An unqualified claim that a product or package is degradable, biodegradable or photodegradable should be substantiated by competent and reliable scientific evidence that the entire product or package will completely break down and return to nature, i.e., decompose into elements found in nature within a reasonably short period of time after customary disposal.Claims of degradability, biodegradability or photodegradability should be qualified to the extent necessary to avoid consumer deception about: (1) the product or package's ability to degrade in the environment where it is customarily disposed; and (2) the rate and extent of degradation.

Compostable: It is deceptive to misrepresent, directly or by implication, that a product or package is compostable. A claim that a product or package is compostable should be substantiated by competent and reliable scientific evidence that all the materials in the product or package will break down into, or otherwise become part of, usable compost (e.g., soil-conditioning material, mulch) in a safe and timely manner in an appropriate composting program or facility, or in a home compost pile or device. Claims of compostability should be qualified to the extent necessary to avoid consumer deception. An unqualified claim may be deceptive if: (1) the package cannot be safely composted in a home compost pile or device; or (2) the claim misleads consumers about the environmental benefit provided when the product is disposed of in a landfill. A claim that a product is compostable in a municipal or institutional composting facility may need to be qualified to the extent necessary to avoid deception about the limited availability of such composting facilities.

GUIDES FOR THE USE OF ENVIRONMENTAL MARKETING CLAIMS