FPA Submits Comments for the FTC’s Request for Public Comment on the Impact of the Green Guides

The Flexible Packaging Association appreciates this opportunity to submit its thoughts and suggestions on the issues and environmental claims on which the Commission solicited comments in its December 2022 Notice initiating the FTC’s review of the 2012 Green Guides, 16 CFR Part 260.1 In addition to requesting comment regarding the efficacy, costs, and benefits of the 2012 Green Guides and whether to retain, modify, or rescind them, the Notice also requests input on specific types of environmental claims – many of which were not discussed in the 2012 Guides or which have evolved significantly over the past decade. Importantly, the Commission also requests the public’s views on whether the Commission should consider codifying the Green Guides into enforceable federal regulations.