AHPA submits comments to FTC on Green Guides

April 26, 2023

The American Herbal Products Association (AHPA) has submitted comments to the Federal Trade Commission (FTC) regarding the review of its Guides for the Use of Environmental Claims. This regulation – commonly known as the “Green Guides” – sets out FTC's expectations regarding what environmental marketing claims are considered unfair or deceptive under the Federal Trade Commission Act.
Among other elements, AHPA's extensive comments called on FTC to expand the scope and depth of its environmental claim regulations in several areas, including to establish consistent national standards for what items can be called “recyclable,” to establish rules for what activities or products can be labeled “sustainable,” and to provide requirements for the placement and formatting of any qualifying statements associated with environmental claims. AHPA's comments also underscored its position that the United Stated Department of Agriculture National Organic Program has the authority to regulate organic claims in dietary supplements.

“The Green Guides are a vital resource in need of expansion,” said Robert Marriott, AHPA Director of Regulatory Affairs. “A more detailed and consistent set of standards for product and packaging claims will ensure an even playing field for companies looking to promote their environmentally conscious activities.”




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