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On December 20, 2022, the Federal Trade Commission (FTC) published a Request for Comment (Request) on potential revisions to its Green Guides for the Use of Environmental Claims (Green Guides). The Request seeks information on a wide range of environmental marketing claims both currently and potentially covered by the Green Guides – including claims related to recycling, climate change, energy use and efficiency, and sustainability. The Green Guides outline the FTC’s position on avoiding deceptive environmental marketing claims, including the level of evidence needed to support specific kinds of claims. The FTC and others, including state and private-party litigants, often rely on the Green Guides in bringing enforcement actions related to environmental claims.


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