The best way to reduce the environmental impacts associated with paper use is to reduce the use of paper. Many organisations actively work to reduce paper waste, and some promote paper reduction with customers by giving them the option to communicate through electronic rather than paper-based mail.

If your organisation is a large paper consumer, and you have exhibited leadership in responsible paper purchasing and efficiency, you may have been contacted by Two Sides, an organisation representing the paper and print industries. For several years, Two Sides has been running a campaign targeting “corporate greenwashing due to misleading environmental claims.” Two Sides contacts companies with messaging on their customer communications, such as “go green, go paperless” that offer the opportunity to avoid the resource extraction, production, printing, transport, clutter, slower delivery, and waste management of unnecessary paper use by allowing customers to opt for electronic-only communications. In their messaging, Two Sides pushes for the removal of all “green” paperless marketing messages because they “may run the risk of violating Federal Trade Commission (FTC) regulations.”

Recently, many organisations have approached the Environmental Paper Network for assistance with ensuring that their messaging is accurate. The Environmental Paper Network firmly supports verification of environmental claims and our global membership scrutinizes the credibility of eco-labels and certifications. We also recognize that both paper use and digital communications have a footprint on the environment. We therefore offer the following three simple steps to help ensure that your organisation’s marketing claims regarding paper waste reduction are accurate, follow federal green marketing guidelines, and are fully substantiated. We are pleased to offer this guidance and help reduce paper waste for your organisation, your customers, and the environment.

Step 1: Be specific and avoid general statements.

The FTC Green Guides are designed to help marketers ensure that the claims they make are truthful and substantiated. To follow this guidance, instead of using language like “go green, go paperless” or “go paperless and save trees/help the environment,” be more specific in stating the benefits and results of reducing paper consumption. The FTC recommends using marketing claims that are truthful, not misleading, and supported by a reasonable basis of competent and reliable scientific evidence[1]. An easy way to ensure this is to use the Environmental Paper Network’s Paper Calculator to quantify your organisation’s estimated environmental savings from reducing paper use or from switching to recycled content paper (see Step 2 to learn more about the Paper Calculator). Also be sure to acknowledge that electronic communications have environmental impacts by noting that the benefits cited are based solely on paper savings.

Here are two examples of specific, substantiated and properly cited claims:

If 50% of our customers switched to electronic billing, the savings every year would be approximately 200,000 pounds of paper, equivalent to 740,000 pounds of wood or 2,400 trees. (Environmental impact estimates were made using the Environmental Paper Network Paper Calculator Version 3.2.1. For more information visit www.papercalculator.org.)

By switching to electronic statements, our customers have saved approximately 2,000 tons of paper annually, equivalent to 48,000 trees. (Environmental impact estimates were made using the Environmental Paper Network Paper Calculator Version 3.2.1. For more information visit www.papercalculator.org.)

You can also safely make statements such as the following:

By choosing e-statements/to go paperless, you can:

  • Reduce the amount of paper, ink and power used to produce paper statements
  • Help us reduce the cost of producing and mailing paper statements
  • View and save statements on your computer any time
  • Reduce the waste and associated environmental impacts of disposing of paper statements
  • Reduce the risk of theft of personal information during disposal
  • Receive an e-mail alert when your e-statement is available

Step 2: Cite research to back up your claims using the life cycle assessment estimates of the Paper Calculator.

The Environmental Paper Network’s Paper Calculator is a free and trusted resource to provide environmental impact estimates for paper reduction efforts. The Paper Calculator is supported by the Environmental Paper Network’s 140 not-for-profit member organisations. It was originally launched in 2005 and is based on the first ever peer-reviewed life cycle assessment (LCA) and analytical report of the impacts of paper production and disposal. This report was produced after several years of study by the Paper Task Force, a voluntary, private-sector initiative that included Environmental Defense Fund, Duke University, Johnson & Johnson, McDonald’s, Prudential Insurance, and Time Inc. The Environmental Paper Network owns and operates the Paper Calculator and a leading independent life cycle assessment firm provides management and consulting expertise. The Paper Calculator is kept up to date with new inputs and information based on North American paper industry data and new advancements in the understanding of the paper lifecycle. The methodology and data sources for the Paper Calculator have been peer-reviewed and are transparent. You can learn more about the Paper Calculator’s long list of credentials here.

Using and citing a respected scientific tool like the Paper Calculator will ensure that your marketing statements are verified and clear, and in full compliance with the FTC and other guidelines. The Environmental Paper Network takes great care to research, update and verify the information in the Paper Calculator with independent sources. We stand by the data and environmental impact estimates provided. The Paper Calculator is transparent about the fact that it uses industry averages to make estimates about the environmental impacts of paper (see “terms and conditions” on the Paper Calculator home page). And as long as users properly cite the Paper Calculator, which is required and noted on the Paper Calculator home page, your statements will be clear and understood as independent and reliable estimates.

Step 3: Keep calm and carry on (the FTC’s actions show that they agree that paper reduction conserves resources).

We agree that any accusation that your messaging may violate regulations should be taken very seriously. But we’d like to clarify what the FTC and the Green Guides actually do. The Green Guides are not agency rules or regulations. They are simply guidance that describes the types of environmental claims that the FTC may or may not find deceptive under Section 5 of the FTC Act. If someone files a report with the FTC regarding your marketing claims, then they will review your messaging. If it is found to be unsupported or deceptive, then they may take action including demands to remove it and prohibiting such marketing in the future. Fines could be applied if those orders are later violated.[2]

The FTC has brought action in recent years related to deceptive claims related to product biodegradability, bamboo content, and environmental certification claims as part of its overall effort to ensure that environmental marketing is truthful and substantiated. To date, there has never been an enforcement action by the FTC related to paperless assertions, and there is no indication that the FTC’s concerns extend to companies stating that source reduction due to paper use efficiency has specific positive environmental impacts. Still, we recommend that you follow steps 1 and 2 in order to ensure compliance.

Since some messages from Two Sides may be confusing on this point, we think that it is important to note that the FTC does not require use of an LCA to support an environmental claim, so by using the Paper Calculator (which is based on lifecycle assessment) you are actually providing an extra step of verification. Specifically, the Green Guides say “Marketers must ensure that all reasonable interpretations of their claims are truthful, not misleading, and supported by a reasonable basis before they make the claims. In the context of environmental marketing claims, a reasonable basis often requires competent and reliable scientific evidence. Such evidence consists of tests, analyses, research, or studies that have been conducted and evaluated in an objective manner by qualified persons and are generally accepted in the profession to yield accurate and reliable results.“[3] The Environmental Paper Network is confident that the Paper Calculator meets and exceeds these qualifications.

People are seeking to reduce wasteful consumption and their environmental footprint. This work is often challenging, but the Environmental Paper Network believes that through collaboration and helping one another we can advance meaningful solutions and our shared interest in managing our planet’s natural resources sustainably and fairly. We welcome the opportunity to work with any person or organisation to ensure that paper sustainability efforts are genuine and clearly communicated because we believe that we’re all on the same side when it comes to reducing wasteful consumption and fostering a healthy planet.

The Environmental Paper Network is here to offer assistance. We can help analyze and strengthen your marketing statements, assist with calculations, review citations for accuracy, and answer questions. Contact us via email at info@environmentalpaper.org or phone at 828-251-8558.

Helpful Links:

FTC Issues Revised “Green Guides”: Will Help Marketers Avoid Making Misleading Environmental Claims: https://www.ftc.gov/news-events/press-releases/2012/10/ftc-issues-revised-green-guides

“Environmental Claims – Summary of Green Guides,” a four-page summary of the changes in the Guides: https://www.ftc.gov/sites/default/files/attachments/press-releases/ftc-issues-revised-green-guides/greenguidessummary.pdf


References:

[1]  PART 260– FTC GUIDES FOR THE USE OF ENVIRONMENTAL MARKETING CLAIMS page 3. https://www.ftc.gov/sites/default/files/attachments/press-releases/ftc-issues-revised-green-guides/greenguides.pdf

[2] FTC Issues Revised “Green Guides” Will Help Marketers Avoid Making Misleading Environmental Claims
https://www.ftc.gov/news-events/press-releases/2012/10/ftc-issues-revised-green-guides

[3] PART 260– FTC GUIDES FOR THE USE OF ENVIRONMENTAL MARKETING CLAIMS page 3. https://www.ftc.gov/sites/default/files/attachments/press-releases/ftc-issues-revised-green-guides/greenguides.pdf