Let’s Do This! The Green Guides are being revised! And the FTC wants YOUR Advice!
In response to the FTC’s upcoming revision of the Green Guides, JVC seeks jewelry industry comments on environmental terminology.
Please submit your comments by Friday, March 10th, 2023. (Just do it now…)
Follow the JVC
The U.S. Jewelers Vigilance Committee (JVC) has asked us (the Roskin Gem News Report) to forward their request to you. They want your input before they submit their requests to the Federal Trade Commission (FTC). For those outside of the United States, the FTC is the governmental body that oversees business practices, and has set guidelines specifically for the jewelry trade. Because these guides are not often updated, it is imperative that we take advantage of the opportunity to request changes and additions to the guides now.
According to the JVC, “the Federal Trade Commission’s ‘Guides for the Use of Environmental Marketing Claims’ (the ‘Green Guides’) were first issued in 1992 and were last updated in October of 2012. The Green Guides cover a wide range of industries and are intended to help marketers and advertisers avoid making environmental claims that could mislead consumers.”
This is exactly what is being discussed right now with companies claiming to have socially and environmentally responsible practices, ethical supply chains, etc.
“For the jewelry industry,” continues the JVC, “the FTC’S 2023 review of the Green Guides is particularly important, as consumers continue to show an increasing desire to purchase products they view as ‘good for the environment.’ In light of this sentiment, members of the industry struggle with how to appropriately market items such as diamonds (whether natural or laboratory-grown), gemstones and precious metals without causing consumer confusion. Unfortunately, the current version of the Guides lacks clarity in several key areas.”
Because these Guides are under review for the first time in over ten years, it is absolutely essential that every sector of the jewelry and watch industries come together and give input on the terminology up for review such as ‘recycled’, ‘organic’, ‘sustainable’, and more. Jewelry and watches are just one industry that will be commenting, as these definitions apply broadly across industries, and our responses must be strong and unified to both get the attention of the FTC and set the tone of the revision process at this essential beginning stage. That will ensure the greatest chance to succeed at the ultimate goal, informing and protecting the US consumer,” says Tiffany Stevens, CEO & General Counsel Jewelers Vigilance Committee.
As consumer interest in sustainability grows, jewelry marketers and brands shift business models to meet demand. Commonly used terms are being examined, including “recycled,” “sustainable,” and “eco-friendly.” The guides will be modified to reflect a company’s products, packaging, services, and manufacturing processes, as well as environmental claims not currently explored in the Green Guides. For businesses and manufacturing facilities promoting carbon offsets to the public, terminology such as “carbon-neutral,” “carbon-negative,” and “net zero” is on the table. It is imperative to collect, consider, and review an abundance of data across a breadth of the trade to advocate for its interest.
Comment on JVC’s FTC Green Guide Public Comment Form at https://jvclegal.org/ftc-green-guides-comments/ JVC is accepting rolling comments through March 10, 2023.
Terms that need Defining
As examples, the JVC notes that the FTC intentionally chose not to address the following terms:
Other terms also undefined, are:
“Finally, the definitions of some terms are confusing and not always appropriate for the needs of jewelry industry members. For example, per the current Guides:
• ‘Recycled’ claims should only be made, ‘… for materials that were recovered or otherwise diverted from the waste stream, either during the manufacturing process (pre-consumer) or after consumer use (post-consumer).”
See a full summary of the current Green Guides here.
JVC urges us all to send our comments, questions, and concerns through the JVC portal, at JVC Green Guides Comments, or to contact them directly at GreenGuides@jvclegal.org to speak directly with one of JVC’s on staff attorneys.
If you want to file your comments directly to the FTC, you can do so online or on paper, by following the instructions in the Request for Comment part of the SUPPLEMENTARY INFORMATION section. Write “Green Guides Review (16 CFR part 260) (Matter No. P952501)” on your comment, and file your comment online at https://www.regulations.gov/, by following the instructions on the web-based form.
If you prefer to file your comment on paper, mail your comment to the following address: Federal Trade Commission, Office of the Secretary, 600 Pennsylvania Avenue, NW, Suite CC-5610 (Annex J), Washington, DC 20580. follow for more Roskingemnewsreport
“JVC has been the industry leader in ethics, compliance, and education for over 100 years. JVC’s role as the industry’s leader for ethics and legal compliance is well-established, including its longstanding relationships with the industry’s regulators in Washington, D.C. Having completed previous FTC guide reviews, JVC’s expertise in bringing industry knowledge to the table is essential for the Green Guides revision process. JVC’s legal compliance experts will shepherd the jewelry and watch industries through the revision process, both by gathering feedback from the industry and drafting comments based on the FTC’s requests,” says Sara Yood, Deputy General Counsel, Jewelers Vigilance Committee.
Mobilizing the industry, the comment form was developed under the aegis of JVC to safeguard the trade.