COMMENTARY | New Green Guides Must Address Renewable Energy

Monica Mercola

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New Green Guides Must Address Renewable Energy

This commentary was originally published in the Spring 2023 edition of PEEReview.

Concern about climate change creates fertile ground for misleading marketing claims around environmental issues. An important tool in protecting consumers from phony marketing schemes is the Federal Trade Commission’s (FTC) “Green Guides.” PEER recently submitted comments to the FTC on updating these guides.

Consumers want products which reduce their carbon footprint, don’t further contribute to climate change, and are environmentally friendly. This has led to marketing claims which greenwash the environmental attributes of “renewable” energy. PEER’s Climate Integrity Project has stepped forward and proposed significant modifications to the Green Guides by cracking down on misleading claims like “renewable” energy, “net zero,” and “carbon neutral.”

One focus of our effort revolves around renewable energy credits, or RECs, which are electronic certificates representing one megawatt of renewable electricity. Many RECs are bought, sold, and negotiated in closed, untransparent markets, leading to false or misleading claims regarding who actually is using and consuming renewable energy.  Our recommendation to the FTC is simple—only entities that purchase clean or renewable energy should be allowed to claim renewable energy credits.

PEER is also targeting misleading claims about carbon offsets marketed as representing greenhouse emission reductions. Purchasers of offsets continue to emit greenhouse gases and pay for projects that are assumed to provide climate benefits elsewhere. Yet, many of these offsets are not incremental, enforceable, or verifiable, rendering any “net zero” claims utterly unsubstantiated. We recommend that the FTC provide clear language stipulating that, while offsets can provide environmental benefits, purchasers cannot use them to claim actual greenhouse gas reductions or to make “net zero” energy claims.

Tough FTC guidelines help curtail these deceptive marketing practices and strengthen real climate solutions. PEER supports a rule which develops guidance for unfair, false, and deceptive claims regarding RECs and carbon offsets.

Monica Mercola is PEER’s staff counsel. 

Phone: 202-265-7337

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Silver Spring, MD 20910-4453

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