Write sustainability claims as specific, qualified statements that your evidence file can back up, not as general words like "eco-friendly" or "sustainable." The FTC's Green Guides set out the agency's views on environmental marketing, and they point toward naming the specific attribute, stating its limits, and keeping substantiation on hand. Bring every claim to counsel before it runs, since state rules may add requirements.
Sustainability language spreads quickly through a brand. It starts on one hero product, moves into the About page, shows up in email subject lines, and ends up in a hundred product descriptions written by people who never saw the supplier certificate. By then nobody remembers which claims were checked.
This is a content-planning question for brand owners and marketing leads, not legal advice. The Green Guides are federal guidance, and state laws can also reach environmental claims, so take your claims list to counsel who knows where you sell.
What the Green Guides say about broad claims
The Green Guides, 16 CFR Part 260, say of themselves that "They do not confer any rights on any person and do not operate to bind the FTC or the public." They describe how the FTC views environmental marketing, and they are blunt about broad claims: section 260.4 says "marketers should not make unqualified general environmental benefit claims." Section 260.3 adds that a claim "should not overstate, directly or by implication, an environmental attribute or benefit." The FTC asked for public comment on possible updates to the Guides in December 2022, and the quotes on this page come from the eCFR text as published in October 2026, so have counsel confirm the current version before relying on any section.
For a brand, that turns "sustainable," "eco-conscious," and "planet-friendly" into words to retire or qualify. A material is not a benefit. "Recycled polyester lining" names something about the product; "better for the planet" promises an effect the brand would have to support. A useful rewrite names the attribute, the part of the product it applies to, and where the evidence sits.
Claims that carry specific conditions
Several claims common in retail have their own sections in the Guides. Bring these to counsel with the product facts in hand:
- Recycled content. Section 260.13 treats a recycled content claim as deceptive unless the item is "composed of materials that have been recovered or otherwise diverted from the waste stream," and says that for partly recycled items "the marketer should clearly and prominently qualify the claim" as to the amount or percentage, by weight.
- Recyclable. Section 260.12 ties unqualified recyclable claims to the availability of recycling facilities, and in that context defines "substantial majority" as "at least 60 percent." The FTC's 2022 request for comment asked "whether it should change the current threshold," so confirm the figure in force before a page relies on it.
- Renewable materials. Section 260.16 says "It is deceptive to misrepresent, directly or by implication, that a product or package is made with renewable materials," and advises qualifying these claims.
- Free-of. Section 260.9 says free-of claims "should be clearly and prominently qualified to the extent necessary to avoid deception," and warns that a true free-of claim can still mislead in some cases.
- Seals and certifications. Section 260.6 says a third-party seal "may be an endorsement," and that a seal which does not convey its basis likely conveys a general environmental benefit unless it carries qualifying language.
Packaging claims deserve the same attention as product claims. A recyclable mailer and a recycled-content garment are different statements with different evidence, and they often sit side by side on the same product page.
Claims also need an exit plan. Suppliers change, certificates lapse, and a packaging run switches to a different material when stock runs short. Each of those events should trigger a check of every page that makes the related claim, which is only practical if the brand knows where each claim appears. Keep that list next to the evidence file, and treat a lapsed document as a reason to pull the claim until the new one arrives.
Build the evidence file before the copy
Section 260.2 says that for environmental claims, "a reasonable basis often requires competent and reliable scientific evidence." In practice, the content team needs the evidence before it needs the adjectives. One question tests every claim on the site, and it belongs with your sourcing lead: "If a shopper emailed asking how we know this, which document would we send?" Any claim without an answer comes down until one exists.
Here is a hypothetical evidence file for a fictional outerwear brand in Oregon. The claims and documents are invented to show the format.
| Claim on the page | What it covers | Evidence held | Owner | Next review |
|---|---|---|---|---|
| Lining contains 50% recycled polyester by weight | One component of one style | Mill certificate and bill of materials | Sourcing lead | Each production run |
| Shipping mailer is recyclable | Packaging only | Supplier documentation, reviewed by counsel against the recyclable section | Operations lead | When the packaging supplier changes |
| Certification logo on a product page | What that certification covers, and nothing more | Current certificate, its scope, and the certifier's logo use terms | Compliance contact | Before the certificate expires |
Keep claims consistent across hundreds of pages
A claim that is accurate on one product page can become inaccurate when it is copied to the next. The recycled lining on one jacket is not on every jacket. The writer should not have to work out which products carry which attribute from a style name or a photo; that belongs in the product data, set by the people who sourced the materials. When a claim lives as a field attached to each product, copy can only make it where the field is filled.
Apply the same discipline to brand-level pages. An About page that calls the whole brand sustainable sits above every product page and speaks for all of them. Rewrite it to describe the specific programs you run and point to where each is documented. Origin claims follow a separate FTC standard, covered in our page on explaining where and how products are made, and our retail, DTC and beauty overview lists the other federal rules brands meet most often.
A fictional before and after
Here is an invented product description for the same fictional Oregon outerwear brand.
Before: Our eco-friendly jackets are made sustainably to protect the trails you love.
After: The lining of this jacket is 50% recycled polyester by weight. The shell fabric is not recycled. We keep the mill certificate for this lining on file and review it with each production run.
The after version is less romantic and far easier to stand behind. Every number in it comes from the evidence file, and counsel reviews the wording before it runs. The general habit of putting proof beside a claim is covered in the proof your website needs to help buyers choose.
In Hudson South's process, the Authority Asset is where the evidence file lives: certificates, bills of materials, and the claims your counsel has approved. Hudson Twenty-One records how the brand communicates across 21 dimensions, so a qualified claim still sounds like the brand rather than a disclaimer. Market Intelligence researches what shoppers in your category ask about materials and packaging, and AEO Creation writes answers from the approved claims.
Check your claims against your evidence
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- 16 CFR Part 260, Guides for the Use of Environmental Marketing Claims. Electronic Code of Federal Regulations. Read 2026-10-16.
- 16 CFR 260.6, Certifications and seals of approval. Electronic Code of Federal Regulations. Read 2026-10-16.
- 16 CFR 260.13, Recycled content claims. Electronic Code of Federal Regulations. Read 2026-10-16.
- FTC Seeks Public Comment on Potential Updates to its 'Green Guides' for the Use of Environmental Marketing Claims. Federal Trade Commission. Read 2026-10-16.