Coalition Comment Extension Request on FTC Green Guides

The FTC is seeking comments on the efficiency, costs, benefits, and regulatory impact of the Guides to determine whether to retain, modify, or rescind them. Our organizations appreciate the opportunity to provide comments and look forward to advising on specific aspects of the Guides on which the FTC is seeking input. While there was general awareness that the FTC would commence regulatory review of the guides sometime in 2022, it was unclear to stakeholders as to what substantive updates the Commission would be considering. It has been more than 10 years since the last update of the Guides, and the evolution and consumer relevance of environmental marketing practices over the last decade have been momentous. In order to provide FTC with fulsome and accurate responses to its request for information, especially with regard to consumer perception research, it will take additional time, resources, and evaluation by our respective organizations.