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The Updated Green Guides Will Address Consumer Perceptions That Require Legal Substantiation for Digital Marketing Compliance

April 29, 2023

The FTC's Green Guides Update

In December 2022, the FTC announced that it would be seeking public comment on potential updates to its Green Guides, which were last updated in 2012.

The FTC's stated purpose of the Green Guides is to “help marketers avoid making environmental marketing claims that are unfair or deceptive under Section 5 of the FTC Act.”

What are "aspirational claims" in digital marketing compliance?

Specifically, the Green Guides address environmental ad claims that are classified as “aspirational claims.”

Generally, aspirational ad claims are designed to appeal to a target market's desire to identify with something they value, separate than merely the specific attributes of a product or service.

It's all about triggering a positive, emotional response from consumers in the target market.

Aspirational marketing strategy is based on the premise that emotions may play a more important role than a rational appeal for buying preferences.

Examples of value identification that may resonate with consumers include a specific person who represents certain desirable values (in many cases, a celebrity), a specific, desirable lifestyle, or a preferred social or political movement.

The FTC recognizes the current trend of basing transformational ads on the movement known as the "green transformation" may motivate consumers to buy so-called "green"-related products and services.

The FTC's concerns with "green" advertising

One of the FTC's concerns with "green" advertising is how consumers perceive green claims, including claims that incorporate terms such as:

  • "Carbon offset,"
  • "Recyclable,"
  • “Recycled Content," and
  • "Degradable."


Consumer perception is the key to FTC substantiation requirements.

The FTC's concern regarding specific green advertising terms is how reasonable consumers perceive the meaning of green advertising terms for perceived “net impression” that is required to be substantiated before publication.

In addition, the FTC is interested in determining whether consumers perceive “measurable attributes” in green advertising claims that require substantiation.

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