U.S. FTC Green Guides Revision Status

The Federal Trade Commission's (FTC) "Green Guides" is a guidance document that helps companies ensure environmental marketing claims—such as "recyclable," "biodegradable," or "carbon neutral"—do not constitute unfair or deceptive practices under Section 5 of the FTC Act. The Guides have not been updated since their last revision in October 2012—over a decade ago. In December 2022, the FTC opened a public comment period toward revision, closing it on April 24, 2023. This process included workshops on the effectiveness of recyclability claims and informal hearings related to the Energy Labeling Rule, and revision was initially expected to be completed within 2024. However, following the change in administration in January 2025, changes in the FTC's commissioner composition (a shift from Democratic to Republican majority, with the appointment of new Chairman Andrew Ferguson) caused the revision process to stall. Chairman Ferguson has made clear his position that an outgoing commission should not adopt new rules, suggesting that a reconsideration of the revision's content under the new leadership will be necessary. As of August 2026, the revised Green Guides have not been formally published, and the 2012 version remains the operative guidance. In light of this prolonged stall, several states (including California) are moving to enact their own recyclability and environmental labeling regulations, with state law increasingly filling the gap left by the absence of federal guidance.