A Trial Lawyer's Guide to the New FTC Green Labeling Guidelines
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Consumer and market demands for sustainability played a part in bringing packaging into the food safety system. For example, increased pressure to use recycled material in food packaging has led to unintended consequences like those revealed by 2011 Swiss research regarding the unsafe migration of mineral oil from recycled paper and cardboard into foodstuffs.
While the food safety community strives to bring packaging under Hazard Analysis and Critical Control Points safety models, both packaging and food producers must now also consider the impact of the “Green Guides “recently issued by the Federal Trade Commission (FTC). The FTC’s guidance regarding package and product
environmental claims can affect both food safety concerns and potential consumer action for false labeling. Because the purchases of eco-friendly consumers continue to be influenced by environmental packaging efforts, companies need to understand what’s at stake in deciding to adopt—or ignore—the guidance provided.
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