gDiapers and the FTC Green Guides
In the spirit of fair dinkum that is core to who we are, I wanted to share with you more information about the FTC review of our claims and advertising. Following the FTC update of the Green Guides in September 2012, we have co-operated with the FTC for over a year to refine and further support our benefits, and made the necessary changes to our website and packaging last year. Rest assured that our product and core benefits are unchanged – our disposable inserts are Cradle to Cradle Certified (cm) Silver, flushable, and home compostable (wet ones only). In fact, as part of this process we have done additional testing requested by the FTC that further supports these benefits. To learn more about gDiapers and the FTC Green Guides, please read below.
A Letter to Our Customers
gDiapers prides itself on open communications with all our stakeholders and especially our customers and loyal gMums and gDads. We have always been transparent about how we run the company, how we treat our employees, the product and how we support our product claims.
In October 2012 the Federal Trade Commission (FTC) announced an updated version of their green marketing guidelines. They contacted gDiapers asking us to show support for our compostable, flushable and biodegradable claims. gDiapers, as the first consumer packaged good and only diaper to be certified Cradle-to-Cradle is proud to have led the charge to eliminate conventional disposable diapers from the planet, pioneering an entirely new category of diapers. We have worked with the FTC over the past year to make absolutely sure that the claims we make are clear and accurate.
We are hopeful that our experience and open dialogue will inspire our customers to do their own research into the environmental claims we, and other companies make about products.
The Nitty Gritty
To dive into the details, the FTC ultimately had several issues with how we communicated our claims.
(I) They took issue with how we were communicating our products’ biodegradability and compostability. We have long said our product can be “flushed, composted or tossed.” The FTC felt that we had claimed that our Disposable Inserts biodegraded in a landfill. However, gDiapers has always stated on our website and packaging that “nothing truly biodegrades in a landfill” – language adopted after reviewing the FTC’s 2008 draft green marketing guidelines. Regardless of what we intended to communicate, the FTC didn’t feel we were placing that statement in close enough proximity to the main product claims. We’ve now made our disclaimer statements clearer and closer to one another on packaging and online to eliminate any possible confusion: “gDiapers Disposable Inserts are Cradle To Cradle Certified (cm) Silver, flushable and break down in home compost (wet ones only).”
(II) As many of you know, we’re also the world’s only flushable diaper! The FTC felt we were implying our inserts biodegrade completely when flushed. The FTC’s definition of biodegradability is 100%. We agree with the FTC that it’s unlikely that our inserts degrade 100% when flushed into one of the U.S.’s wastewater treatment centers – just due to the nature of the water treatment process. Today, our product continues to be flushable – yet because it is extremely difficult to test what percentage of the product biodegrades when flushed – we no longer call out the product’s biodegradability in this regard. However, we continue to believe that flushing is an excellent option that allows parents to put solid waste where it belongs.
(III) The FTC also felt we’d led our customers to believe that both soiled and wet gDiapers’ inserts were home compostable (as opposed to “wet ones only.”) because we didn’t say “wet ones only” every place we said compostable. This was never our intention. Our goal has always been to communicate to our customers that home composting was for “wet ones only” which was always on our website and packaging. This disclaimer is now in close proximity to any composting claims we make and a regular part of our communications to customers.
(IV) The FTC questioned gDiapers claim that it’s products were “certified” biodegradable. We used an internationally recognized biodegradable certification protocol, namely ASTM D6400 recommend to us by the Biodegradable Products Institute and passed these tests. But we didn’t have a third party certifying body certify the results of these tests. Therefore, we no longer refer to our products as being “certified” biodegradable.
We sponsored additional testing of the disposable inserts using a protocol that more accurately reflected a home composting environment. The results of this test supported the results of previous testing done by the company, specifically the ASTM testing and the peer-reviewed and published testing conducted by the University of Tasmania, Australia’s researchers over the past 15 years. We maintain, with pride, that our disposable inserts are safely home compostable (wet ones only). And the product is still Cradle to Cradle Certified (cm) Silver.
(V) Lastly, the FTC took issue with a number of smaller matters. Our use of the phrase “plastic free” was in reference to the disposable inserts, but they believed that statements were written in a way that the consumer could misunderstand and believe the claim was applicable to the reusable gPants which are part of the gDiapers system. These have obvious plastic components and were never meant to be part of the “plastic free” claim. The FTC also raised an issue about the biodegradability of a previous generation of baby wipes that we addressed prior to their inquiry.
Since launching in 2005, gDiapers has always embraced being “Fair Dinkum” – an Australian expression that means being genuine and authentic with everyone you encounter.
While receiving an inquiry from the FTC wasn’t a part of our 2013 plan, it led us to closely re-examine the way in which we share information with our customers and friends. Most of the alterations we’ve made in our communications are small in nature and the core benefits of the product remain unchanged.
We hope that you, our gMums, gDads and loyal followers, will benefit from the changes we’ve made in our claims and communications and we look forward to continually evolving and improving the way in which we celebrate our products’ unique features and benefits.
Jason and Kim Graham-Nye