PR6: Programs for adherence to laws, standards, and voluntary codes related to marketing communications, including advertising, promotion and sponsorship

In 2010, the US Federal Trade Commission proposed revisions to the guidance known as the “Green Guides” that it gives marketers to help them avoid making misleading environmental claims. The proposed changes are designed to update the Guides and make them easier for companies to understand and use.

The proposed revised Green Guides caution marketers not to make blanket, general claims that a product is “environmentally friendly” or “eco-friendly” because the FTC’s consumer perception study confirms that such claims are likely to suggest that the product has specific and far-reaching environmental benefits. Very few products, if any, have all the attributes consumers seem to perceive from such claims, making these claims nearly impossible to substantiate. [source: FTC Press Release]

The proposed Guides also caution marketers not to use unqualified certifications or seals of approval – those that do not specify the basis for the certification. The Guides more prominently state that unqualified product certifications and seals of approval likely constitute general environmental benefit claims, and they advise marketers that the qualifications they apply to certifications or seals should be clear, prominent, and specific. [source: FTC Press Release]

Next, the proposed revised Guides advise marketers how consumers are likely to understand certain environmental claims, including that a product is degradable, compostable, or “free of” a particular substance. For example, if a marketer claims that a product that is thrown in the trash is “degradable,” it should decompose in a “reasonably short period of time” – no more than one year. [source: FTC Press Release]

In light of the proposed changes to the Green Guides, Anvil undertook a review of its product description vocabulary and claims and removed, wherever possible, marketing language that did not meet the proposed Green Guide recommendations or required too much contextual copy to support the claim.  It has not been easy to remove all the terminology that would differentiate the products in our line that claim some sustainable (a word we can still use) fiber or certification over our conventional products.  This is still a work in progress as we develop and test new vocabulary but in the end, we believe that it may simply come down to simple fiber content descriptions.

In 2010, we did discover that AnvilRecycled(r) totes were made from cotton left over from the ginning process and not pre-consumer textile clippings as our AnvilRecycled(r) t-shirts so we changed the label and discontinued that sku.  There is some basis to also conclude that the FTC will not consider pre-consumer textile clippings as “recycled” since the apparel industry has been recycling scrap for other use for some time.  We await the final Green Guides in order to determine our position on the AnvilRecycled(r) t-shirt.  We still believe that it is important for us as an apparel manufacturer to recycle our waste and find new products to make with that waste.  In the meantime, the AnvilRecycled(r) t-shirt was used as a case study by the WRI/WBCSD GHG Protocol on recycled content (page 75).

As previously reported, all of our communications continue to be governed by the principles contained in Anvil’s Code of Ethics and Anvil’s marketing communications are subject to internal review by our product development and compliance departments and to applicable law. In light of the nature of product claims made regarding our AnvilOrganic®, AnvilRecycled® and AnvilSustainable™ product lines along with our various certifications, we regularly host training sessions for our marketing, sales and customer service teams.  In 2010, Anvil developed a Brand Identity Guide and an online resource which were released for the 2011 season.

Our product development and textile teams also continue to conduct testing of specific product claims and provides this information to our compliance team to ensure product claims are supported.  We have developed Fact Sheets for most of our products that have certain fiber or other attributes and these are made available online.

We have also identified the need to continue training internally as we hire new marketing and sales personnel as well as ongoing training of our distributors and customers about our company and product certifications and our products’  life cycle information. We view this as an ideal opportunity to share information about our sustainability initiatives and to differentiate our company and products in the marketplace.

Anvil’s promotion and sponsorship materials are also subject to the same internal compliance review.

While we strive to ensure that all our marketing, promotion and sponsorship materials are accurate and complete, it continues to be a challenge to monitor the content of materials that is developed in international markets.  That is why we have started to require more oversight and develop more training materials for our extended sales and marketing distribution chain.

PR7: Total number of incidents of non-compliance with regulations and voluntary codes concerning marketing communications, including advertising, promotion and sponsorship, by type of outcomes

Anvil has not identified any incidences of non-compliance with regulations concerning marketing.