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Comments on “Factual Statement Proposal” – Received at 12/5/08 Meeting

Summary of Discussion and Agency Response:

The proposal on “Factual Statements” for pesticide products highlighted some key benefits across all pesticide types related to helping consumers better identify pesticide products that are concerned about carbon-foot printing.  However, some of the Agency’s concerns relate to:

  1. How helpful are these types of statements in meeting the overall goal of the workgroup? Though these statements would not be speaking to product safety, would consumers still interpret such environmentally-friendly statements to relate to product safety?
  2. Each of these factual statements would require review of additional supporting data – some of which may even require review from other parts of EPA in order to ensure accuracy and appropriateness.

Following are more specific comments from workgroup members regarding the Factual Statements Proposal:

  1. It’s good to communicate the benefits other than just the ingredients
  2. Team needs to collect the large spectrum of statements that would be considered acceptable statements
  3. “Mineral derived and Plant derived” statements may be true but not helpful
  4. Mineral derived and Plant derived statements are not meant to be a safety statement but to help with the choice of products to use that are more sensitive to environmental factors

    Make this a question in your pilot to see if the consumer is affected by this type of statement in making their choice of products – if this is what you’re interested in achieving with this initiative.  Need to be clear about the objective – environmental or procurement in nature.

    From the procurement perspective, it’s helpful for them to have mineral derived and plant derived info on the label

    “How does the consumer perceive these types of statements versus what was intended?”

    Plant derived and mineral derived is similar to organics program – it doesn’t mean that it’s safer – but it does appeal to those individuals who are concerned with carbon-foot-printing – some consumers are looking for this type of information.

  5. Factual statements should also include “those that have a reasonable basis for being made (accepted in the industry) and/or are generally accepted claims
  6. If you have a choice between “fact-based claims” versus “comparative claims”, it is better to look at the factual statements approach
  7. It would be good to work with the NGO community on this
  8. This is the most straight forward option.  It makes sense to distinguish between product/packaging/etc. – this would be an easier program to develop and implement.
  9. The claims should be reviewed – good idea to have national uniformity

    Statements would need to be reviewed – some might say, “this product contains ingredients that are included in “Clean Ingredients Database,” but may not say “this product also contains some other ingredients that are not on the “Clean Ingredients Database”

  10. Mixed feelings about carbon foot-printing – consumer is concerned about the AI – NGO’s perspective is not to have irrelevant claims to a product’s function on pesticide labels
  11. Many people in the government community are concerned about environmental benefits.  Can we get to the beginnings of the life-cycle statements so we can look at the product as a whole?
  12. Need definitions to prevent argument and confusion – however, this proposal looks like it might be the most ready for primetime

    Would like to be holistic, but don’t think we’re there yet…

    Just because a product can point to environmental savings based on how it’s transported does not mean we can overlook its toxicity – needs to be balanced approach

  13. Be careful not to make the program too stringent – may start to limit innovation
  14. Don’t want the decisions about acceptable claims for a program like this to be only within the labeling committee – would like the opportunity to discuss the benefits of these claims before they are denied
  15. Who certifies that the material is actually soil-based versus oil based, or plant derived, etc?
  16. The States see these claims as easily misleading and very difficult to manage
  17. Factual statements that are not misleading or deceptive should be allowed
  18. Please remember that retailers are customers as well and they are concerned about carbon-foot-printing
  19. The Agency asked if the term Eco-shape currently used on many Deer Park bottles be considered a type of claim that the proposal subgroup thought would be a factual claim.  The subgroup responded by stating that the words eco-shape might not make much sense, however, stating that the container was made with 30% less plastic would be more in line with what they would consider an appropriate factual claim.
Others cautioned that a standard should be set and used – because if you allow people to say 30% less, there’s no clear reference to what you are 30% better than (e.g., previous bottles, other competitors bottles, etc.)

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