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The FTC's New Green Guides in Practice: A Real-Life, Detailed Case Study

Image credit: gDiapers

gDiapers is a Portland, Oregon-based diaper company offering mums and dads a diaper insert that is flushable, home-compostable and plastic-free. My wife and I moved from Sydney, Australia to Portland, Oregon in 2004 to launch the company. As new parents ourselves at that time, we felt strongly that there had to be a better way than the current choice of diapers. 

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 Cradle-to-Cradle-certified, is proud to have led the charge to eliminate conventional disposable diapers from the planet, pioneering an entirely new category of diapers. 

We cooperated 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. 

Jason Graham-Nye,
co-founder/CEO of gDiapers,
speaker at
SB '14 San Diego

Our product and core benefits are unchanged — our disposable inserts are still Cradle-to-Cradle certified, flushable, biodegradable in home compost (wet ones only, in 70-150 days) with a plastic-free outer layer. In fact, as part of this process we have done additional testing requested by the FTC that further supports these benefits.

Cooperating with the FTC for the better part of 2013 wasn't part of my plan but through it we are now somewhat experts in the field. Rather than just move on, I want to share our experiences firsthand with you, our colleagues, at Sustainable Brands '14 (the first time I will be speaking publicly about the case), so you can leave informed and educated in a practical way about the new guidelines and what they mean for your brand and marketing efforts. 

The focus of this session will be on how the FTC is applying the new General Environmental Benefit Claims rule in the real world. The FTC now prohibits any unqualified general green claims being made including using terms such as "green," eco-friendly" and "environmentally sound." It is also not limited to words: It includes symbols (no more green leaves?), logos (no more logos with green leaves?) or product brand names, and applies to all forms of marketing in any medium whether asserted directly or by implication. 

I will also cover an important lesson for us that may apply to your efforts related to:

  • our intent (good, always)
  • the execution of our claims (erred at times) and
  • the FTC's interpretation (errors were intentional and intentionally misleading) 

The implications for sustainable brands and their marketing is significant and no longer academic — I can attest to that! And I am excited to share our learnings with you. 

Jason Graham-Nye is the co-founder & CEO of gDiapers (, the company redefining disposable diapers.

Jason has had a circuitous route to the Executive Suite of a diaper company. He started his career with Nomura Securities in Tokyo as… [Read more about Jason Graham-Nye]

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