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Source Reduction

It is deceptive to misrepresent, directly or by implication, that a product or package has been reduced or is lower in weight, volume, or toxicity. Source reduction claims should be qualified to the extent necessary to avoid consumer deception about the amount of the source reduction and the basis for any comparison asserted.

Example 1

An ad claims that solid waste created by disposal of the advertiser’s packaging is “now 10 percent less than our previous package.” The claim is not deceptive if the advertiser has substantiation that shows that disposal of the current package contributes 10 percent less waste by weight or volume to the solid waste stream when compared with the immediately preceding version of the package.

Example 2

An advertiser notes that disposal of its product generates “10 percent less waste.” The claim is ambiguous. Depending on contextual factors, it could be a comparison either to the immediately preceding product or to a competitor’s product. The “10 percent less waste” reference is deceptive unless the seller clarifies which comparison is intended and substantiates that comparison, or substantiates both possible interpretations of the claim.


It is deceptive to misrepresent, directly or by implication, that a package is refillable. An unqualified refillable claim should not be asserted unless a system is provided for: (1) the collection and return of the package for refill; or (2) the later refill of the package by consumers with product subsequently sold in another package. A package should not be marketed with an unqualified refillable claim if it is up to the consumer to find new ways to refill the package.

Example 1

A container is labeled “refillable x times.” The manufacturer has the capability to refill returned containers and can show that the container will withstand being refilled at least x times. The manufacturer, however, has established no collection program. The unqualified claim is deceptive because there is no means for collection and return of the container to the manufacturer for refill.

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