Two Sides Submits Comments to FTC

The Need for the Green Guides is as Urgent as Ever

The U.S. Federal Trade Commission recently announced its intent to review its Green Guides (Guides for the Use of Environmental Marketing Claims), asking for public comment to determine if the Guides should be retained and, if so, how they can be improved. Two Sides responded, telling the FTC that the Guides are needed now more than ever, and provided several recommendations for improvement.

First published in 1992 and most recently revised in 2012, The Green Guides were developed to help marketers avoid using unsubstantiated environmental claims that mislead consumers. They have been an invaluable tool in Two Sides’ Anti-Greenwashing Campaign to persuade major corporations and other organizations to eliminate anti-paper “Go Green, Go Paperless” claims from their customer communications.

Research conducted by Two Sides last year found that 65% of U.S. consumers who have seen anti-paper greenwashing claims from their service providers are influenced to switch from paper to electronic communications. The study also showed that the Two Sides North America Anti-greenwashing Campaign is having a powerful impact, preserving more than $308 million in revenue for the print, paper and mailing sector each year.

You can help Two Sides put an end to deceptive greenwashing claims that ultimately damage every business in the print and paper industry. If you see anti-paper greenwashing claims from your service providers, please scan or snip a copy and send it to

Download a copy of Two Sides’ comments to the FTC here.

The deadline for submitting comments on the FTC Green Guides has been extended from February 21 to April 24.  If your company or organization wishes to submit comments on the Guides, you may do so here.

New Research Shows Anti-paper Greenwashing Works, Misleading U.S. Consumers to Switch from Paper to Electronic Bills and Statements

But Two Sides North America’s Anti-greenwashing Campaign Preserves Millions in Annual Revenue for the U.S. Paper, Printing and Mailing Sector

CHICAGO – May 18, 2022 – Anti-paper greenwashing works, unfairly costing the U.S. paper, printing and mailing sector huge sums in lost revenue each year. But Two Sides North America’s (TSNA) Anti-greenwashing Campaign is succeeding in eliminating many of these misleading claims, clawing back hundreds of millions for these businesses, according to the results of the latest TSNA study.

In their efforts to cut costs, many leading U.S. financial institutions, utilities, telecom companies and other service providers are using unsubstantiated environmental marketing claims – greenwashing – to persuade consumers to switch from paper to digital bills and statements, suggesting that going paperless is “green,” “saves trees” or is “better for the environment.”

The new TSNA research results illustrate the damaging effects these greenwashing claims have on the U.S. paper, printing and mailing sector, finding that 65% of those who have seen anti-paper greenwashing claims are influenced to switch from paper to electronic bills and statements. The study, conducted in partnership with global research firm Censuswide, also showed that the Two Sides North America Anti-greenwashing Campaign is having a powerful impact, preserving more than $308 million in annual revenue for the sector.

The Two Sides study surveyed 2000 U.S. consumers and evaluated data on major U.S. companies that have eliminated unsubstantiated and misleading environmental claims as a result of the TSNA Anti-greenwashing Campaign. These companies represent approximately 9.5 billion annual bills and statements.

“This study not only confirms the remarkable success of Two Sides’ Anti-greenwashing Campaign, but also drives home the serious financial risk that greenwashing among service providers poses to the paper, printing and mailing sector, threatening the economic security of more than 7 million Americans whose livelihoods depend on paper,” says Two Sides North America President Kathi Rowzie.

In its most recent report (2020) on transactional mail, the U.S. Postal Service reported that U.S. households annually receive more than 15 billion bills and statements in the mail, representing 41% of total First Class mail. Bills are primarily from credit card companies, utilities, telephone/cable companies and insurance companies, while statements are predominantly sent from the financial/banking sector.

“The Two Sides Anti-greenwashing Campaign has been highly successful, but there’s much more work to do as service providers continue to distort the paper industry’s great environmental record and threaten paper, print and mail volumes with opportunistic greenwashing claims,” Rowzie says.

“And it’s important to note that banks, utilities and telecoms are not the only ones using unsubstantiated environmental claims to promote going paperless,” she adds. “Two Sides is also challenging entities like government agencies and large digital document management firms that are greenwashing to encourage both individual consumers and businesses to switch all paper communication to digital versions in the cloud, at the same time failing to recognize the vast and growing environmental footprint of electronic communication.”

Two Sides challenges greenwashing companies and other organizations in a non-confrontational way, educating CEOs and other senior management with facts from credible, third-party sources that clearly demonstrate the unique sustainability characteristics of paper products and the solid and continually improving environmental record of the North American paper industry.

“Paper is one of the few products on earth that already has an environmentally sustainable, circular life cycle,” Rowzie says. “North American paper is made from an infinitely renewable natural resource – trees grown, harvested and regrown in sustainably managed forests. It’s manufactured using mostly renewable, carbon neutral bioenergy in a process that uses water, but in reality consumes very little of it. And paper products are recycled more than any other material. But many consumers believe paper is bad for the environment because organizations seeking to cut costs or promote their own digital business objectives are telling them so. Two Sides is working hard to change that.”

For more information about the Two Sides North America Anti-greenwashing Campaign, visit



About Two Sides

Two Sides is a global, member-funded non-profit organization dedicated to promoting the uniquely sustainable attributes of print, paper and paper-based packaging. Two Sides’ members span the entire print, paper and paper-based packaging value chain, including forestry, pulp, paper, packaging, inks and chemicals, finishing, publishing, printing, envelopes and mail operators.  For more information, visit

Media Contact:

Kathi Rowzie, President

Two Sides North America