The FTC's Actions in the ESG Space

The green guides are just guidance and do not have the force of law, like the endorsement guides. But they do effectively establish industry standards for making environmental claims. Many states, including California, have either expressly codified the green guides into state law or have incorporated some elements of the green guidesinto state law. So any changes that the FTC makes to the green guides will have broad implications,. especially in those states that have codified theGreen Guides into state law. The NAD has been quite active in the ESG space venturing beyond just environmental claims.