What does made with renewable energy mean on clothing? The FTC wind power example

On a clothing label or product page, made with renewable energy is a claim about the power used to make the item, and the FTC's rule is strict about it. Under 16 CFR 260.15, an unqualified claim is deceptive unless all or virtually all significant manufacturing processes use renewable energy, or energy matched by renewable energy certificates. If renewable energy covers only part of the use, the percentage should be stated.

The rule, in plain terms

Section 260.15 is the FTC's renewable energy section of the Green Guides. Paragraph (a) says misrepresenting renewable energy use, directly or by implication, is deceptive. It adds that unqualified claims are problematic if fossil fuel or fossil derived electricity powers any part of making the item or running the service, unless renewable energy certificates, known as RECs, match that use.

Paragraph (b) warns that consumers may read renewable claims differently than marketers intend. Marketers need substantiation for express and implied claims, and should qualify them clearly and prominently, for example by naming the energy source such as wind or solar.

Paragraph (c) sets the threshold. An unqualified made with renewable energy claim is deceptive unless all or virtually all significant manufacturing processes use renewable energy or RECs matched energy. Otherwise, marketers should clearly state the percentage of renewable energy used in those processes.

Paragraph (d) closes a common loophole. A marketer that generates renewable electricity but sells the RECs for all of it cannot claim it uses renewable energy.

The clothing example

Few of the Green Guides examples mention clothing. This one does. Example 1 says a made with wind power claim is deceptive when wind covers only 50% of the energy used. Saying that wind energy is purchased for half of the manufacturing facilities is not deceptive.

The lesson is about precision. "Made with wind power" on a hoodie tells the buyer the whole garment was wind powered. "Half of our manufacturing facilities run on purchased wind energy" is a smaller, true statement. The rule asks sellers to choose the second.

Other examples are useful for a brand with a mixed supply chain. A "made with renewable energy" claim is acceptable if the marketer clearly discloses all sources in a mixed portfolio, or says "made from a mix of renewable energy sources" and names the largest source, which may be calculated annually. A product with non renewable parts but renewable powered assembly can be described as "assembled using renewable energy."

Renewable materials is a different claim

Shoppers often blur energy and materials. The FTC does not. Section 260.16 covers renewable materials claims. Paragraph (c) says a made with renewable materials claim needs qualification unless the product, excluding minor incidental components, is made entirely of renewable materials. One way to reduce the risk of unintended implied claims, paragraph (b) says, is to name the material and explain why it is renewable.

The examples are not about fabric. Example 1 involves bamboo flooring: an unqualified claim may also be read as claiming recycled content, recyclability and biodegradability, which would need substantiation. A qualified version names the bamboo and notes its growth rate. Example 2 covers packaging that is 50% plant based and made from fast growing plants converted into bio-plastics, which is adequately qualified when it identifies the material and explains why it is renewable.

For clothing, the same logic would apply to a viscose or rayon garment sold as renewable because its raw material is a plant. Our reading, not the rule's text, is that such a claim would be safest if it named the plant and the fiber, in the way the FTC already does for bamboo. The agency's Bamboo Textiles page says textiles can only be called bamboo if they are made directly from actual bamboo fiber, and that rayon (or viscose) made from bamboo may be advertised as exactly that.

Why the distinction matters on a product page

A brand can be strong on one claim and silent on the other. A recycled polyester jacket sewn in a factory running on grid electricity has recycled content but no renewable energy claim. A viscose dress made from a plant can be called plant derived in a specific way, yet the mill that made it may run on ordinary grid power. The two claims do different work, and the FTC treats each separately.

The renewable energy rule also depends on a technicality that shoppers cannot see: RECs. A company can buy certificates to match its electricity use, and the rule accepts that as renewable energy use. What it rejects is double counting, where a company sells the certificates and still claims the energy.

How to read the claim

• Which step? Fabric weaving, dyeing and sewing are different processes. The rule speaks of significant manufacturing processes.
• What share? If it is not all or virtually all, expect a percentage.
• Which source? Naming wind or solar is the FTC's own suggested qualifier.
• Energy or material? If a brand says renewable without saying which, ask.

A third claim, recycled content, is often bundled with these two, and it follows its own rule in section 260.13.

Our take

Read made with renewable energy as a precise statement about power, not a halo around the garment. The FTC's own wind example shows that half is not enough to say it unqualified. Buy when the label gives a source and a share. Skip it when it gives a mood. We would watch for brands that move from adjectives to percentages, since that is what the rule rewards.