FTC says company didn’t have support for “organic” mattress claims

By: Lesley Fair at the FTC      Click here to see this article on the FTC Website.

Dads and Moms want what’s best for their babies, so some companies feature adjectives like “organic” or “natural” in ads for infant gear. Those are among the terms Illinois-based Moonlight Slumber used to sell its baby mattresses online and at some of the nation’s biggest retailers. But according to an FTC complaint, when it came to backing its mattress claims with proper support, the company was asleep at the switch.

In ads for its Starlight Simplicity and Little Star mattresses, Moonlight Slumber described the products as “organic” and “a safe, organic alternative to traditional crib mattresses” with a “Natural Latex Core.” The company said other mattresses it sold were made from “BabySafe Natural Materials,” including “eco-friendly plant-based foam.” The company also claimed that testing proved “there are no VOCs (Volatile Organic Compounds, commonly known as ‘Off Gassing’).”

And Moonlight Slumber suggested that parents didn’t have to just take their word for it. According to a logo the company prominently displayed, its products had the “Green Safety Shield.”

Organic and natural? Won’t emit VOCs? Proven by testing? Bearing the Green Safety Shield? On a parent’s shopping list, that’s a check, check, check, and check. But according to the FTC, those claims were deceptive, deceptive, deceptive, and deceptive.

The complaint alleges that a substantial majority of the content in the Starlight Simplicity and Little Star mattresses wasn’t organic. The cores and fire barriers contained no organic content at all and the cotton cover was 70% non-organic. In fact, according to the FTC, the only purely organic content was the mattress ribbon, a minor decorative component.

What’s more, most of the company’s mattress cores were made wholly or primarily of polyurethane, a non-natural material made from isocyanates and polyols derived from petrochemicals. Despite Moonlight Slumber’s ad claims, the latex core for the Little Star mattress was synthetic, not natural – and six other mattress styles contained little or no plant-based material. The FTC also alleges that the company didn’t have sound science to support the claim that its products didn’t emit substances like VOCs. What about Moonlight Slumber’s representation that it had testing to back up that promise? False, says the FTC.

And who bestowed the “Green Safety Shield” on Moonlight Slumber? The company awarded the seal to itself.

The proposed order prohibits a host of misrepresentations about whether a product is organic, natural, plant-based, emissions-free, or VOC-free. It also requires appropriate proof for testing claims and for representations about other environmental and health benefits. In addition, the order nixes misleading certifications and requires the company to clearly disclose when it has a material connection to an endorser. The FTC is accepting public comments about the proposed settlement until October 30, 2017.

For companies that want to rest easy about their substantiation obligations, the case offers two take-aways.

Consumers won’t take deceptive organic claims lying down. Advertisers must substantiate their organic claims. The U.S. Department of Agriculture’s National Organic Program develops standards for organically-produced agricultural products. For other product categories not covered by the National Organic Program, long-standing FTC substantiation principles apply. Advertisers must have a reasonable basis for claiming that their non-agricultural products – for example, mattresses – are “organic.” FTC and USDA staff, along with various stakeholders, discussed these issues at an October 2016 roundtable on consumer perception of organic claims.

It’s risky to sign, seal, and deliver your own seals. Duck-lipped mirror shots used to be our least favorite form of selfie, but we have a new cellar dweller: seals or certifications that companies award themselves without clearly explaining that to consumers. As the FTC’s Green Guides and dozens of law enforcement actions establish, misleading certifications raise particular concerns when they appear to give an independent authoritative A-OK for health, safety, or environmental claims that consumers can’t evaluate for themselves. If your ad features seals or certifications of your own designation, make that abundantly clear to consumers.

SSA President Dale Read clarifies who can and cannot use the USDA-NOP Seal in their marketing

The following does not represent a legal opinion or a legal representation. This is merely a research report on links and materials readily available from USDA-NOP and the Organic Trade Association (OTA.)

Manufacturers of Finished Textile or “Fiber” Products May NOT Use the USDA-NOP Seal.

A question has arisen on a number of occasions with members of the Specialty Sleep Association (SSA) and other mattress, pillow and textile products manufacturers concerning the use of the USDA-NOP Seal with marketing tools, websites, signage and public relations.

The US Government USDA and the USDA-National Organic Program (NOP) receive their authority and financing through the Farm Bill. As a result the jurisdiction or authority to create standards and enforcement for the USDA-NOP are reserved for “agricultural crops or animals  and the farms, ranches and plantations where these agri-products are grown or raised, and in the case of food products, the subsequent processing. The farms are inspected and the agri-source receives the USDA-NOP certification and use of the seal. If you use cotton, wool, coir, hemp or other “organic” fibers, even if they originate on a farm or an agricultural site that has the USDA-NOP seal, the minute you handle, wash, comb, spin, weave or process the textile or create a finished textile or fiber product, you are not authorized to use that USDA-NOP seal. There are NO USDA-NOP mattresses, pillows, futons,  toppers, sheets, comforters, or other mattress and bedding products.

The labeling requirements of the NOP apply to raw, fresh products and processed products that contain organic agricultural ingredients. Agricultural products that are sold, labeled, or represented as organic must be produced and processed in accordance with the NOP standards. Except for operations whose gross income from organic sales totals $5,000 or less, farm and processing operations that grow and process organic agricultural products must be certified by USDA-accredited certifying agents.



Since then, the seal has become a highly sought-after labeling mark in the world of agricultural products and has appeared on millions of labels, advertisements, and marketing materials.


Textile products that are labeled as “organic” must not:

•Use the USDA organic seal unless they are certified in accordance with the NOP regulations. 

•Imply or lead the consumer to believe that the final product is certified under the NOP Regulations unless they are certified in accordance with the NOP regulations. 

•Use a combination of both organic and non-organic sources for a single fiber that is identified as “organic” in the final product.


As a practical alternative, the policy memo explicitly confirms that textile products produced in accordance with GOTS, such as apparel, mattresses, or socks, may be sold as “organic” in the United States, although they may not refer to NOP certification or carry the USDA Organic seal. 

The BEDFAX Survey Results are in

The Specialty Sleep Association (SSA) wants our membership’s opinions as we pursue various policies and programs.  Our active SSA Board of Directors has voted specifically to reach out to our retailer and manufacturing members to get your opinions on various topics.  One of those topics is the BEDFAX® Verified Contents Label Program for Mattresses. We launched our BEDFAX volunteer labeling program with a fanfare of enthusiasm expecting a high participation rate from the industry in what we thought would be a powerful consumer-focused sales tool for mattress sales. We found however, that initial enthusiasm did not in fact translate into high participation. With this in mind, we created a five-question survey on BEDFAX and sent it out to our extensive list of SSA Showroom Attendees …a total of 3128 recipients including retail owners, retail buyers, manufacturers and suppliers. Our plan was to get a broad-based response from as many SSA showroom attendees as we could get.

Distribution and response rate:  Out of a total of 3128 e-mailed surveys, the SSA heard from 197 respondents (a rate of 6%). While that is an average response rate, the number was so large that we received some valuable although diverse information from those who replied. Out of the 197 respondents 110 only answered the very first question, while 87 completed the entire five-question survey. The vast majority of respondents (167 or 85%) were retailers, while a much smaller percentage (30 or 15%) were manufacturers and suppliers to the mattress industry.

The findings were very informative, if somewhat contradictory. Let us explain.

The first question was simply: Do your customers ever ask you or your retailers, “What is this mattress made of?”  An overwhelming 81.31% of respondents replied YES.  Only 18.69% said that consumers do not inquire about the contents of mattress. So on the surface that should put the debate over that question to bed...or so you’d think. It more or less confirms that contents are an issue, and those consumer-focused advocates who want a complete contents label are not wrong in their assumptions that consumer DO care about “what’s inside” ...at least that is what 81% of our survey says.

The second question is where things began to get a bit contradictory or slightly confusing. The SSA asked “Do YOU have mattresses for which you would find this kind of contents verification helpful for the RSA or consumer? Again 81.61% of the people answering all the questions said “YES.”  But the 18% who said “NO” had strong opinions. One said, “We believe that the information supplied is adequate.” Another said, ‘”Nothing really tells what is in our mattresses.” A third, said, “ Virtually no one cares.” And another said that such a system would expose, “the really junky foam and coat hanger wire scam the major brands market.” While a minority, the negatives were loud and clear in their opinions.

Our third question was, “Do you think a clearer contents label would affect the sale of mattresses to any degree? (Would it be helpful?) While the answer was still a strong “YES” at 74% favorable, the 26% of NO’s still were strong in their opinions. On the favorable side one theme that evolved out of this research and was repeated several times: ”This would be very helpful, especially when it comes to ‘natural’ content. This is applicable to environmental concerns.”  On the other hand several respondents stated that consumers do not read the label or that too much information can be a bad thing for selling.  One retailer said that the information already provided was adequate, and another stressed that “comfort is the main determinant.” The one trend that did seem to emerge from this question was that the BEDFAX labeling program could lend itself to “environmental” or “natural” sales. There is a parallel with health, safety and wellness customers with consumers concerned about truth in labeling.

The next question focused on details of the label program itself, more or less guidance and details on how such a labeling program would work effectively. This question deserves a separate report or write-up itself, as the SSA plans and executes the details of the BEDFAX® Program.

Our final question was a critique. We asked our members and attendees what their biggest reservation or concern was about the BEDFAX® Verified Mattress Contents Label Program.  “Could it be a negative?”  Only 36% answered that this could be a negative, while 63 % answered, “No, it was not a negative.” In fact a few expressed support such as “I’m not sure I have any objections” or “I love the idea.”  Some were neutral or mildly concerned expressing ideas such as, ”Not every customer cares or understands” or they expressed concern that an open system could actually benefit competitors. However the 36 % negatives (1/3rd of the respondents) really did give us a lot to think about. Answers varied from: “Offers too much honesty.” “Customers may shy away from mattresses with high petroleum-based foam content” or “there has to be methodology to prevent manufacturers from cheating with their claims.” One respondent worried that too much information could create confusion and complicate the sale, another was concerned about too many labels and another said he/she did not have enough information to answer.

Stepping back, there are several overall conclusions at this point.  I think we can safely conclude that if the BEDFAX program is to succeed, it has to be consumer-driven. When consumers ask for better/clearer/more trustworthy contents labels on mattresses that they buy, (as they enjoy on other goods), then we will see retailers asking their manufacturers to provide them. Without this push, the industry alone has too many reservations and concerns to get involved. Finally, and probably most importantly, there really does seem to be a correlation between environmental or health, wellness and safety marketing claims and a successful contents label program.

We welcome any further thoughts, opinions or feedback you may have.

Bedfax® Member NATUREPEDIC ORGANIC featured in OTA News

From The Organic Trade Association Newsletter May 5th

Beyond food: Organic lifestyle brands star in pop-up event in New York -Organic Trade Association and sponsors present "Live Organic from Farm to Home"

WASHINGTON, D.C. (May 5, 2017)—Organic is not just for eating anymore, and more than a dozen cutting-edge and innovative organic fashion and home textile brands are helping the Organic Trade Association (OTA) prove that point in an inspiring, educational and entertaining two-day pop-up event in the heart of Manhattan.

Presented by OTA and OTA's Fiber Council with the generous support of 24 outstanding sponsors, the specially designed pop-up venue – open to the public on Friday and Saturday, May 5 & 6, at the Treehaus organic café and food market -- showcases the latest in organic products for the home and for the closet. 

The all-organic pop-up shop features organic cotton T-shirts and baby clothes, organic wool sweaters and socks, organic sheets and blankets, even organic mattresses. "Live Organic from Farm to Home" is connecting the dots between that organic T-shirt or sweater and the organic cotton farmer and the organic sheep raiser; between the organic mattress factory or an organic fabric dyeing factory and the downstream impact on our water and soil.

"At Timberland, we hold ourselves accountable for what goes into our products as well as how they're made, and we're constantly seeking innovative solutions to reduce their environmental impact," said Colleen Vien, Sustainability Director for outdoor lifestyle brand Timberland, one of the event's sponsors. "Conventionally grown cotton uses more insecticides and requires significantly more water than organically grown cotton. As such, Timberland has had a longstanding goal of increasing our use of organic cotton year over year." 

Kicking off #LiveOrganic was a VIP reception on Thursday evening. Media guests met and mingled with the leaders and pioneers of the organic textile industry, talked with the farmers who are committing their lives to growing organic fiber in the most environmentally sustainable way, and heard the unique stories of each of the sponsoring brands. 

"We've worked diligently for 23 years to maintain our integrity as environmental stewards and to educate the consumer on the importance of using U.S. grown organic cotton. You care about what you put into your body ...you should care about what you put on your body as well," said Jimmy Wedel, an organic cotton farmer from the Texas High Plains and President of the Texas Organic Cotton Marketing Cooperative (TOCMC) in Lubbock, Texas. TOCMC farmer members produce most of the organic cotton grown in this country. Wedel is a third generation farmer who farms over 4,000 areas, almost all certified organic.

Living an organic lifestyle

Today's consumer is embracing an organic food-to-fashion-and-home lifestyle. Organic food is now found in over 80 percent of American kitchens. And the American organic textile market is now a billion-dollar-plus market, posting robust double-digit growth in recent years. Organic fiber is in demand for everything from organic bath towels to baby clothes to high fashion. Consumers are increasingly looking for clean products without toxins, unnecessary ingredients, and which are produced in ways that do not harm the environment.

"Coyuchi knows how important organic fiber and sustainable practices are to our customers, so we've gone one step further," said Eileen Mockus, CEO of Coyuchi organic bedding company. "To extend the longevity of our organic cotton bedding and towels and ensure it won't end up in a landfill, we're created our new circular subscription service which lets you send back your linens and allows us to renew, upcycle, or recycle them." 

More than 13 million tons of textiles end up in U.S. landfills, according to findings by the U.S. Environmental Protection Agency. But long before textiles reach the landfill, the production of conventional fiber is compromising the environment. Over thirty eight million pounds of pesticides were used on conventional cotton in 2014 in the U.S., making cotton third in terms of pesticide use after only corn and soybeans, according to the U.S. Department of Agriculture.

Sponsors of #LiveOrganic inspired the enthusiastic gathering on Thursday when they shared the mission of their companies and the passion for a clean world that created – and continues to create – their widening array of products.

"Responsible sourcing through environmentally and socially conscious practices, along with a commitment to transparency and community are important to everyone at Ramblers Way," said Nick Armentrout, Supply Chain Manager for sustainable and organic clothing maker Ramblers Way. "When Ramblers Way sources organic wool, we use the Global Organic Textile Standard (GOTS) to help us assure environmental and social standards are followed from farm to fabric to fashion."

"From the field to your home, the Grund organic cotton bath rugs offer a chemical free option – no harmful pesticides and chemicals during production, harvesting and processing," said Michael Twer, Vice President, Sales/General Manager for organic bath maker Grund. "Each rug to towel is responsibly made to the absolute highest social and environmental standards, and the cotton used can be traced to the very community of cultivation."

"Naturepedic mattresses do not contain any polyurethane foam, formaldehyde, pesticides, GMOs, vinyl or any questionable materials," said Chris Robinson, Vice President, Sales & Marketing for Naturepedic organic mattress company. "Our mattresses are made without harmful chemicals of any kind, including flame retardant chemicals, or chemical flame barriers."

While the pop-up focuses on what we put on our body, the dots also connect organic cotton production to healthy organic food. Two-thirds of the harvested organic cotton crop is used in food and cattle feed. Organic cottonseed has been found to be a source of high nutrition, protein and energy in organic animal feed rations, and to boost milk production and butterfat in dairy cows. Cottonseed oil is one of the most widely used cooking oils, and organic cottonseed oil offers consumers the huge benefits of being produced from crops grown without pesticides and chemicals. 

"Our company was founded on the belief that organic makes a difference for families, farming communities and the environment," said Mike Ferry, president of Horizon Organic dairy company. "That commitment remains true today, so we are proud to support organic throughout the supply chain, in the dairy industry and beyond, and are happy to sponsor the OTA's first Live Organic from Farm to Home Pop-Up Shop."

A healthier world for all, from farm to home

OTA's Organic Fiber Council was convened in 2015 with the goal to unite the organic fiber sector with a cohesive voice, identify the challenges and opportunities in the organic fiber sector, educate the consumer about the importance of organic fiber, and help move the sector forward. 

"OTA and the Organic Fiber Council are thrilled to be telling the story of organic fiber and textiles, and to be showing the public in such a fun and engaging way why it truly makes a difference when you choose organic in every part of your life. And we're honored to be working with these industry pioneers – they're creating a healthier world for all of us," said Gwendolyn Wyard, Vice President of Regulatory and Technical Affairs for OTA and staff coordinator for the Organic Fiber Council.

The #LiveOrganic pop-up can be visited on May 5 and 6 from 11 a.m. to 8 p.m. at Treehaus MiMA, 470 West 42nd St.

The sponsoring organic fiber brands are Coyuchi, Dhana, Gallant, Grund, MetaWear, Naturepedic, Organic Cotton Plus, prAna, Ramblers Way, Spiritex, Synergy, Syona Home and Timberland. Sponsoring brands, farmers, organizations and retailers are Control Union, Global Organic Textile Standard (GOTS), Horizon Organic, OneCert, Oregon Tilth, MOM's Organic Market, Organic Valley, Texas Organic Cotton Marketing Cooperative, Textile Exchange, Whole Foods, and the Richard D. Siegel Law Offices.

Organic Trade Association presents "Everything you want to know about labeling textiles"

See the OTA Newsletter here

The Organic Trade Association, Global Organic Textile Standard and Textile Exchange are coordinating a joint webinar to provide the industry with guidance on labeling textiles that contain organic material for sale in the United States. Any company with product sold in the United States or that is planning to begin sales in the U.S. is invited to attend the webinar. Learn more about U.S. regulations for organic textile labeling, different kinds of organic claims and how you can use the Organic Content Standard (OCS) and Global Organic Textile Standard (GOTS) to support your communications on products. The webinar will take place two times on Tuesday, April 11, to allow attendees from Europe, Asia, and North America to take part. Register here for 10 a.m. Eastern, 3 p.m. GMT, 4 p.m. CET, and 10 p.m. China. Register here for 12 Noon Pacific, 2 p.m. Central, and 3 p.m. Eastern.


Bedfax® at ISPA Seeking Answers From Mattress Manufacturers, Suppliers & Retailers

Bedfax®  sponsored a table at the 2017 ISPA (International Sleep Products Association) Conference in order to conduct the first phase of a new survey asking about transparency in marketing and the use of the BEDFAX as a tool for selling mattresses.  More to come on this very soon.

Dale and Tambra enjoyed the conference with SSA members Kenny Oliver and Richard Ayers from Jones Fiber Products, Kevin Callinan and Jim Gutierrez from Latexco, Nate Cangemi and Uli Hammer from Muller Textiles, Angela Owen from Suite Sleep and Tim and Henry McCree from Wm. T. Burnette.  

SSA President Dale Read and Executive Director Tambra Jones at the Bedfax® Table

SSA President Dale Read and Executive Director Tambra Jones at the Bedfax® Table

Kevin Callinan and Jim Gutierrez from Latexco, with SSA Chairman Angela Owen from Suite Sleep

Kevin Callinan and Jim Gutierrez from Latexco, with SSA Chairman Angela Owen from Suite Sleep

Kenny Oliver and Richard Ayers from Jones Fiber Products with SSA's Tambra Jones

Kenny Oliver and Richard Ayers from Jones Fiber Products with SSA's Tambra Jones

Uli Hammer and Nate Cangemi from Muller Textil Group

Uli Hammer and Nate Cangemi from Muller Textil Group

Harrison Murphy from Ventex with SSA members Tim and Henry McCree from Wm. T Burnette.

Harrison Murphy from Ventex with SSA members Tim and Henry McCree from Wm. T Burnette.

FTC Rules California Naturel, Inc. Misled Consumers, Violated the FTC Act. Order bars company from deceptively labeling products as “all natural”

FTC Rules California Naturel, Inc. Misled Consumers, Violated the FTC Act.  Order bars company from deceptively labeling products as “all natural”

As of Monday, December 12th. the Federal Trade Commission (FTC) announced action taken against a company called “Naturel, Inc.” claiming that the company “Misled Consumers and Violated Sections 5 and 12 of the FTC Act.  The FTC findings are quite self-explanatory:      Click headline to read full article

SSA Has Revised Its Vision, Mission, Elected New Officers and Board Members, Two New Websites, the BEDFAX® Program and Created a New SSA Logo

After two years of working-committee meetings and SSA Board of Directors meetings, the Specialty Sleep Association (SSA) has completed the non-profit industry group’s updated vision and mission statements; elected new officers; created an expanded board; introduced two new websites (www.sleepinformation.org and www.bedfax.org ); introduced the final, restructured BEDFAX® consumer disclosure contents label program and promulgated the new SSA logofor membership and marketing purposes at the Las Vegas Summer 2016 market.
Starting with a meeting held in the snow in Boulder, Colorado in the early spring of 2014, over a period of two years the SSA redefined its overall vision for the future and its mission (see below) , and then set about restructuring the governing board, the association’s websites, its consumer transparency labeling program and concluded this fundamental phase of the change process with the introduction of the new clean, crisp and modern SSA logo (see attached). “It took us two plus years,” says SSA President Dale T. Read; “however, this focused non-profit industry association has emerged with new board members and officers, new vitality and energy, new websites, a renewed message and a new look and feel with both the BEDFAX® program and the SSA logo.”

“To serve sleep innovators, both manufacturing and retail, by promoting members, product transparency, and education.”

SSA’s vision is to be a trusted authority for consumers on product transparency and education for specialty sleep products.

“Our re-focus with the updated mission statement,” says Read, “puts us back center stage in the business of advocacy for innovators and emerging companies in the specialty sleep field. If you look at our SSA Showroom in Las Vegas, where we have over 30 manufacturing exhibitors, you will see innovative, cutting edge products offered by emerging companies. These innovators offer the industry new types of foams, suspension systems, biometric monitoring and measurement systems, organic materials, new designs, accessories for heating and cooling,  power and electronics, as well as top-of-bed, under-the-bed andfashion accessories to name a few of the product categories,” says Read. “For over two decades we have been an advocate or a host for emerging specialty sleep companies offering new products to the retail marketplace. Many of the larger, well known mattress/ bedding exhibitors in Las Vegas today started out with the SSA over 20 years ago on our show floors in Orlando, San Francisco or Las Vegas. Both returning and new companies approach us for every market, and we are pleased to serve the vital role as an advocate and a sponsor for these emerging companies,” states Read.

“We should also note because of this vital service, which we offer specialty sleep and accessories manufacturers and the attending retailers of all types and sizes, we have sold out our show space for the past several years.  Since the time following the Recession in 2010, we at the SSA have experienced a strong rejuvenation, and financial solvency that allows us to carry out our multi-faceted mission focused around advocacy and retailer education of innovative sleep products.”

News Leadership and the Next Horizon  

This past summer in Las Vegas, the SSA elected three new officers to govern the board and added two new members to the SSA board.  Angela Owen, CEO and Owner of Colorado based Suite Sleep was elected to serve as Chairman of the Specialty Sleep Association. Owen, who has more than fifteen years of experience in the sustainable bedding industry, sees her leadership as a bold challenge to try to change the industry’s “smoke and mirrors” sales tactics to clear and transparent product labeling. “As the new chairperson of the SSA, I see two distinct challenges ahead,” states Owen, “First, we need to redirect our education and appeal for the BEDFAX®  transparency labeling program to retailers and consumers, as opposed to just manufacturers. Secondly, we are going to explore added-value for SSA members to encourage growth and expansion of our membership including specialty sleep retailers, manufacturers and industry suppliers,” says Owen.

Sarah Bergman, who is Vice President of Marketing & Creative for PureCare, who oversees the company’s brand development, design, social media, PR, marketing and retail enhancements ( POP,etc.) was elected to serve as Vice Chairman of the SSA. At the same meeting, Pascal Roberge, Director of Sales for Beaudoin, a leader in bed frames, support systems and upholstered beds was elected to serve as the SSA Secretary / Treasurer. Among other duties, Roberge will be focused on developing SSA-sponsored research and marketing advocacy for the expanding under-the-bed, frame and support category.  Dale Read and Tambra Jones were also re-appointed to serve respectively as President and Executive Director of the SSA.

In addition to the three newly elected officers, the SSA board also elected two new members to the board expanding it to a total of ten voting members.

With the goal of increasing and strengthening retailer representation on the SSA board, the board has elected specialty sleep veteran Brian Davis, General Manager of the Saint Louis, MO-based Bedroom Store with 15 locations in the Midwest. Davis’s long affiliation with specialty sleep guru and former President of the SSA Denny Boyd helps re-focus the SSA in its mission to address specialty sleep issues at the retail level. Davis will serve for three years on the board. At the same time, looking for new blood and an international perspective, the board elected Thomas Frismodt, CEO of US-based Danican, an innovative and growing specialty sleep company, to a three-year term. Frismodt has blazed a trail of marketing and product achievements at companies in Denmark, Sweden and now in North and South America. Frismodt’s company brings a new, expanding and modern touch to the SSA showroom C-1565 at the World Market Center, Las Vegas.

The unveiling or introduction of the new SSA Logo was the final act or icing on the new cake for the SSA. The logo was developed by a branding committee consisting of Sarah Bergman, Mark Miller, Angela Owen and Tambra Jones. “We are pleased to introduce this new, clean, contemporary and stylish logo: one that fulfills our vision, mission and our future plans. It works very well with our new BEDFAX® logo introduced earlier in the year at the ISPA EXPO in Florida, states Executive Director Jones.

Putting Disclosures to the Test - A public workshop


The Federal Trade Commission will host a public workshop in Washington, DC on September 15, 2016 to examine the testing and evaluation of disclosures that companies make to consumers about advertising claims, privacy practices, and other information.

Effective disclosures are critical in helping consumers make informed decisions in the marketplace.  

  • Many advertisers have used disclosures in an attempt to prevent their advertisements from being deceptive. Disclosures must be crafted with care both with respect to their language and presentation. Disclosures used in the marketplace are sometimes ineffective.  Commission staff has recommended that disclosures be tested for effectiveness.
  • Disclosures are also challenging in the privacy arena, whether disclosing to consumers that their physical location or online interactions are being tracked, or explaining privacy practices when consumers sign up for a service. Privacy policies are often long and difficult to comprehend and privacy-related icons may fail to communicate information meaningfully to consumers. Furthermore, the accompanying mechanisms for consumers to provide informed consent or exercise choices about the use of their data may also be confusing. The Commission has long encouraged the development and testing of shorter, clearer, easier-to-use privacy disclosures and consent mechanisms.
  • The FTC has issued guides to help businesses avoid deceptive claims, such as guidance related to endorsements, environmental claims, fuel economy advertising, and the jewelry industry. Often the guidance presents options for qualifying claims to avoid deception. In developing guides, the Commission has sometimes relied on consumer research to gauge whether specific disclosures can be used to qualify otherwise misleading claims.

The FTC has a long commitment to understanding and testing the effectiveness of consumer disclosure, and is especially interested in learning about the costs and benefits of disclosure testing methods in the digital age.  A number of factors impact the effectiveness of disclosures, including whether they contain the most essential information and consumers notice them, direct their attention towards them, comprehend them, and are able to use that information in their decision making.  Some testing methods are more appropriate than others for evaluating these factors.

The workshop is aimed at encouraging and improving the evaluation and testing of disclosures by industry, academics, and the FTC.  The FTC’s workshop will explore how to test the effectiveness of these disclosures to ensure consumers notice them, understand them and can use them in their decision-making.   It is intended to further the understanding of testing and evaluation of both offline and online consumer disclosures, including those delivered through icons, product labels, short text, long text, audio or video messages, interactive tools, and other media. Topics may include evaluation criteria, testing methodologies and best practices, case studies, and lessons learned from such testing.

An agenda will be available prior to the event. No registration is necessary to attend. The workshop will be webcast and a link will be available here on the day of the event.








Under the Freedom of Information Act (“FOIA”) or other laws, we may be required to disclose to outside organizations the information you provide when you pre-register. The Commission will consider all timely and responsive public comments, whether filed in paper or electronic form, and as a matter of discretion, we make every effort to remove home contact information for individuals from the public comments before posting them on the FTC website.

The FTC Act and other laws we administer permit the collection of your pre-registration contact information and the comments you file to consider and use in this proceeding as appropriate. For additional information, including routine uses permitted by the Privacy Act, see the Commission’s comprehensive Privacy Policy.

This event is open to the public and may be photographed, videotaped, webcast, or otherwise recorded. By participating in this event, you are agreeing that your image — and anything you say or submit — may be posted indefinitely at ftc.gov or on one of the Commission's publicly available social media sites.

Addressing organic claims on non-agricultural products

The Federal Trade Commission (FTC) has released a study on consumer perceptions of organic claims,  and announced it will host a roundtable discussion with the U.S. Department of Agriculture in Washington, D.C., on October 20 to help the two agencies better understand how consumers perceive “organic” claims made on non-agricultural products such as personal care products and textiles. The roundtable is open to the public, and FTC welcomes written comments, including further evidence of consumer perceptions. The comment period for written comments will remain open until December 1. This action comes as a result of the Organic Trade Association (OTA) participating in numerous meetings with FTC and the National Organic Program, and submitting extensive comments urging FTC to exercise its consumer protection authority and take action against the fraudulent and misleading use of the term “organic” on products that fall outside of NOP’s scope of authority (such as shampoo, t-shirts, mattresses, household cleaners). OTA will attend the roundtable event and submit comments. OTA is in the initial stages of reviewing the study, and will convene a task force to help shape comments on how to best address consumer deception and education. Interested in learning more, or in participating in a task force? Contact Gwendolyn Wyard, OTA’s Vice President of Regulatory and Technical Affairs.