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Ledger 1 : 33 — For each dollar financing nature-based solutions in 2023, about $33 financed activities harmful to nature. (UNEP)
Cases / Green claim · United States · 2022

FTC and Justice Department seek penalties from Kohl's and Walmart over "bamboo" textile claims (United States, 2022)

Short record: the main facts, with sources. A full case file has not been prepared.

Nature's voice · report
2.5 million US dollars were paid in penalties in my name. No one has measured what reached me.
Did nature suffer? Not measured.
Not on record
  • The record does not name which of my species, waters, soils or forests were harmed.
What the record lacks: 3 none on record · 1 insufficient · 1 not measured See the gaps

On 8 April 2022 the US Federal Trade Commission announced that the Department of Justice had filed complaints and proposed consent orders against Kohl's and Walmart over rayon textiles marketed as bamboo, with penalties of $2.5 million for Kohl's and $3 million for Walmart. The orders take effect once a district court judge approves and signs them.

$2.5 million (Kohl's) and $3 million (Walmart)Penalties sought by the FTC and DOJ, 8 April 2022
Amounts in the proposed consent orders filed in the US District Court for the District of Columbia; the FTC described them as by far the largest penalties in this area.

Status As of 8 April 2022: complaints and proposed consent orders filed; the sources reviewed do not record court approval or payment.

What?
The FTC announced complaints and proposed consent orders, filed by the DOJ, with penalties of $2.5 million (Kohl's) and $3 million (Walmart) over rayon textiles marketed as bamboo with environmental-benefit claims. US Federal Trade Commission (ftc.gov)
Where?
United States: US District Court for the District of Columbia. US Federal Trade Commission (ftc.gov)
When?
8 April 2022; the products were marketed since at least January 2015, according to the complaints. US Federal Trade Commission (ftc.gov)
Who?
Gained
None on record
Lost
None on record
Harmed
None on record
Why?
The FTC alleged that the textiles were rayon rather than bamboo and that the environmental-benefit claims were false and misleading because rayon manufacture uses toxic chemicals and emits hazardous pollutants. US Federal Trade Commission (ftc.gov)
How?
The DOJ filed the complaints and proposed consent orders on the FTC's behalf, relying on the FTC's Penalty Offense Authority. US Federal Trade Commission (ftc.gov)
5 of 6 questions answered from the record · open: who

What happened

The record, in order.

On 8 April 2022 the US Federal Trade Commission (FTC) announced that the Department of Justice (DOJ), on the FTC's behalf, had filed complaints and proposed orders in the US District Court for the District of Columbia against Kohl's and Walmart. According to the complaints, their supposed "bamboo" textiles are actually made of rayon derived from bamboo, and since at least January 2015 each company had marketed at least two dozen items as made of bamboo in product titles and descriptions. The FTC said some of the "bamboo-derived" products were described as providing environmental benefits, such as being "free of harmful chemicals, using clean, non-toxic materials", and that the rayon manufacturing process uses toxic chemicals and results in the emission of hazardous pollutants.

The complaints allege violations of the FTC Act and the Textile Act and Rules. The proposed orders require Kohl's to pay a penalty of $2.5 million and Walmart $3 million, which the FTC called by far the largest penalties in this area, and prohibit unsubstantiated bamboo and related environmental claims. The Commission voted 4-0 to refer the complaints to the DOJ and approve the orders. The FTC said consent orders have the force of law when approved and signed by the district court judge.

  1. 20228 April: FTC announces that the DOJ has filed complaints and proposed consent orders against Kohl's ($2.5 million) and Walmart ($3 million) over "bamboo" textile claims

What was said

Claims, in the words of those who made them.

“False environmental claims harm both consumers and honest businesses, and companies that greenwash can expect to pay a price.”

How it looked

What was shown, beside what was recorded.

Shown

  • Textiles marketed as "bamboo", some described as free of harmful chemicals and made with clean, non-toxic materials, as alleged in the FTC's complaints.
    Kohl's and Walmart · US Federal Trade Commission (ftc.gov)

Recorded

  • The FTC's complaints allege that the "bamboo" textiles were rayon derived from bamboo, whose manufacture uses toxic chemicals and results in the emission of hazardous pollutants.
    US Federal Trade Commission (ftc.gov)
  • Proposed penalties of $2.5 million (Kohl's) and $3 million (Walmart), in consent orders that take effect once approved and signed by the district court judge.
    US Federal Trade Commission (ftc.gov)

In nature's name

What was promised in nature's name, the money that moved, and what was measured.

Money moved in nature's name

WhatKindAmountPeriod
Penalty in the proposed consent order against Kohl's
Kohl's
US Federal Trade Commission (ftc.gov)		Penalty$2.5m2022
Penalty in the proposed consent order against Walmart
Walmart
US Federal Trade Commission (ftc.gov)		Penalty$3m2022

What was measured

Not measured

The action concerned the description of the products. No independent measurement of an environmental benefit from the textiles is on record in the sources reviewed; the FTC states that rayon manufacture uses toxic chemicals and emits hazardous pollutants.

What the products were
Rayon derived from bamboo, not bamboo textiles
FTC complaints, 8 April 2022 US Federal Trade Commission (ftc.gov)
Pollution from rayon manufacture
Toxic chemicals used; hazardous pollutants emitted
As stated by the FTC; no quantities in the sources reviewed US Federal Trade Commission (ftc.gov)
Independent measurement of environmental benefit
None on record
No measurement in the sources reviewed

Findings on record

  • Registry action US Federal Trade Commission and US Department of Justice (2022-04-08) · Complaints and proposed consent orders against Kohl's ($2.5 million) and Walmart ($3 million) over rayon marketed as bamboo: “the rayon manufacturing process uses toxic chemicals and results in the emission of hazardous pollutants” US Federal Trade Commission (ftc.gov)

In court and with insurers

Every proceeding and every insurer decision on record.

Lawsuits and rulings

  1. 2022-04-08–Settled$2.5m proposed penalty
    FTC and DOJ action against Kohl's over "bamboo" textile claims
    US District Court for the District of Columbia (complaint and proposed consent order filed by the DOJ for the FTC) · Regulatory · FTC (through the DOJ) → Kohl's

    Complaint under the FTC Act and the Textile Act and Rules over rayon marketed as bamboo; proposed consent order with a $2.5 million penalty. Court approval is not recorded in the sources reviewed. US Federal Trade Commission (ftc.gov)

  2. 2022-04-08–Settled$3m proposed penalty
    FTC and DOJ action against Walmart over "bamboo" textile claims
    US District Court for the District of Columbia (complaint and proposed consent order filed by the DOJ for the FTC) · Regulatory · FTC (through the DOJ) → Walmart

    Complaint under the FTC Act and the Textile Act and Rules over rayon marketed as bamboo; proposed consent order with a $3 million penalty. Court approval is not recorded in the sources reviewed. US Federal Trade Commission (ftc.gov)

Insurers

No insurer decision on record.

What nature saw

Outcomes measured on the ground, and nature's note.

Nature's report opens this page. Below: further outcomes measured on the ground.

Product description
Rayon derived from bamboo, sold as "bamboo"
FTC complaints, 8 April 2022
Pollution from rayon manufacture
Toxic chemicals used and hazardous pollutants emitted
As stated by the FTC; no quantities in the sources reviewed
Independent measurement of environmental benefit
None on record
No measurement in the sources reviewed

What we don't know

Undisclosed, unproven, untried: recorded as data.
Benefit not measured

Nature

  • Not measured Harm to nature: The record holds no measurement of harm to nature.

Record

  • None on record Kohl's and Walmart's own responses: not on record in the sources reviewed.
  • None on record The sources reviewed do not say whether the district court approved and entered the consent orders, or on what date.
  • Insufficient Unconfirmed: an order against Kohl's dated 4 May 2022.
  • None on record The complaints and orders themselves are not among the sources reviewed; the number of products and the sales involved are not stated in the FTC press release.

Did the harm stop?

Not established in the sources reviewed.

Who paid?

Penalties proposed against Kohl's ($2.5 million) and Walmart ($3 million). Court approval and payment are not stated in the sources reviewed.

Sources

Voices on record: — Company or project✓ Government and regulators— Courts— Press and investigations— Communities and civil society— Researchers

Government and regulators

Connected cases

Related matters, and cases linked to this one through the same organisations, with the role each played in both.
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