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Many products, often times foods or cleaning supplies use the phrase "Chemical Free" in their advertising and packaging. This is often used in products containing more naturally derived ingredients, and is directed towards consumers who may conflate "chemicals" with being "un-natural" or harmful.

The problem is that literally everything made out of matter is a chemical. The advertising may as well say "Matter Free".

Since there is no agreed-upon colloquial definition of "chemicals" in this sense, and the advertisement essentially relies on the consumer's unawareness, would this practice fall under the category of false advertising?

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    Doctor! I've been poisoned! Someone just gave me dihydrogen monoxide, dodecacarbon monodecahydrate, ascoltin, natrium hydrogen carbonate, and ethanoic acid. It was bubbling, so I know it must be bad. – Ray Butterworth Apr 14 at 0:47
  • Do you have an example mass produced product that explicitly is labeled "chemical free" without a qualifier? Specific compounds' non-use are often labeled in my experience (e.g. phosphate, rBST, dyes or fragrance) but I am not in the moment aware of a consumer product or food with the unqualified phrase "chemical free". – user662852 Apr 14 at 4:17
  • Another issue here is whether "chemical free" is just a "puff", i.e. a claim which is a matter of opinion and not therefore actionable. E.g. "our hand cream makes your skin super-smooth". Given the lack of consensus about what "chemical free" really means, an advertiser could claim that it doesn't mean anything and is therefore just a puff. – Paul Johnson Apr 14 at 16:28
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No

A reasonable person understands “chemical free” to mean free of artificial (i.e. man-made) chemicals.

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Not yet – in the US. There is no such thing as an "agreed-upon colloquial definition" of any term (we elect presidents, not definitions), so the existence of an ordinary meaning of every word is subject to debate pro and con. Typically, if the meaning of a word is at issue and the law has not stipulated a specific meaning in some case, the courts rely on dictionaries, or occasionally allow expert testimony. A scholarly study of dictionary definitions would show that "artificially created" is an essential aspect of the definition, and a random survey of English speakers is likely to include the sense "created by high-tech means" (most wood ash is not naturally occurring and blobs of tallow are not found in the woods: "artificial" also has a common meaning that excludes many man-made products.

The claim is therefore probably true, even though there is a specialized technical definition of "chemical" according to which the claim is false. See Nix v. Hedden for an 1893 case where the Supreme Court rejected a technical definition of tomato as "fruit" in favor of a more common interpretation. But in specific instances (depending on what's in the product) the claim might be deceptive. The term "natural" has also been applied to products for a long time, and there is a bit of clarity from the FTC. Taking the ABS complaint as an example, their decision hinges on their finding that the products "contain at least one synthetic ingredient". This is an FTC decision, which is not as powerful as a court ruling or statutory declaration by Congress, but it is meaningful. The term "synthetic" narrows the meaning of "all-natural", now we know that according to the FTC the term does not mean "found like that in mother nature with no human processing".

At present, FTC involvement in "chemical free" is fairly limited. They have found against companies whose products release VOCs, but the claims made were plainly false in claiming to not release VOCs when they do, and the rulings do not hinge simply on using "chemical" in a non-technical way.

A similar terminological crisis arose decades ago over the term "organic", which was resolved by the USDA promulgating regulations governing use of their "organic" logo, encoded in 7 CFR Part 205, and this took an act of Congress (the Organic Foods Production Act). It is extremely unlikely that the FTC will decide that the expression "chemical-free" means "contains no matter": that would be absurd. But Congress could make that decision, or, more likely, it would more narrowly state what it means to be "chemical-free".

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