On September 11, 2017, WLF filed comments with the FTC, opposing the agency’s proposed efforts to re-open and modify prior consent agreements by settling new enforcement proceedings with third parties. In new orders published on July 11, 2017, the FTC seeks to modify its pre-existing Green Guides regime for regulating environmental marketing claims, specifically with respect to emissions and VOC-free claims. The FTC also proposes to “harmonize” the new rules with consent orders the agency entered into back in 2013. WLF’s comments raise practical and constitutional concerns and highlight the competition-policy implications of the FTC’s ever-changing compliance regime for the architectural coatings industry. Rather than “regulation by consent decree,” WLF argues that the FTC should implement its new interpretations in formal regulations pursuant to notice-and-comment procedures. That process is much more transparent, binds the agency, and includes input from all affected stakeholders.