NOVEMBER 2020 / BEVERLEY THORPE, CHERI PEELE , & MARK S . ROSSI

RETAILER'S GUIDE TO SAFER CHEMICALS & MATERIALS

GETTING STARTED & BEYOND

Clean Production Action is a nonprofitdedicated to designing and deliveringstrategic solutions for green chemicals,sustainable materials, and environmentallypreferable products. Our tools simplify thecomplexity of reducing the chemicalfootprint of products and supply chains. Ourcollaborations provide effective platforms forpractitioners and thought leaders to worktogether in advancing safer chemicals andhealthy materials. Business, environmental,investment, government, and academicleaders use GreenScreen® for SaferChemicals and the Chemical FootprintProject Survey, and engage in our BizNGOgroups and Investor Environmental HealthNetwork, to create a safer and healthiertomorrow for people and the planet.

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WHO WE ARE

Introduction (4)

1. Why Retailers Should Take Action on Chemicals of High Concern (5)a. Weak regulations amplify the business risk of selling products containing hazardous chemicals and underline the need for retailers to move beyond legal compliance (5) b. Hazardous chemicals cause long term and serious health impacts – and many are found in consumer products (7)c. Increasing Demand by Consumers for Safer Chemicals and Sustainable products (9)d. Investors are including chemical risk in the materiality of retailers (10)

2. The Retailer's Guide: Steps to Best Practice from the Chemical Footprint Project (CFP) (12)

a. Become a CFP Signatory (13)b Respond to the CFP Survey (13)

3. How to Use this Guide: Five Modules (14)

Module 1:  Management Strategy: Developing a Chemicals Policy (16)

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CONTENT OVERVIEW

ManagementStrategy: Chemicals

Policy

a. Learn from external stakeholders (16)b. Establish a chemicals policy and integrate into business strategy (18)c. Implement & communicate the chemicals policy (22)

Module 2:  Restricted Substances List and Priority Products:Removing Chemicals of Concern in Products (24)

a. Identify priority products and Chemicals of High Concern (24)b. Develop a restricted substances list (RSL) and priority chemicals list (26)c. Commit to continuous improvement (31)

Module 3: Chemical Inventory: Working with Brands (33)a. Work to build a chemical inventory (33)b. Engage brands & suppliers in disclosing chemicals in products (business to business) (34)c. Engage brands and suppliers in disclosing chemicals to consumers (business to consumer) (36)d. Prefer brands who use safer chemicals and third party certifications (36)

Module 4: Chemical Footprint Measurement: Getting Started (38)a. Measure the chemical footprint in defined product categories (39)b. Set goals to reduce the chemical footprint in defined product categories (39)

Module 5: Public Disclosure of Policies, Chemicals and Progress toGoals (41)

a. Measure the chemical footprint defined in product categories (42)

RestrictiedSubstances List (RSL):Priority Chemicals &

Products

Chemical Inventory:Priority Chemicals &

Products

Chemical Footprint:Goals & Progress to

Goals

Public Disclosure ofPolicies, Goals &

Progress

b. For private label products, disclose chemical ingredient information (business to consumer) (42)c. Disclose progress to goals (43)

Glossary (46)Appendix A: Chemical hazard list resources (49)

Sitting at the interface between consumers and brands, retailers are in the unique position tointegrate sustainability features into the products they place on their physical and virtual shelves –but knowing how to do this may seem overwhelming. This is a how-to guide for retailers that wantboth to address consumer concerns with hazardous chemicals in products and meet consumerpreferences for products made with the safest and healthiest chemicals and materials.  This Retailer's Guide is for those who are starting, or already on the journey to chemicalsmanagement beyond legal requirements. Retailers are often caught by surprise and need to reactquickly to customer concerns, campaigns from environmental groups, and new chemicalregulations but knowing what actions to take can be challenging. The Guide lays out the rationalefor moving beyond regulatory compliance to safer chemicals in retail through five modules.

The Retailer's Guide builds from Clean Production Action’s more than 15 years of experience inworking with companies and non-governmental organizations (NGOs) in documenting best andbetter practices in chemicals management. Our Healthy Business Strategies report (2006), theBizNGO Guide to Safer Chemicals (2012), and The Business Case for Knowing Chemicals in Productsand Supply Chains (written for the United Nations Environment Programme) all documented howcompanies are achieving positive business results through good chemicals management in a rangeof sectors, including apparel, electronics, building, and retail.

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INTRODUCTION

Our research findings and discussions within our BizNGO working groups reveal that chemicalsmanagement is a journey, with many steps to be taken and lessons to be learned along the way.Both The Guide to Safer Chemicals and the Chemical Footprint Project Survey recognize theimportance and challenges of taking the first steps beyond regulatory compliance.

Retailers are joining the Chemical Footprint Project and BizNGO to learn how to assess andimprove the chemicals management practices of their suppliers as well as those of their ownorganizations. We welcome retailer participation in the Chemical Footprint Project and BizNGO anvalue feedback from all interested parties on how to improve this Guide and related resources tosupport all organizations in their journeys to safer and healthier chemicals. Retailers thatimplement a comprehensive chemicals management program can meet customer demands foravoiding hazardous chemicals and using safer alternatives in products and supply chains andanticipate regulatory pressures to do so. The CFP Survey gathers data on best practices incorporate chemicals management and is a useful foundation for this Guide.

Retailers spend resources on being in legalcompliance but this does not provideinsurance against the business risk of sellingproducts containing hazardous chemicals,because most hazardous chemicals areunregulated.  In fact, of the more than80,000 known chemicals widely used incommerce, few have even been adequatelytested for human health and environmentalimpacts due to the historical legacy ofallowing chemicals to be put on the marketwith little to no data requirements. This hasresulted in international regulatory effortsto fill these data gaps and then pass

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WHY SHOULD RETAILERS TAKE ACTION ONCHEMICALS OF HIGH CONCERN? Because weakregulations, health impacts, consumer trends andinvestor focus on chemicals are all business risks

1.

For investors, hazardouschemicals represent ‘thenew carbon.’

BANK SAFRA SARASIN LTD.

Chemicals are the building blocks of materials and products. Acleaning product, an article of clothing, and a piece of furniture areall comprised of chemicals. Some chemicals are inherentlyhazardous to human health or the environment, such as lead,Bisphenol A (BPA), and formaldehyde.  These chemicals may play aneeded function but have unintended consequences by leaking outinto the environment and posing threats to human health wildlifeand the natural world.

Other chemicals, such as water, or H2O, a substance wedrink and bathe in every day, are inherently safer forpeople and the planet. But for retailers the questionand challenge is, how can they move proactively toensure that their private label products and brandproducts avoid hazardous chemicals?  How can theystay ahead of new concerns with chemicals?

a. Weak regulations amplify the business risk of sellingproducts containing hazardous chemicals and undermined theneed for retailers to move beyond legal compliance.

regulations to restrict the use of hazardouschemicals, but the regulatory ‘catch up’process is slow with a lagging review process.However, many chemicals can be classified aschemicals of high concern because of theirpresence on authoritative chemical hazardlists.  These lists and databases keep abreastof new scientific understanding of chemicalhazards. Therefore retailers can move beyondlegal compliance by identifying chemicals ofhigh concern in products and packaging andwork with suppliers to restrict them.

that is carcinogenic, mutagenic, or toxic toreproduction (CMR); orthat is persistent in the environment,bioaccumulative, and toxic (PBT); orthat causes any other adverse effect forwhich there is scientific evidence of probableserious effects to human health or theenvironment that give rise to an equivalentlevel of concern (for example, an endocrinedisruptor or neurotoxicant); or whose breakdown products result inchemicals or substances that meet any of theabove criteria.

The regulatory process to restrict chemicals isslow, even in the face of new scientificinformation, and it has a lagging reviewprocess with ongoing challenges ofconfidential business claims for access todata on many chemicals.

Even when a chemical is shown to have highhazard, it may only be restricted in certainuses. For example some regulations haverestricted the use of BPA in baby bottles butstill allow its use in cashier receipts and canlinings, even though the same degree ofhazard remains with different exposureroutes.

Chemicals of high concern (CoHC) pose seriousthreats to human health and the environment.Clean Production Action defines a CoHC as achemical or substance:

This definition aligns with the GloballyHarmonized System for Chemicals and theEuropean Union’s definition of a Substance ofVery High Concern. Chemicals with the abovecharacteristics of a CoHC are commonly found inconsumer products and manufacturingprocesses, requiring retailers to move beyondregulatory compliance for a variety of reasons:

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Americans are exposed to atoxic soup of more than 80,000different chemicals, but wehave no idea what the impactof those chemicals is on ourbodies — or those of ourchildren. Current law has failed toprotect Americans andCongress can't afford to standon the sidelines any longer. SEN. TOM UDALL, MARCH 10, 2015SPEAKING OF THE NEED FOR TOXICSSUBSTANCES CONTROL ACT REFORM.

Not knowing about the extent of hazardouschemicals in products is a business risk forretailers. NGO campaigns routinely testproducts for hazardous chemical ingredientsto alert the public and shareholders, such asPFAS in microwaveable popcorn bags,phthalates in macaroni and cheese fast food,formaldehyde in flooring, or heavy metals andPVC in a range of retail products.

Markets are continually shifting and movingbeyond regulatory compliance. For example,BPA-free water bottles are in demand due toscientific evidence of BPA health impacts andconsumer awareness. In 2011, SIGGSwitzerland’s distributor in the U.S. filed forbankruptcy with $13 million in liabilities afterfailing to disclose the presence of Bisphenol Ain its aluminum water bottles.

In 2013, Walmart paid $81.6 million in finesfor the mishandling of products sold in itsstores that became damaged or werereturned, thus becoming hazardous waste.This was a factor in prompting the retailer todevelop a chemical management plan beyondlegal compliance.

Dollar Stores are prevalent incommunities near high risk chemicalfacilities and hazardous chemicals inproducts sold by these retailers willfurther compound residents’exposures.

Hazardous chemicals that injure thedeveloping brain are among the knowncauses for a rise in neurodevelopmentaldisabilities, including autism, attention-deficit hyperactivity disorder, and dyslexia.

economies. Hazardous chemicals released intocommunities compound the problem. In the UnitedStates, almost 124 million people (39% of the U.S.population) live within 3 miles of one of about12,500 hazardous facilities according to the US EPA. These high-risk industrial and commercial facilitiesuse or store very hazardous chemicals resulting inair and water contamination of nearby communitieswhich are predominantly low-income communitiesof color, causing disproportionate exposure to thesealready vulnerable populations. Dollar Stores areprevalent in communities near high risk chemicalfacilities, and hazardous chemicals in products soldby these retailers further compound residents’exposures.

The production and use of hazardous chemicals continues to generate lawsuits and drop instock value. For example, DuPont and 3M face ongoing legal suits from PFAS contamination;Johnson & Johnson for the presence of asbestos in talc products and Bayer for herbicidescausing cancer and crop damage. Retailers who stock products containing these and otherchemicals of concern are under increasing pressure to remove them and find safersubstitutes.

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For many people...the mostsignificant exposures to hazardouschemicals may come fromconsumer products.

Since the frequency of consumercontact with products and theexposure duration are often high,these exposures can result insignificant chemical concentrationsin human bodies, especially duringpregnancy.

PG. 123. UN GLOBAL CHEMICALS OUTLOOK 2019.

b. Hazardous chemicals cause long term and serious healthimpacts - and are found in consumer products.

Common household products can be a keysource of exposure to harmful chemicalsthrough direct contact, ingestion and/orthrough the surrounding environment suchas household dust or air. The GlobalChemicals Outlook report stated that formany people in higher-income countries(and some in middle - and lower-incomecountries) the most significant exposures tohazardous chemicals may come fromconsumer products. This report notes that,“Since the frequency of consumer contactwith products and the exposure durationare often high, these exposures can result insignificant chemical concentrations inhuman bodies, especially during pregnancy”(pg. 123).

In addition the most common sources ofindoor air contaminants in high consumingsocieties are building materials, householdfurnishings, and products. Products such asperfumes, hairsprays, air fresheners,furniture polish, cleaning solvents, hobbyand craft supplies, pesticides, glues,adhesives, sealants, and carpet and fabricdyes and fibers are all likely contributors.

However it is not just product exposure thatimpacts health in high consuming

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Exposure to hazardous chemicals in the womb and duringchildhood is particularly worrying because of their impacts on achild’s physical and mental development. Hazardous chemicalsthat injure the developing brain are among the known causesfor a rise in neurodevelopmental disabilities including autism,attention-deficit hyperactivity disorder, and dyslexia. Thesehealth impacts affect millions of children worldwide. Decadesof research show hormone disrupting chemicals – many foundin consumer products – are associated with a 50% fall in spermcounts in men, increased miscarriages in women, and a rise inobesity and weakened immune systems. They are alsoassociated with hormone-dependent cancers such as prostate,uterine, thyroid, and breast cancer.

Attention to chemicals in products and supply chains is a keyfactor in any sustainability road-map due to the immediate andlong term impact hazardous chemicals are having on the healthof people and our environment, all of which is exacerbated byclimate change. For example, higher temperatures can allowcertain chemicals to vaporize more easily and enter the air,plus encourage the breakdown of some chemicals into toxicbyproducts. This is notwithstanding the risks to communitiesfrom more intensive hurricanes and flooding in regions with ahigh density of chemical manufacturing plants and refineries,such as Cancer Alley.

Attention to chemical hazards in retailer operations is crucial.Not knowing the extent of hazardous chemicals sold inproducts can be a large financial and reputational risk butcompanies can be proactive by adopting a managementstrategy that goes beyond regulatory compliance. The goodnews is that company leaders are using available tools,strategies, and collaborations to identify hazardous chemicalsin product sectors and work with suppliers to adopt safersubstitutes.

Learn more about the health effects of hazardouschemicals, read factsheets on commonly used chemicalsand search hazard profiles of thousands of substances inthe free chemhat database, and toxnot.com.

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c. Increasing demand by consumers for safer chemicals andsustainable products.

In an environment withincreasing chemical regulationand market demand for saferchemicals, investors requireclear, comparable information toassess company strategies forevaluating progress toward theuse of safer chemicals.

CAROLINE BODEN, MERCY INVESTMENTSERVICES

Toxic chemicals in products and supplychains are hidden liabilities, posingpotentially significant regulatory andreputational risks to brands.

Investors increasingly have little patiencefor companies that ignore the science,policy and consumer concerns withhazardous chemicals.

LAUREN COMPERE, BOSTON COMMON ASSETMANAGEMENT

Between 2013 and 2018, sustainability-marketed products were responsible formore than half of the growth in consumerpackaged goods (CPGs) in that perioddespite the fact such goods account for justunder 17 percent of the market. The 2019study conducted by NYU Stern Center forSustainable Business noted that theseresults reinforce the idea that embracingsustainability leads to better businessresults.

In December 2019, First Insight surveyedconsumers in the U.S. on how sustainablepractices are mpacting shopping and purchasedecisions. The results point to the growingexpectation for sustainable models, withGeneration Z making more shopping decisionsbased on sustainable retail practices than evenMillennials and Generation X. The majority ofGeneration Z (54 percent) state that they arewilling to spend an incremental 10 percent ormore on sustainable products, with 50 percentof Millennials saying the same. It appears thatwith every generation, the quest forsustainability strengthens. Consumer demandsfor transparency of chemical ingredients inproducts continue to grow and are reflected in 

growing regulatory requirements aroundchemical transparency. State legislatures haveresponded to public demand for greaterchemical transparency by enacting laws thatestablish disclosure or reportingrequirements. For example, the States ofCalifornia and New York, Maine, New York,Oregon, Vermont, and Washington requirepublic disclosure of priority chemicals inproducts. Companies and trade associationshave created voluntary initiatives to addressthe pressure they experience from theircustomers and from environmental and publichealth advocates.

Retailers who require chemical disclosure fromsuppliers mitigate their own business risk. Italso helps retailers respond to investors’questions about how they are avoidinghazardous chemicals in products that gobeyond regulatory requirements.

In addition, the Mind the Store retailercampaign and annual report card thatbenchmarks retailers on their efforts to phaseout toxic chemicals, is a growing influence withconsumers. The report card mobilizesconsumers to send emails and messages toretailers on social media urging them to act.

Investors are paying increasing attention to environmental, social, and governance (ESG)issues because they matter to financial performance. Changing social expectations mean thatwhat is material for an industry will change.

In June 15, 2020 Trillium Asset Management and First Affirmative Financial Network filed ashareholder proposal asking the retailer TJX to issue a report describing if and how it plans toreduce its chemical footprint. First time shareholder proposals often receive support levels inthe single digits, as investors need time to evaluate the issues addressed, but over 44% of theretailer’s shareholders voted for action to reduce chemical risk. This increasing scrutiny ofinvestors to include chemical risk in the materiality of retailers is particularly well detailed bythe Sustainable Accounting Board Standards (SASB) for retailers.

SASB standards are designed to identify a minimum set ofsustainability issues most likely to impact theoperating performance or financial condition ofthe typical company within an industrysector. SASB’s Investor Advisory Group andSASB Alliance include leading asset ownersand asset managers who are committed toimproving the quality and comparability of sustainability-related disclosure to investors. The SASB Investor Advisory Group members total above fifty members including Bank of America, Merrill Lynch,Calvert, Domini, Franklin Templeton, Fidelity, GoldmanSachs and Morgan Stanley Investment Management.

SASB lays out a particularly detailed set of questions on chemicals management for The Multilineand Specialty Retailers & Distributors sector because they consider this of growing importance tothe materiality of retailers. SASB asks retailers to ‘describe how it prioritizes chemicals forreduction and/or elimination from products it offers for sale, how it communicates these prioritiesto suppliers and enforces compliance, and whether it encourages or requires suppliers to consideralternative chemicals in product formulations.’

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d. Investors are including chemical risk in the materiality of retailers.

On June 15, 2020, a near majority ( 44%) of shareholders votedin support of TJX Companies, Inc. issuing a report describing ifand how it plans to reduce its chemical footprint.

CFP list of CoHC includes over 2,200 chemicals.Responses to I3 in Chemical Inventory addresswhether companies have a “Watch List” ofchemicals beyond RSLs.

Responses to I6 in Chemical Inventoryaddress the scope of activities companiestake to verify chemical content.

The CFP Survey is a hazard based frameworkof chemicals management

2. Describe whether approach to chemicalsmanagement is characterized by a hazard-based, risk-based, or other approach

3. Discuss the operational processes employedfor chemicals management (for example, useof restricted substances lists — RSLs)

6. Disclose if testing and/or third-partycertification to verify chemical content ispursued

7. Optional: list chemicals the business hasfound in products for which it has a policy toreduce, eliminate, or assess

Requirements for Accounting Metric: Assessand manage risks and/or hazards associatedwith chemicals in products”

CFP Survey Questions & Response OptionsRelevant to SASB Accounting Metrics

The following chart shows the parallels between the SASB questions on chemicals management forretailers and the Chemical Footprint Project Survey, on which this Retailers Guide is structured.

Responses to the Footprint Measurement pillar(5 questions) along with the supplier questionsin Chemical Inventory (I3 and I6) address SASBmetric #4

Responses to the Chemical Inventory pillar(6 questions) address SASB metric #3

The 4 pillars of the CFP Survey specify aholistic chemicals management framewor.Responses to Management Strategy pillarquestions (M1, M2, M3, and M4) are relevantto SASB metric #1

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SASB STANDARD FORRETAILERS:

CHEMICAL FOOTPRINTPROJECT SURVEY (CFP):

4. Describe how chemicals forreduction/elimination from products offeredfor sale are prioritized, how the priorities arecommunicated to suppliers and compliance isenforced, and whether suppliers areencouraged/required to consider alternativechemicals in products

5. Describe policies and practices for disclosingfull chemical formulations for the productsoffered for sale

1. Discuss the business and operationalprocesses employed to assess and managepotential risks and hazards associated withmaterials, chemicals, and substances inproducts offered for sale

Responses to M1 in Management Strategy andD1 in the Disclosure & Verification pillar addressSASB metric #5

the scope of its chemicals managementpolicy; a process for prioritizing and reducingCoHCs, and working with suppliers tochoose safer alternatives;the information it collects from suppliers;andwhat information it discloses to customers.

The goal of chemical footprinting is toevaluate the presence of hazardouschemicals in products, manufacturingprocesses, supply chains, and/or packagingand work toward eliminating their use orsubstituting with safer alternatives.

The CFP Survey encourages a systemsapproach to chemicals management byproviding a means for a company to assess:

Signatories to the Chemical Footprint Project(CFP) now include investors, retailers, healthcare organizations, governments, and NGOs.These organizations represent over $2.8 trillionin assets under management and purchasingpower that are asking companies to respond tothe CFP survey.

To participate in the Survey, companies submittheir responses along with documentation thatis protected by data security for confidentialityto Clean Production Action for scoring. Thescores companies receive provide a metric forevaluating overall chemicals managementprograms, charting progress over time, andbenchmarking to peers. Responders can opt tomake their responses and/or score public. The2019 annual CFP report highlighted tendisclosure leaders who publicly released theirresponses and score.

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2. The Chemical Footprint Project (CFP) canhelp retailers with steps to best practice

This Retailer's Guide is modeled on theChemicals Footprint Project (CFP) whichoutlines a systems approach tocomprehensive chemicals management.

Based on input from leading brands andretailers, the CFP defines essential elements ofgood chemicals management into the fourpillars of: Management Strategy, ChemicalInventory, Footprint Measurement, andDisclosure and Verification – all of which arereflected in the five modules within thisRetailer's Guide.

CFP has created two metrics: (1) the CFPSurvey score, which evaluates overallcorporate chemicals management systemsand, (2) a chemical footprint, which measuresCoHCs used in the products a companyproduces or sells. CFP draws from the CarbonDisclosure Project and introduces chemicalfootprinting to the family of sustainabilitymetrics that includes carbon, water and wastefootprints.

Retailers can become a CFP Signatory andencourage their suppliers to take part inthe CFP Survey. Signatories to the CFP areorganizations such as investors, retailers,and large-scale purchasers like health caresystems, that are interested in responsesprovided by companies to the CFP Survey.For many companies, investors, andpurchasers there was no common platformto access leadership in chemicalsmanagement. That is why the CFP wasestablished and why organizations areregistering to become Signatories.

CFP currently has investors as signatorieswith a combined $2.8 trillion in assetsunder management. CFP’s retailers andlarge scale purchaser signatories have acombined $600 billion in purchasing powerand include CVS Health, Staples, and

We urge retailers to become Signatories to the CFP to encourage their supplier to take the Survey. In addition, retailers can participate as Responders. This Retailer's Guide provides many resourcesthat will help retailers participate either as a signatory or as a responder, in addition to theguidance provided by the CFP.

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a. Become a CFP Signatory.

In 2016, we became the first majorpharmacy chain in the country tobecome a signatory of the ChemicalFootprint Project.CVS HEALTH

b. Become a CFP Responder. Retailers can also become a Responder by participating in the CFP Survey. The CFP Surveyprovides a common language for companies to talk about their chemicals management.Responders to the CFP Survey are finding it valuable as a self-assessment tool, where they canmeasure their own progress internally and report externally to investors and businesscustomers. The Survey also enables responders to determine whether their own practices arealigned with best practices identified across sectors.

Walmart. The data from the CFP Survey,especially as the data set grows over time, willenable Signatories to benchmark companiesand identify leaders. Signatories agree to havetheir names listed on the CFP website and toencourage companies in their sphere ofinfluence to participate in the CFP Survey.

To become a Signatory to the ChemicalFootprint Project, register athttps://www.chemicalfootprint.org/value.

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Beginning in 2020, AholdDelhaize USA and itscompanies will participate inThe Chemical FootprintProject, reporting annually onprogress toward thecommitment. Consideredtogether, the companies ofAhold Delhaize USA comprisethe largest grocery retail groupon the East Coast and thefourth largest group in thenation, with nearly 2,000 retailstores and more than 6 billionannualized online groceryorders.

Retailers have several options in responding to the CFPSurvey. Retailers that manufacture private label productsmay choose to respond only relative to those products, fromthe perspective of a manufacturer or brand. Alternately,retailers may choose to respond relative to the third partybrands they sell, from the perspective as a retailer of thosebrands. In either case, the retailer may choose to respondbased on a subset of either its private label products or thethird party brands it sells.

Responders to the CFP Survey may choose to publiclydisclose any combination of their participation, theirresponses, and their score, or they may choose to remainanonymous.

It is noteworthy that the Mind the Store retailer report card questions and the campaign awardspoints to retailers who take part in the CFP. Because the Guide is aligned with the CFP framework,following the recommendations in the Guide will help retailers boost their score in the annual Mindthe Store retailer report card ranking.

To become a responder to the Chemical Footprint Project Survey, register athttps://www.chemicalfootprint.org/assess/assessment-tool

3.  HOW TO USE THIS GUIDE

This Guide includes 5 Modules that outlinesteps that retailers can take when firststarting to develop a chemicals managementprogram as well as activities that can betaken for continuous improvement toward acomprehensive management system.

There are many pathways to getting startedon chemicals management beyond regulatorycompliance. Each retailer will choose anapproach that is appropriate to itsorganization. Some retailers begin bydeveloping a chemicals policy while othersbegin by conducting an internal assessment,

communicating with their supply chain andthen developing and making public achemicals policy. Because chemicalsmanagement is complex, most activities areiterative and will be developed and improvedupon over time.

There is no set order to completing the steps,though some clearly build on the success ofothers. We suggest you review them all, andthen develop a plan that fits with yourcompany’s culture and situation.

Within each module you will find:

checklist of actions for chemicals management that builds from and aligns with the CFP

Survey, examples of retailer actions

resources and other practical information

The Retailer's Guide will be reviewed and updated periodically as an online resource. We inviteretailers to contact us for feedback on the Guide as well as new content on their progress to saferchemicals adoption.

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Management Strategy:Chemicals Policy

Restrictied SubstancesList (RSL): Priority

Chemicals & Products

Chemical Inventory:Priority Chemicals &

Products

Chemical Footprint:Goals & Progress to

Goals

Public Disclosure ofPolicies, Goals &

Progress

Many companies are establishing environmental, social andgovernance (ESG) commitments but attention to chemicals inproducts and supply chains is often inadequately integrated intooverall management systems.

Retailers can establish an organizational chemicals policy,engage external stakeholders, integrate chemicals safety intobusiness strategy, provide incentives for implementing thechemicals policy, and require senior management engagement.

Important initial steps for retailers in developing a proactive chemicals management strategy are to:

a) learn from external stakeholders; b) establish a chemicals policy; and c) implement and communicate the chemicals policy

In starting the journey to safer chemicals retailers have the opportunity to tap into a diversecommunity of stakeholders to inform their decisions. NGOs, trade associations, informalcollaborations, consultants, and investors bring rich and varied experiences, knowledge, andresources to creating a proactive chemicals management strategy.

Retailers can engage with various multi-stakeholder collaborations, such as:

MODULE 1Management Strategy: Chemicals Policy

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Management Strategy:Chemicals Policy

a. Learn from external steakholders.

The Beauty and Personal Care Sustainability Project (BPC):a pre-competitive collaboration of stakeholders across theindustry value chain with the aim to increase the numberof sustainable beauty and personal care products onretailers’ shelves. It has released a points system forretailers to use with brands. The non-profit, Forum for theFuture is the co-host organization for BPC alongside TheSustainability Consortium (TSC). The rating system forproducts, completed in early 2018, is managed by TSC.

Green Chemistry & Commerce Council: GC3 is a multi-stakeholder collaborative that drives the commercialadoption of green chemistry by catalyzing and guidingaction across all industries, sectors and supply chains. Itsmembers include both downstream users and chemicalproducers. It provides an open forum for memberbusinesses to share innovations in green chemistry and towork together to scale up and commercialize thesesolutions. The GC3 Retailer Leadership Council (RLC)promotes safer chemicals, materials, and products acrossretail supply and value chains. RLC members include:Amazon, Best Buy, CVS Health, Home Depot, Kingfisher,Lowe’s, Meijer, Sephora, Staples, Target, TJX and Walmart.In addition, the GC3 Retailer Database providesinformation on tools and resources for safer chemistry.

BizNGO: a project of Clean Production Action, convenes downstreamusers of chemicals (brands and retailers), NGOs, and governments inthree multi-stakeholder work groups on chemicals management,chemical hazard assessment, and public policy. BizNGO also hostsan annual meeting for meaningful, in-depth, and open discussions.BizNGO participants co-develop principles, policies, strategies, andtechnical resources such as The Guide to Safer Chemicals andChemicals Policy Template for Brands and Manufacturers.

Mind the Store: The Mind the Store campaign is acollaboration of NGOs challenging retailers to eliminatetoxic chemicals in products and packaging and developcomprehensive safer chemicals policies. The campaignraises the voices of thousands of consumers, publishesnew scientific research, and engages companies indialogue and sharing policy recommendations. The annualRetailer Report Card ranks retailers against acomprehensive scoring rubric of 13 criteria. These criteriaalign with other corporate safer chemicals policies andbest practices identified in the BizNGO Principles for SaferChemicals, BizNGO Guide to Safer Chemicals, and theChemical Footprint Project.

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"Lowe’s has been working with trusted partners, such as the Green Chemistry andCommerce Council (GC3) to continuously support green chemistry initiatives as well asparticipating in the Retail Leadership Council of the GC3 to better align the retail sector.Lowe’s will also continue to partner with credible NGOs, associations and industry partners."

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These initiatives offer multipleperspectives and opportunities forlearning from peers in retail andother business sectors, as well asfrom NGOs, regulators, andacademics. Many offer webinars,discussion groups, and meetings toshare successes, challenges, andemerging trends and opportunities.Some initiatives are fee-based andrequire membership, while others arefree to join. NGOs can be a valuableresource to retailers, and they oftenare well networked with solutionsproviders.

A growing body of scientificevidence has shown healthhazards from exposure tochemicals such as phthalates,PFAS, and flame retardants.

The fact that so many companieshave improved their chemicalpolicies over the last year is thusinspiring and hopefully will be astrong impetus for others to act.

DR. ROBIN M. WHYATT, COLUMBIA UNIVERSITYCOMMENTING ON RESULTS OF THE 2019RETAILER REPORT CARD.

Engaging with external stakeholders is beneficial both internally and externally. For example,both the Chemical Footprint Project (CFP) Survey and Mind the Store Retailer Report Cardevaluate companies on their external engagements. In addition, because the Mind the Storeretailer report card uses criteria aligned with the CFP, this Guide will help retailers boost theirscore in the annual Mind the Store retailer report card ranking.

The Environmental Defense Fund has published A Roadmap to Sustainable E-commerce thatincludes tips for assessing and reducing chemical and carbon footprints.

b. Establish a chemicals policy and integrate into business strategy.

Retailers often choose to start a chemicalsmanagement program by determining arestricted substances list (RSL) or a watchlist for action.

Embedding a RSL in an overall chemicalspolicy can help ensure its successfulimplementation. A chemicals policy is acorporate level statement that addresseshow an organization manages chemicals inits products, materials, supply chains, andoperations. A chemicals policy is distinctfrom a company’s overall sustainabilitypolicy in that it provides specific guidancerelated to chemicals management beyondwhat is required by regulation.

A comprehensive chemicals policy aims toavoid chemicals of high concern andincludes a stated preference for the use ofsafer alternatives.

Model corporate policies

A chemicals policy articulates anorganization’s strategy for both reducingits chemical footprint (that is, the use ofCoHCs in products and supply chains) andpromoting safer alternatives. TheEnvironmental Defense Fund’s ModelChemicals Policy for Retailers ofFormulated Products, defines acomprehensive framework and includes:

a vision statement;the scope of products that the policyapplies to; supply chain transparency – supplierrequirements for disclosing chemicalingredients;informed consumers – commitment todisclose chemicals in products onpackaging and online; product design – commitment to creating alist of CoHCs, engaging suppliers insubstituting CoHCs with safer alternatives,and measuring reductions in CoHCs; and public commitment – being transparentabout the policy along and progress tomeeting goals and outcomes.

Retailers with private label products can alsouse the BizNGO Chemicals Policy Template forBrands and Manufacturers as a model forcorporate policy which builds from EDF’sretailer policy. Both of these templates mirrorthe questions in the CFP Survey on chemicalsmanagement and the SASB questions toretailers on their chemicals management. Implementing the key elements of achemicals policy will allow retailers to reducethe chemical footprint of the products theysource and sell and become industry leaders.

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Most retailers start with a fewkey categories of private labelproducts and a list of chemicalsof high concern as a way forcompanies to get some earlywins and build momentum.

An important principle in chemicalsmanagement is, “don’t let the perfect be theenemy of the good.” Most retailers start with afocus on eliminating CoHCs from a few keycategories of private label products. They thenexpand their CoHC list and product categorieswith requirements for greater disclosure ofchemical ingredients from suppliers, a statedpreference for safer alternatives, and publicreporting on progress to goals. CleanProduction Action encourages retailers todevelop a chemicals policy that addresses allsix attributes of EDF’s model policy, though werecognize that for many retailers it may bedifficult to initially gain senior managementsupport for a comprehensive policy at thebeginning of this journey.

Bed Bath and Beyond Chemicals Policy which is embedded in the company’s CorporateResponsibility Report, contains a RSL for all products, a Flame Retardant list for someproducts, and a Priority Chemicals list for household cleaning, personal care and cosmeticproducts. The goal is elimination of Priority Chemicals from owned brand baby personalcare products by the end of 2020 and the retailer will strive for ingredient disclosure on

Examples of Retailer Policies

Examples of retailer chemicals policies below show the range of issues that retailers areaddressing in their policies. All are publicly disseminated. Some are more comprehensive thanothers but at a minimum, these policies include a RSL and applied product scope. Manyretailers add their promotion of vendors’ use of safer alternatives such as EPA’s Safer Choicelabeled products, and request for product ingredient disclosure from brands. Morecomprehensive policies provide a vision statement, actions taken to increase the use of saferchemistries in their supply chains, and continuous improvement goals with timelines.

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Best Buy Chemicals Policy is contained in their corporate report noting that they will continueto participate in chemicals management work groups with organizations such as theResponsible Business Alliance and the Green Chemistry & Commerce Council. Their ChemicalManagement Statement details their RSL, Manufacturing Restricted Substances List (MRSL) andtheir Reporting list of chemicals for private label and direct import products.

Amazon Chemicals Policy states that the baseline list of chemicals of concern included on theirfirst RSL identifies the chemicals that they will seek to avoid in Amazon-owned Private Brandsbaby, household cleaning, personal care, and beauty products in the U.S. and Europe. Theyprioritize which chemicals of concern to focus on based on product type, customer concerns,and the availability of safer alternatives. The retailer notes that they will expand this policy toadditional brands, product categories, and geographies over time.

Costco Chemicals Policy is comprehensive and includes a vision statement: ‘Costco’s ChemicalManagement Policy helps to protect the health and safety of our members and theenvironment by establishing and developing products and processes that are safer, healthier,and more sustainable. We strive to go beyond the boundaries of regulatory compliance, in aneffort to reduce or remove potential chemical harm to humans and to the environment. Werecognize that this will be an area of continuous improvement for us as new rules, regulationsand testing protocols are introduced.’

Walgreens Chemicals Management addresses RSLs that go beyond regulatory compliance,disclosure of product ingredients, reporting on progress and search for safer alternatives.Their detailed chemicals policy lays out a vision statement, specifies the RSL used in definedproduct groups, and describes how it will promote transparency: ‘Walgreens Boots Alliance willpursue a long-term goal of full ingredient transparency, including generic terms such as‘fragrance,’ for Walgreens and Boots owned brand and exclusive consumer retail formulatedproducts in the baby, beauty, personal care, and household cleaning product categories.Annually, we will measure and report our progress toward fuller ingredient disclosure.’

owned brand baby personal care products both online and on product packaging beginning in2020. The Company also encourages all vendors of household cleaning, personal care, andcosmetic products to include ingredient disclosures on product packaging as well as otherrecommendations.

The retailer outlines their RSL with product categories and provides details about how theywork with suppliers to find safer alternatives. The Costco Smart Screening Program uses third-party laboratories to identify and reduce over 300 chemicals of concern in both own brand andnational brand product categories including: children’s and adult apparel, bedding, hometextiles, pet beds, furniture, luggage, handbags, sporting goods, personal care products,cleaning products, and more. Screening results are reviewed with suppliers and information isprovided in The Smart Screening User Guide to help suppliers develop safe replacementchemicals and processes.

Ahold Delhaize Sustainable Chemistry Policy, announced September 2019, is not yetincorporated into their yearly sustainability reports. The retailer is building on a previouscommitment to remove all synthetic colors, artificial flavors, artificial preservatives,sweeteners, MSG, and high fructose corn syrup from all private brands products by 2025. Theretailer will produce a RSL that will be updated regularly and collaborate with suppliers toadvance safer chemistries. Beginning in 2020, Ahold Delhaize USA and its companies willparticipate in The Chemical Footprint Project, reporting annually on progress toward thecommitment.

CVS Health Chemicals Policy is based on customer feedback for safer chemicals. The retailerhas a RSL for specific product categories what is updated yearly, and is committed toremoving parabens, phthalates and the most prevalent formaldehyde donors from ownbrand products by the end of 2019. The retailer’s 2019 CSR report notes they continue toreduce chemicals of concern through ongoing collaboration with NGOs and since 2016 CVShas participated in the Chemical Footprint Project as a signatory.

H&M Group Chemical Roadmap is a comprehensive approach with a bold vision of toxic-freefashion by 2030. The retailer gives specific goals about how they will report on progress through a range of measures including: traceability of the input of chemicals used in H&MGroup production for commercial goods by 2030; policy engagement to push legislation andsupport public policies that promote progressive chemical management; transparency aboutchemicals with customers including full public disclosure of wastewater discharge test data;and the promotion and development of greener chemistries in their supply chain. The retailerwas one of the first in the industry to establish a Chemical Restrictions List in 1995, which hasbeen constantly updated and with which their suppliers are contractually bound to comply.The retailer provides metrics on their reduction of hazardous chemicals in their supply chainand provides information on their roadmap to achieving a clean circular economy for theirproducts.

Walmart released its initial list of eight chemicals of high concern in 2013 and in 2017published its Walmart Sustainable Chemistry Commitment. The commitment is detailed andaddresses the criteria in the EDF policy framework for retailers. The commitment coversformulated (chemical-based) consumables products sold through Walmart U.S. and Sam’sClub U.S. store in defined product categories such as health & beauty aids, pet supplies,laundry & home care, and baby care. Walmart aims to reduce by 10 percent the consumableschemical footprint of Walmart U.S. and Sam’s Club U.S. stores by 2022. A strength of itschemicals policy is the transparency of the metrics used to assess progress towards the goalof ingredient disclosure, chemical footprint reduction and number of suppliers using thirdparty certifications for safer chemical ingredients. Walmart was the first retailer to participatein the Chemical Footprint Project survey as a responder.

Target has a very comprehensive chemicals policy which is based on a commitment to drivetransparency, proactive chemical management and innovation across all the retailer’s ownedand national brand consumer products, and operations. In 2018, Target released their firstRestricted Substance List (RSL) and Manufacturing Restricted Substance List (MRSL) for their

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The Home Depot chemical policy is based around increasing the assortment of products thathave transparency of product ingredients and third-party certification of chemical ingredients,and that meet high environmental standards. The retailer is working with suppliers on greenchemistry initiatives particularly in categories with the greatest potential impact on indoor airquality and they list their RSL for specific product categories.

Credo is a mission-driven retailer with the vision of changing the Beauty industry noting thatBeauty is one of the least regulated consumer categories for chemical ingredients. All brandsavoid using the ingredients on the retailer’s ‘Dirty List’ comprising 2700+ chemicals and mustmeet the Credo Standard for sustainable, ethical, and transparent products. They furtherinform consumers through hazard-based justification for allowable ingredients.

Whole Foods Market Quality Standards detail their RSL of over 100 ingredients for beauty andbody care and 70+ chemicals for cleaning products where in must be listed on the label, exceptfor proprietary fragrance and enzyme blends.

aims to avoid CoHCs; has an explicit preference for the use of safer alternatives;addresses chemicals in products, packaging, facilities, and supply chains; andis posted publicly.

textiles categories and has subsequently established a vision, detailed set of goals to advancesafer chemicals in all products and quantitative metrics to these goals. The retailer offerschemical ingredient disclosure to consumers through a series of icons and online informationthat is searchable via brands or product categories. The retailer has confirmed the materialityof chemicals as a ‘higher value’ in their stakeholder engagement, details of which are availablein their 2019 corporate report.

Retailers participating in the Chemical Footprint Project (CFP) Survey are awarded points forhaving a chemicals policy that:

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c. Implement and communicate the chemicals policy.

Ensure executive level buy-in.

To become a retailer leader, it is essential thatemployees are knowledgeable about theircompany’s chemicals policy, engaged in itsimplementation, and rewarded for theirparticipation. In addition, a systematic transitiontoward the use of safer chemicals and productsrequires support and accountability at highlevels of the organization. When a member ofthe executive team of an organization isaccountable for reducing the use of chemicals

of high concern, it is more likely that he orshe will engage other members of thecompany to help achieve this objective. Thiswill also help resolve any perceivedcompeting measures of success betweenbuyers and sustainability staff.

Coordinating the prioritization, creation,and updating of a list of CoHCs. Reviewing documentation from suppliers. Communicating any changes to the list ofCoHCs to suppliers.Responding to suppliers’ questionsregarding the list of CoHCs.Acting as the organization's contact forsectoral initiatives.

Name a chemicals management point ofcontact.

Having one or more points of contact whoare accountable for the different aspects ofmanaging chemicals in a companydemonstrates investment in chemicalsmanagement and clarifies communicationinside the organization and outside withsuppliers and customers. It is helpful if thecontact’s job title identifies his/her chemicalsmanagement role. It is not necessary to haveprofessional toxicologists or chemists onstaff. Consultants with this expertise cansupport specific and in-depth scientific ortechnical needs.

Communicate the contact’s name internallyto all staff and to relevant supply chainpartners, in particular Tier 1 suppliers, alongwith a description of the point of contact’sduties and expectations of suppliers. Dutiesmay include:

The contact(s) may be located in differentareas of an organization, such asstewardship, supply chain, or sustainability.Some companies name two points of contact,one in regulatory affairs/health and saftey,

to address regulated chemicals, and one in thesustainability or stewardship group, to addresschemicals that are not regulated, but of concern. Ifmore than one person is named as the point ofcontact, a coordinated response to issues,concerns, and questions that arise will be mosteffective.

Questions from customers or suppliers regardingCoHCs may need to be answered by staff indifferent departments in the company such asengineering, financial, and regulatory affairs. Inthis case, the point of contact would act as anintermediary, determining who is best placed torespond to questions and communicatinganswers to suppliers on their behalf.

Communicate the chemicals policy internallyand externally.

When implementing the policy, educating allrelevant staff and suppliers is critical, as is activeongoing communication on progress towardmeeting goals. Periodic reporting requirements tomeasure progress will help provide incentives todevote time and resources to implement achemical policy. Publicly reporting your chemicalspolicy meets consumer and investor demands.

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a. Identify priority products andchemicals of high concern (CoHC)

Retailers usually begin by prioritizing a small list ofCoHCs in defined product categories for action. Criteriafor choosing this list may include: the volume of thechemical contained in products, the likelihood ofexposure to chemicals in these products, anticipatedregulatory actions, public concern, or somecombination of these criteria. Continuous improvementthen involves identifying a longer list of CoHCs andexpanding the product categories for action.

MODULE 2Restricted Substances List and Priority Products: Removing Chemicals of Concern in Products

Restrictied SubstancesList (RSL): Priority

Chemicals & Products

Choosing product categories involves multiple criteria. A retailer can choose a single chemical in asingle product category, such as Bisphenol A (BPA) in water bottles. This is the process taken, forexample, in California under the Safer Consumer Product (SCP) Regulations, where the stateprioritizes chemicals by product category, such as methylene chloride in paint strippers. Moreexpansive efforts include all CoHCs in a product category (e.g., household cleaning products) or asingle CoHC across all product categories. In addition retailers and some regulators are focusingon entire classes of chemicals for restriction. The recent proposal by California’s Department ofToxic Substances Control to list treatments containing the entire class of PFAS chemicals used astreatments on carpets, upholstery, clothing and shoes, as Priority Products under the SCPregulations, is a case in point. The retailers Lowe’s and Home Depot took measures to stop sellingcarpets and rugs containing PFAS.

Product categories

Priority product categories vary by type ofretailer. A department store, office supplystore, home improvement store, andsporting goods store each carry distinctlydifferent types of products. Each productcategory has its own chemical hazard andexposure concerns. Exposure to CoHCs isan important consideration whenprioritizing product categories for action.Consider how likely it is that humans will

come into contact with the CoHC, and thepopulation that could be exposed. Willvulnerable groups such as children,pregnant women, or people withcompromised immune systems beexposed?

Examples of products with high exposurepotential to vulnerable groups include anyproduct intended to be applied to the bodyor sprayed, food contact materials andproducts intended to be chewed or

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mouthed by small children. Otherproducts include carpets and rugs whereinfants crawl, and products used by babiesand children such as car seats, nap mats,and baby furnishings. Exposure tohazardous chemicals in such productsoccurs because many chemical additivesare not bound in the substrate andtherefore may leach into the environmentwhere humans can be exposed throughinhalation or ingestion. Another exampleis electronic products with flame retardantchemicals where tests have shown thesechemicals to be released from the plasticcasings and adhere to house dust posingongoing exposure.

Take action on formulated products.

Many retailers begin developing achemicals management program with afocus on formulated products. Formulatedproducts refer to a preparation or mixtureof chemical substances that can begaseous, liquid, or solid (e.g., paints, liquidcleaning products, adhesives, coatings,cosmetics, detergents, dyes, inks, orlubricants).

Retailers often prioritize formulatedproducts for action because consumershave greater awareness and concernabout chemicals in these productsbecause they are applied to the skin.Target, for example, started with personalcare, beauty, household cleaning, andbaby care products. Whole Foods Marketprioritized household cleaners. AndWalmart prioritized household cleaning,personal care, beauty, and cosmeticproducts.

Most retailers first prioritize action ontheir private label brands and then extend

CVS Health prioritized its private label linesof beauty and personal care products, andcommitted to remove parabens, phthalates,and formaldehyde donors from theseproducts.Amazon’s first RSL applies to its private labelproducts, including baby (shampoo, lotion,wipes), household cleaning (all-purpose,kitchen, and bathroom cleaners), personalcare (shampoo, sanitizers, moisturizers), andbeauty (make-up) products. Rite Aid first focused on eight CoHCs informulated private label products, thenexpanded both its list of CoHCs and itsapplication to include formulated productsmade by national brands.Walmart’s chemicals policy focusses on its“formulated consumables” products, whichincludes cleaning and personal careproducts. Walmart first identified eight HighPriority Chemicals from its longer WalmartPriority Chemicals list as a starting point forsuppliers. In 2016 Walmart released theidentity of the eight high priority chemicalsas well as the almost 2,000 prioritychemicals in its Priority Chemicals List. In2017, Walmart announced a 10% chemicalfootprint reduction goal for theirconsumables by 2022.

restrictions to both private label and nationallabel brand products in the same productscope.

Take action on articles.

Retailers are increasingly focusing on CoHC in articles. The term ‘article’ comes from theEuropean Union’s chemicals regulation known as REACH, and this terminology has becomecommonplace. An article is: “an object which during production is given a special shape, surfaceor design which determines its function to a greater degree than its chemical composition.”Examples of articles include furniture, electronics, household goods, and apparel. These productcategories have many associated CoHCs not usually found in formulated products such as per-and polyfluoroalkyl substances (PFAS), organo-halogenated flame retardants, PVC plastic, BPA,and heavy metals.

Identify product categories containing specified CoHCs and communicate to suppliers.

H&M group’s Chemicals Program has separate restriction lists for variousproduct groups ranging from textile products, accessories, cosmetics, foodcontact products, toys, electrical products, medical devices, aerosoldispensers and furniture. Marks & Spencer is a UK retailer that has practiced Responsible ChemicalsManagement since 2008. The 2020 update of their MRSL and RSL is appliedto very specific product categories such as the prohibition of Bisphenol A inthermal paper and plastics; alkly phenol ethoxylates in all fibre materials; or phthalates in all clothing, footwear and accessories. The RSL lists over40 chemicals or chemical classes applied to defined product categories.

Most retailers communicate both the CoHC list and the product categories tosuppliers because it is easier to identify products or product categories thatcontain chemicals of concern, such as BPA in water bottles, food cans, and cashreceipts, or PFAS in all carpets and rugs and packaging. For example:

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b. Develop a restricted substances list (RSL), a manufacturingrestricted substances list (MRSL), and a watch list

The most relevant CoHCs for a retailer will depend on the product category or categories itprioritizes for action. The CoHCs that many retailers initially prioritize are chemicals of concern toNGOs, consumer activists, and/or government regulators. These chemicals can form a RSL, aMRSL, or a watch list for restriction or other action.

The purpose and scope of a list of CoHCs will vary depending on the retailer and its products. Ofcourse any retailer’s list of CoHCs should comply with the regulations in the regions where itoperates. States and local governments may have their own restrictions and reportingrequirements.

Toxnot provides a robust commercial toolsetthat allows retailers to apply chemicalshazard assessment in their products andchemical inventories as well as providingsupport for reporting and complianceinitiatives. Access to chemical hazardlistings, including GreenScreen ListTranslator scores, are free.

Scivera screens ingredient lists and offers achemical hazard assessment of ingredientsthat do not appear on lists to help predictfuture restricted chemicals and materials.

Frequently, chemical restrictions includethreshold levels permitted for a givenconcentration in a component or product.

When determining additional CoHCs, it may bevaluable to involve staff from procurement,supply chain management, and governmentaffairs, as well as staff and consultants withchemical expertise. NGOs can also be a goodsource of intelligence about known andemerging CoHCs of relevance to your productlines. Some third-party service providers haveextensive information on different geographicalregulatory requirements plus RSLs/MRSLs andpriority lists beyond regulatory compliance. Forexample:

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The BizNGO working group on chemicals management has listed key considerationsfor retailers to take when developing a list of chemicals of concern.

Chemical risksInherent hazardOpportunity for exposure through supplychain and during productionOpportunity for exposure from product useVulnerability of exposed population (e.g.,children)Availability of alternatives that provideperformance neededCost of alternativesBrand reputationCompetitorsNGO/consumer concerns

Business opportunitiesCustomer preferencesProduct certifications & standardsAvailability of alternatives that provideperformance neededInvestor preferences, e.g., SASB keyperformance indicators

TrackCollect information on chemical useIdentify watch list -- chemicals for possible future actionInform suppliers of organizationalpreferences & intent to restrict

ReduceWork with suppliers to identify saferalternativesSelect suppliers that do not use specifiedCoCsAvoid use in newly designed/formulatedproducts

Redesign/ReformulateWork with suppliers to redesign orreformulate existing products to excludethe use of CoHCs and utilize saferalternatives

RestrictRestrict to de minimus level in all orspecified usesDo not allow in specified uses

What action(s) did you take?

Chemicals in products (brands and private labels)on store shelves (brick and mortar, and virtual)Chemicals used in the supply chainChemicals in packagingChemicals used in facility operations andmaintenance (cleaning, grounds maintenance,etc.)Chemicals in built spaces (retail stores and officespace)

What is the scope?

Laws and regulationsLaws and regulations in jurisdictions ofoperation/salesLaws and regulations relevant to sectorworldwide

Standards, Trade Associations, & NGOsEco-label requirementsSector generated CoHC lists (e.g., BPC)NGO generated lists of CoHCs (e.g., SIN List,GSLT)

Authoritative Bodies & Scientific ResearchAuthoritative lists: developed bygovernment/inter-government/scientificbodies (e.g., IARC)Emerging scientific evidence of a chemical'shazard, likley exposure routes and potentialrisk

What sources do you use?

Future regulationson store shelves (brick andmortar, and virtual)

Anticipated legal requirementsCompany values and goals

Organizational missionCorporate policies and goals

Relevance to product portfolioLikely presence in productsQuantity usedSales volume

What criteria do you use to prioritizeCoHCs beyond compliance?

HOW TO DEVELOP A COHC LIST

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Retailers generally take one of twoapproaches when developing an initial list ofCoHCs. Some retailers select a limitednumber of high profile CoHCs to get started,and then expand this over time. Someretailers adopt an existing list of CoHCsdeveloped by a government, scientific body,sectoral organization, competitor or anNGO.

Select a limited number of high profileCoHCs to get started, and then expandthis over time:

Choosing a small number of high profileCoHCs allows retailers and their suppliers tofocus on a smaller scope and expand it overtime.

For example Dollar Tree lists an initial 17CoHCs in specific private label products forelimination by 2020 or sooner.

Dollar General prioritized eight CoHCs toreduce or eliminate by 2022 from its privatelabel core formulated products initially inHome Cleaning and Beauty & Personal Care.

Among "Walmart Priority Chemicals,"Walmart worked with NGOs, academics,government, and industry stakeholders toidentify a subset of eight "Walmart HighPriority Chemicals" (HPCs) as a starting pointfor suppliers in Walmart’s initialCommitment on Sustainable Chemistry in2014. As of 2017, the retailer now flags overa thousand Priority Chemicals (PCs) in theWERCSmart system.

A commitment to review and expand theRSL is important for consumers andinvestors. For example Rite Aid first focusedon eight CoHCs in formulated private labelproducts, then expanded its list of CoHCsbeyond private label products to include

formulated products made by national brands.

Retailers such as CVS Health and Walgreensupdate their RSL annually as well as report onprogress.

Costco has a RSL of over 300 chemicals andprovides updates in their annual corporatereports.

Adopt an existing list of CoHCsdeveloped by a government, scientificbody, sectoral organization, competitoror an NGO.  Retailers may choose to develop or adopt alonger list of CoHCs in addition to or instead ofa shorter list. Selecting a well-documented listdeveloped by a respected third-partyorganization can save time and money. Thesecomprehensive lists may include chemicalsthat are regulated but not relevant to retailers. See Appendix A for examples of lists ofCoHC developed by regulatory bodies, sectoralorganizations, and NGOs as well as chemicalhazard assessment tools.  Canadian Tire sets out its chemicals of concernrestrictions for both formulated products andarticles that include specific chemicals ofconcern in product sectors, such as aprohibition of the use of brominated flameretardants in any product or a restriction ofphthalates in children’s products, as well asusing the EU Substances of Very High Concernlist for restriction in their own brand nameapparel products. Many brands and retailers involved in beautyand personal care products reference theBeauty and Personal Care SustainabilityProject list, which is based on internationalchemical hazard lists.  The full list ofchemicals can be obtained via accessing theindividual retailer’s sustainability program,

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although many of the lists can be accessedvia independent database provides such asthe LOLI Database. Sephora’s private label products mustcomply with an extensive RSL and theretailer reports on its progress to saferalternatives and increased transparency.  Retailers can also consider adopting a MRSLfor their own brand products andencouraging their suppliers to adopt theMRSL as well. Some chemicals used inmanufacturing may cause negative healthimpacts to workers and communities as wellas toxic impacts to fish or drinking waterdownstream from manufacturing sites. Thetextile industry is a leader in this area ofestablishing MRSLs and leading brands inthe apparel and footwear sector complywith the MRSL requirements of the ZeroDischarge of Hazardous Chemicals (ZDHC)industry program.  Retailers who sell ownbrand apparel are increasingly adopting thisMRSL.

After finalizing a CoHC list, retailers needto communicate it internally and tosuppliers. If suppliers are required toeliminate the CoHCs, they will need atimeline for elimination.

A watch list is a list of chemicals of concernthat a company does not currently prohibit,but is considering prohibiting in the futuredue to scientific evidence that a chemicalmay cause harm to human health or theenvironment. This gives suppliers time toprepare for eventual restriction and seeksafer substitutes.

Walmart has compiled its list of PriorityChemicals (PCs) by referencing chemicalsthat appear on a number of authoritative 

and regulatory lists of the European Union, USEPA, and several US states. This list of over athousand chemicals is used to measure thereduction of their Consumable ChemicalFootprint by weight volume, by number of UPCs,and by number of suppliers. All of these metricsare public.

The Chemical Footprint Project has developed aCoHC list which comprises over 2,200 chemicalsthat retailers can adopt as their prioritychemicals list. If retailers use the same list ofCoHCs and report on their chemical footprintreduction, they can be compared to their peers. Some third-party service providers haveincorporated this list into a database for easieraccess and product screening.

Note it is important to keep up to date withchemicals of emerging concern. For example,the focus on per- and polyfluoroalkyl substances(PFAS) has galvanized leading retailers to workto eliminate this entire chemical class from foodpackaging and food service ware products, aswell as carpeting.

List Compliance: Product Testing.

Customers and investors will want to know howRSL/MRSLs are being enforced and manyretailers list compliance methods, testingprotocols and threshold limits in their RSL/MRSLrequirements with suppliers. Goodcollaborations with suppliers allow goodknowledge exchange that is verifiable.

For example:

IKEA assesses chemical risk before production,and conducts testing during production and offinal products both at their own laboratory andat external third-party laboratories to verifycompliance. The retailer then conducts ongoingverifying tests as well as audits with random

checks to follow-up on fulfilment of requirements.

Costco utilizes third-party testing and data platforms to gather product ingredients bill ofsubstances (BOS) of cleaning products and health and beauty products. These products arescreened against the list and other regulated chemical lists. When chemicals of concern areidentified, suppliers are encouraged to utilize toxicologists to identify preferred alternatives.

Expand the CoHC list and product scope with timelines and update the chemicals policyregularly.

Retailers need to stay current with new regulations and scientific research on chemical hazardlistings. Establishing an annual process to review and decide on changes to the list of CoHCs andproduct scope will allow reviews to happen in an efficient, timely manner. Stakeholders andNGOs can be a valuable source of information, along with third-party service providers. Forexample, retailers can use the freely accessed Toxnot database which compiles up to datechemical hazard information on over 50,000 substances.

Note that while a list of CoHCs helps to know what is not in products, it does not provideinformation on what is in a product. A CoHC may be replaced by another chemical that is ofequal hazard but is not on a list because lists are lagging indicators. The process of putting achemical of concern on a list can be a slow process due to the challenge of confidential data fromsuppliers, the resources involved to do comprehensive toxicological testing, and the review timewithin the regulatory process. That is why a comprehensive chemical inventory is invaluable andwhy retailers need to keep up to date with chemicals of emerging concern.

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c. Commit to continuous improvement

Publicly reporting on the expansion of a chemicals list along with timelines,communicates to consumers and investors a commitment to transparency andimprovement. For example, in April, 2018 The Home Depot announced it has asked itssuppliers to exclude nine chemicals from residential household cleaning chemicalproducts sold online and in Home Depot stores by the end of 2022. This announcement

builds on the company’s chemical managementstrategy, first published in October 2017, as well as itscommitment to work with suppliers to improvechemicals in categories with the greatest potential toimpact indoor air quality.

Target set a goal of removing added PerfluorinatedChemicals (PFC’s) and added flame retardants fromtextile products by 2022, and improve beauty, baby 

For third-party brands, in 2019 Sephoraidentified a list of high-priority chemicals forreduction and elimination with a goal toreduce the number of products that containany of the chemicals in the nine chemicalcategories by 50% in three years.

Walmart was the first retailer to set achemical footprint reduction goal of 10% forconsumables by 2022. Currently, consumersand NGOs are waiting to see how the retailerwill commit to continuous improvement byexpanding its product scope and increasingits chemical footprint reduction goal.

Support Green Chemistry research andinnovation to increase safer alternatives.

Retailers who engage in green chemistryinitiatives are rewarded by brandenhancement, investor interest, and NGOacknowledgement in the Mind the StoreRetailer Report Card and the ChemicalFootprint Project Survey. Support forinnovation can take many forms.

For example:

Canadian Tire eliminated BPA from cashregister receipts in 2018, and is now lookingfor enhanced alternatives to also eliminateBisphenol S (BPS) and Bisphenol F (BPF) –chemicals which are now known to beregrettable substitutes. The retailer is alsoexpanding their use of electronic receipts inall associate stores.

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care, personal care and household cleaningproduct categories by formulating withoutphthalates, propyl-paraben, butyl-paraben,formaldehyde, formaldehyde-donors, or NPE’sby 2020.

In March 2019, Target hosted a hackathon tobring the industry together to sparkinnovation on the removal of undesirableflame retardant chemicals from children’sloose-fit sleepwear. Together with brands,other industry partners and students,innovative proposals were developed thatwould meet regulatory requirements (e.g.,flammability), guest preferences andsustainability goals. Target provided astipend to the winning team and is workingwith the team to test the viability of its idea.Target aims to invest up to $5 million ingreen chemistry innovation by 2022. Theretailer’s 2019 Corporate Report reports onits progress.

Lowe’s plans to complete their transition toneonicotinoid free outdoor pesticides for allcategories except Tree & Shrub Care by 2022.Neonicotinoids are implicated in the increaseof bee deaths and other pollinators. In theabsence of a relevant third-party certifiedstandard other than organic certification, theretailer is working with suppliers to explorealternative Tree & Shrub Care chemistriesthat do not rely on neonicotinoids.

Restrictied SubstancesList (RSL): Priority

Chemicals & Products

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MODULE 3Chemical Inventory: Working with Brands andSuppliers

Chemical Inventory:Priority Chemicals &

Products

a. Work to build a chemical inventory

Retailers need to know what chemicals are in theproducts they sell in order to identify where thereare CoHC. Knowing which chemicals are – and arenot - in products involves communication withsuppliers, who themselves may not easily have theaccess to the data required. Many retailers areachieving success in gathering data from suppliersby giving the option of providing ingredientinformation to third-party service providers that willprotect confidential business information.

Formulated products are increasingly subject to regulation in regard to ingredient disclosureand reporting. Retailers with own brand products will need to comply. The trajectory for full ingredient disclosure in articles is expanding. For example in thebuilding materials industry, Health Product Declarations are increasingly required bypurchasers.Chemicals of concern such as PFAS in textiles, carpets, and food containers are underconsumer scrutiny and legislative action.Retailers can be proactive and prepared for new chemical regulatory restrictions and marketdemands if they have achieved full chemical disclosure for the products they source and sell.Retailers with a comprehensive system of data collection in place will reduce the burden onstaff and suppliers as new voluntary and legislative requirements occur.Full ingredient disclosure helps retailers and suppliers to avoid regrettable substitutes, or thereplacement of one CoHC with another that is equally or more hazardous.

It is important to begin identifying a list of CoHC and working to remove them, while also workingto obtain full chemical ingredient disclosure from suppliers. Note that reputational and financialrisk will usually fall on the brand or retailer if CoHCs are identified in products, so it is of value toseek full ingredient disclosure.

A complete chemical inventory and full ingredient disclosure from suppliers is challenging but it isa valuable goal for retailers because:

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With full ingredient disclosure retailers can prioritize which CoHC to restrict now and which torestrict in the future. Such a watch list gives suppliers a heads up that a retailer is notcurrently restricting it but is collecting information about the extent of the use of a chemical.Retailers can use this watch list to calculate the chemicals footprint of products andbenchmark their progress to reduce their use.

The CFP Survey promotes the practice of chemical inventory by evaluating the efforts companiesmake to identify CoHCs in products, and awarding points for the extent of chemical data collectedfrom suppliers. The Survey also helps companies evaluate their systems for managing chemicaldata and ensuring supplier compliance with their reporting requirements

Retailers can ask suppliers to report to them on chemicals in products (business to business - B toB); and retailers can promote disclosure from the brand to consumers (business to consumers - Bto C)

b.  Engage brands & suppliers in disclosing chemicals in products(B to B)

Manufacturers of formulated products, such ascleaning solutions, personal care products, orcosmetics, generally have a betterunderstanding of their product’s chemicalcomposition than manufacturers of articles,such as electronics, apparel, or furniture. Thesupply chain for articles is typically muchlonger and more complex than for formulatedproducts and therefore information onchemical composition may be more difficult tocollect. But some retailers are now seeking fullingredient disclosure from suppliers of articlesas well due to customer demands andincreasing regulatory requirements toeliminate CoHCs in articles.

Both Target and Walmart track their success inachieving chemical ingredient disclosure fromsuppliers. Target’s success in achievingtransparency to all ingredients, includinggenerics such as fragrance in beauty, babycare, personal care and household cleaningformulated products by 2020 is reported on inits annual report. For example, Target’s 2019

corporate report provides metrics on its abilityto screen 76 percent of their in-scopeassortment with at least 22 percent ofproducts meeting its transparency goal in2018.

Walmart provides metrics on supplierdisclosure in its 2017 Walmart SustainableChemistry Commitment Report with data onnumber of suppliers, UPCs and sales volumesthat are meeting its transparency goals.

Requirement for disclosure to third partyorganizations is also promoted by retailerleaders. For example Home Depot recognizessuppliers who disclose product ingredients intheir own communications or on packaging, orthrough a third party organization including,but not limited to: Cradle to Cradle ProductsInstitute, HPD, UL Product Lens, and DeclareLabel.

The GC3 Retailer Leadership Council (RLC) hasdeveloped a Statement on Chemical

Innovation Priorities and Transparency RoadMap to encourage improvements in supplychain and public transparency. This RoadMap does not seek to set out requirementsor standards for suppliers. Rather, itdescribes what the RLC views as bestpractices in the short-term (2019–20) andincludes a longer-term vision that will needfurther development by all stakeholders.The RLC understands that legitimateconfidential business information must beprotected. This Statement also includes aset of chemical and application priorities forinnovation in safer alternatives that the RLChas collectively identified.

Third-party service providershelp retailers to access data fromsuppliers. Third-party service providers collect datafrom suppliers, manage it, and provide thedata in an organized format to retailers. Thisallows suppliers to maintain control ofconfidential business information. Serviceproviders generally collect data from anumber of suppliers for a number ofretailers, streamlining the process for bothsuppliers and retailers. Third party serviceproviders operate at different points indifferent supply chains. Examples of thirdparty service providers popular withretailers include UL, and Toxnot. Walmart,for example, requires suppliers ofconsumables to provide online ingredientdisclosure via WERCSmart, which isadministered by UL.

WERCSmart connects manufacturers withretailers to meet product compliance,chemical transparency and safetyrequirements. WERCSmart is essentiallyUL’s regulatory compliance platform for USformulated products allowing customers toorganize, analyze, and share sensitive

product information with the higheststandards of confidentiality. Suppliers canmaintain a single formulation record that isused to support generation of retailer-specificregulatory guidance. Suppliers of formulatedproducts register their products onWERCSmart. They provide full formulations(ingredient lists + ingredient concentrations)as well as other product data needed togenerate guidance about how to transport,store and dispose of their products incompliance with national, state and localregulations. The system can also generateSafety Data Sheets for products to supporthazard communication regulations. Over 50retailers subscribe to WERCSmart to obtaindata feeds containing this information for theproducts they have in their assortments.

Purview is UL’s chemical policy andsustainability platform. With supplierconsent, retailers can make use ofWERCSmart formulation data and collectadditional information from suppliers toassess products using a variety of evaluativeframeworks. These frameworks can includeretailer restricted substance lists, sectorstandards (like the Beauty and Personal CareSustainable Product Rating system) or multi-attribute product curation standards. Forexample, Target operates its Clean Iconqualification program on Purview, screeningproducts for Unwanted Chemicals andevaluating their ingredient transparency.Qualified products are awarded icons thatTarget promotes to its online and instoreconsumers as indicators of safer or moresustainable products. In addition, supplierslike Method operate their sustainable productdevelopment program on Purview.

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c. Engage brands & suppliersin disclosing chemicals toconsumers (B to C)

Require brands to report ingredientsonline and/or on packaging.

Requiring brands to report ingredientsonline will allow your customers to accessthis information. Retailers gain value frombrand B to C disclosure because the moretransparent, the less likely productingredients will have high chemical hazards. This is one more way for retailers to haveconfidence that the products on shelveshave lower hazards which in turn buildstrust with customers.

Walmart began requiring brands to listWalmart Priority Chemicals on productpackaging in January 2018. This requirementis intended to incentivize suppliers to phaseout use of priority chemicals of concern.

Target reinforces this goal of productinnovation claiming that ‘by supporting ourvendors in being more transparent aboutthe ingredients in products, we can spurinnovation across all of our productcategories and operations.’

d. Prefer brands who usesafer chemicals and thirdparty certifications

Actively preferring brands that avoid CoHCsand use safer chemicals requires intensiveengagement with suppliers on the part ofretailers. Third-party certifications can giveretailers assurance that chemicals have beenscreened for reduced hazards. In a 2020published report, Sustainable PurchasingPatterns and Consumer Responsiveness to 

Home Depot recognizessuppliers who demonstrate acommitment to ingredienttransparency. Suppliers shoulddisclose product ingredients intheir own communications oron packaging, or through athird party organizationincluding, but not limited to:Cradle to Cradle ProductsInstitute, HPD, UL Product Lens,and Declare Label

Sustainability Marketing by New YorkUniversity’s Stern School of Business,researchers found that in four of the fivecategories examined, third-party certifiedsustainability-marketed products significantlyoutgrew sustainable products that hadsustainable messaging, but no third-partycertification.

Retailers are increasingly including thispreference for third-party certified productsin their chemicals policies.

Walmart encourages its suppliers to usemethods, databases, and lists recommendedin its Sustainable Chemistry ImplementationGuide to reduce and eliminate prioritychemicals using informed substitution. Theretailer tracks the number of third-partycertified products from its suppliers andmakes these metrics public. The Home Depot Eco Options® programidentifies environmentally preferredproducts, including cleaners that have

obtained certifications from independent third party testers such as EPA’sSafer Choice and Cradle to Cradle Certified™. 

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In four of the five categoriesexamined, third-partycertified sustainability-marketed productssignificantly outgrewsustainable products thathad sustainable messaging,but no third-partycertification.

INYU Stern School of Business

 The GC3 created the Retailer Tools for Safer Chemistry that show a variety of Restricted Substances Lists, Standards, Certifications & Labels and Chemicals

cleaning and janitorial productsfurnitureHealth & Beauty, cosmetics/, pharmacylawn and garden    textiles, and more

Management Software available for a variety of product categories.  For example,retailers can view which third-party certifications apply to:

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MODULE 4Chemical Footprint Measurement: GettingStarted

Chemicals are the New Carbon. Similar to measuringa carbon footprint using greenhouse gas emissions, achemical footprint measures the presence ofhazardous chemicals allowing retailers to setquantifiable metrics and chart progress over time.

A RSL and/or MRSL that includes a timeline forsuppliers to comply are a means to achieve theelimination of these chemicals in specified productcategories, but it does not quantify the reduction ofthese chemicals.

Chemical Footprint:Goals & Progress to

Goals

Chemical footprinting on the other hand, is the process of evaluating and measuring the presenceof hazardous chemicals in products, manufacturing processes, supply chains, and/or packaging. By measuring a baseline chemical footprint and then continuing to measure it on an annual basis,companies can quantify the mass of CoHCs reduced.

Chemical footprinting can help retailers to:

• Conduct a gap analysis of an organization's performance in managing chemicals.• Identify opportunities for action.• Enable benchmarking of performance with clearly defined metrics.

Beginning in 2017, Walmarthas annually participated inthe Chemical Footprint Projectbased on aggregatedinformation it receives throughthe Sustainability Index andThe WERCS. By 2022, Walmart aims toreduce its consumableschemical footprint for WalmartU.S. and Sam’s Club U.S. storesby 10 percent.

Chemical footprints provide retailers withbaseline data for evaluating performanceand benchmarking progress away fromhazardous chemicals to safer alternatives. Measuring a chemical footprint is doneusing count (number of chemicals ofconcern) or mass (lbs. or kgs of chemicalsof concern used) within a defined productscope. It can be challenging to collect thedata needed to calculate a chemicalfootprint. It is a dynamic process with thegoal of continuous improvement to get tozero in the use of hazardous chemicals.

This requires a good chemical inventory and a good chemicals management system tobenchmark progress away from hazardous chemicals to safer alternatives.

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We believe that chemical managementis a meaningful risk that companies areobligated to disclose to investors, and itis in the company’s interest to report ifand how it can reduce its chemicalfootprint.

SUSAN BAKER, TRILLIUM ASSET MANAGEMENT,2020

Choose a product category Measure CoHC by mass/and orcount in that product category usinga robust chemical hazard list. TheCFP has a comprehensive list of CoHCto reference and also the smaller EUSVHC Reference List to help retailersget started.

Retailers can move beyond setting aRSL and begin chemical footprintingwith the following steps

1.2.

3. Set goals to reduce a chemical footprint in defined product categories and work with suppliers to achieve that goal with transparently safer alternatives.

4. Expand the product categories for additional chemical footprinting.

a.  Measure the chemical footprint in defined product categoriesMeasuring chemical footprints requires collecting and managing data on CoHCs in products,including the number and mass of CoHCs in each product. Choosing the products for chemicalsfootprinting is similar to choosing priority products for RSLs. Walmart, for example, choseconsumables for Walmart U.S. and Sam’s Club U.S. stores to measure chemical footprints.

b.  Set goals to reduce the chemical footprint in defined productcategories

Once retailers choose a CoHC list and define priority products they can set timelines and metricsto reduce their chemical footprint.

Retailers can begin by asking for disclosure on, at minimum, the presence of chemicals on theEuropean Union’s SVHC List in products from their suppliers. In fact, that is an option offered inthe CFP Survey to get started and understand the process of chemical footprint measurement.Retailers should then use that information to set chemical footprint reduction goals, and increasethe number of chemicals on the reporting list. 

The CFP provides resources to help explain the process of chemical footprinting.

The Chemical Footprint Project asks about the goals that a company sets to reduce CoHCs, itsefforts to establish a baseline chemical footprint and measure progress, and its process forassessing and implementing safer alternatives.

The Survey guidance notes that the absence of SVHCs in a product category does not equate to azero chemical footprint, because the data field is too small. Ideally, a retailer should expand tothe CFP list of over 2,200 chemical substances.

Several large retailers have been requesting their suppliers, especially those of formulatedproducts, to provide full chemical ingredient information on products through a third partydatabase for several years. Other retailers now making this request for the first time can buildfrom this work. Major brands will already be familiar with the request, and retailers may be ableto access the same third party database. As a result, retailers just beginning this work should beable to skip a pilot phase where they ask suppliers to report on a small number of chemicals,gradually ratcheting up the number over time.

PAGE | 40

Several large retailershave been requestingtheir suppliers, especiallythose of formulatedproducts, to provide fullchemical ingredientinformation on productsthrough a third partydatabase for severalyears. Other retailers nowmaking this request forthe first time can buildfrom this work.

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MODULE 5Public Disclosure of Retailer Policies, Goals andProgress: Being Transparent

Public Disclosure ofPolicies, Goals &

Progress

Target Clean is a new, easy way toidentify products formulatedwithout specific ingredients youmay not want.TARGET

Investors increasingly want information on corporatechemical policies and want to understand howcompanies will evaluate progress to reduced chemicalrisk. Consumers and NGOs increasingly rate retailerson their ability to provide assurance that hazardouschemicals are not present in the products they buy,and the Mind the Store Retailer Report Card facilitatesconsumer engagement with retailers for continuousimprovement in goal setting.

Leading retailers are communicating their RSLs and chemicals policies to the public to ensurethat key stakeholders, including investors, NGOs, and customers, are aware of their commitmentto safer chemicals adoption. Progress made should be included in corporate socialresponsibility reports, ideally in a separate section so that investors and other stakeholders canidentify it easily.

Internal organizational resistance may arise to publicly disclosing a RSL. Some may believe thatby not discussing chemicals management, customers, potential customers, and investors will notassociate the company’s products with any hazard. But NGO and investor requests for disclosurewill continue to grow while public awareness of chemical safety in products will require validresponses from retailers. Silence on the topic may be perceived as a lack of care for the healthand well-being of customers and the general public.

Manufacturers of chemicals containedin RSLs may also object to the list beingmade public. However, since retailersand brands are in the public eye, they,unlike chemical manufacturers, usuallyface the most financial andreputational risk.

As listed in Module 1, many retailers posttheir chemicals policy online, therebycommunicating chemicals managementpriorities to customers, consumer andenvironmental organizations, investors,and suppliers. Public posting of corporatepolicies online may seem a bold move totake, but increased transparency makesgood business sense and is increasinglythe norm. It communicates to investorshow the retailer is working to reduce theregulatory, reputational, and market risksof hazardous chemicals in products andsupply chains. It also informs consumersand advocacy organizations that want tounderstand the retailer’s approach toensuring chemical safety in products.Progress made toward reducing the use ofCoHCs can be included in the retailer’sannual social responsibility report as wellas in the annual Chemical FootprintProject Survey.

Mind the Store Campaign’s Retailer ReportCard annually ranks retailers on publiclyavailable information about theirchemicals management practices. TheRetailer Report Card uses a transparentset of criteria and scoring methodologythat can give guidance to retailers as wellas provide information on a competitor’sefforts to reduce CoHC in products andmanufacturing. As noted, the RetailerReport Card has criteria aligned with theframework of this Guide, so suggestions inthis Guide will help retailers increase theiryearly benchmark score.

A 2017 Harris poll found that more than six inten women in the US report that they read labelson personal care products and avoid productsthat contain certain chemicals. Health concernaround the thousands of chemicals used in‘fragrances’ have trumped traditional claims ofconfidentiality and many formulators, retailersand brands are now disclosing ingredients ontheir product labels and company websites.

Target has developed Target Clean icons andWellness icons with detailed online informationabout the chemicals that have been restricted ineach product group. Target Clean wasintroduced to online shoppers in March 2019across over 4,000 products in householdessentials, beauty, personal care, babyessentials and pet food categories, and identifiesproducts formulated without a group ofcommonly unwanted chemicals such asphthalates, sodium laureth sulfate, propyl-paraben and butyl-paraben, and others relevantto key frequency categories. Users can search byproduct category or brand. Target Cleancontinues to be rolled out across the retailer’sstores. Wellness icons include phthalate-free,paraben-free and other wellness attributesacross a larger range of product categories.

Sephora has taken a similar approach by givingconsumers the option to choose ‘Clean bySephora’ products which comply with theretailers 1,300+ RSL. By 2020, Sephora aims for100% of formulated beauty and personal careproducts to have all intentionally addedingredients listed on its US Sephora.comwebsite.

PAGE | 42

a.  Measure the chemicalfootprint in definedproduct categories

b.  For private label products,disclose chemical ingredientinformation (B to C)

The Credo Clean Standard takes a ‘preferredchemical’ approach by ensuring all beautyand personal care brands comply with theretailer’s standard for chemicals safety,chemical sourcing, sustainability, sourcingand transparency. This includes therequirement that products are free of over2700 chemicals listed in the retailer’s RSL.Credo provides comprehensive chemicalingredient disclosure including the rationalefor specific chemical ingredient use inproducts.

In the absence of ingredient labelingregulations, retailers can voluntarily disclosechemical ingredients online and on pack forown brand products. For example CVS givesconsumers the option of buying more than1,000 skin care products labeled as CVS®Clean which are free from parabens,phthalates and formaldehyde donors andfor some products there is a full ingredientlist rather than just a ‘free of’ list.

PAGE | 43

c. Disclose progress to goals

Retail leaders report on progress to goals inannual corporate reports. It is moremeaningful to demonstrate quantitativeprogress to meeting goals rather thanincluding generic qualitative statements.

Both Walmart and Target calculate metricson supplier ingredient disclosure, reductionin CoHC use and other goals set in theirpolicy statements. As the first retailer tocommit to a chemical footprint goal, Walmartsupplies metrics on its progress to a 10%reduction of its consumables chemicalfootprint for Walmart U.S. and Sam’s ClubU.S. stores by 2022. It does by measuringweight reduction, Universal Product Codes(UPCs) and number of suppliers (data from2017). However, the retailer does not trackprogress on chemical footprint reductionbeyond consumables.

Target’s chemicals policy aims to address their entire value chain, operations and every product category. Target’s 2019 report stated that they achieved full business-to-business ingredientdisclosure in owned-brand beauty, baby care, personal care and household cleaning formulatedproducts. They report progress on access to screen 76 percent of in-scope assortment, with 22percent meeting their transparency goal and 44 percent meeting their chemical managementgoal as of 2018.

The Mind the Store Campaign Retailers’ Report Card ranks retailers on progress tocomprehensive chemicals management with transparent scoring methodology, key findings,conclusions, and recommendations. The campaign continuously expands the number of retailersassessed and has become the leading NGO scorecard for ranking retailers on progress towardssafer chemicals adoption.

# of UPCs containingin-scope PCs N/A

Restrict and Eliminate In-scope Walmart Priority Chemicals in our Consumable ChemicalFootprint

REDUCTION OF WALMART PRIORITY CHEMICALS

PAGE | 44

Reduce volume of In- scope Walmart Priority Chemicals in our Consumable Chemical Footprint Weight (Volume) of in-scopePCs in Products Sold in 2017 Percent change vs. previous year Percent change vs. baseline

189,448,032 lbs N/A N/A

Metric Percent change vs. previous year

Percent change vs.baseline

N/A

2017

# of Suppliers using inscope PCs

65% of UPCs

N/AN/A45% of Suppliers

Reduce volume of, Restrict, and Eliminate HPCsWeight (lbs) of HPCs inProducts Sold in 2017 # of UPCs Containing HPCs

475,242 lbs 11% of UPCs

# of Suppliers Using HPCs

16% of Suppliers

Source: CY 2017 Walmart Sustainable Chemistry Commitment Report

Cancer is the leading cause of death by disease among children in the United States. Butbusinesses can stop the use of chemicals known to cause cancer and other diseases. A dramaticand equitable transition away from hazardous chemicals to safer alternatives is now a priority.

Retailers can play a huge role in building a safer world by demanding safer chemicals in theirsupply chain. We look forward to working with you for a healthier future. Contact us.

Management Strategy:Chemicals Policy

Restrictied SubstancesList (RSL): Priority

Chemicals & Products

Chemical Inventory:Priority Chemicals &

Products

Chemical Footprint:Goals & Progress to

Goals

Public Disclosure ofPolicies, Goals &

Progress

CLEAN PRODUCTION ACTIONPAGE | 45

CLEAN PRODUCTION ACTION PAGE | 46

GLOSSARY

Alternatives assessment: A process foridentifying, comparing and selecting saferalternatives to chemicals of concern(including those in materials, processes ortechnologies) based on their hazards,performance, and economic viability. Aprimary goal of alternatives assessment is toreduce risk to humans and the environmentby identifying safer choices.

Article: An object which during production isgiven a special shape, surface or design whichdetermines its function to a greater degreethan its chemical composition.

Bioaccumulation: The accumulation ofsubstances, such as pesticides, or otherchemicals in an organism. Bioaccumulationoccurs when an organism absorbs asubstance at a rate faster than that at whichthe substance is broken down in the bodyand excreted.

BPC: The Beauty and Personal CareSustainability Project (BPC) is a pre-competitive collaboration of stakeholdersacross the industry value chain with the aimto increase the number of sustainable beautyand personal care products on retailers’shelves.

Brand: The originator of the final productand owner of any associated label/trademark.“Brand” includes a retailer’s privatelabel/private brand products.

Carcinogenic, mutagenic or toxic toreproduction: Substance of very highconcern that is carcinogenic (causes cancer),mutagenic (causes damage to genes) or

In product: Chemicals intended to be partof the finished product. An example is adurable water repellent chemicalformulation that is applied to a textile.Another example is a chemical plasticizeradded to a plastic product or component.Management process: A task or functiontowards a defined goal or objective. Thecombination of related processescomprises a management system.Management system: The set ofprocedures an organization needs tofollow to meet its objectives. A “chemicalsmanagement system” describes the set ofprocedures an organization needs tofollow to meet its chemicals managementobjectives.Manufacturer: The company thatmanufactures the chemical product.

reproductively-toxic (causes either a decreasein fertility or problems with development ofthe fetus.

Chemical:

Chemicals of High Concern (CoHCs): arechemicals that meet any of the followingcriteria: 1) carcinogenic, mutagenic, or toxic toreproduction (CMR); 2) persistent,bioaccumulative and toxic substance (PBT); 3)any other chemical for which there is scientificevidence of probable serious effects tohuman health or the environment that giverise to an equivalent level of concern (forexample, an endocrine disruptor orneurotoxicant); or 4) a chemical whosebreakdown products result in a CoHC thatmeets any of the above criteria.

Chemicals Policy: A statement of how acompany manages chemicals in its materials,supply chains, products, and operationsbeyond what is required by regulation.

Chemicals in Products: Refers to chemicalsthat are intended or anticipated to be partof the finished product. Examples includedyes, silicone finishes, screen printing, inks,labels, a durable water repellent chemicalformulation, or a chemical plasticizer addedto a plastic product or component.

Chemical Footprint is the total mass ofchemicals of high concern (CoHCs) inproducts sold by a company, used in itsmanufacturing operations its facilities andby its suppliers, and contained in packaging.

Chemical footprinting is the process ofassessing progress toward the use of saferchemicals and away from chemicals of highconcern to human health or theenvironment.

The Chemical Footprint Project Surveyevaluates responders' chemicalsmanagement systems against best practiceto measure and reduce chemical footprints.

Endocrine Disruptors: Substances of veryhigh concern that mimic or inhibit theeffects of hormones. Many of thesesubstances are also CMRs.

Formulated Product: A preparation ormixture of chemical substances that can begaseous, liquid, or solid (e.g., paints, liquidcleaning products, adhesives, coatings,cosmetics, detergents, dyes, inks, andlubricants). Note it can be an intermediateproduct sold to another formulator,fabricator, or distributor or final productsold to a consumer or retailer.

GreenScreen List Translator™ (GSLT): Anabbreviated version of the full GreenScreenmethod that can be automated. It is basedon the hazard lists that inform theGreenScreen method. The GreenScreen List

Translator maps authoritative and screeninghazard lists, including GHS countryclassifications, to GreenScreen hazardclassifications. The GreenScreen List Translatorcan be accessed through Pharos or Toxnot.

Hazard (chemical): Inherent property of asubstance having the potential to cause adverseeffects when an organism, system, or populationis exposed, based on its chemical or physicalcharacteristics.

Hazard Assessment: The process ofdetermining under what exposure conditions(e.g., substance amount, frequency and route ofexposure) a substance can cause adverse effectsin a living system. Toxicology studies are used toidentify the potential hazards of a substance bya specific exposure route (e.g., oral, dermal,inhalation) and the dose (amount) of substancerequired to cause an adverse effect.

Persistence: Attribute of a substance thatdescribes the length of time that the substanceremains in a particular environment before it isphysically removed or chemically or biologicallytransformed.

Persistent, Bioaccumulative and Toxic (PBT):Chemical that is toxic, persists in theenvironment and bioaccumulates in food chainsand, thus, poses risks to human health andecosystems.

Restricted Substances List (RSL): A list ofchemicals restricted by a company in products,parts, or components from its suppliers. A RSLmay include only chemicals that are currentlyrestricted by regulation. It may also includechemicals that are not yet legally restricted buthave been identified as being of concernbecause of scientific evidence that they maycause harm to human health or theenvironment.

PAGE | 47

Safer Chemical: A chemical that, due to itsinherent chemical and physical properties,exhibits a lower propensity to persist in theenvironment, accumulate in organisms andinduce adverse effects in humans oranimals.

Safer Alternative: A chemical, material,product, process or technology that is lesshazardous for humans and theenvironment than the existing approach.

SIN List. ‘Substitute It Now’ list fromChemsec consists of chemicals that havebeen identified by ChemSec as beingSubstances of Very High Concern, based onthe criteria defined within REACH, the EUchemicals legislation. The SIN List isimplemented in many corporate chemicalsmanagement policies, third-partyverification labels and procurementrequirements including the Dow JonesSustainability Index product stewardshipcriterion.

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Supplier: Any actor in the supply chain thatprovides intermediate and/or finalproducts and/or supporting services tobrands and/or retailers. This includes:materials, assembly, and finished productsuppliers.

Tier 1 Supplier: A manufacturer whoprovides products directly to a companywithout dealing with a middleman or othermanufacturers.

Watch List: A list of chemicals of concernthat a company does not currentlyprohibit, but is considering prohibiting inthe future due to scientific evidence that achemical may cause harm to human healthor the environment.

CLEAN PRODUCTION ACTIONPAGE | 49

APPENDIX A Chemical Hazard List Resources

The REACH Candidate List of Substances of Very High Concern (SVHCs) includes chemicalsbeing considered for restriction in the European Union (EU). If a chemical is restricted,businesses must apply for and receive authorization to continue its use. The Candidate List isimportant for retailers in the EU who are required to divulge – within 45 days - the presenceof any SVHCs present in an article over 0.1% by weight. The REACH Authorization List includes chemicals included in Annex XIV of REACH, theEuropean Union’s comprehensive chemicals regulation. Use of chemicals on this list isrestricted unless authorized in the European Union.The EU Restriction of Hazardous Substances (RoHS) restricts the use of hazardous chemicalsin electrical and electronic equipment.The Washington State Chemicals of High Concern to Children Reporting List includeschemicals that manufacturers must report to the Department of Ecology when used inchildren’s products sold in the state.The California Safer Consumer Products Candidate Chemicals List is an informational list ofchemicals that exhibit a “hazard trait and/or an environmental or toxicological endpoint” andare either found on one or more specified authoritative lists of hazardous chemicals oridentified by the California Department of Toxic Substances Control as meeting specifiedcriteria.

The Beauty and Personal Care Sustainability Project (BPC): defines their stewardship list ofchemicals of concern from a combination of international chemical hazard lists.The American Apparel and Footwear Association Restricted Substances List (RSL) includesmaterials, chemicals, and substances that are restricted or banned in finished home textile,apparel, and footwear products because of a regulation or law. In each case, the RSLidentifies the most restrictive regulation. The list is updated annually. AFIRM has developed a Restricted Substances Guidance for the apparel and footwear supplychain. The RSL Guidance is a review of all AFIRM brand RSLs, and is updated regularly. Itcreates a compilation of commonly defined pairs of "lowest limit" plus corresponding "mostsuitable test method" established by and prevalent in AFIRM member companies. Individualbrand RSLs may differ in specific parameters. The Guidance is available in nine languages. The Zero Discharge of Hazardous Chemicals (ZDHC) Manufacturing Restricted Substance List(MRSL) is a list of chemicals to be avoided in the apparel supply chain. ZDHC is an NGOformed by apparel and footwear brands and retailers to support the industry substitutingCoHCs with safer alternatives. Over 150 companies have adopted the ZDHC MRSL.

Examples of chemical hazard lists include:

Government

Sectoral Organizations

Safer Chemicals, Healthy Families has a useful series of fact sheets on key CoHCs which drawfrom the leading peer-reviewed science and are of direct relevance to retailers as well as a listof ‘Hazardous One Hundred’ chemicals for retailers to get started. The ‘Mind the Store’campaign is an excellent resource to track emerging chemicals of concern and how retailersare responding. The SIN list of over 900 chemicals was compiled and is maintained by ChemSec, a EuropeanNGO. The SIN database lists chemicals that meet the REACH criteria for chemicals of highconcern but which may or may not be regulated. . The SIN list was created to helpbusinesses proactively identify chemicals of concern as part of their chemicals management. Clean Production Action developed GreenScreen® List Translator, a list-based hazardscreening method, to enable users to quickly identify known CoHCs. It does this by evaluatingchemicals based on information from over 40 hazard lists and then “translates” thisinformation into a score indicating whether a given chemical is a “CoHC” as defined byGreenScreen® for Safer Chemicals. It is available in an automated framework (see below fordetails). Trainings on how to use the List Translator are available.The Chemical Footprint Project’s CoHC list includes over 2,200 chemicals, which wereidentified using GreenScreen List Translator.

Hazard listings - Associations between chemicals and specific human and environmentalhealth endpoints identified by governmental and professional authorities. Restricted substance lists (RSLs) - Listings of chemicals whose use is restricted and/ormanaged by regulatory or corporate policy or subject to voluntary program guidance. Hazard assessments - Toxicological assessments using the GreenScreen™ protocol thatbenchmarks the inherent hazards of chemicals across a broad range of health endpoints.Pharos contains a comprehensive list of all GreenScreen assessments published for publicuse.Identification - Approximately 50,000 chemicals are listed in Pharos, searchable by over150,000 CASRNs and synonyms utilizing the NIH PubChem database.Physical properties - chemical formulas and some key physical data are drawn from the NIHPubChem database.Compound groups - Pharos is the home of the Chemical Class Population Project whichcreates structural or other definitions for the chemical compound groups referenced byauthoritative hazard lists.

NGOs

List-based Chemical Hazard Assessment Tools

Pharos

Pharos provides resources to assess human and environmental health hazards of chemicals plustools to collaborate to find safer alternatives. It incorporates the GreenScreen List Translator plusthe following data sources:

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Toxnot

Toxnot is a chemicals management and hazard assessment platform that has incorporatedGreenScreen Chemical Hazard Assessments and GreenScreen List Translator into its suite oftools. Retailers can understand product and supply chain hazards at no cost. Other offeringsinclude platforms that allow brands, customers, and suppliers to collaborate on chemicalstransparency both through an open exchange of data and by pooled funding of chemical hazardassessments. Toxnot also provides a robust commercial toolset that allows companies to applychemicals hazard assessment in their products and chemical inventories as well as providingsupport for reporting and compliance initiatives.

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DESIGN BY KAYLA WILLIAMS / LAST EDIT NOVEMBER 2020

1310 Broadway, Suite 101, Somerville, MA 02144www.cleanproduction.org • 781.391.6743 • moreinfo@cleanproduction.org • @CleanProAct