New EDF Report on Smart Innovation and the Case of Preservatives

Today EDF released a new report, Smart Innovation: The Opportunity for Safer Preservatives, which offers a framework for safer chemical and product development. The report details baseline toxicological information on a select set of preservative chemicals used in personal care products, and makes the case for why and how access to uniformly developed sets of chemical health and safety information can help drive safer chemical and product innovation.

Consumers are demanding safer products for their homes, schools, and places of work. Growing awareness about the health and environmental impacts of chemicals is driving this demand. The entire consumer goods supply chain, from chemical manufacturers to retailers, plays a significant role in ensuring products on the market are healthful—i.e. made up of ingredients or materials that are as safe as possible and support healthy living.

How can we use data to strengthen the marketplace and ensure better innovation and competition for safer chemicals? Companies introduce new products into the marketplace all the time, but too few strive towards innovation that is safer for people and the planet. We need innovation that generates ingredients and materials that not only perform, but are also safer than their predecessors. Smart innovation is data-driven, deliberate, and delivers solutions that support health.

Unfortunately, the lack of availability and access to comprehensive and transparent toxicological information on chemicals across the supply chain continues to be a major obstacle to smart innovation. Such baseline information is invaluable for setting safer chemical design criteria that chemical and product developers can integrate into their R&D efforts.

In EDF's new report, we demonstrate how this type of information can be useful in the pursuit of safer preservatives – an ingredient class that has garnered much regulatory and market scrutiny. For example, major retailers like Walmart, Target, and CVS have published chemicals policies that aim to drive chemicals of concern off their shelves while ensuring consumer access to safer chemicals and products. Preservatives are present on each of these retailer’s lists of chemicals targeted for removal.

Ultimately, delivering products to the marketplace that use the safest possible ingredients requires concerted effort and informed, smart innovation. Our report discusses how this can be achieved via the creation of a collective Chemicals Assessment Clearinghouse that is leveraged across the supply chain. Such a Clearinghouse would provide a strategic intervention to unlock safer chemicals innovation to benefit companies, consumers and the environment.

Dear CEO: How EPA is critical to protect your customers from harmful chemicals

American businesses benefit tremendously from the robust voluntary and regulatory programs of the U.S. Environmental Protection Agency. These programs are now under threat of massive budget cuts and regulatory roll backs. This blog, focusing on chemical safety, is the latest in a series from EDF + Business highlighting how industry stands to lose from a weakened agency. To prevent these negative consequences, the business community needs to be at the forefront and demand policymakers support the U.S. EPA and its critical mission. 

Recent attacks against EPA for purported regulatory overreach and an anti-business agenda ignore EPA’s crucial work on safer chemicals in the marketplace. EDF + Business works closely with leading companies to address public health and consumer concerns regarding exposure to chemicals. Leading companies rely on smart, science-backed regulations to provide market certainty and protect their industries from bad actors. Threats to underfund and deregulate EPA could jeopardize its continued leadership, which is desperately needed on chemical safety.

In June 2016, the Frank R. Lautenberg Act was signed into law. The Lautenberg Act was the result of a strong bipartisan effort to reform the Toxic Substances Control Act (TSCA) and finally give EPA the means to protect Americans from exposure to toxic chemicals. The Lautenberg Act not only had strong support from both sides of the aisle in Congress, it also had strong support from business: including trade groups like the American Chemistry Council, the Chamber of Commerce and individual companies like BASF and SC Johnson. Why? Because they agreed that empowering EPA to review both new and existing chemicals and make affirmative decisions about their safety – thereby providing a consistent foundation for the safety of chemicals in the marketplace – would not only be good for improving public health, it would be good for business. The EPA’s job is to ensure a clean, healthy environment for all Americans. After years of input and strong bipartisan support, the reformed TSCA gave EPA the necessary tools to protect the public from toxic chemicals.

Business stands to benefit from greater market certainty and consumer confidence under the reformed TSCA. For example, product manufacturers should worry less about investing in the commercialization and usage of a chemical that years later could be found to imperil human health. And if the law meets its expectation, companies may in the long-term have less to fear about the state activity that had picked up when the federal government was not equipped to do its job. This action had been filling the void but led to a patchwork of requirements and regulations that bedeviled companies and left consumers confused about which chemicals in products were safe. The promise of greater market certainty and greater consumer confidence was critical to the Lautenberg Act’s support in Congress. Republican Senate sponsor David Vitter said, “Republicans agree to give EPA a whole lot [of] new additional authority. . . In exchange, that leads to … a common rulebook.”

However, fulfilling the promise of market certainty for industry and greater protection of consumer health depends on a funded and staffed EPA.  If some in industry and their allies in Congress seek to undermine EPA at every turn – whether through budget cuts, anti-regulatory legislation, or stall tactics – they will stymie the promise of the Lautenberg Act and find themselves back at square one. If on the other hand, business, environmentalists, Democrats and Republicans cooperate as they did to get the Lautenberg Act passed – but this time to ensure that EPA is enabled to implement the Lautenberg Act successfully, putting public health first – we could see a new era of chemical safety and innovation in the industry. And finally achieve what business and everyday Americans need.

Effective enforcement of bipartisan legislation is not the only place that the EPA can and must continue to lead. Creating opportunities for business leadership is also important. The innovative Energy Star program, a joint EPA-DOE voluntary energy efficiency program, is a great example of successful collaboration between business and federal agencies.  The EPA is also the architect of another, perhaps lesser known, voluntary corporate leadership program called Safer Choice.

The Safer Choice program is widely used by companies, celebrated by consumer advocacy groups, and helps to reduce the level of exposure to potentially hazardous chemicals. Touted by Consumer Reports as a meaningful tool for shoppers, the Safer Choice program recognizes products whose chemical ingredients are the safest within their function (e.g. solvents). Each product bearing the Safer Choice label – over 2000 today – has been evaluated by EPA scientists to ensure that the product’s ingredients meet the program’s rigorous human health and environmental safety criteria. BASF, Levi Strauss, Clorox, Staples, AkzoNobel, Sun Products are just a few of the 500 companies in the retail supply chain that have made the offering of Safer Choice ingredients or products a key part of their business. Likewise, influential trade associations such as The Worldwide Cleaning Industry Association (ISSA), with over 7000 members, and the Consumer Specialty Products Association (CSPA), with over 250 companies representing $100 billion in sales annually, have recognized and promoted Safer Choice as a program that can give companies a competitive edge in the marketplace. In a recent op-ed, CSPA called for the new EPA Administrator to support Safer Choice because it “has provided tangible, bottom-line results for consumers, businesses and environmental advocates.”

EPA regulatory enforcement to protect health, and voluntary programs that recognize leading companies, benefit all Americans.

Target moves up the safer chemicals leadership ladder

Yesterday Target announced a new chemicals policy that applies to all products sold in its stores and to its operations. Does this policy have the capability to transform the marketplace by ushering in safer affordable products? Let’s take a look.

In the new policy, Target announces aspirations and time-bounded goals framed in three major areas: transparency, chemical management, and innovation.

On transparency, Target has surpassed its competitors by committing to gain not only full visibility into the chemicals in final products but also into chemicals used in manufacturing operations. Target also takes a leadership stance by aspiring for this full material disclosure across all product categories. This goal is significant and noteworthy, considering the number and variety of products (and associated manufacturing processes) at the average retail store. Target will first implement this transparency goal in “beauty, baby care, personal care and household cleaning formulated products by 2020”. In one drawback, Target is quiet regarding if and how this enhanced supply chain transparency will translate into greater ingredient transparency to consumers.

In the second area, chemical management, Target vows to implement a hazard-based approach to prioritize chemicals. It announces the use of hazard profiles – which characterize the inherent health and environmental hazards of chemicals – in judging which chemicals get added to Target’s new Restricted Substances Lists (RSLs) and Manufacturing Restricted Substances Lists (MRSLs), for future reduction and/or removal. This approach is critical to fostering safer product design and is in line with the philosophy of the Commons Principles for Alternatives Assessment, guiding principles EDF helped develop.  To kick off this work, Target outlines chemical and product specific goals: removal of PFCs and flame retardants from textiles by 2022 and removal of formaldehyde and formaldehyde donors, phthalates, butyl paraben, propyl paraben, and NPEs from the formulated product categories mentioned above by 2020.

Finally, Target commits to directly support safer chemicals innovation. In doing so, Target has shown its understanding that eliminating hazardous chemicals from the consumer product value chain is half the battle; promoting the development or discovery of safer alternatives and enabling their usability in products is as important. Specifically, Target pledges an investment of up to $5 million in green chemistry innovation by 2022.

Target also pledges to publicly share progress against its new policy on an annual basis. We look forward to this regular engagement of the public and hope it will include quantitative measures of progress.

EDF commends Target for establishing a corporate chemicals policy, making it ambitious, and stipulating time-bound goals in specific product categories. Target continues the emphasis on beauty, home and personal care, and baby products that it initiated in 2013 with its Sustainable Product Index. New to the fold is action on safer textiles. In another welcome development, Target has publicly released a key set of chemicals of concern that it plans to remove from these product categories. Interestingly for formulated products, Target’s starting list of chemicals for removal is very similar to the initial set of high priority chemicals Walmart disclosed in 2016. With the two largest retailers in the U.S. not slowing down on safer chemicals leadership, the future of the marketplace looks healthier.  Will other retailers finally follow suit?

How can your company detox in 2017? EDF’s new tools for safer chemicals in products

Green Business Businessman Inspiration Peaceful Concept

Becoming a leader on safer chemicals is a meaningful way to address increasing consumer demand for ingredient transparency and safer products. The good news: taking the first step is easy to do.

In these uncertain times, corporate leadership is more important than ever in maintaining momentum to address our most serious environmental challenges – from climate change to water depletion to exposure to hazardous chemicals. Recently, I participated in the 11th annual BizNGO Conference titled “Measuring Progress to Safer Chemicals.” The event was full of solutions-oriented dialogue among NGOs, investment firms, and leading consumer product companies – in textiles, personal care, health care, electronics, cleaning, and more – about topics from meaningful transparency to measuring the ubiquity of chemicals of concern. Overall, the conference renewed my belief that companies are ready and willing to accelerate the adoption of safer chemicals in the marketplace. For example, now over 60 organizations, including Staples and CVS Health, have signed on to the Chemical Footprint Project, which recognizes companies that have effectively demonstrated public commitment to improved chemicals management. Elsewhere, some companies are publicly showing success at reducing the use of chemicals of concern.

Although leading companies are paving the way, it is clear that we need more companies, especially more retailers, to achieve full marketplace transformation. Companies that are interested – but uncertain of where to start – should explore building a chemicals policy.

A written corporate chemicals policy is the most effective tool in jump-starting and sustaining Institutional Commitment for safer chemicals. It helps a company articulate its chemical management goals and set a course for success. A strong chemicals policy begins with an overarching aspirational vision that conveys the company’s desire to take a leadership stance. The company’s specific objectives for attaining leadership on safer chemicals are the meat of a chemicals policy. At a minimum, these objectives should focus on:

  • Improving Supply Chain Transparency
  • Cultivating Informed Consumers
  • Embedding safer Product Design, and
  • Showing Public Commitment

What are the benefits of writing all of this down? Goal embedment and alignment, employee empowerment, and sparking accountability internally and within the company’s supply chain – to name a few.

But what does all of this really look like on paper? EDF has created templates retailers can use when fleshing out their own chemicals policy. Our templates provide starting text as well as tips and resources for customization.

Consumers are looking to companies to lead the way — publicly and credibly. Use our templates to help you build a chemicals policy that gives you a competitive edge and builds consumer trust.

 

Is Walmart a Leader on Safer Chemicals?

Consumers want to know that the products they buy contain ingredients that are safe for them and their loved ones. EDF has identified five pillars of leadership to help companies meet that demand and in doing so build consumer trust in the products they make and sell. One company that has recently taken major steps to drive safer chemicals and products into the market is Walmart.

In 2013, Walmart published its Sustainable Chemistry Policy, which focuses on ingredient transparency and advancing safer product formulations in household and personal care products. EDF worked with Walmart as it developed its policy and has advised the company during implementation and data analysis. This past April, Walmart announced that the company achieved a 95% reduction in the use of high priority chemicals of concern. Now, Walmart has shared considerable additional information detailing the progress made, including the identities of the high priority chemicals.

In our previous blog, we broke down the wealth of information that Walmart has shared. However, to fully evaluate the significance of the numbers, we now look at how well Walmart has done against EDF’s five pillars: institutional commitment, supply chain transparency, informed consumers, product design, and public commitment.

Read more

Major Strides: Walmart Details Progress on Chemicals

baby

In 2013, Walmart published its Sustainable Chemistry Policy, which focuses on ingredient transparency and advancing safer product formulations in household and personal care products. EDF worked with Walmart as it developed its policy and has advised the company during implementation and data analysis.

This past April, Walmart announced that the company achieved a 95% reduction by weight in the use of high priority chemicals of concern. Today, Walmart shared considerable additional information detailing the progress made, including the identities of the initial high priority chemicals. Let’s unpack this.

Revisiting Walmart’s Sustainable Chemistry Policy

Broadly speaking, Walmart made three commitments in its 2013 policy:

  1. to increase transparency of product ingredients,
  2. to advance safer formulations of products, and
  3. to attain U.S. EPA’s Safer Choice certification [formerly Design for the Environment] of Walmart private brand products

The policy, which went into effect in January 2014, focuses on formulated household cleaning, personal care, and beauty products, sold at Walmart U.S. and Sam’s Club U.S. stores. A few months after releasing the policy, Walmart published a policy implementation guide that gave suppliers greater specificity as to Walmart’s expectations and, importantly, outlined the quantitative metrics Walmart would use to track and report progress.

How Walmart has fared so far

  1. “Transparency”:

Walmart’s policy requires its suppliers to be more transparent about the ingredients in their products in two ways. First, Walmart requires suppliers to submit “full product formulations” – the names and concentrations of all ingredients in a product – to WERCSmart, a 3rd party- managed product ingredient database. WERCSmart provides the retailer with aggregate information about the types and quantities of chemicals in the products on its shelves without divulging specific product formulation data.

Second, the policy requires suppliers to increase ingredient transparency to consumers by calling for disclosure of product ingredients online starting in 2015. Further, any Priority Chemical found in a product must be disclosed on the product’s packaging starting in 2018. Priority Chemicals (PCs) are Walmart’s designated chemicals of concern, drawn from 16 reputable regulatory and authoritative lists.

To track the first requirement, Walmart determined the number of products whose ingredients are fully accounted for in the WERCSmart database. According to the data, 94% of the product formulations are full formulations. This suggests that the other results Walmart presents today are based on real data.

To track ingredient transparency to consumers, Walmart polled suppliers about their online disclosure practices using the Walmart Sustainability Index, its annual environmental issues survey sent to suppliers. In 2015, 78% of respondents reported they disclose ingredients online for all their products. Walmart also breaks down the responses  in more detailed ways, such as by department.

  1. “Advancing safer formulations of products”:

The bulk of Walmart’s policy focuses on providing safer products to customers by calling for the “reduction, restriction, and elimination” of Priority Chemicals (PCs), and for product reformulations to be undertaken using “informed substitution principles.” Because the list of PCs includes hundreds (if not thousands) of chemicals — as evidenced by Walmart’s reference list of regulatory and authoritative lists used to define its PCs — Walmart focused its suppliers’ attention on a shorter list of High Priority Chemicals (HPCs).

Today, Walmart identified the HPCs as propylparaben, butylparaben, nonylphenol ethoxylates (NPEs), formaldehyde, dibutyl phthalate, diethyl phthalate, triclosan, and toluene. These eight chemicals and chemical classes appear on a number of authoritative lists (e.g. EU REACH Substances of Very High Concern) for their hazardous properties and are worthy of action by Walmart. The revelation of the identities of the chemicals was long-awaited and provides context to the rest of the information Walmart shared today.

To assess the portion of its chemical footprint[1] related to product sales covered by the policy, Walmart has measured progress in two ways: (i) the total weight of HPCs contained in products sold, i.e. pounds of HPCs going out the door, and (ii) frequency of use, i.e. the number of products on store shelves that contain HPCs and the number of suppliers using HPCs in their products. Walmart relied on RetailLink, its internal product inventory database, and WERCSmart, mentioned earlier, to make these calculations. Walmart has also computed and published this data for all Walmart PCs in the covered product categories.

Walmart reports a dramatic reduction in the total weight of PCs and HPCs going out the door. The total weight of HPCs dropped by 95% and PCS by 45%.  The more than doubling of reduction of HPCs suggests that focusing attention on a subset of chemicals accelerated action.

Walmart attributes part of the success to its ability to determine which select set of suppliers used the majority (in pounds) of HPCs. This illustrates the utility of a product ingredient database that can provide aggregate information by supplier while not disclosing proprietary information.

As it relates to progress made in reducing the frequency of use of HPCs, the results were far more modest.  Unfortunately, it appears that suppliers who use HPCs are largely still using them, though the aggregate mass has dropped. Overall, the percent of products containing HPCs dropped by only 3 percentage points (to 16%), while the percent of suppliers using HPCs increased slightly (to 39%). Meanwhile, the percent of products containing any Priority Chemical actually went up one percentage point (to 80%).

So while the weight amount of HPCs, and PCs more broadly, has dropped significantly, there is clearly much more work to be done to achieve complete elimination of these chemicals.

  1. “Safer Choice [formerly Design for the Environment] in private brands”:

Lastly, Walmart committed to increase the number of private brand product offerings bearing Safer Choice certification. As discussed in our recent blog, the Safer Choice Program is a voluntary program implemented by the U.S. EPA that seeks to recognize and bring consumer awareness to products that are leading the way when it comes to safer ingredients. This is the only commitment for which Walmart has not released quantitative data. The company reports that it has hit snags in making progress against this target but is still committed to the program.

Conclusion

Overall, Walmart has made major strides regarding the commitments set forth in its policy. Equally notable, it has set in place effective systems to measure and track progress over time – an ability that can’t be underestimated.

In our next post, we’ll assess where Walmart’s progress rates against EDF’s five pillars of leadership for safer chemicals in the marketplace.


[1] As defined by the Chemical Footprint Project, a chemical footprint is “the total mass of chemicals of high concern in products sold by a company, used in its manufacturing operations and by its suppliers, and contained in packaging.”

Further Reading:

Making Strides on Companies’ Chemical Footprints

Behind the Label_FAs we’ve written here before, public commitment is one of the essential pillars of leadership on safer chemicals. When a company leads on public commitment, that means communicating not just its initial goal-setting, but its full safer chemicals journey, publicly and honestly.

That’s no small task. The rise of shareholder resolutions across a wide range of sectors shows that investors and purchaser communities are becoming increasingly interested in how companies manage chemicals and mitigate risk. With the release of its inaugural report, one organization is throwing a spotlight on companies that are not just making, but following through on, those commitments.

Ingredients for measuring your (chemical) footprint

Chemical Footprint Project logoThe Chemical Footprint Project (CFP) recognizes companies that have effectively demonstrated public commitment to improved chemicals management. A joint effort launched in June 2015 by Clean Production Action, Pure Strategies and the Lowell Center for Sustainable Production at the University of Massachusetts-Lowell, the CFP was created as a simple way for investors and purchasers to assess these critical aspects of corporate value.

The CFP’s evaluation system was designed to be flexible and can be used for any business sector, from personal care products to toys. Using a twenty question survey, the CFP assesses companies’ performance in four areas:

  1. Chemicals management strategy (i.e. corporate chemicals policies),
  2. Chemical inventory (i.e. knowing the chemicals used in products, manufacturing processes and supply chains),
  3. Chemical footprint measurement (i.e. knowing the mass of chemicals of high concern in a company’s products and packaging, processes, and supply chain and tracking progress toward safer alternatives), and
  4. Public disclosure and verification.

A company’s performance is scored on a 100-point scale, with a bonus for verification – respondents receive up to 4 points for independent validation of reported data.

Breaking down CFP’s findings

Last week, the CFP released its inaugural report, with 24 companies from seven sectors participating. Though individual company scores are presented without identification, CFP’s initial report reveals many interesting themes: Read more

Walmart Makes Progress on Its Sustainable Chemistry Policy

Behind the Label_FIt’s been two and a half years since Walmart first committed to adopting a sustainable chemistry policy. Since then, consumers, companies and advocates have been watching the retailer with interest. Today, Walmart released its ninth annual Global Responsibility Report (GRR), which outlines its environmental and social activities for the past year. For the first time, this report includes information about the progress it has made against its Sustainable Chemistry Policy adopted in 2013, which aimed for more transparency of product ingredients and safer formulations of products.

According to Walmart, it has reduced the usage (by weight) of its designated high priority chemicals by 95 percent, a pretty sizeable number. Walmart has said that it will post more specifics in the coming weeks on its Sustainability Hub, including quantitative results on all aspects of the policy’s implementation guide and details about how they achieved the substantial reduction.

casestudy-walmartWhile this is a promising step in the right direction, the GRR doesn’t identify the high priority chemicals that have been reduced. It is difficult to fully appreciate Walmart’s accomplishments without knowing the names of these chemical targets. We expect that the names of the high priority chemicals will be revealed on the Sustainability Hub.

Walmart’s announcement marks the first time a major retailer has publicly measured and shared the progress it has made against its commitment on chemicals. This is especially important to EDF because we know through research and experience that shared stories about progress can prompt others to follow, to the benefit of public and environmental health.

We believe there are three key factors that have made Walmart's progress possible: 1) the existence and use of a 3rd party-managed chemicals database that can generate quantitative, aggregate information about the chemicals on Walmart’s shelves, 2) a policy that prioritizes specific chemical targets, and 3) a time-bound business commitment to track and share progress publicly (in Walmart’s policy they committed to start sharing progress in 2016). We look forward to the day these practices reflect the business norm rather than the exception.

Market leadership will always have an important role to play alongside policy in driving safer chemicals and products into commerce. EDF looks forward to the additional details forthcoming on Walmart’s Sustainability Hub.

Follow Boma Brown-West on Twitter: @Bbrown_west

Also of interest:

Alternatives Assessment: A Key Tool for Safer Chemicals in Products

Increasing the safety of products calls for a structured, thoughtful approach: knowing which chemicals of concern you want to remove from your supply chain, putting in place a methodology and resources to meet that goal, and evaluating progress as you move forward. That’s at the core of the pillars of leadership for safer chemicals we’ve identified through our collaborations with Walmart and others.

Behind the Label - the blueprint for safer products in the marketplaceHowever, figuring out how to move from hazardous chemicals to those that are inherently safer – without increasing risk or compromising performance – takes having a clear, replicable process. Chemicals Alternatives Assessment (CAA), sometimes referred to simply as Alternatives Assessment, is one such process, a powerful methodology that can help you select ingredients in line with your safer product design objectives. CAA helps product designers identify, compare and select safer alternatives to chemicals of concern (including those in materials, processes or technologies) on the basis of key attributes – notably their hazards, exposure potential, performance, and economic viability.

CAA was born out of a need to help companies make smarter choices about the chemicals used in every day products, and ultimately make our world a healthier one. As a methodology, CAA was developed as a practical way of incorporating safer product design into product development and reformulation. Read more

Leading On Chemicals: Not Just by Example, But By Commitments

BtlHeadlinesFor a number of years in the environmental world, we’ve been able to talk about the public commitments companies are making – and achieving – with respect to impacts like greenhouse gas emissions and water usage. Lately, companies have begun to publicly discuss goals related to safer products, recognizing that safer chemicals are part of the sustainability conversation.

For example, in the food sector, companies have cracked opened the proverbial “kitchen door” and started to share with consumers what is not in their products. This glimpse into the food-making process comes in the form of public commitments made by more than 10 major food manufacturers and restaurants in 2015 alone to eliminate or reduce artificial colors and flavors. Similar activity is occurring elsewhere, like the electronics sector and personal care sector.

But, what is leadership when it comes to public commitments? Today, we tackle this question as part of our series on the leadership pillars for safer chemicals in the marketplace. In a nutshell, leadership on public commitment goes beyond a one-time publication of goals; it requires a company to make frequent, transparent communication about its safer chemicals journey. Three key actions companies can and should take:

  1. Publish a corporate chemicals policy
  2. Share progress and
  3. Communicate the process

Of course, going public has its challenges, such as opening the door to criticism. But, good things happen as well when a company goes public with its goals and journey.

A company can rally its supporters inside the company and supply chain. It can find new allies in the media, business, and non-profit worlds. It can build consumer confidence in its brand. Finally, being open about goals and the subsequent journey helps a company succeed in its quest to meet those goals.

Today we've updated our Behind the Label website to delve further into the elements of leadership on public commitment and the associated hurdles and opportunities.

In addition to outlining what leadership on public commitment means, we've started tracking the commitments some companies are making, so those newer to the process have a sense of where to get started. We're beginning with the food sector, where grocers, restaurants and food manufacturers have become increasingly vocal about the food additives they are eliminating.

Further reading to help you get Behind the Label: