Who is Promising What on Home and Personal Care products in the U.S.?

Business leadership is critical in realizing a safer marketplace. Companies are committing to be more transparent about ingredients and to remove certain chemicals of concern from products.

To track the movement in the marketplace, we made a tally of the public commitments made in the household cleaning and personal care product sectors. For our tally, we have included only those commitments that are explicitly stated on the companies’ websites.

This is a living document and is in no way an exhaustive tally, but we aim to update it over time. Please let us know if you have any suggestions to improve the list — especially if we have missed a company.

Find existing commitments at the following links:

Retailers with "never use" ingredient lists

RetailerProducts coveredStated commitment
CVS"Earth Essentials" cleaning productsNo phosphates, phthalates
CVS store brand baby, beauty and personal care productsNo chemicals on CVS store brand restricted substances list
Target"Made to Matter" labeled products“Made to Matter Standards” include one (voluntary) criterion that product should be made without “additives and harsh chemicals"
Walgreens"Well Beginnings" lineNo parabens, phthalates, formaldehyde donors
"Ology" lineNo ammonia, chlorine bleach, DEA, TEA, parabens, phthalates, formaldehyde, nonylphenol ethoxylates (NPEs), triclosan, sulfates, dyes, and artificial fragrances
Whole FoodsAll personal care productsOver 100 ingredients banned
Premium Body CareTM productsOver 400 ingredients banned
All cleaning productsEco-Scale product rating system (red, orange, yellow, green tiers) listing “unacceptable ingredients” – ingredients not allowed in products labeled at the different tier levels

Brand manufacturers with "never use" ingredient lists

Brand manufacturerProducts coveredStated commitment
AvedaAll productsNo parabens, phtalates, and sodium lauryl sulfate
Beauty CounterAll productsThe Never List – 1500 ingredients banned
Burt's BeesAll productsNo parabens, phthalates, petrolatum, sodium lauryl sulfate, chemical sunscreens (synthetic chemicals), glycols (synthetic chemicals), polyethylene glycols (PEGs) or polypropylene glycol (PPGs) (synthetic ingredients), DEA or TEA (synthetic stabilizers), formaldehyde donors (DMDM hydantoin, diazolidinyl urea, methylisothiasolinone (MIT)), 1,4-dioxane (contaminant).
Petroleum-free packaging.
EO ProductsAll productsNo parabens, laureth sulfate, synthetic fragrances, propylene glycol, polysorbates, phthalates, artificial colors or dyes, GMOs.
The Honest CompanyAll products"Honestly free guarantee" – Hundreds of ingredients banned
MethodAll ProductsNo chlorine bleach, triclosan, EDTA, phosphates, 2-butoxyethanol, phtalates, parabens, ammonia, ethanolamine (MEA)
MychelleAll products"The Dirty 30" ingredients banned
Seventh GenerationAll productsNo phosphates, optical brighteners, synthetic surfactants, volatile synthetic surfactants, volatile organic compounds (VOCs).
Tom's of MaineAll productsNo artificial colors, flavors, or fragrances, artificial preservatives, animal ingredients, ethylene glycol, gluten, grapefruit seed extract, parabens, peroxides, petrochemicals, phthalates, artificial sweeteners
UnileverBaby care productsFormaldehyde releasers/donors
Home and personal careNo mecury compounds
All productsIso-parabens, diethyl phthalates (DEP),

Retailer commitments to ban, phase-out, restrict, or reduce use of certain chemicals of concern

RetailerProducts affectedSpecific commitmentsDates
Bed Bath & Beyond Inc.Products as specifiedRestricted Substances List (RSL) including Manufacturing Restricted Substances ListEffective: 2014, updated annually
All productsCertain flame retardants bannedCompleted; date not specified
Sanitizers and hand or body cleansersTriciosan bannedCompleted; date not specified
All private label productsReductions in lead, cadmium, and phthalates (in plastics)In effect; date not specified
CVSAll CVS Brand productsRemoved Cocamide and Cocamide DEACompleted: 2013
Essence of Beauty ProductsParabens removedCompleted: 2013
“Essence of Beauty” body and hand creamsArtificial dyes removedCompleted: 2013
All CVS brand products, most name-brand productsTriciosan removedCommitted: 2014
Effective: 2015
CVS Brand ProductsMicrobeads removedCommitted: 2014
Effective: 2015
CVS Brand baby products, certain non-medicated adult cleansing wipesFormaldehyde removedCommitted: 2014
Effective: 2015
All CVS store brands in baby, beauty and personal care productsRestricted Substances List (RSL) including parabens, phthalates, formaldehyde donorsCommitted: 2017
Goal completion date: 2019
TargetPersonal care, Beauty, Household cleaning, Baby care productsRewards products that don’t contain one or more ingredients on Target’s high priority listCommitted: 2013
Remove phthalates, propyl-paraben, butyl-paraben, formaldehyde, formaldehyde donors, and NPEs
Restricted Substances Lists and Manufacturing Restricted Substances Lists
Walmart (U.S), Sam’s Club U.S.Health & beauty, Household paper, Pet supplies, Household chemicals, Cosmetics & skincare,Infant consumables, JanitorialRemove propyl paraben, butyl paraben, triclosan, toluene, dibutyl phthalate, diethyl phthalate, formaldehyde, nonylphenol (NP) and nonylphenol ethoxylates (NPEs)
Reduce chemicals on Walmart Priority Chemicals list
Committed: 2013
10% weight reduction in Walmart Priority Chemicals (or consumables chemical footprint)Committed: 2017
Goal completion date: 2022

Brands' commitments to ban, phase-out, restrict, or reduce use of chemicals of concern

CompanyProducts affectedSpecific commitmentsDates
AvedaAll productsElminate parabensCompleted: No date specified
Clean Control CorporationAll productsInorganic phosophorusCompleted: No date specified
Select floor strippers, concentrated laundry detergentsNo ammonia
No monoethanolamine (MEA)
Completed: No date specified
All products2-butoxy ethanol phthalatesCompleted: No date specified
Johnson and JohnsonAll baby products
All new products by 2015 (with rate exceptions>
Formaldehyde releasers removedCompleted: 2015
All productsParabens banned (except methyl, ethyl and propyl in adult products)
Fragrance oils: animal-derived ingredients, nitromusks and polycyclic musks, tagetes, rose crystal, diacetyl, Diethyl phthalate (DEP)
Completed: 2015
All productsMicrobeads removedCommitted: 2013
Completed: 2017
All productsTriciosanCommitted: 2011
Completed: 2015
P&GCleaning productsPhosphates phased-outCompleted: 2016
All formulated products No alkylphenols and alkylphenol ethoxylates, benzene, BPA, heavy metals, microbeads*, organotins, polyvinyl chloride (PVC), polycyclic aromatic hydrocarbons (PAHs), polychlorinated bphenyls (PCBs), phthalates*, triclosan, triclocarban*Completed: No date specified
* These ingredients are not used in current products and P&G has committed to removing them from exisitng products
Reckitt BenckiserAll productsFormaldehyde, dichlorvos, glycol ethers (monoethylene series), paradichlorobenzene (PDCB) removedCompleted: 2006
Formaldehyde-donor preservatives, Non-geranyl nitrile fragrance raw materials,  certain brominated flame retardants, alkyl phenol ethoxylates (APEs), NPEs removedCompleted: 2007
Chlorpyrifos, certain boron compounds, geranyl nitrile (GN) fragrance raw materials removedCompleted: 2009
Polyethylene beads to be removedGoal completion date: 2018
CosmeticsIsoparabens removedCompleted: 2015
All products except healthcare productsPVC packaging of household products removedCompleted: 2009
Seventh GenerationAll productsAcutely orally toxic ingredients and chronic toxicants phased outGoal completion date: 2020
Laundry detergentBoric acid removedCommitted: 2014
Completed: 2015
Formulated productsMethylisothiazolinone (MIT) removedCommitted: 2014
SC JohnsonAll productsNo "zero-rated" materials (unless at restricted levels)Committed: 2001
UnileverMost leave-on personal care products
Rinse-off personal care products
Methylisothiazolinone (MIT) removed
All productsTriclosan, triclocarban removedCommitted: 2015
Completed: 2017
New and existing fragrance formulationsLyral removedCompleted: 2017
Exfoliating productsPlastic scrub beadsCompleted: 2014

Retailer commitments on ingredient transparency to consumer

CompanyProducts affectedSpecific committmentsDates
TargetPersonal care, Beauty, Household cleaning, Baby care productsRewards products for increasing levels of ingredient disclosure on product labelsCommitted: 2013
WalmartHealth & beauty, Household paper, Pets & supplies, Household chemicals, Cosmetics & skincare, Infant consumables, JanitorialRequires suppliers to disclose all ingredients online (by product) and on product labelCommitted: 2013
Effective date: 2015 for online disclosure
Effective date: 2018 product label disclosure

Brand manufacturers commitments on ingredient transparency to consumer

Brand manufacturerProducts affectedLevel of transparencyDates
BeautycounterAll productsingredient name and function at product level onlineCompleted: No date specified
Clean Control CorporationAll productsIngredient name and function for non-fragrances at product levelCompleted: 2014
CloroxAll productsIngredient name and function for non-fragrances at product levelEffective: 2015
Flags EU fragrance allergens (with conditions) by product onlineEffective: No date specified
Ecos (Earth Friendly Products)All productsIngredient name and function at product level online and product labelCompleted: No date specified
The Honest CompanyAll productsIngredient names at product level online and product labelCompleted: No date specified
MethodAll productsIngredient names, function, safety information at product levelEffective: 2009 for online disclosure
Effective 2012 for product label disclosure
P&GAll productsPreservatives paletteEffective date: 2017
Fragrance palettes (with conditions)Committed: 2017
Goal completion date: 2019
Reckitt BenckiserAll productsIngredient name and function for non-fragrances at product level online and on-packEffective: 2009
Committed: 2017 for product label disclosure on US cleaning products
Disclosure of 99.99% of fragrance ingredients onlineCommitted: 2017
Full disclosure of dyes and preservativesCompleted: No date specified
SC JohnsonAll products (staged roll-out by product category)Ingredient names and functions for non-fragrances at product level onlineEffective: 2009
Exclusive Fragrance Palette onlineEffective: 2012
Product-specific fragrance information (with conditions) onlineEffective: 2015
Fragrance and non-fragrance skin allergen palette online and then by productEffective: 2017
Completed: 2017 for Palette
Goal completion date: 2018 for product-level information
Seventh GenerationAll productsAll ingredients disclosed on product packagingEffective: 2008
All ingredients, materials, packaging, and supply chain disclosed publicallyGoal completion date: 2020
UnileverAll productsNon-fragrance ingredient names and functionEffective: 2017
Fragrances at product level online (and available via SmartLabel QR code on product label)Committed: 2017
Goal completion date: 2018
Personal care productsFlag EU fragrance allergens on product labelCommitted: 2017

For more examples of companies leading on ingredient transparency, visit EDF's Rules for Online Disclosure

Sustainable Finance

Where ROI meets ROE (Return on Environment)

Sustainable investing has grown over the past decade, ushering in a new era of protecting the environment while earning financial returns. However, the cost of addressing the world’s urgent environmental challenges exceeds the capacity of philanthropic and public sector resources – this leaves a major financing gap. New research shows that blended financing can bridge that gap by directing private investment dollars to projects that deliver environmental outcomes and competitive financial returns.

Environmental Defense Fund’s (EDF) Sustainable Finance program works with the financial sector, with investors, and via public-private partnerships to find and scale innovative financing solutions that foster economic and environmental prosperity.

EDF Sustainable finance strategy

We seek to leverage the influence, expertise and capital of the financial marketplace to protect the environment, improve livelihoods and achieve ambitious environmental goals. We’ll do this by working with others to implement the following strategies:

1. Getting the rules right2. Making engagement & investment easier3. Demonstrating returns
We are working to advance policies and practices that improve transparency, reduce risks and create clear incentives and price signals in order to design more efficient and effective markets for environmental investment opportunities.To spur new investment in environmental solutions, we must lower investment barriers and transaction costs. We are creating and promoting tools and resources that improve information flows, standardize complex projects and build capacity in the marketplace.Environmental investments remain below the radar for many investors. We aim to connect private capital with priority environmental opportunities by working with partners on “lighthouse” or pilot transactions that demonstrate a strong investment case, mitigate risks and deliver returns. In the process, we are creating new investment models that others can follow and take to scale.

EDF is a proven leader in working with the financial sector to drive innovation and progress. Over the past several years, EDF initiatives have:

  • Raised the bar for environmental management across the private equity (PE) industry through pioneering partnerships with KKR, Carlyle, and Oak Hill Capital to measure, manage, and improve environmental and financial performance across PE portfolios.
  • Delivered healthier air to millions of New York City residents by empowering building owners and operators to invest in nearly 6,000 heating oil conversions through NYC Clean Heat, reducing emissions of fine particulate matter from buildings by over 65%.
  • Accelerated the transition to sustainable fisheries management by providing loans totaling over $4.2 million to support California Fisheries Fund

EDF’s Sustainable Finance experts also help to scale impactful financing through research, insight and case studies. EDF’s latest report, Unlocking Private Capital to Fund Sustainable Infrastructure, presents a framework for state and local governments, philanthropists and financial institutions to advance new partnerships for impact.

For regular updates please follow the EDF+Business blog. 

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EDF Model Policies

When it comes to safer chemicals in the marketplace, EDF's Five Pillars of Leadership offers a guiding framework for industry. But we are often asked how a retailer, grocer or brand can put those into action effectively. The most effective tool in jump-starting and sustaining leadership is a written corporate chemicals policy. A chemicals policy institutionalizes your commitment to lead on safer chemicals and articulates to all levels of the business, as well as to your suppliers, what the company wants to achieve. At a minimum, your chemicals policy should outline your aspirations for:

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

What does that look like? EDF created templates that you can use when designing your own chemicals policy. Our templates provide the text you need as well as tips and resources for starting your journey.

Model Food Additives Policy for Retailers/Grocers

Model Chemicals Policy for Retailers of Formulated Products 

An Investor's Guide to Methane

Oil and gas industry investors face increasing financial, reputational and regulatory risks from widespread methane emissions. An Investor’s Guide to Methane: Engaging with Oil and Gas Companies to Manage a Rising Risk, by EDF and the Principles for Responsible Investment (PRI), is a first-of-its kind guide to help investors manage methane risk through company engagement.

Methane — the primary component of natural gas and a climate pollutant 84 times more powerful than carbon dioxide over a 20-year period — is responsible for a quarter of global warming happening today.

The oil and gas sector is the largest industrial source of methane emissions, costing an estimated $30 billion in lost product each year. The guide was developed for concerned investors following the release EDF’s breakthrough Rising Risk report, which found that as of early 2016, none of the 65 leading upstream and midstream oil and gas companies operating in the United States disclosed methane reduction targets, and less than a third disclosed baseline emissions information via accessible, investor-facing data sources. Engagement from investors will be required to gain the data they need to factor methane management into portfolio selection, while encouraging continuous improvement as operators progress across the spectrum. This guide is designed to be a tool to support such constructive dialogue, holding companies accountable for managing methane and driving results.

This guide can help investors manage methane risks and keep more saleable product in the pipeline – a win-win for investors, companies, and communities.

Sean Wright  Lead author and Senior Manager, EDF

With the Investor’s Guide [PDF], EDF and PRI provide constructive tools for investors to engage with oil and gas companies on methane reporting and mitigation, to engage with senior management in constructive dialogue, and to identify concrete actions to improve methane performance.

This guide provides investors with an extremely valuable tool to understand these risks.

Jonas Kron  Senior Vice President, Trillium Asset Management

The guide provides practical advice on what investors should expect from companies regarding operational practices and disclosure. While the guide is aimed at public equity investors, the document can also be useful for investors in private companies, energy lenders such as investment banks and insurance companies, who may be looking to benchmark methane performance as they implement ESG and risk-management policies. Likewise, this guide can also be a reference for oil and gas companies to benchmark their operations and identify best practices.

Performance Assessment Tool

Through the guide, EDF and PRI have introduced a new Performance Assessment Tool [PDF] to rank company methane management performance.

Download the Assessment Tool

Methane Detectors Challenge

The Methane Detectors Challenge (MDC) is a groundbreaking partnership between Environmental Defense Fund (EDF), oil and gas companies, U.S. based technology developers, and other experts.

This collaboration aims to catalyze the development and deployment of stationary, continuous methane monitors. So far, the competition has led to several cost-effective, state-of-the-art options – including sensor and laser technologies that oil and gas companies are already adopting.

In January, Statoil became the first energy producer to purchase and install a new solar-powered technology device to continuously detect methane leaks, reduce emissions and minimize waste. The device was approved and tested through the Methane Detector Challenge and designed by Quanta3.

“We believe oil and gas production should be leak free,” said Dirk Richter, founder and CEO of Quanta3. “When I heard about the Methane Detectors Challenge and size of the emission problem in the oil and gas sector, I was inspired to put my research background in laser-based systems to work to develop a 24/7 monitoring technology.”

In addition, California's PG&E has since installed a low-cost laser technology developed by Acutect Inc., a San Francisco-based startup company.

"The Methane Detectors Challenge created the framework through which I was able to bring together a Chinese manufacturer of laser-based methane detection components and a team of product development engineers I’d previously helped spin out of Carnegie-Mellon, SenSevere LLC,” said Peter Foller, founder of Acutect Inc. 

In August, Shell launched a Quanta3 sensing system to continuously monitor methane emissions at a shale gas site in Alberta, Canada.

By advancing technologies to market, this innovative partnership is adding to the pool of more than 130 U.S. companies creating jobs by offering solutions to the methane problem.


Why Methane Matters

Methane is a potent greenhouse gas and the primary component of natural gas. In its first twenty years, methane has more than 80 times the global impact of carbon dioxide. The largest source of methane emissions in the U.S. and globally comes from the oil and gas industry. The good news? This can be fixed, benefitting both business and the environment.

25-gfx

See full infographic


 The Impact of Collaboration & Innovation

EDF Model Food Additives Policy for Retailers/Grocers

When it comes to safer food additives in the marketplace, we have identified Five Pillars of Leadership. But we often get asked how a retailer can put those into action effectively. The most effective tool in jump-starting and sustaining leadership is a written corporate chemicals policy. A chemicals policy institutionalizes your commitment to lead on safer food additives and articulates to all levels of the business, as well as to your suppliers, what the company wants to achieve. At a minimum, your chemicals policy should outline your aspirations for:

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

What does that look like? EDF has created a template you can use when fleshing out your own chemicals policy. Our template provides the text you need as well as tips and resources for starting your journey.

EDF Safer Food Additives Model Policy for Food Retailers

<publication date>

1. Vision Statement +
At <company name>, our mission is to provide our customers with products that meet their needs and are made with the safest ingredients.

What: The vision statement is the articulation of your aspiration

Why: It sets expectations that will drive internal decision-making and execution

2. Scope +
This policy applies to food and beverage products+ sold in our stores.

What: The scope defines which products are covered by the policy.

Why: This helps suppliers determine if they are impacted by the policy

Tips: You may want to start by covering a limited number of product categories first and expanding the scope of your policy after you achieve initial success. A common approach is to start with the firm’s private label products.

3. Supply Chain Transparency +
Our goal is to make informed decisions about the products we sell by improving our understanding of product composition. All suppliers must disclose complete product ingredient data+ to <product ingredient database>+ by <date>+.

What: A supply chain transparency goal clearly articulates your approach to gaining greater insight into the ingredients in the products you sell.

Why: Better knowledge of your supply chain enables you to identify potential risks; set, measure, and achieve safer chemical goals; and effectively communicate product ingredient information to customers.

Tips: Data should include the specific chemical identities of all substances in a product recipe, their CAS numbers, and concentrations – and who authorizes their use. Ingredient functions are also useful data to capture, as well as the identification of any Priority List chemicals in the product packaging (whether intentionally present or known to be likely contaminants).

Example Resources: U.S. FDA’s Everything Added to Food in the United States database

Tips: Third-party management of product ingredient data enables the analytics you need (e.g. calculation of the total volume of a particular chemical found on store shelves) while protecting suppliers' proprietary formulation data.

Example Resources: Label Insight, GC3 Retailer Tools for Safer Chemistry*, OECD Substitution and Alternatives Assessment Toolbox*

* Though not tailored to food, one or more of the resources featured above may be applicable.

Tips: Setting timelines helps your company and your suppliers plan for successful execution against stated expectations. Timelines should be informed by resource availability, business intelligence, and the scope of products covered by your policy. Timelines should be feasible yet ambitious enough to pass muster with external stakeholders.

4. Informed Consumers +
Our goal is to maintain consumer confidence in the products we sell by providing meaningful and easily accessible product ingredient and contaminant information.

What: Consumers have readily available access to product information that is comprehensive, understandable, and meaningful.

Why: Disclosure enables informed purchase decisions and builds consumer confidence, trust, and loyalty.

Disclosure online:+ Suppliers are required to disclose online a list of ingredients (no generics, i.e., flavor) and the ingredient functions by product by <date>+. For our private label products, this information will be made available directly on our website.

Tips: Requiring suppliers to share online ingredient information that extends well beyond regulatory requirements is a powerful step towards building and sustaining trust. While product packaging physically limits the amount of information that can be shared, online disclosure allows greater flexibility in terms of the extent and type of ingredient (and contaminant) information shared, as well as how that information is accessed and presented.

Example Resources: Label Insight

Tips: Setting timelines helps your company and your suppliers plan for successful execution against stated expectations. Timelines should be informed by resource availability, business intelligence, and the scope of products covered by your policy. Timelines should be feasible yet ambitious enough to pass muster with external stakeholders.

5. Product Design +
Our goal is to sell products that meet customer expectations, perform well and contain the safest available ingredients. To reach this goal, we will develop and implement a safer product design process by <date>+. As part of this process, we will:

What: A product design goal clearly articulates your approach to delivering effective products while driving out hazardous ingredients and assuring the use of safer ones.

Why: This step distinguishes those companies who go beyond talking the talk and make real, measurable progress towards safer products.

Tips: Setting timelines helps your company and your suppliers plan for successful execution against stated expectations. Timelines should be informed by resource availability, business intelligence, and the scope of products covered by your policy. Timelines should be feasible yet ambitious enough to pass muster with external stakeholders.

a. Develop and share a priority list+ of ingredients and contaminants that suppliers are required to reduce and ultimately remove+ from products;

Tips:: The Priority List is a list of chemicals that you have identified as critical to take action upon. This list should contain chemicals that have been identified as hazardous or potentially hazardous by authoritative and regulatory bodies and have been prioritized by you because of impact factors such as direct exposure potential, prevalence of use, or impending regulatory activity. In building your list, it is useful to keep an eye on authoritative determinations made not only in your operational jurisdiction(s) but also in other geographical locations. It is also useful to consider multiple hazard endpoints (e.g. carcinogenicity, reproductive toxicity, skin sensitization). As progress is made on reducing and removing chemicals on your initial Priority List from your products, you can re-apply your prioritization factors to identify additional chemicals to act upon.

Example Resources: GreenScreen List Translator Specified Lists, IC2 U.S. State Chemicals Policy Database

Tips: Depending on the chemicals on your Priority List and the availability of drop-in safer alternatives, you may need to work with your suppliers to develop interim targets and phase-out goals.

b. Require that all other ingredients used be reviewed by FDA+ for safety; and

Tip: Ensuring FDA’s scientists review the safety of additives reaffirms your commitment to provide your customers with the safest ingredients.

c. Periodically and systematically measure+ the reduction in the use of ingredients and contaminants we have targeted and the expansion of the use of safer food additives.

Tips: Measuring the reduction in use of chemicals of concern reasserts your commitment to making measurable progress towards safer chemicals. Mass, sales volume, and percent of product portfolio/inventory are useful units of measure. Third party software tools used to improve supply chain transparency may be useful in supporting efforts to measure reductions in chemicals of concern.

Example Resources*: OECD Substitution and Alternatives Assessment Toolbox, GC3 Retailer Tools for Safer Chemistry, Chemical Footprint Project

* Though not tailored to food, one or more of the resources featured above may be applicable

6. Public Commitment +
We will be transparent about our goals and outcomes. We will make public this safer food additives policy and progress on implementation through annual status reports.

What: Public commitment is about sharing your policy and its implementation with the public.

Why: This helps you reinforce your dedication to transparency, hold yourself accountable, and gain goodwill for your brand.

Example Resources: EDF's Who is Promising What on Food Additives?

Download Template (.pdf)

Behind the Label Mainpage

EDF Model Chemicals Policy for Retailers of Formulated Products

When it comes to safer chemicals in the marketplace, we have identified Five Pillars of Leadership. But we often get asked how a retailer can put those into action effectively. The most effective tool in jump-starting and sustaining leadership is a written corporate chemicals policy. A chemicals policy institutionalizes your commitment to lead on safer chemicals and articulates to all levels of the business, as well as to your suppliers, what the company wants to achieve. At a minimum, your chemicals policy should outline your aspirations for:

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

What does that look like? EDF has created a template you can use when fleshing out your own chemicals policy. Our template below provides the text you need as well as tips and resources for starting your journey.

EDF Model Chemicals Policy for Retailers of Formulated Products

<publication date>

1. Vision Statement +
At <company name>, our mission is to provide our customers with products that are both effective and made with the safest available ingredients.

What: The vision statement is the articulation of your aspiration

Why: It sets expectations that will drive internal decision-making and execution

2. Scope +
This policy applies to non-edible formulated products+ sold in our stores.

What: The scope defines which products are covered by the policy.

Why: This helps suppliers determine if they are impacted by the policy

Tips: A policy that covers non-edible formulated products applies to chemically-intensive or consumable products that are used for household cleaning (indoor and outdoor), beauty and personal care, automotive care, child care, pet care, and other similar categories. You may want to start by covering one product category first and expanding the scope of your policy after you achieve initial success.

3. Supply Chain Transparency +
Our goal is to make informed decisions about the products we sell by improving our understanding of product composition. All suppliers must disclose complete product ingredient data+ to <3rd-party product ingredient database>+ by <date>+.

What: A supply chain transparency goal clearly articulates your approach to gaining greater insight into the ingredients in the products you sell.

Why: Better knowledge of your supply chain enables you to identify potential risks; set, measure, and achieve safer chemical goals; and effectively communicate product ingredient information to customers.

Tips: Data should include the specific chemical identities of all known substances (i.e. intentionally added chemicals and known contaminants) in a product formulation, their CAS numbers, and concentrations. Ingredient functions are also useful data to capture, as well as the identification of any Priority List chemicals in the product packaging (whether intentionally present or known to be likely contaminants).

Tips: Third-party management of product ingredient data enables the analytics you need (e.g. calculation of the total volume of a particular chemical found on store shelves) while protecting suppliers' proprietary formulation data.

Example Resources: GC3 Retailer Tools for Safer Chemistry, OECD Substitution and Alternatives Assessment Toolbox

Tips: Setting timelines helps your company and your suppliers plan for successful execution against stated expectations. Timelines should be informed by resource availability, business intelligence, and the scope of products covered by your policy. Timelines should be feasible yet ambitious enough to pass muster with external stakeholders.

4. Informed Consumers +
Our goal is to maintain consumer confidence in the products we sell by providing meaningful and easily accessible product ingredient information.

What: Consumers have readily available access to product information that is comprehensive, understandable, and meaningful.

Why: Disclosure enables informed purchase decisions and builds consumer confidence, trust, and loyalty.

Disclosure on product packaging:+ Suppliers are required to disclose all intentionally added product ingredients on product packaging by <date>+.

Tips: Whether the product contains active and inactive ingredients, ingredients that are single chemicals or chemical mixtures, all intentionally added ingredients should be disclosed on the product packaging using non-generic names. Where space is limited, it is useful to indicate a website that features additional useful details, such as a list of the chemicals contained in a fragrance ingredient.

Example Resources: CSPA Dictionary, INCI dictionary

Tips: Setting timelines helps your company and your suppliers plan for successful execution against stated expectations. Timelines should be informed by resource availability, business intelligence, and the scope of products covered by your policy. Timelines should be feasible yet ambitious enough to pass muster with external stakeholders.

Disclosure online:+ Suppliers are required to disclose online the identities and functions of all intentionally added ingredients, by product by <date>. For our private label products, this information will be made available directly on our website.

Tips: Requiring suppliers to share online ingredient information that extends well beyond regulatory requirements is a powerful step towards building and sustaining trust. While product packaging physically limits the amount of information that can be shared, online ingredient disclosure allows greater flexibility in terms of the extent and type of ingredient information, as well as how that information is accessed and presented.

Example Resources: EDF's Rules for Online Disclosure

5. Product Design +
Our goal is to sell products that perform well and contain the safest available ingredients. To reach this goal, we will:

What: A product design goal clearly articulates your approach to delivering effective products while driving out hazardous ingredients and assuring the use of safer ones.

Why: This step distinguishes those companies who go beyond talking the talk and make real, measurable progress towards safer products.

    • develop and share a Priority List+ of chemicals that suppliers are required to reduce and ultimately remove+ from products

Tips:: The Priority List is a list of chemicals that you have identified as critical to take action upon. This list should contain chemicals that have been identified as hazardous or potentially hazardous by authoritative and regulatory bodies and have been prioritized by you because of impact factors such as direct exposure potential, prevalence of use, or impending regulatory activity. In building your list, it is useful to keep an eye on authoritative determinations made not only in your operational jurisdiction(s) but also in other geographical locations. It is also useful to consider multiple hazard endpoints (e.g. carcinogenicity, reproductive toxicity, skin sensitization). As progress is made on reducing and removing chemicals on your initial Priority List from your products, you can re-apply your prioritization factors to identify additional chemicals to act upon.

Example Resources: GreenScreen List Translator Specified Lists, IC2 U.S. State Chemicals Policy Database

Tips: Depending on the chemicals on your Priority List and the availability of drop-in safer alternatives, you may need to work with your suppliers to develop interim targets and phase-out goals.

    • set the expectation that our suppliers use the most current science+ to ensure that all ingredients in new and reformulated products are safest in class

Tips: It's important to set the expectation that suppliers must demonstrate that new or reformulated products do not introduce other chemicals of concern. Using the most current science in ingredient selection decisions requires that suppliers sufficiently characterize and compare the hazards and risks of chemicals. For example, suppliers could indicate the frameworks they utilize to drive the use of safer chemicals in their product development processes or the tools they use to assess ingredient hazard.

Example Resources: OECD Substitution and Alternatives Assessment Toolbox, GC3 Retailer Tools for Safer Chemistry, EPA Safer Chemical Ingredient List, IC2 Chemical Hazard Assessment Database, The National Academies Framework to Guide Selection of Chemical Alternatives

    • begin certifying our private label products, with <3rd party safety certification program>+ by <date>+ to provide further assurance that they are made with the safest available ingredients, and

Tips: Reputable third party certification programs involve comprehensive assessments of the safety of all ingredients in a product and of product performance, thereby providing assurance of safer and effective products.

Example Resources: U.S. EPA Safer Choice Program, Cradle to Cradle, GreenSeal, GC3 Retailer Tools for Safer Chemistry

Tips: Setting timelines helps your company and your suppliers plan for successful execution against stated expectations. Timelines should be informed by resource availability, business intelligence, and the scope of products covered by your policy. Timelines should be feasible yet ambitious enough to pass muster with external stakeholders.

  • regularly measure+ the reduction in the use of chemicals we have targeted and the expansion of the use of safer chemicals

Tips: Measuring the reduction in use of chemicals of concern reasserts your commitment to making measurable progress towards safer chemicals. Mass, sales volume, and percent of product portfolio/inventory are useful units of measure. Third party software tools used to improve supply chain transparency may be useful in supporting efforts to measure reductions in chemicals of concern.

Example Resources: OECD Substitution and Alternatives Assessment Toolbox, GC3 Retailer Tools for Safer Chemistry, Chemical Footprint Project

6. Public Commitment +
We will be transparent about our goals and outcomes. We will make public this chemicals policy and progress on implementation through annual status reports.

What: Public commitment is about sharing your policy and its implementation with the public.

Why: This helps you reinforce your dedication to transparency, hold yourself accountable, and gain goodwill for your brand.

Example Resources: Walmart Sustainable Chemistry Policy

Download Template (.pdf)

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Public Commitment | Pillars of Leadership for Safer Food Additives

Behind the Label: A Blueprint for Safer Food Additives in the Marketplace

When a company leads on public commitment, it communicates its safer food additive’s journey publicly and honestly. Effective public commitment goes beyond a one-time publication of goals; it is the frequent, transparent, and public-facing communication about a company’s efforts to meet those goals. Why? Because results matter.

Effective communication of a company's policy, timelines and progress towards goals can garner valuable support from the general public. Telling the story about one’s journey – and the pitfalls along the way – can be just as powerful as sharing success stories. Going public will reinforce internal alignment on the goals and spur the innovation of safer food additives needed to create higher quality products. Going public can also lead to useful partnerships or engagements with other organizations, which in turn can provide companies with additional expertise, best practices, and recognition.

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How does a company become a leader on public commitment?

  1. Publish its corporate safer food additives policy: Publication is a signal that a company is serious about its mission to lead on safer food additives and products. Making its policy public tells consumers, suppliers, and investors that a company has a goal-oriented strategy in place, thoughtful timelines, and is making an institutional commitment to reach success.
  2. Share progress: A company needs to communicate honestly, highlighting the good news, but also being upfront about the things that didn’t quite work. The public is as interested in success stories as it is stories about the journey. Hearing about the pitfalls or mistakes that may have occurred along the way adds credibility to the successes. This is particularly relevant when it comes to millennial shoppers who have shown their cynicism towards perfectly polished brands.
  3. Communicate the process: A company sets itself up for harsh criticism from customers if it shares broad platitudes about its strategy instead of more descriptive, concrete information. The public wants to know how companies plan on achieving their commitments. When a company commits to safer product design, which products will it focus on first and why? How will safer food additives be identified? What will suppliers be asked to do to help a company improve its products? Who are the partners that will provide useful guidance and insights along the way? Responses to these types of questions signal intent to follow through on commitments.

 Good things happen when a company embraces public comment

  • Increased consumer confidence: Consistent communication about a company’s policies and progress against its goals builds consumer trust and confidence. Openness can also increase consumer engagement, providing more insights into consumer behavior and desires. This kind of feedback can improve the effectiveness of communications. Social media provides powerful tools for this type of two-way communication.
  • Emergence of new allies: When a company communicates openly and frequently about its safer food additive efforts, new allies emerge that can support and expand its success. Potential allies include media outlets that applaud a company’s progress, expert organizations who can become useful partners in accelerating a company’s success, or fellow companies who have similar goals that can be met faster by working together.
  • Supplier buy-in: Suppliers realize their customer is serious about transformation and see an opportunity to support the initiative. This can spur competition to provide safer food additives—a race towards continuous improvement.
  • Improved internal alignment: Public communication solidifies internal commitment throughout the business, providing the unity necessary for successful implementation and progress against goals. It also provides another avenue for enhancing employee engagement. Executing on and being recognized for a commitment to bringing safer food additives and foods to the marketplace can boost morale and translate into increased employee recruitment and retention.

Overcoming hurdles on the path to public commitments leadership

  • Criticism:When a company goes public with its strategies and progress, feedback may come in the form of accolades, criticism, or new demands based on the progress made. Rather than becoming defensive against criticism, a company should make use of it as positive feedback. Any external feedback is a powerful vehicle by which a company can discover new information or engage new allies to revise its strategy and continue to progress forward.
  • Greenwashing:When touting successes through new marketing claims and logos, a company must also beware of greenwashing. In the legal context, a company must comply with the regulatory agency’s labeling requirements and ensure its claims conform to fair trade practices.

Public commitments for food ingredients and food packaging

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Informed Consumers | Pillars of Leadership for Safer Food Additives

Behind the Label: A Blueprint for Safer Food Additives in the Marketplace

Sharing ingredient and contaminant information with consumers is key to business leadership on food additives. It can build consumer confidence, trust, loyalty – and market advantage. It shows that a company embraces and executes on the philosophy that consumers have the right to know what is in the products they buy. Additionally, consumer transparency fosters accountability within the company to make informed decisions about the ingredients and products they buy, sell and design to meet customer demands for increased product safety and sustainability. It also provides a means for public recognition of safer food additive leadership.

The key to success in cultivating an informed consumer is providing product information that is comprehensive, accessible, and, importantly, meaningful. Consumers want to:

  • Have easy access to consistent, reliable information;
  • Feel empowered when making purchasing decisions for themselves and their families;
  • Understand what they’re bringing into their homes;
  • Avoid adverse health and environmental impacts; and
  • Trust that brands and retailers respect their interest in knowing product composition.

How does a company cultivate an informed consumer? For starters, by sharing ingredient and contaminant information on product packaging and/or online for products it makes or sells, with content that extends well beyond regulatory requirements. While packaging physically limits the amount of information that can be shared with consumers, online disclosure allows greater flexibility in terms of the extent and type of ingredient information, as well as how that information is accessed and presented.

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Source: Center for Food Integrity

Addressing three key questions fosters informed consumers:

  • What chemicals are in the product: This means providing the specific identity of intentionally added ingredients as well as known contaminants. If a product contains a ‘free-of’ claim, there should be verification that the product complies with the regulatory agency’s labeling rules and the Federal Trade Commission’s Green Guides to prevent green-washing. Further, free-of claims should be substantiated by a third party.
  • Why these chemicals are in the product: This requires clear and understandable information about what function each ingredient serves.
  • How to make meaning out of the information: While the what and the why form the core of the information a company shares with their customers, how this is presented is critically important as that defines accessibility. Product ingredient and known contaminant information needs to be easy to find on a manufacturer’s or retailer’s website, not buried. It is most helpful if information is also presented in a consistent manner across products and product lines.

Overcoming hurdles on the path to informed consumer leadership

  • Available information: Companies themselves can have trouble finding the ingredient and contaminant information that’s important to share with consumers. For example, manufacturers may not know the individual ingredients of a fragrance or flavor blend or the food contact substances used in their products, yet this information can be critically important for consumers with allergies, pregnant women or young children. Supply chain transparency – another core pillar of safer food additive leadership – can enable effective systems for increasing information flows and expanding product ingredient information.
  • Managing an online platform: Online disclosure involves the transfer of internal data to a public-facing platform. To do this, a company may face software infrastructure challenges. Managing this effectively will require time, personnel, and financial resources. The site will need regular maintenance to ensure product information is always up-to-date, particularly if a formulation changes, and to accommodate increased data as the company gains more transparency into product ingredients and contaminants.

 Resources for informing consumers of food ingredients and packaging

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Supply Chain Transparency | Pillars of Leadership for Safer Food Additives

Behind the Label: A Blueprint for Safer Food Additives in the Marketplace

To most effectively introduce safer products, a manufacturer or retailer needs to understand how a product is created. A product manufacturer needs to have a clear picture of the ingredient used to make its products, just as a retailer needs to have transparency into the ingredients and known contaminants in the products it sells. This information is needed for well-informed decision-making and risk mitigation and enables more timely response to queries and concerns and to better monitor progress.

EDF defines supply chain transparency as the ‘what,’ ‘how much,’ ‘why,’ and ‘who’ of a product’s ingredients and known contaminants.

  • What is in the product: Companies should strive for full transparency at the product level. This means knowing all the ingredients, including those in chemical mixtures like fragrances and flavors, as well as known contaminants.
  • How much is usedIt is critical to know the concentration of ingredients and known contaminants to assess exposure. Per-product data better informs the potential risk. Concentration information at the product category and portfolio level aid in assessing aggregate exposure, the risk of exposure to a single chemical via all possible exposure routes and sources. Avoid concentration thresholds that allow small amounts of purposefully added chemicals to go undisclosed. If an ingredient is part of a product formula, the retailer needs to know.
  • Why is it used: Understanding why an ingredient or food contact substance is used is about knowing its functional value. An ingredient may be added as a preservative to prevent microbial growth, as a flavor or fragrance, as a dye to impart color, and so on. A food contact substance may be used to protect the food from spoilage or make the container more durable. Knowing this information also helps to identify those areas where safer ingredient options may be lacking. This in turn can spur research and development of new alternatives that can meet the functional requirements with reduced human or environmental health impacts.
  • Who makes the ingredients and food contact substances: While a company’s direct suppliers, or Tier One suppliers, provide the first level of transparency into a product, they may not know the full formulation of an ingredient mixture, especially for fragrances or flavors, or the presence of contaminants. To be fully knowledgeable, a company often needs to go beyond its immediate suppliers to secondary and tertiary sources, sometimes even to raw material suppliers. Building relationships with suppliers can improve transparency along the supply chain and facilitate innovative changes to formulations of products and packaging.

visualizing-the-chemical-supply-chain

Overcoming hurdles on the path to supply chain transparency leadership

  • Data management: Ingredient data management can be a laborious task. An effective management process captures, stores, updates, verifies, and analyzes this information. Though effective systems are only just emerging in the food sector, we provide a few resources below to help companies get started.
  • Trust: Companies want to protect their intellectual property (IP). In some sectors, especially flavors, fragrances and packaging, the formulation can be a company’s primary IP. So, naturally, transparency requests can cause trepidation. A retailer or a brand must navigate how to gain access to the information it needs to understand and mitigate its business risks while assuring suppliers that legitimate IP is protected. Third-party software-based data management systems featuring data security protocols can be useful tools in mitigating trust issues.
  • Participation along the supply chain: Getting timely participation from the full supply chain can be challenging, particularly the further upstream a company needs to go to collect the necessary data. It can often take time and persistence. When a company is not a large purchaser, convincing suppliers to divulge details can be tough, especially if the request is optional. Suppliers can also be overwhelmed by requests from different companies that ask for data in slightly different ways. The good news is that as more and more companies are seeing the business value in transparency, supplier requests for disclosure are becoming a common business practice. As more suppliers face multiple requests for information, a greater emphasis is being placed on creating data uniformity that can benefit the entire supply chain.

Resources for transparency on food ingredients

  • Affirmative lists of ingredients: Unlike household and personal care products, there are affirmative lists of allowed ingredients for food products available from the regulatory agencies.
    • Europe has a comprehensive list of ingredients allowed by the European Commission in food, including flavors. The European Food Safety Authority (EFSA) is completing a comprehensive review of the safety of these ingredients. EFSA’s review reflects the latest scientific knowledge and exposure data. As a result, many ingredients allowed in the US are no longer allowed in Europe.
    • Food and Drug Administration (FDA) maintains a list of allowed ingredients through its ‘Everything Added to Food in the United States’ (EAFUS) database. However, the name is a misnomer; EAFUS does not include additives self-certified by industry as ‘generally recognized as safe’ (GRAS) whether or not FDA reviewed it for safety. FDA does not require industry to inform it of these decisions although it does encourage voluntary notices, which it posts on-line. The flavor industry also self-certifies flavors as GRAS and makes the list publicly available. Most of the GRAS flavors are on EAFUS. EDF maintains an integrated list of FDA-reviewed ingredients and food contact substances.
  • Third-party services: Unlike household and personal care products, third-party services providing supply chain transparency for food products are only just emerging:
    • Final product labelling. Two services provide detailed information on the words that are on the package of the product. However, they do not appear to be evaluating the supply chain. Both are limited to what is on the product label.
      • Food Essentials and Label Insight: Provides detailed information on product and assigns ‘attributes’ describing marketing features.
      • Gladson: Tracks product package and label information provided by food manufacturers to facilitate shelf-stocking and marketing.
    • Sustainability and regulatory compliance: Third-party services such as WERCSmart that provide limited supply chain information on household and personal care products may be expanding into food products.

Resources for transparency on food packaging ingredients

Additives in food packaging, whether final product or raw material, and in food handling equipment (e.g. tubing) may migrate into food during processing, manufacturing and storage. These additives may become contaminants of the final food product. FDA approves these as ‘food contact substances’ or ‘indirect additives’ or ‘secondary direct additives.’ It maintains online databases of its regulatory approvals and decisions on various notification programs. Because industry can self-certify additives as GRAS for use in packaging without informing the agency, these lists are incomplete. Europe also sets standards for plastic packaging and has an affirmative list, the Union List, for plastics. It is expanding its review to other materials.

Potential role of ‘Food Safety Plan’

Firms could use the new ‘Food Safety Plan’ that FDA requires most food facilities to develop and implement to comply with its Hazard Analysis and Risk-based Preventive Control (HARPC) rule by September 2016 to identify ingredients that have not been reviewed by FDA for safety and/or to set a higher standard by demanding FDA review or approval.

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