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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