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)

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