The BizNGO Chemicals Work Group has developed a Chemicals Policy Template for Brands and Manufacturers. The Policy Template, which builds from EDF’s Model Chemicals Policy for Retailers of Formulated Products, is designed to help brands and manufacturers that are developing or strengthening their chemicals policies. It aligns with the Chemical Footprint Project Survey questions and provides examples and resources from a range of companies.
Ideally, the Chemicals Policy will be both for internal use and publicly disclosed.
Intent+
At , we aim to manufacture high-performing products made with chemicals and materials that do not harm human health or the environment. The purpose of this policy is to direct (company’s) actions toward meeting this intention.
What: This statement is the articulation of your company’s aspiration
Why: It sets expectations that will drive internal decision making and execution
Tip+
Example statement of intent: “As part of our commitment to environmental leadership, we are dedicated to reducing the environmental and human health impacts of materials and chemicals throughout our supply chain.” (HP)
Scope
This policy applies to our manufacturing processes + and/or our facilities+.
What: The scope defines which aspects of your company, including products and/or processes are covered by the policy.
Why: This delineation helps staff and suppliers determine if they are impacted and what their responsibilities are in regard to the policy
Tips+
You may want to start by covering one aspect of your chemical use and expand once you achieve initial success. Many companies begin by focusing on chemicals in the products they produce. Larger companies with complex product portfolios may choose to focus on one or several products or product families. You may also wish to delineate who is responsible for implementation. "Our manufacturing processes" include plants owned and operated by a company. Contract manufacturers are considered part of a company’s supply chain.
"Our facilities" includes chemicals in products (excluding those used directly in manufacturing), used in offices, retail space, laboratories, distribution centers, outdoor space. This includes, e.g., cleaning products, landscaping products, furniture, building products, etc.
Supply Chain Knowledge
To make informed decisions about chemicals use, we must have information on the chemicals used in manufacturing our products +. We therefore will prefer those suppliers that disclose full chemical ingredient information + by date +. Suppliers must demonstrate that chemicals restricted by our company are not present over identified thresholds.
What: A supply chain transparency goal clearly articulates your approach to gaining greater insight into the ingredients in the products you manufacture.
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+
"Full chemical ingredient information":
For formulated products: Data should include 100% of the intentionally added substances by CAS number and mass and any impurities that are both a CoHC and present at 100 parts per million (ppm) or higher in the formulation.
For articles: Data should include 95% of the intentionally added substances by CAS number and mass and any impurities that are both a CoHC and present at 1000 ppm or higher in a homogeneous material.
Ingredient functions are also useful to capture.
Some companies start by asking suppliers to disclose their use of chemicals of concern beyond restricted substances.
"Date": 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.
Timelines may be incorporated into the chemicals policy or, alternatively, in related documents. For example, an SOP for suppliers may state that chemical content information pertaining to a restricted substances list should be submitted “within three months of being requested.”
Requiring suppliers to provide test data in addition to statements of purity is a good way to increase your chemical knowledge.
Safer Chemistry
Our goal is to manufacture products that perform effectively and use the safest available chemicals and materials across the life cycle of our products. To reach this goal, we will identify and reduce the use of chemicals of high concern +, and work to replace them with safer alternatives +.
What: This goal articulates your approach to delivering effective products while eliminating hazardous chemicals and materials 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+
Companies should create or reference a list of chemicals of high concern, communicate that list to suppliers, and update annually.
The purpose and scope of a list of chemicals of high concern may vary. At a minimum, your company’s list of chemicals of high concern should include those restricted in the regions where you operate. Note that states and local governments may have their own restrictions and reporting requirements. Frequently, chemical restrictions include threshold levels permitted for a given concentration in a component or product. This is known as a “restricted substances list” or RSL.
Companies may choose to expand their list of chemicals of high concern beyond legally restricted chemicals. To determine additional chemicals of concern, it may be valuable to involve staff from the legal department, product development, or in-house toxicologists, if available, along with external consultants. NGOs that conduct research on chemicals of concern can also be a good source of intelligence about known and emerging chemicals of concern of relevance to your product lines.
Safer alternatives": a chemical that due to its inherent chemical and physical properties exhibits a lower propensity to persist in the environment, accumulate in organisms, and induce adverse effects in humans or animals than chemicals in current use. In addition, the alternative must deliver the needed functional performance. A safer alternative may eliminate the need for the chemical through material change, product re-design, or product replacement; or by altering the functional demands for the product through changes in consumer demand, workplace organization, or product use.
Resources: OECD Toolbox, GC3 Retailer Portal, The Commons Principles of Alternatives Assessment
Informed Customers
Our goal is to maintain consumer confidence in the products we sell by providing meaningful and easily accessible product composition 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.
Tip+
"Product ingredient information":
Formulated products: 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 CAS numbers and a list of the chemicals contained in a fragrance ingredient.
Articles: Progressively more comprehensive ingredient disclosure options include:
- Generic material content for 95% by mass of chemicals in products
- Chemicals on the EU’s Candidate List of Substances of Very High Concern in products
- Chemical identity for 95% by mass of chemicals in products
Examples: Health Product Declaration Collaboration, Declare, Safer Choice
Some companies choose to certify their products using respected third-party eco-labels or certifications that evaluate chemical hazards.
Resources: CSPA Dictionary, INCI dictionary
Public Commitment+
We will set annual objectives for safer chemical use and be transparent about our objectives. We will make this policy available to the public and publicly report on our progress in annual status reports. We follow a philosophy of continuous improvement and will update our objectives as we meet specified milestones. +
Tips+
Public commitment: Similar to goals and objectives companies set for carbon footprint reduction, waste reduction and water reduction, set and report on goals and objectives for safer chemical use. Transparency about your goals, objectives, and progress will demonstrate both to investors and large scale purchasers the deliberate steps you are taking to reduce their risk, either in investing in your company or in purchasing your products.
Examples:
Levi Strauss & Co. has set comprehensive goals to reduce its use of hazardous chemicals and reports on progress annually.
GOJO set a goal in 2016 to reduce its chemical footprint by 50 percent by 2020 and reports on its progress annually.
Seventh Generation set a goal for 2020 that its products would not be acutely orally toxic and would be free of chronic toxicants. For 2016, it reported that it had reduced the overall use of the preservative Methylisothiazolinone (MIT) in formulated products.
Milestones could include these elements when measuring reduction of CoHCs:
- Identity and mass of chemicals of high concern reduced
- Number of products reformulated
- Scope of reduction – across product portfolio, product line or product(s), process chemistry, or other
Time frame: Companies are also encouraged to set goals and measure the adoption of safer alternatives.