Apple earned a grade of A, scoring 103 points out of 135 possible points, the highest score of 30 retailers. This company has made impressive strides in this area, not only maintaining and regularly updating a restricted substances list (Apple’s Regulated Substances Specification or RSS) but also aiming for full material disclosure of its private label products to analyze every component in the products it sells, with over 20,000 out of 40,000 reviewed so far. Its restricted substance list applies to private label and brand name products, packaging, manufacturing processes, and in-house purchasing. The company has a comprehensive system to ensure compliance, including training on the RSS and on chemicals management more broadly such as through the Apple Environmental Health and Safety Academy.
Since 2003, Apple has reduced or eliminated chemicals of concern from products, including lead, arsenic, brominated flame retardants, and PVC/phthalates from certain components. In 2015, the company eliminated beryllium from various components. Apple also recently reported that it achieved 100% compliance with the RSS “for process chemicals at all final assembly sites.” Apple takes strong steps to ensure the substances used in place of hazardous chemicals are an “environmentally responsible substitution” by requiring alternatives assessments. This company has also created its own Green Chemistry Advisory Board and collaborated with outside groups on safer chemicals and eliminating toxins.
Opportunities for improvement: Apple can make even more progress by setting public quantifiable goals for reducing and eliminating chemicals of concern and expanding its Full Material Disclosure initiative to brand name products sold in Apple stores and on Apple.com. Apple should also become a signatory to the Chemical Footprint Project and pilot it with key private label suppliers.
Summary of Apple’s Grade
12 out of 15 points
Policy: Adopted a retailer safer chemicals policy
So far the company has analyzed compositions of more than 20,000 components in all of its products and has fewer than 20,000 left.
Apple’s Regulated Substances Specification (RSS) details thresholds for chemicals in its products, and functions as a Beyond Restricted Substance List (BRSL) because many of these chemicals or classes of chemicals are not regulated by any governmental entity.
The RSS also serves as a Manufacturing Restricted Substance List (MRSL) for several chemicals, setting content restrictions for chemicals including benzene, chlorinated organic solvents (e.g. methylene chloride, and trichloroethylene), N-methylpyrrolidone, and toluene used in cleaning agents, degreasers, demolder solutions in all manufacturing processes. In 2016, Apple “achieved 100 percent compliance with [its RSS] for process chemicals at all final assembly sites.” According to Apple’s 2017 Progress Report on Supplier Responsibility, the company plans to “continue to assess suppliers against our Regulated Substances Specifications to identify any hazardous chemicals we might limit or prohibit in our manufacturing processes.”
The RSS applies to both products and packaging: “This Regulated Substances Specification describes Apple’s global restrictions on the use of certain chemical substances or materials in Apple’s products, accessories, manufacturing processes, and packaging used for shipping products to Apple’s end-customers.” Additionally, the RSS also applies to in-house purchasing, as the Code of Conduct states: “Suppliers shall comply with Apple’s Regulated Substances Specifications for all goods it manufactures for, and provides to, Apple.”
In the company’s retail stores, Apple requires janitorial chemicals to comply with a Green Seal standard and follows a standard related to the design of high-performance green buildings that also requires environmental protect declarations (ASHRAE 189.1). For new stores (and those that opened in the last 2.5 months), Apple also sets limits on VOC emissions in “back of house.”
Although Apple does not have public quantifiable goals for reducing or eliminating chemicals of high concern, in its RSS the company does prioritize “the chemicals it intends to phase out of Apple products in order to work effectively with its supply chain” and restrictions may be added in the future.
10 out of 10 points
Oversight: Established management responsibilities and incentives
The authors of the September 2016 white paper on Integrating Toxicological Assessments in Material Selection for Apple Products are managers (Environmental Technologies Manager, Green Chemistry & Restricted Substances Manager, Green Chemistry Program Manager, EHS Program Manager, and Environmental Program Manager).
The chemical policy is included in job descriptions -e.g., for a Restricted Substances Program Manager posted in the fall of 2016, the summary stated: “The candidate will work closely with Apple’s product design teams and suppliers to track the use of materials, identify substances that should be removed due to their hazardous properties, investigate safer alternatives, and drive execution of phase out programs.”
Apple provides financial incentives for its senior management to implement the company’s chemical policy. The company states that each Executive Team member’s overall performance on indicators including chemical management and using safer, greener materials, “may be considered when determining the amount of the individual’s annual cash bonus or whether the individual should remain as a member of the Executive Team and participate in the executive compensation program.”
10 out of 10 points
Accountability: Ensures supply chain accountability
According to the Regulated Substances Specification, Apple audits suppliers’ Full Material Disclosure “data submissions to ensure conformity with the requirements.” Audits also involve inventorying chemical purchasing and mapping chemicals across the supply chain, according to Apple’s website.
Apple employees state that in 2016, the company trained 900 suppliers in two cities in China on the Regulated Substances Specification and Full Materials Disclosure. Also, Apple’s 2017 Progress Report on Supplier Responsibility states that in 2016, the company provided 81 sites, both final assembly and critical component manufacturing locations, “with consultation and training to strengthen their ability to identify and solve [chemicals management] issues on their own … [and] developed a model to provide chemical management oversight with each new product, and to ensure past improvements remain in place”.
Additionally, the Apple Supplier Responsibility Standards, as a supplement to the Code of Conduct, have requirements related to chemicals management and requires suppliers to “identify the Chemicals that are banned or restricted in accordance with Apple’s Regulated Substances Specifications.” The company helps new suppliers understand the code, shares best practices with suppliers, and educates suppliers on common missteps and proven solutions. Apple also educates local managers on topics including chemicals management through the “Apple Environmental Health and Safety Academy.” This Academy also includes a requirement for managers to “create and implement projects to improve environment, health, and safety conditions at their facilities” to put what they learn into practice; 3,300 projects have been launched so far.
The Regulated Substances Specification states that “Apple requires test reports from certified labs as proof of compliance for [certain] substances [restricted per Apple’s policies] in homogeneous materials…A nationally or internationally certified laboratory must issue the test report. Supplier-owned laboratories are acceptable if they are independently certified.”
As stated in the “Scope” of the Regulated Substance Specification, “Suppliers should take action to reduce or eliminate the use of chemicals of concern listed in this specification as a first step. We hold our suppliers accountable by conducting factory audits, testing components with independent laboratories, and verifying the results at our own in-house laboratory”. According to the 2017 Environmental Responsibility Report: Apple also runs its own environmental testing lab with state-of-the-art advanced equipment to “look for any potentially harmful substances rather than waiting for a third-party to identify them for us.”
7.5 out of 10 points
Disclosure: Requires suppliers to report use of chemicals in products to retailer
So far Apple has analyzed composition data for more than 20,000 out of the 40,000 components in their products.
Apple has not yet expanded its FMD initiative to brand-name products sold in its stores.
12 out of 15 points
Action: Reduced or eliminated chemicals of high concern within the last three years
In Apple’s 2017 Progress Report on Supplier Responsibility (and in its 2017 Environmental Responsibility Report), the company noted that in 2016, it “achieved 100 percent compliance with our Regulated Substances Specification for process chemicals at all final assembly sites …[and] verified that 100 percent of all process chemicals at all final assembly facilities were free of Apple-restricted substances such as benzene, n-hexane, and chlorinated organic solvents in cleaners and degreasers.”
Apple’s restrictions on chlorinated organic solvents, N-methylpyrrolidone, and toluene in manufacturing processes were driven by the company’s own policy rather than regulatory requirements. “Significant resources and commitment were required to achieve 100 percent compliance” with the RSS and “materials containing chemicals of concern have been disqualified from Apple products during the product development process.” It appears that this is true for manufacturing further upstream as well.
10 out of 10 points
Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes
The Apple Supplier Responsibility Standards require each supplier to “ensure that its selection processes for all new Hazardous Chemicals include a thorough evaluation of non-hazardous alternatives.”
Apple’s September 2016 white paper Integrating Toxicological Assessments in Material Selection for Apple Products, in the discussion on process chemical evaluation, states: “Classification of solvents and degreasers according to hazard was an effective prioritization tool for finding safer materials.” The white paper also describes how using a “comparative chemical hazard assessment framework, such as Clean Production Action’s GreenScreen® for Safer Chemicals,” enables Apple toxicologists to make material use decisions based on the toxicological properties of the material and its application in the product.” This framework could be used to evaluate alternatives to determine if they are in fact safer. Apple has paid for more than 500 GreenScreen assessments to date.
9 out of 15 points
Transparency: Demonstrates a commitment to transparency and public disclosure
On the “Tech Specs” pages of its website, Apple specifies if products are totally free of brominated flame retardants (BFRs) and beryllium (as well as PVC) and have “arsenic-free display glass” and a “Mercury-free LED-backlit display.” In product launch keynotes, “senior executives highlight CHC[s] restricted from products. The calling out of our action on CHC[s] for certain new products … is a powerful safer products message because of high global media coverage and public interest (high views on livestream and video-sharing websites).”
All major Apple products have a “Product Environment Report” that describes in general terms the weight of the materials used – e.g. stainless steel, glass, and plastics – and of the components – e.g. the battery. Apple does not specify the specific type(s) of plastic. Apple employees note that while the company is working towards understanding all ingredients in its products, since “[there are tens of thousands of different parts used at Apple, each one with a highly complex chemical make-up … [public] [d]isclosure of all ingredients in a complex, assembled product is unlikely to be achievable right now.”
The company does not appear to further encourage or require the disclosure of ingredients in products sold online or on product packaging.
0 out of 7.5 points
Chemical Footprint: Evaluates its chemical footprint
7.5 out of 7.5 points
Third-party Standards: Promotes credible third party standards for safer products
Apple has had 16 of its product types certified to this standard – iMac (desktop), iPad, iPad Pro, iPad mini, iPhone 6s, iPhone 6s Plus, iPhone 7, iPhone 7 Plus, iPhone 8, iPhone 8 Plus, iPhone SE, Mac Mini, Mac Pro, MacBook, MacBook Air (11, 13 in.), and MacBook Pro (13, 15 in). They advertise that certification for their iMac, Mac, Macbook, and iPad products, and most of their iPhones.
0 out of 5 points
Joint Announcement: Public commitment demonstrated through joint announcement
15 out of 15 points
Continuous Improvement: Shows continuous improvement by steadily expanding safer chemicals policy
Apple has also reported on steady progress through the years as described on its website: in 2006, phased lead out of display glass and solder; in 2008, eliminated arsenic from display glass and brominated flame retardants from thousands of parts; and in 2009, eliminated mercury-based fluorescent lamps. Apple employees stated that the company completed its phase out of beryllium in new products released as of 2015 (this chemical was found in copper alloys used to make connectors and springs). The company also replaced PVC and phthalates with safer thermoplastic elastomers in all U.S. products, but it’s unclear when the replacement happened.
Last year, the company introduced Full Material Disclosure to evaluate all components in the private label products they sell – 40,000 total.
0 out of 5 points
Safer Products: Program to promote safer products in stores and/or on website
5 out of 5 points
Collaboration: Actively participates in collaborative process to promote safer chemicals
Also, Apple has joined the Business Group of ChemSec, “a Swedish-based nonprofit that works with decision-makers, industry, NGOs, and scientists to achieve a toxic-free environment.” As part of ChemSec’s Business Group, the company will work with others to “refine [their] knowledge of safer materials.”
Further, according to their website: “We also invite experts from around the world to meet with leaders at Apple. Together, we focus on eliminating toxins at each stage of our process, while sharing our learnings through Green America’s Clean Electronics Production Network. And we seek out the best ideas and insights from top NGOs to help us make our products and processes even safer.”
5 out of 5 points
Impact Investment: Investing financial resources into independent research into safer alternatives and/or green chemistry solutions
Apple has also issued green bonds totaling $2.5 billion earmarked for investment in environmental projects. One of the six eligibility criteria is for promoting the use of safer materials in Apple’s products.