Who’s Minding the Store? — A Report Card on Retailer Actions to Eliminate Toxic Chemicals evaluates the progress made and challenges that remain since the 4th annual report card was released in 2019 and the earlier launch of the Mind the Store campaign, Campaign for Healthier Solutions, Getting Ready for Baby campaign, and Environmental Defence Canada’s campaign for toxic-free products. This year’s fifth-annual report card addresses the ongoing need for transformational change in the retail marketplace to promote safer chemicals in products, packaging, and global supply chains.
In this fifth annual report card, we evaluated the safer chemicals policies of 50 of North America’s largest retailers: 7-Eleven, 99 Cents Only, Ace Hardware, Ahold Delhaize (Food Lion, Stop & Shop, Giant, and Hannaford), Albertsons (Safeway), ALDI US, Alimentation Couche-Tard (Circle K, Couche-Tard), Amazon, Apple, Best Buy, buybuy BABY, Canadian Tire, Chipotle, Costco, CVS Health, Dick’s Sporting Goods, Dollar General, Dollar Tree, Dunkin’, The Home Depot, IKEA, Kohl’s, Kroger, L Brands (Victoria’s Secret, Bath & Body Works), Loblaw, Lowe’s, Macy’s, McDonald’s, Metro, Nordstrom, Office Depot, Panera Bread, Publix, REI, Restaurant Brands International (Burger King, Popeyes, Tim Hortons), Rite Aid, Sally Beauty, Sephora, Sobeys, Staples, Starbucks, Subway, Target, TJX Companies (T.J. Maxx, Marshalls, HomeGoods), Trader Joe’s, Ulta Beauty, Walgreens, Walmart Stores (Walmart, Sam’s Club), Whole Foods Market, and Yum! Brands (KFC, Pizza Hut, Taco Bell).
These retailers were selected for evaluation because they were among the top 50 U.S. or Canadian retailers by sales or they commanded a major market share in one of twelve major retail sectors (see the sectors in the chart below).
New retailers evaluated: This year’s report card includes seven new retailers, for 50 companies in total. The new companies we evaluated are convenience store chains (as part of the Groceries category below) 7-Eleven and Alimentation Couche-Tard, outdoor apparel retailers Dick’s Sporting Goods and REI, restaurant chains Chipotle and Dunkin’, and an apparel and beauty retailer: L Brands (Victoria’s Secret, Bath & Body Works, Pink).
Retailers Evaluated in Who’s Minding the Store? by Key Consumer Sector
|Key Consumer Sector||Retailers Evaluated in Who’s Minding the Store?|
|Apparel||Amazon, Dick’s Sporting Goods, Kohl’s, L Brands (Victoria’s Secret, Pink), Macy’s, Nordstrom, REI, Target, TJX, Walmart|
|Baby/Children||99 Cents Only, Amazon, buybuy BABY (Bed Bath & Beyond), Costco, Dollar General, Dollar Tree, Target, Walmart|
|Beauty & Personal Care||99 Cents Only, Ahold Delhaize (Food Lion, Stop & Shop, Giant, and Hannaford), Albertsons, ALDI US, Amazon, Costco, CVS Health, Dollar General, Dollar Tree, Kohl’s, Kroger, L Brands (Victoria’s Secret, Bath & Body Works), Loblaw, Macy’s, Nordstrom, Publix, Rite Aid, Sally Beauty, Sephora, Sobeys, Target, Trader Joe’s, Ulta Beauty, Walgreens, Walmart, Whole Foods Market|
|Department Store||Kohl’s, Macy’s, Nordstrom|
|Dollar Store||99 Cents Only, Dollar General, Dollar Tree|
|Drugstore||Ahold Delhaize, Albertsons, Amazon, Costco, CVS Health, Kroger, Loblaw, Metro, Publix, Rite Aid, Sobeys, Target, Walgreens, Walmart|
|Electronics||Amazon, Apple, Best Buy, Costco, Kohl’s, Macy’s, Office Depot, Staples, Target, Walmart|
|Furniture/Home Goods||Amazon, Bed Bath & Beyond, Canadian Tire, Costco, IKEA, Kohl’s, Macy’s, Target, TJX, Walmart, Target|
|Groceries||7-Eleven, 99 Cents Only, Ahold Delhaize (Food Lion, Stop & Shop, Giant, and Hannaford), Albertsons (Safeway), Alimentation Couche-Tard (Circle K, Corner Store, Holiday), ALDI US, Amazon, Costco, CVS Health, Dollar General, Dollar Tree, Kroger, Loblaw, Metro, Publix, Rite Aid, Sobeys, Target, Trader Joe’s, Walgreens, Walmart, Whole Foods Market|
|Home Improvement||Ace Hardware, Amazon, Canadian Tire, The Home Depot, Lowe’s|
|Office Supplies||Amazon, Office Depot, Staples|
|Restaurant / Fast Food||Chipotle, Dunkin’, McDonald’s, Panera Bread, Restaurant Brands International (Burger King, Popeyes, Tim Hortons), Starbucks, Subway, Yum! Brands (KFC, Pizza Hut, Taco Bell)|
To evaluate retailers’ safer chemicals policies and practices, we developed and applied a scoring rubric of 13 criteria (listed below). The rubric was first developed in 2016. We aligned the criteria with other best practices identified in the BizNGO Principles for Safer Chemicals, BizNGO Guide to Safer Chemicals, and the Chemical Footprint Project. As in past years, this year we made some key changes to improve the glossary and criteria. You can read a summary of improvements made to the criteria since the 4th annual report card in 2019.
Each criterion was assigned a maximum number of points, ranging from 0 to 26 points including extra credit as applicable. These points were weighted based on our best professional judgment as to the criterion’s importance to the goal of eliminating the use of harmful chemicals and plastics in consumer products, packaging, manufacturing, and store operations. We created a tiered grading structure for each criterion, awarding points for partial steps retailers have taken toward the maximum allowable score under each criterion. Across the 13 criteria, the maximum score is 164 points. This year, we slightly tweaked the curved letter grading system going from F to A+ to reflect the increase in possible points for an A+. This did not impact the grading for any other letter grade (see the grading table).
We reviewed publicly available information reported by the retailers, including in corporate social responsibility or sustainability reports, websites, news releases and blog posts, in the summer, fall, and winter of 2020. We also reviewed official correspondence between the 50 retailers selected for evaluation and the Mind the Store campaign, Campaign for Healthier Solutions, Getting Ready for Baby campaign, and/or Environmental Defence Canada. After an initial evaluation of the retailers, we sent each one its preliminary scores on all 13 criteria with a standardized email, providing every company an opportunity to review our findings, disclose additional information, and/or make new public commitments to correct or improve its draft score and grade. We followed up with each retailer multiple times to ensure that staff had received the preliminary grade and understood the report’s deadline and process. If requested by a retailer’s staff, we scheduled a phone call with the retailer to review and discuss our findings. After receiving and reviewing written input, we adjusted and finalized each score based on any new information that was disclosed in writing.
*** Of course, we can only grade retailers on the policies and practices that they publicly announce or that they disclosed to the authors in response to correspondence. We make no representations about policies or practices that retailers chose to keep confidential.
Below is the list of the 13 criteria that describe the “best in class” initiatives or actions needed to achieve the maximum number of points for each category. For more details, including extra credit available in each category, download the full scoring rubric spreadsheet here.
Key resources for Who’s Minding the Store?
Description of Actions Needed to Earn Maximum Points
Policy: Adopted a retailer safer chemicals policy (See Special Note on Food Products below)
The retailer has a written safer chemicals policy that aims to avoid chemicals of high concern (CHCs) beyond regulatory compliance in products or in packaging offered for sale. Within its scope, the policy also includes all of the seven following elements:
- Sets public quantifiable goals for reducing and eliminating CHCs or at least two types of plastics of environmental health concern (PEHC) (see glossary for definition) in at least one major category of the products and/or packaging the company sells or in at least one major aspect of operations, with the deadline(s) being either in the last year (since November 2019) or at any point in the future;
- For at least one major packaging category, includes a beyond restricted substance list (BRSL) for chemicals of high concern (i.e. CHCs not yet subject to government restriction);
- For at least one major aspect of operations (e.g. purchasing and materials used in retail stores, corporate offices, and/or distribution warehouses), includes a BRSL for CHCs;
- Restrictions on chemicals apply to all locations where products are sold (whether or not the company has locations outside the U.S.);
- For at least one major product category, includes a BRSL for CHCs;
- For at least one major product or packaging category or one major aspect of operations, includes a beyond restricted material list (BRML) (see glossary for definition) for at least two types of plastics of environmental health concern (PEHC); and
- For at least one major product category, includes a manufacturing restricted substance list (MRSL) for CHCs (i.e. CHCs used to manufacture products but not present in the final product).
SPECIAL NOTE on FOOD PRODUCTS: For the retail sale of food products, our evaluation is limited to chemical policies and practices regarding “indirect food additives,” which are the chemicals used in food contact materials (e.g. plastic, paper, metals, inks, adhesives, etc.) that may migrate from food packaging and other food contact articles (e.g. gloves, tubing, conveyor belts, etc.) into the food product. Indirect food additives do not include direct food additives (i.e. ingredients), pesticide residues or environmental contaminants. For example, food contact chemicals that are indirect food additives include per- and polyfluoroalkyl substances (PFAS), bisphenols (such as BPA and BPS), and ortho-phthalates. For additional examples, see the Food Packaging Product Stewardship Considerations published by the Food Safety Alliance for Packaging. For food products sold at retail, please keep in mind that when the words “product” and “packaging” are used throughout this rubric, that “packaging” refers to food packaging and that “product” only includes a food product when the presence of a food contact chemical in the food product may result from the use of food contact materials upstream in the supply chain (e.g. during food processing) or in the retail environment (e.g. during food preparation).
Oversight: Established management responsibilities and incentives
The retailer engages its employees and managers in implementing its safer chemicals policy (beyond regulatory compliance) through both of the following practices:
- Assigned a member of senior management with responsibility for safer chemicals policy, and
- Established financial incentives for senior management related to safer chemicals policies.
Accountability: Ensures supply chain accountability
The retailer engages in all of the four following practices to assess and ensure supplier conformance with retailer safer chemicals policy, BRSL, MRSL, or BRML:
- Delineates requirements associated with safer chemicals policy, BRSL, MRSL, BRML, and/or reporting in contracts with suppliers;
- Trains suppliers in safer chemicals policy, BRSL, MRSL, BRML, and/or reporting requirements;
- Requires supplier(s) to conduct testing in third-party laboratories and provide results to assure conformance with safer chemicals policy, BRSL, MRSL, or BRML; and
- Routinely tests parts, materials, or ingredients provided by suppliers to assure conformance with safer chemicals policy, BRSL, MRSL, or BRML.
Disclosure: Requires suppliers to report use of chemicals in products to retailer
For all retailers except restaurant chains: The retailer requires all private label and brand name suppliers to report to the retailer full chemical ingredient information for all formulated products and articles.
For restaurant chains: The retailer requires all private label suppliers to report to the retailer full chemical ingredient information for all packaging.
Action: Reduced or eliminated chemicals of high concern (CHCs) or plastics of environmental health concern (PEHCs) within the last three years
The retailer publicly reports on metrics in reducing and eliminating several chemicals of high concern (CHCs) or at least two plastics of environmental health concern (PEHCs) in the past three years (since November 2017) across multiple major product categories, packaging categories, manufacturing processes or aspects of operations. Metrics include (a) confirming the complete elimination of CHCs or PEHCs from products, packaging, manufacturing processes, or aspects of operations, or quantifying the reduction of CHCs or PEHCs in products, packaging, manufacturing processes or aspects of operations; (b) quantifying the products, packaging, manufacturing processes, or aspects of operations in which CHCs or PEHCs have been reduced or eliminated; or (c) quantifying the suppliers that are selling fewer products or packaging containing CHCs or PEHCs. Quantification can be by weight, number, or percent as appropriate. (Partial credit may be awarded for action on minor product categories.)
Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes
The retailer commissioned or required suppliers to conduct a credible hazard assessment, using detailed guidance, for alternatives to chemicals of high concern (CHCs) in products, packaging, or operations; and has integrated retailer’s criteria for a safer alternative consistent with MTS definition into private-label product development process.
Transparency: Demonstrates a commitment to transparency and public disclosure
Transparency around safer chemicals policy (7.5 points):
The retailer’s safer chemicals policy and beyond restricted substance list (BRSL) (as well as the manufacturing restricted substance list (MRSL) and beyond restricted material list (BRML)**, if applicable) are all publicly available.
**Note: to receive full credit for a BRML, the retailer needs to publicly disclose a BRML that applies to at least two plastics of environmental health concern (PEHC).
Transparency around consumer ingredient disclosure (12.5 points):
For all formulated products: the retailer requires suppliers to publicly disclose full chemical ingredient information, using industry naming standards rather than generic terms (e.g. for fragrance ingredients), online and on product packaging.
For all articles: the retailer requires suppliers to publicly disclose full chemical ingredient information, using industry naming standards rather than generic terms (e.g. for ink ingredients), online or on product packaging.
Chemical Footprint: Evaluates its chemical footprint
The retailer engages in all of the three following practices:
- Completes the Chemical Footprint Project (CFP) survey in 2020,
- Makes its 2020 CFP score and responses publicly available, and
- Is signatory to CFP.
Third-Party Standards: Promotes credible third-party standards for safer products
The retailer requires certification to credible third-party safer chemicals standards (see glossary for examples) in every relevant category of retailer private-label products or packaging going beyond regulatory compliance.
Joint Announcement: Public commitment demonstrated through joint announcement
The retailer participated in a joint public announcement in the last two years (since November 2018) with Mind the Store, Campaign for Healthier Solutions, the Getting Ready for Baby campaign, or Environmental Defence Canada.
Continuous Improvement: Shows continuous improvement by steadily expanding safer chemicals policy
The retailer has demonstrated significant improvement on a consistent basis over the long term in restricting chemicals of high concern (CHCs) going beyond regulatory compliance.
Collaboration: Actively participates in collaborative process to promote safer chemicals
The retailer engages in one of the following three activities:
- Actively participates in a collaborative process to promote safer chemicals (see glossary for examples),
- Retains an independent expert institution (not a consulting firm) to assist in meeting the same goal, or
- Created an external advisory board to collaborate with stakeholders to seek input into implementation of safer chemicals policy.
Impact Investment: Investing financial resources into independent research into safer alternatives and/or green chemistry solutions
The retailer or retailer’s foundation invests significant financial resources into independent research into safer alternatives to chemicals of high concern (CHCs) and/or green chemistry solutions.