Amazon earned a letter grade of C+, which reflects an improvement from its C grade in 2018. The company scored 55.75 out of 146.5 possible points, ranking 14th out of the 43 retailers evaluated this year.
The company has continued to make progress over the past year by banning the sale of methylene chloride- and NMP-based paint removal products. These are, notably, the first brand-name products in which Amazon has restricted toxic chemicals since it launched its safer chemicals policy last fall. The company also expanded its safer chemicals policy to Amazon-owned private-brand baby, household cleaning, personal care, and beauty products in the E.U.
Last year, it developed a new safer chemicals policy, which includes a beyond restricted substance list (BRSL) targeting more than 50 chemicals of concern for elimination in Amazon private-brand baby (shampoo, lotion, wipes), household cleaning (all-purpose, kitchen, and bathroom cleaners), personal care (shampoo, sanitizers, moisturizers), and beauty (make-up) products. The company noted that it “began [its] reformulation efforts towards this goal with Private Brand formulated products because [it has] the most control over how these products are developed.” The policy does not yet address other private-brand products or brand-name products (besides the paint strippers) on Amazon.com, though the company stated that “in 2019 Amazon will continue to work on additional product category RSLs under this Chemicals Policy, and work to achieve fuller ingredient disclosure on its Private Brand product detail pages.” The company has yet to disclose this work.
On transparency, the policy states: “Our goal is to make product health and sustainability data as easy for customers to access and interpret as price and customer reviews. This is why we are working on website features that will make it easier for customers to access comprehensive information about product ingredients and third-party certifications. … We hope that making this information more readily available for customers will encourage additional brands to move away from potentially hazardous chemistries in their products and adopt safer chemistries.” Amazon cites Safer Choice, Made Safe, Green Seal and Cradle to Cradle as examples of third-party standards it is focused on. The company has yet to disclose progress on these transparency efforts.
Opportunities for improvement: Amazon can make progress by setting public quantifiable goals with clear timelines for reducing and eliminating additional chemicals of high concern (CHCs), especially per- and polyfluoroalkyl substances (PFAS), toxic flame retardants, and phthalates. The company should publicly report on metrics in implementing its goals on an annual basis. In 2019-2020, Amazon should expand its safer chemicals policy to other chemically intensive private-label product categories, particularly electronics, apparel, and food contact materials. As a growing retailer of food, Amazon should eliminate and safely replace toxic indirect food additives in food contact materials, with special attention paid to any bisphenols and per- and polyfluoroalkyl substances (PFAS) that may be in food packaging and other food contact materials as well as phthalates that may be in food and food contact materials in its supply chain. The company should also expand the policy to restrict highly hazardous chemicals in brand-name products sold on Amazon.com, building on its work to phase out methylene chloride and NMP in paint and coating removal products. Amazon should become a signatory to the Chemical Footprint Project and pilot it with key private label suppliers.
Note: Amazon acquired Whole Foods Market in August 2017. Whole Foods Markets has been scored and graded as a separate company, given that the two companies’ safer chemicals policies are significantly different.
Summary of Amazon’s Grade
7.5 out of 17.5 points
Policy: Adopted a retailer safer chemicals policy
The company also published its first-ever restricted substance list (RSL), which functions as a BRSL for purposes of this report card, for these private-brand product categories in 2018. Amazon states: “Our initial RSL is available here and will apply to all consumer Private Brand Baby (shampoo, lotion, wipes), Household Cleaning (all-purpose, kitchen, and bathroom cleaners), Personal Care (shampoo, sanitizers, moisturizers), and Beauty Products (make-up). It is based on the leading science and customer feedback, and includes a baseline list of chemicals of concern that all brands should work to phase out and eliminate. In particular, it focuses on paraben preservatives, formaldehyde donor preservatives, phthalate solvents, nonylphenol (NP) and nonylphenol ethoxylate (NPE) surfactants, Toluene, and Triclosan. The set of RSL chemicals will be reviewed and updated periodically. Our brands have and will continue to develop even more restrictive RSLs for their businesses.”
In late November 2018, Amazon disclosed it was completely phasing out all methylene chloride- and NMP-based paint strippers for sale on Amazon.com by March 2019. Since Amazon gave itself a timeline for this phaseout, we are giving the company partial credit for setting public quantifiable goals, as the company has not set these goals for eliminating other CHCs from other products.
Amazon’s safer chemicals policy does not appear to apply to brand-name products sold on Amazon.com besides the paint strippers and does not appear to apply to packaging or operations. Since the policy does not apply to other locations outside of the U.S besides the EU, we are awarding partial credit for this component. Amazon does not have a publicly available manufacturing restricted substance list (MRSL) and has not set other public quantifiable goals for reducing and eliminating CHCs besides methylene chloride and NMP.
3.75 out of 5 points
Oversight: Established management responsibilities and incentives
Amazon did not provide further information on financial incentives for senior management to implement its safer chemicals policy, so we are only awarding partial credit for this component.
2.5 out of 12.5 points
Accountability: Ensures supply chain accountability
Amazon has not specifically disclosed that it incorporates its safer chemicals policy or reporting requirements in supplier contracts, that it requires suppliers to conduct testing in third-party laboratories and provide results to the retailer, or that it conducts its own testing to ensure suppliers comply with its safer chemicals policy.
2.5 out of 13 points
Disclosure: Requires suppliers to report use of chemicals in products to retailer
In 2019, the company stated: “Our private brand product managers ensure that all private brand suppliers in the relevant categories are informed that they need to register their formulations with WERCSmart as part of their product development and product launch processes. Amazon receives weekly participation reports from WERCSmart tracking product registrations by relevant private label suppliers.”
In 2019, the company disclosed progress and stated: “100% of Amazon US Consumables Private Brand suppliers enroll products in WERCSmart.”
These disclosure practices do not apply to the hundreds of millions of other products sold on Amazon.com that are not covered by the policy.
Suppliers making Amazon Elements products also provide information on the origin and integrity of ingredients used in those products.
3 out of 16 points
Action: Reduced or eliminated chemicals of high concern (CHCs) within the last three years
In its safer chemicals policy, Amazon has disclosed 54 chemicals that are in its BRSL. The company “encourages manufacturers to phase out potentially hazardous chemistries and adopt green chemistry alternatives” and the policy currently applies to “all consumer Private Brand Baby (shampoo, lotion, wipes), Household Cleaning (all-purpose, kitchen, and bathroom cleaners), Personal Care (shampoo, sanitizers, moisturizers), and Beauty Products (make-up).” The company states: “It is based on the leading science and customer feedback, and includes a baseline list of chemicals of concern that all brands should work to phase out and eliminate. In particular, it focuses on paraben preservatives, formaldehyde donor preservatives, phthalate solvents, nonylphenol (NP) and nonylphenol ethoxylate (NPE) surfactants, Toluene, and Triclosan. The set of RSL chemicals will be reviewed and updated periodically. Our brands have and will continue to develop even more restrictive RSLs for their businesses.” However, the company has yet to disclose progress in achieving reductions of these chemicals of concern since last year.
In 2019, the company stated: “Amazon continues to launch Private Label brands that have chemical curation that goes beyond the RSL, including Belei, a beauty brand that contains no sulfates, parabens, or phthalates.”
In 2017, the company shared that “avoiding chemicals of concern has become a part of the brand promise of several Amazon private-label brands. Elements-brand baby wipes, for example, do not contain phthalates, parabens, the formaldehyde donor bronopol, methylisothiazolinone (MIT) or dyes.” The company also noted that its Presto!-brand biobased household cleaners have product guidelines that restrict specific classes of ingredients, such as “no synthetic fragrances,” “no VOC’s,” and “no phosphates.” Presto! also restricts use of ingredients if they exhibit any of the following hazard traits: carcinogenicity, mutagenicity, reproductive toxicity, endocrine disruption, neurotoxicity, or PBT. A variety of U.S. and international hazard identification lists are used to identify chemicals with these traits (e.g., Proposition 65, EPA IRIS neurotoxicants).
Amazon has otherwise not documented how these efforts have led to the reduction of toxic chemicals over the past three years.
4.5 out of 13.5 points
Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes
Additionally, some Amazon private-label brands operate with guidelines that prefer safer alternatives. For example, Presto! and Mama Bear laundry detergents are all formulated with EPA Safer Choice and USDA Biobased ingredients.
9 out of 18 points
Transparency: Demonstrates a commitment to transparency and public disclosure
The company’s chemicals policy states: “Our transparency efforts are grounded in the belief that Amazon should provide customers with information that helps them make informed purchasing decisions. Our goal is to make product health and sustainability data as easy for customers to access and interpret as price and customer reviews. This is why we are working on website features that will make it easier for customers to access comprehensive information about product ingredients and third-party certifications. We hope that making this information more readily available for customers will encourage additional brands to move away from potentially hazardous chemistries in their products and adopt safer chemistries.”
The company goes on to note: “Recent innovations include Amazon Pages [www.amazon.com/brandname], which allow brands to tell their story directly to customers, and the A+ Enhanced Marketing Content on detail pages, which allows brands to explain product features and benefits to customers. This information can include the steps they are taking to ensure that their product selection is safe and healthy, with the backing of a robust set of guidelines to maintain a high-bar of content quality to only include factual, easily verifiable, and objective information. To provide additional information on physical packaging, Amazon developed 2D codes through our Transparency service that are retailer agnostic and available to all brands. These codes can link to information about the products, their product supply chains, and any third-party certifications they have received. To further our commitment to transparency, in 2019 Amazon will…work to achieve fuller ingredient disclosure on its Private Brand product detail pages.”
However, it is unclear how much information about chemical ingredients will be made public, and the company does not appear to currently require or formally encourage its suppliers to make this disclosure. Partial credit was awarded. In 2019, the company stated that its “Belei products are disclosing additional ingredient information on their detail pages.” This is a positive step, though this is just one brand.
0 out of 7.5 points
Chemical Footprint: Evaluates its chemical footprint
3 out of 8.5 points
Third-party Standards: Promotes credible third party standards for safer products
All Amazon Presto! and Mama Bear household cleaning products and laundry detergents meet the EPA Safer Choice and USDA Biobased standards. The company does not appear to require certifications to other credible third-party safer chemicals standards in other private-label products, such as electronics and apparel.
2.5 out of 5 points
Joint Announcement: Public commitment demonstrated through joint announcement
10 out of 15 points
Continuous Improvement: Shows continuous improvement by steadily expanding safer chemicals policy
Last year, the company launched its first-ever Chemicals Policy, which it published online along with its BRSL for certain private-label product categories. The company notes that to “further [its] commitment to transparency, in 2019 Amazon will continue to work on additional product category RSLs under this Chemicals Policy, and work to achieve fuller ingredient disclosure on its Private Brand product detail pages.” Amazon went on to state that the policy “will be expanded to additional brands, product categories, and geographies over time.” However, the company has not disclosed which product categories the policy will be expanded to and whether or not the policy will be expanded to other brand-name products sold on Amazon.com.
2.5 out of 5 points
Safer Products: Program to promote safer products in stores and/or on website
In 2017, Amazon invested $13.7B to acquire Whole Foods Market, long known for its commitment to offer customers a safe and healthy selection that minimizes the use of CHCs. In 2018, the company stated: “Since the acquisition of Whole Foods, Amazon has rapidly expanded customer access to safe and healthy products by making portions of the Whole Foods private brand product selection (including Household Cleaners, Food, and Beauty and Personal Care items) available to customers on Amazon.com, Amazon Fresh, Prime Pantry, and Prime Now. Amazon is committed to making Whole Foods products more affordable and easily available to customers around the US.”
In 2019, the company stated there are several initiatives underway to promote safer products, saying: “The launch of the Conscious Cleaning Store…Whole Foods Market 365 Everyday Value products being available across Amazon (Amazon.com, Amazon Fresh, Amazon Pantry, etc.)…The entire Whole Foods Market selection experience is available in some markets on Amazon.” The company went on to note: “There are plans to expand the experience available…but we cannot comment on the expansion plans or timing.”
For the Conscious Cleaning Store, Amazon staff elaborated, stating: “It is a curated selection from brands that meet one or more of several sustainability-related attributes for cleaning products, including ingredients and formulations. The Amazon Chemicals Policy was not used as part of the selection criteria for this store.”
Partial credit is awarded since Amazon has not thoroughly implemented a program to feature and market safer products to its customers.
5 out of 5 points
Collaboration: Actively participates in collaborative process to promote safer chemicals
0 out of 5 points
Impact Investment: Investing financial resources into independent research into safer alternatives and/or green chemistry solutions