Apple earned a letter grade of A+, the same letter grade it achieved last year. The company scored 109.75 out of 146.5 possible points and ranked 1st out of the 43 retailers evaluated this year.
In 2018, Apple had continued to make impressive strides by maintaining and frequently updating a beyond restricted substance list (BRSL), Apple’s Regulated Substances Specification (RSS), but also aiming for full material disclosure of its private-label products to analyze every component in the products it sells, with more than 25,000 out of 50,000 reviewed at that time. According to the company’s 2019 Environmental Responsibility Report (ERR), Apple collects “detailed chemical information for tens of thousands of components and over 75 percent of product mass for new iPhone, iPad, and Mac products.”
Its RSS 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. In 2018, Apple revised its RSS by adding or strengthening restrictions for a number of chemicals in products, including chemicals on the REACH Candidate List for Substances of Very High Concern (unless pre-approved by Apple), and established “non-use” restrictions for manufacturing process chemicals.
The company has not revised its RSS since the 2018 report card was released, but in late November 2018, Apple released a Chemical Prioritization Protocol to help the company identify chemicals that may need to be managed by qualitatively assessing information on chemical hazard, use, exposure potential, and public concern. The company used the protocol to determine which chemicals to add to its RSS last year before the protocol was officially released. Apple is also piloting, at some of its facilities, a tool the company helped develop that standardizes reporting on the use of manufacturing process chemicals in the electronics industry.
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 reported that it achieved 100% compliance with the RSS “for process chemicals at all final assembly sites” in 2015, 2016, 2017, and 2018. Apple takes strong steps to ensure the substances used in place of hazardous chemicals are an “environmentally responsible substitution” by requiring alternatives assessments and evaluates alternatives using the GreenScreen Framework and EPA’s Safer Choice Program. The company replaced hazardous cleaning chemicals used in final assembly facilities with safer alternatives that are free from chemicals designated as Benchmark-1 or -2 and List Translator-1. The 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 transparent public, quantifiable goals with specific timelines for reducing and eliminating chemicals of concern, including per- and polyfluoroalkyl substances (PFAS) that may be present in packaging, and by expanding its Full Material Disclosure (FMD) initiative to brand-name products sold in Apple stores and on Apple.com. The company should consider restricting CHCs that may be present in the building materials for new or renovated Apple stores. Apple should also become a signatory to the Chemical Footprint Project and pilot it with key private label suppliers.
Summary of Apple’s Grade
16.25 out of 17.5 points
Policy: Adopted a retailer safer chemicals policy
Apple’s Regulated Substances Specification (RSS) details thresholds for chemicals in its products, and functions as a 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, prohibiting chemicals, including benzene, chlorinated organic solvents (e.g. methylene chloride and trichloroethylene), N-methylpyrrolidone (NMP), n-Propyl Bromide (nPB) (prohibited in 2018), and toluene used in cleaning agents, degreasers, and demolder solutions, in all manufacturing processes. According to Apple’s 2019 Supplier Responsibility Report, 2018 represented the fourth year in a row in which “process chemicals at [Apple’s] final assembly facilities were verified as 100 percent compliant” with the RSS. The report also stated that in 2017, Apple “sought to expand [its] RSS compliance to commodity and component manufacturers deeper in [its] supply chain.” In 2019, the company noted that its Supplier Responsibility team was active in developing a tool to assess possible risks to workers from hazardous chemical exposure where exposure data isn’t available.
The RSS applies to both products and packaging and applies globally: “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 2019 Supplier Responsibility Standards state: “Supplier shall comply with Apple’s Regulated Substances Specification… for all materials and goods it manufactures for, or provides to, Apple.” In 2017, staff stated that 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 product declarations (ASHRAE 189.1). Also according to statements in 2017, for new stores (and those that opened in the last 2.5 months), Apple also sets limits on VOC emissions in “back of house.”
In its RSS, the company prioritizes “the chemicals it intends to phase out of Apple products in order to work effectively with its supply chain” into “Phase Out Priorities” 1 or 2. Since Apple doesn’t assign specific deadlines to the phase-out priorities, we awarded half points for the subcriterion of “public quantifiable goals.”
5 out of 5 points
Oversight: Established management responsibilities and incentives
The company stated in 2017 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.” In 2019, Apple confirmed that it still provides financial incentives for its senior management to implement the company’s chemical policy.
10 out of 12.5 points
Accountability: Ensures supply chain accountability
Apple employees stated that in 2016, the company trained 900 suppliers in two cities in China on the Regulated Substances Specification and Full Materials Disclosure. Also, according to Apple’s 2018 Environmental Responsibility Report: in 2017, the company expanded its Chemicals Management Program, which is designed “to help suppliers develop a comprehensive approach to managing chemicals safely” to 113 supplier facilities. This program “focuses on shifting to safer chemicals and improving general safety, awareness, and training.” In 2018, staff from the company conducted a training for more than 1,500 supplier employees, representing 500 suppliers, in six locations in Asia on the newly revised Regulated Substances Specification. Additionally, the Apple Supplier Responsibility Standards, as a supplement to the Code of Conduct, have requirements related to chemicals management and require each supplier to “comply with Apple’s Regulated Substances Specification, 069-0135, for all materials and goods it manufactures for, or provides to, Apple.” In 2017, staff stated that 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; so far, about 3,400 projects have been launched across 274 supplier facilities.
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.”
According to the company’s 2019 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 and test products to evaluate compliance with the RSS.” Staff confirmed that to verify supplier data, the company uses both its internal lab and third-party labs.
Apple also requires its suppliers to comply with its safer chemicals policy via supplier contracts. Apple staff stated in 2019: “To do business with Apple, suppliers must agree to operate in full compliance with all applicable laws and regulations, and adhere to our Supplier Code and Standards,” which includes a requirement to comply with its RSS as noted above.
8.5 out of 13 points
Disclosure: Requires suppliers to report use of chemicals in products to retailer
As of October 2018, Apple had analyzed composition data for more than 25,000 out of the 50,000 components in its products. According to the company’s 2019 Environmental Responsibility Report (ERR), Apple collects “detailed chemical information for tens of thousands of components and over 75 percent of product mass for new iPhone, iPad, and Mac products.” This is substantial progress compared with reports from the 2018 ERR, where they discussed collecting “FMDs covering over half of the mass of iPhone 8, iPhone 8 Plus, and iPhone X.”
As of 2019, Apple has not yet expanded its FMD initiative to brand-name products sold in its stores.
Related to disclosure of chemicals used in manufacturing: in 2017, Apple staff mapped chemicals of concern used in the company’s final assembly facilities to determine the opportunities for greener alternatives. This effort evolved into the company’s Chemical Safety Disclosure Program, which quantifies actual chemical usage, and its success contributed to the development and implementation of the Clean Electronics Production Network Process Chemical Data Collection (PCDC) Tool. This tool standardizes reporting on the use of manufacturing process chemicals in the electronics industry, and Apple is piloting the tool at some of its facilities.
16 out of 16 points
Action: Reduced or eliminated chemicals of high concern (CHCs) within the last three years
Apple also revised its Regulated Substances Specification in March 2018. The company added or strengthened restrictions for a number of chemicals in products, including polyaromatic hydrocarbons (PAHs) in all external materials, chlorine and chlorinated compounds in fiber-based packaging, and chemicals on the REACH Candidate List for Substances of Very High Concern (unless pre-approved by Apple). The company also changed content restrictions for several chemicals used in certain products in all manufacturing processes to “non-use” and included a ban on n-Propyl Bromide.
Additionally, in March 2018, as part of its expanded Full Material Disclosure program, Apple identified one plastic part in three products that contained a GreenScreen Benchmark 1 flame retardant. The company identified a safer alternative and took action to replace the material.
12.5 out of 13.5 points
Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes
Apple stated in its 2019 Supplier Responsibility report, discussing its recent effort to substitute safer chemicals for hazardous cleaning chemicals used in manufacturing: “We also encourage safer and greener cleaners and degreasers in our suppliers’ operations. Apple provides both training and assessment tools for suppliers to conduct their evaluations of safer alternatives based on the GreenScreen(R) framework and the U.S. Environmental Protection Agency’s Safer Choice Program.” According to staff statements in 2017, Apple had paid for more than 500 GreenScreen assessments. The 2019 Environmental Responsibility Report states: “We’re continually evaluating the materials used in our products and design to avoid harmful substances altogether. We seek to reduce and remove toxins, by developing new, safer chemistries. When there is not an existing alternative to a chemical we’ve determined harmful, we innovate. We work with our suppliers to develop custom chemistries made with safer substances.”
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.”
In 2019, Apple staff reported that the company participated in developing the public Clean Electronics Production Network Alternatives Assessment guide, designed to help brands and suppliers with assessments.
9 out of 18 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, for example, “Arsenic-free display glass” and a “Mercury-free LED-backlit display.” According to statements made by staff in product launch keynotes in 2017, “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 noted last year that while the company is working toward understanding all ingredients in its products, since “[t]here 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 suppliers to publicly disclose ingredients in products online or on product packaging.
0 out of 7.5 points
Chemical Footprint: Evaluates its chemical footprint
7.5 out of 8.5 points
Third-party Standards: Promotes credible third party standards for safer products
Apple has had 18 of its product types (and 42 products total) registered to this standard – iMac (desktop), iMac Pro, iPad, iPad Pro, iPad mini, iPhone 6s, iPhone 6s Plus, iPhone 7, iPhone 7 Plus, iPhone 8, iPhone 8 Plus, iPhone X, iPhone SE, Phone Xr, iPhone Xs, iPhone Xs Max, Mac Mini, MacBook, MacBook Air (13 in.), and MacBook Pro (13, 15 in). According to the EPEAT website, MacPro isn’t registered via EPEAT at all, but this may be because Apple is releasing a new version this fall. The product environment report for the older version of MacPro mentions that it is EPEAT-registered. The company advertises the gold EPEAT rating for its iMac, Mac, Macbook, and iPad products, and most of its iPhones.
In 2019, Apple noted that it had played a key role in shaping an optional criterion of the standard for computers and displays originally adopted by EPEAT.
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
In its 2018 Supplier Responsibility Report, Apple discussed its use of the GreenScreen framework and the EPA Safer Choice Program “to evaluate the health and environmental impacts of a chemical and identify better alternatives.” Apple reported that it successfully used these programs to identify safer replacements for hazardous cleaning chemicals that had been used in its final assembly facilities. In the 2019 Supplier Responsibility Report, the company relayed that “[i]n 2018, 36 suppliers achieved the elimination of all GreenScreen Benchmark 1 and Benchmark 2 cleaners and degreasers” and Apple staff separately confirmed that the replacement products also do not contain GreenScreen List Translator-1 chemicals.
In late November 2018, Apple released a Chemical Prioritization Protocol, which provides “a framework for prioritizing chemicals of concern in the electronics industry” and for identifying chemicals that may warrant chemical management actions by synthesizing “a wide range of relevant information about chemical hazard, use, exposure potential, and public concern into a simple set of quantitative indicators,” including the information provided through FMD and toxicological assessments. Apple used this tool before it was officially released to determine which chemicals to add to its RSS in 2018. This year, at some of its facilities, Apple is also piloting a tool the company helped develop that standardizes reporting on the use of manufacturing process chemicals in the electronics industry.
Apple has also reported on steady progress through the years as described on its website: in 2006, it phased lead out of display glass and solder; in 2008, it eliminated arsenic from display glass and brominated flame retardants from thousands of parts; and in 2009, it 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 in 2010.
In 2015, the company introduced Full Material Disclosure to evaluate all components in the private-label products it sells – 50,000 total. According to the company’s 2019 Environmental Responsibility Report (ERR), Apple collects “detailed chemical information for tens of thousands of components and over 75 percent of product mass for new iPhone, iPad, and Mac products.”
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
Apple created a Green Chemistry Advisory Board in 2015, with “some of the world’s leading toxicologists, researchers, and academics” to help “explore innovative ways to minimize or eliminate toxins from our supply chain and to incorporate the latest breakthroughs in green chemistry into our products and processes.”
Further, in the 2019 Supplier Responsibility Report, the company states: “Through the Clean Electronics Production Network (CEPN), Apple shares best practices, including our rigorous approach to chemical management, driving transparency in the supply chain, and safer, cleaner substitution. An example of this leadership is funding training videos for CEPN to share with its members and the entire electronics industry.” According to staff statements in 2019, Apple participated in developing the public CEPN Alternatives Assessment guide, designed to help brands and suppliers with assessments.
Apple noted in 2019 that staff serves on leadership committees of the new Association for the Advancement of Alternatives Assessment (A4), which is a professional association of researchers and practitioners “working collaboratively to accelerate the transition to the use of safer chemicals, materials, processes, and products.”
5 out of 5 points
Impact Investment: Investing financial resources into independent research into safer alternatives and/or green chemistry solutions
This year, according to staff, Apple’s Supplier Responsibility team is providing funding to Clean Production Action to develop a “safer cleaner” standard for electronics manufacturing that allows for the assessment of mixtures, not just individual chemical substances. This team is also financing a ToxServices project comparing how safer cleaners are evaluated in the EPA Safer Choice standard and in the ToxFMD Screened Chemistry™ Program.
In 2017, staff reported that Apple issued green bonds in 2016 and 2017 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.