Apple improved on its grade of A from last year, scoring an A+ with 106.25 points out of 135 points this year. Apple ranked first out of 40 retailers. Apple has made impressive strides in this area, not only maintaining and frequently updating a Beyond Restricted Substance 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 more than 25,000 out of 50,000 reviewed so far. 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.
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, and 2017. 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. 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 transparent public, quantifiable goals with specific timelines 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. The company should also report how it is ensuring that the molded fiber packaging materials the company is increasingly utilizing are not treated with PFAS. 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 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, prohibiting chemicals including benzene, chlorinated organic solvents (e.g. methylene chloride and trichloroethylene), N-methylpyrrolidone (NMP), n-Propyl Bromide (nPB) and toluene used in cleaning agents, degreasers, and demolder solutions in all manufacturing processes. According to Apple’s 2018 Supplier Responsibility Report, 2017 represented the third year in a row in which “process chemicals at [Apple’s] final assembly facilities were verified at 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.”
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 Code of Conduct states: “Supplier shall comply with Apple’s Regulated Substances Specifications for all goods it manufactures for, and 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). For new stores (and those that opened in the last 2.5 months), Apple also sets limits on VOC emissions in “back of house,” also according to last year’s statements.
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. Although Apple doesn’t assign specific deadlines to the phase out priorities, we awarded half points for the subcriterion of “public quantifiable goals.”
7.5 out of 7.5 points
Oversight: Established management responsibilities and incentives
At least as of last year, Apple provided financial incentives for its senior management to implement the company’s chemical policy. 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.”
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 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 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 goods it manufactures for, and 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 2018 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.” Staff confirmed that to verify supplier data, the company uses both its internal lab and third-party labs.
7.5 out of 10 points
Disclosure: Requires suppliers to report use of chemicals in products to retailer
In 2017, Apple staff clarified that the company also collects information on the ingredients in packaging materials, not just in the products.
So far, Apple has analyzed composition data for more than 25,000 out of the 50,000 components in its products. According to its 2018 Environmental Responsibility Report, Apple has “also collected FMDs covering over half of the mass of iPhone 8, iPhone 8 Plus, and iPhone X.”
As of last year, Apple had not yet expanded its FMD initiative to brand-name products sold in its stores.
13.5 out of 15 points
Action: Reduced or eliminated chemicals of high concern 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.
10 out of 10 points
Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes
Apple’s March 2018 Regulated Substances Specification states: “For substances that are restricted or regulated and have been replaced with an alternative substance, the supplier is required to ensure the alternative substance is an environmentally responsible substitution. Substitutions should be selected based on minimizing unintended consequences that might occur in phasing out a potentially hazardous substance. Suppliers shall conduct alternative assessments or obtain these assessments from their raw materials suppliers prior to making a replacement. Contact Apple at email@example.com for more information on conducting alternative assessments.”
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.”
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.” 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 the disclosure of ingredients in products 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 18 of its product types certified 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, Mac Mini, Mac Pro, MacBook, MacBook Air (11, 13 in.), and MacBook Pro (13, 15 in). The company advertises that certification for its iMac, Mac, Macbook, and iPad products, and most of its 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
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 manufacturing.
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 phaseout 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 they sell – 50,000 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
Apple created a Green Chemistry Advisory Board with “the world’s leading toxicologists, researchers, and academics” to help “identify innovative ways to minimize or eliminate toxins from our supply chain.”
Further, the company’s website states: “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
Last year, 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.