CVS Health

CVS has a Cosmetics Safety Policy that includes a commitment to “developing action plans to replace ingredients of concern in our branded and private label products when safer alternatives are available and prompting similar action by our suppliers.” The company has developed a list of “chemicals of consumer concern (CCC)” and has stated “we actively identify and prioritize the replacement of CCCs with safer alternatives in certain CVS Brand categories, including beauty, baby and personal care, and food products. As new, conclusive research is published on how certain chemical ingredients are linked to health and environmental risks, and safer alternatives are made available, we apply our Cosmetic Safety Policy. This policy outlines our commitments to customer safety, scientific research, supplier collaboration and continuous improvement as well as the evaluation and replacement of CCCs in CVS Brand products. In 2015, we began the process of developing a sustainable products policy to further inform our strategy and commitments.” In addition to the CCC list, CVS also has an RSL of chemicals it has already phased out or restricted. The company’s RSL applies to its “CVS Store Brand Baby, Beauty and Personal Care Products.”

In April 2017, CVS set public quantifiable goals to reformulate nearly 600 private-label products for key chemicals of high concern from its CVS Health, Beauty 360, Essence of Beauty, and Blade product lines and stated the company, “will stop shipping store brand products that don’t meet these standards to distribution centers by the end of 2019.” In 2017, the company also noted that it plans to “develop and launch [a] sustainable product policy.”

The company has also eliminated BPA in all private-label packaging, such as for infant formula. The company has recently joined the Sustainable Packaging Coalition and is planning to engage its suppliers around packaging through the Beauty and Personal Care Products Sustainability Project (BPC) survey for packaging. However, the company’s chemicals policy does not explicitly apply to packaging.

The company’s Cosmetics Safety Policy does not appear to apply to other products or operations, and the company does not have a publicly available Manufacturing Restricted Substance List (MRSL).

CVS has multiple staff who work on sustainability, including chemicals. Sustainability, which includes chemical management, is embedded in the Work & Development Plans of key leadership across its Store Brands and Quality Assurance teams. Specifically, the reduction of key ingredients is included in annual goal setting for these teams. Employees are evaluated on whether the goals related to chemical management have been met and good performance is incentivized. In its 2015 sustainability report, the company stated: “Our goals are tied to our CSR strategic priorities, which are organized under three pillars. Each pillar has an executive sponsor who oversees progress against these priorities, while specific goals are owned and driven by senior management throughout our organization.” In its most recent sustainability report, the company stated: “The Nominating and Corporate Governance Committee of our Board, pursuant to its charter, is formally charged with oversight of our CSR strategy and performance. Our Senior Vice President of Corporate Social Responsibility and Philanthropy regularly updates the Committee on CSR risks and opportunities, and the Committee provides feedback and direction on our approach to key issues. The Committee also reviews our annual CSR Report prior to publication.”

CVS Health regularly conducts supplier training on adhering to its chemical policy and restricted substance list through on-site training classes, webinars and printed materials. For example, in 2017 the company held a webinar series with all suppliers impacted by its commitment to eliminate parabens, phthalates, and the most prevalent formaldehyde releasers to discuss processes and timelines and answer questions around implementation. It has also added this requirement to its Store Brands Quality Assurance Agreement, which all suppliers are required to adhere to. The company notes that “we also host on-going engagements with our suppliers to ensure that they understand our goals and commitments and understand how we can support them.”

The company utilizes the WERCS to track chemicals on its RSL in order to flag when a chemical from the list is in the formulation of a product.

In the company’s 2016 sustainability report, it states it has “made advancements in ingredient and labeling transparency and verification.” CVS Health stated: “In 2016, we increased the rigor of our label claim substantiation process to give consumers more confidence in product label information. We completed additional due diligence on certifications that appear on labels to ensure reliability. We also began a process of partnering with our suppliers to validate the label claims on all of our store brand products in every category—more than 4,000 products. For example, suppliers who make claims based on studies must provide us with validation of the studies’ methodology and results; this is a more robust review than required under industry standards. This label claim substantiation process is in addition to the required registration and monitoring of product ingredients through WERCSmart, our supply chain compliance tool, as well as our ongoing product testing regime.” For example, if a supplier says a product is “Free of Parabens,” that claim requires substantiation.

CVS Health has otherwise not reported on programs to conduct testing to ensure supplier conformance with CVS Health’s Cosmetic Safety Policy.

CVS says that it “requires suppliers to disclose chemical-based ingredients in certain product categories and for new or reformulated products.” The disclosure is used, in part, to “identify non-compliant products that contain restricted ingredients or are on [its] list of CCCs.” The company states: “In 2015, we invested in a new monitoring tool, which further increases our visibility into the sustainability of our supply chain by allowing us to look deeper into the ingredient profile of products.” The company has recently initiated a program to screen for restricted chemicals via the WERCS and states that it is the first retailer to implement this. This allows CVS Health to screen both publicly disclosed ingredients and any proprietary blends, which are not disclosed to the public but are put into WERCS for screening while protecting suppliers’ “trade secrets.” They go on to say the “CVS team receives a notification from WERCSmart when a product is identified as containing one of our restricted chemicals, so discussions can be initiated with the supplier and merchant for the product to determine the path forward.”

Additionally, the company states: “All of the suppliers impacted by our restriction of parabens, phthalates and the most prevalent formaldehyde donors need to provide full transparency on ingredients. This includes requiring their suppliers to certify that these ingredients are not included in any proprietary fragrance.”

In April 2017, CVS Health announced it “took a major step forward in advancing its efforts to address chemicals of consumer concern by announcing the removal of parabens, phthalates and the most prevalent formaldehyde donors across nearly 600 beauty and personal care products from its store brand CVS Health, Beauty 360, Essence of Beauty, and Blade product lines. The Promise Organic line of store brand products also does not contain any of these ingredients. CVS Pharmacy will stop shipping store brand products that don’t meet these standards to distribution centers by the end of 2019.”

In its most recent sustainability report, the company stated: “We are working with the suppliers to reformulate products as needed to ensure that product benefits and quality are maintained throughout the transition. To date, more than 300 products have been reformulated to meet our standards.”

The company states its staff “actively identify and prioritize the replacement of CCCs with safer alternatives in certain CVS Brand categories, including beauty, baby and personal care, and food products.” CVS states it “use[s] clear guidelines with supplier partners to ensure that when an ingredient is removed, it is not replaced by a regrettable substitution.” The company goes on to state: “We ask suppliers to leverage industry resources such as hazardous chemical lists (including the Hazardous 100+) to evaluate alternative ingredients.”

CVS also notes: “We have recently initiated a program to screen for restricted chemicals via the WERCS, we are the first retailer to implement this. This allows us to screen both publicly disclosed ingredients and any proprietary blends, which are not disclosed to the public, but are put into WERCS.”

CVS’ Cosmetics Safety Policy is publicly available, as is its Beyond Restricted Substance List (BRSL), which was posted to its website in April 2017. The list, which the company has pledged to update on an annual basis every May, identifies the restricted chemicals by product category. However, the company did not posted an update to its BRSL in May 2018.

CVS has disclosed that its Promise Organic line of products does not contain parabens, phthalates, or the most prevalent formaldehyde donors. The packages of the company’s Beauty 360 Makeup Remover Wipes and Earth Essentials by Total Home Dish Soap also disclose that ingredients of concern have been eliminated. The company does not appear to further encourage or require the disclosure of ingredients in products online or on product packaging.

CVS Health became a signatory to the Chemical Footprint Project in 2016, becoming the first major national pharmacy chain to do so. In last year’s sustainability report, it stated this signals “a commitment to chemical transparency across [its] supply chain.”

The company has made no discernible progress on credible third-party safer chemicals standards, though the company stated in its 2015 sustainability report: “In 2015, we began the process of developing a sustainable products policy to further inform our strategy and commitments. In the future, we will work on developing standards or leveraging ones already established by credible third-party partners for specific product categories.” The company has since not shared any details or update about its sustainable products policy.

In 2017, CVS Health partnered with the Mind the Store campaign to announce its plans to reformulate nearly 600 private-label products for chemicals of high concern and also for the first time disclose their Beyond Restricted Substance List.

In April 2017, CVS Health announced it was reformulating nearly 600 private-label products for parabens, formaldehyde-releasers and parabens. At the same time, the company published its Restricted Substance List, which describes ingredients restricted by product category, for the first time. The company announced its intention to expand the list of chemicals and product categories the list applies to going forward, stating: “we look forward to continuing to work with stakeholders to address additional chemicals of consumer concern and focus on more product categories in the future.” In 2018, in its most recent sustainability report, the company noted: “We are working with the suppliers to reformulate products as needed to ensure that product benefits and quality are maintained throughout the transition. To date, more than 300 products have been reformulated to meet our standards.”

In its 2017 sustainability report, the company stated: “we plan to expand the number of CVS Pharmacy locations that offer Promise Organic from 1,700 to about 2,700. We also plan to launch four new Promise Organic baby skin care products in about 2,000 stores in 2017. In March 2017, we became the exclusive national drugstore chain partner for The Honest Company, which is committed to creating products that are delightful, accessible and responsible. More than 4,100 CVS Pharmacy locations will carry items including bio-based, non-chlorinated diapers; biodegradable wipes; and a shampoo made with organic botanicals. Honest Company products will also be available on a dedicated microsite at CVS.com.”

The company has also shared: “We have engaged our partner, BSR to help us develop and implement a practical and impact-oriented approach to sustainable procurement through the adoption of policies that serve both sustainable products and sustainable procurement, and tools to operationalize the policies as part of our existing vendor management process. We expect this project to be complete by the end of 2018.” The company goes on to say: “Our product sustainability policies will include KPIs for each of the categories of products we carry as well as non-merchandise items like uniforms, office desks, facility cleaning products, etc. For the categories where ingredients are pertinent, that will be one of the KPIs we look at and we’re in the process of determining how we will enforce (i.e. through our RSL, through BPC for those categories, through authoritative lists, etc).”

CVS is active in the Green Chemistry & Commerce Council’s (GC3) Retailer Leadership Council (RLC) and the Beauty and Personal Care Sustainability Project (BPC). The company says: “In 2017, we also collaborated with our peers and sustainability nonprofits Forum for the Future and The Sustainability Consortium (TSC) to work toward a more sustainable and transparent beauty and personal care product industry. As part of the group’s work, we developed a common approach to evaluate the sustainability of beauty and personal care products. This is a significant step forward, aligning a wide array of product assessment criteria in use today. An initial version of this assessment tool has been piloted and will now be transitioned for ongoing coordination, development, and implementation to TSC, to leverage their existing work with businesses in a variety of sectors on product sustainability metrics and measurement. Retailers and other organizations that voluntarily adopt this approach can use key performance indicators (KPIs), along with a common method of scoring products against these indicators, to independently evaluate product sustainability. A range of sustainability attributes and activities, from basic practice to aspirational leadership, are reflected within the KPIs.” The BPC criteria has a significant focus on chemicals management and chemicals transparency.

No indication that company invests significant financial resources into independent research into safer alternatives to chemicals of high concern and/or green chemistry solutions.