CVS Health

CVS Health has a Cosmetic 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 that: “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.” The company’s BRSL applies to its CVS store brand baby, beauty, personal care, child, foods, and suncare products. In addition to the CCC list, CVS also has an RSL of chemicals it has already phased out or restricted. CVS Health’s Cosmetic Safety Policy and Restricted Substances List apply to all CVS Pharmacy locations.

In April 2017, CVS set public quantifiable goals to reformulate nearly 600 private-label products for key CHCs from its CVS Health, Beauty 360, Essence of Beauty, and Blade product lines and the company stated it, “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 shared that “more than 75 percent of these 600 products will be reformulated by the first quarter of 2019 and the remaining 25 percent will be reformulated by the end of the year.”

In 2017, the company also noted that it planned to “develop and launch [a] sustainable product policy” but that policy has still not been publicly released.

The company has also eliminated BPA in all private-label packaging, such as for infant formula. However, the company’s chemicals policy does not explicitly apply to packaging, and it has not disclosed any recent efforts to restrict CHCs, such as PFAS or ortho-phthalates, in packaging. The company stated in its most recent sustainability report: “in 2019 we will be developing our criteria for CVS Pharmacy store brand printed packaging to create more sustainable packaging for our products” though it doesn’t clarify whether this will address chemicals of concern in packaging. Last year, the company shared that it joined the Sustainable Packaging Coalition and was planning to engage its suppliers around packaging through the Beauty and Personal Care Products Sustainability Project (BPC) survey for packaging.

The company’s Cosmetic Safety Policy also does not appear to apply to other products or to operations, and the company does not have a publicly available manufacturing restricted substance list (MRSL).

CVS Health has multiple staff who work on sustainability. According to staff statements, sustainability, which includes chemical management, is embedded in the Work & Development Plans of key leaders across the company’s 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 they have met the goals related to chemical management and are given incentives for good performance.

In its most recent sustainability report, the company noted: “Our Senior Vice President of CSR and Philanthropy also ensures we are progressing against our strategy and performance targets. She and her team regularly work with company leadership to align our strategy with business imperatives and collaborate with colleagues throughout the company on key initiatives. She also serves as the Executive Sponsor of our GreenTeam Colleague Resource Group. Colleagues with direct oversight of areas within our three CSR pillars are responsible for driving performance and meeting established targets as part of their business plan. These internal partners are regularly engaged by the CSR team to provide progress updates and identify emerging risks and opportunities. Remuneration of leaders, colleagues, as well as business unit and facility managers is partially linked to performance against these business plans.”

The company noted in its most recent sustainability report that: “Information about our restricted substances list has been added to our Store Brands Quality Assurance Agreement, which requires adherence from suppliers. We employ technological tools, including WERCSmart, to help ensure supplier compliance with our policies. WERCSmart captures supplier ingredient information for all chemical-based products, helping us screen for restricted chemicals.”

CVS Health also shared last year that it 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 covered by its commitment to eliminate parabens, phthalates, and the most prevalent formaldehyde releasers to discuss processes and timelines and answer questions around implementation. The company noted last year 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.”

In the company’s 2016 sustainability report, it stated 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 not specifically disclosed 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.

In its most recent sustainability report, CVS Health stated: “We employ technological tools, including WERCSmart, to help ensure supplier compliance with our policies. WERCSmart captures supplier ingredient information for all chemical-based products, helping us screen for restricted chemicals.” The company also noted that it utilizes (UL) PurView: “to screen all store brand food ingredients,” but it is unclear if that is utilized to screen for indirect food additives, such as PFAS, ortho-phthalates, and bisphenols, in food packaging or other food contact materials.

CVS has previously shared 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 stated: “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 had also shared it initiated a program to screen for restricted chemicals via the WERCS and stated that it was 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.” The company went 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.”

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 shared new progress: “More than 75 percent of these 600 products will be reformulated by the first quarter of 2019 and the remaining 25 percent will be reformulated by the end of the year.”

In 2018, the company also shared progress in eliminating chemicals of concern in sunscreens. It stated: “In addition to our chemical management programs, we work to stay ahead of mandated timelines for regulatory requirements. In 2018, we began removing oxybenzone and octinoxate from our store brand [sunscreens] with SPF 50 and lower, and these products will be reformulated by the end of 2019. Hawaii was the first U.S. state to pass a bill banning the distribution of sunscreens that contain the chemicals due to concern for their impact on marine environments and residing ecosystems. Key West, FL voted in early 2019 to ban the sale of sunscreen containing the same chemicals, concerned about impacts to the Florida Keys’ barrier reef ecosystem.”

The company has stated that 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.”

However, the company has not disclosed additional details about how it ensures these chemicals are actually safer.

CVS’ Cosmetics Safety Policy is publicly available, as is its BRSL, which was first posted to its website in April 2017. The list, which the company has pledged to update on an annual basis every May, identifies CVS’ restricted chemicals by product category. The company last updated it in March 2019.

CVS previously 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 suppliers to publicly disclose ingredients in products online or on product packaging.

CVS Health became a signatory to the Chemical Footprint Project in 2016 and was the first major national pharmacy chain to do so. In its 2017 sustainability report, it stated this signals “a commitment to chemical transparency across [its] supply chain.” However, since then, the company has not made any additional discernible progress on measuring its chemical footprint.

CVS Health has not shown discernible progress on credible third-party safer chemicals standards going beyond regulatory compliance, 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.” Since then, the company has since not shared any details or updates about its sustainable products policy or third-party standards.

In 2017, CVS Health partnered with the Mind the Store campaign to announce its plans to reformulate nearly 600 private-label products for CHCs and also, for the first time, disclose its BRSL. However, since this joint announcement happened before November 2017, credit can no longer be awarded in this category.

In April 2017, CVS Health announced it was reformulating nearly 600 private-label products for parabens, formaldehyde-releasers, and phthalates. At the same time, the company published its BRSL, 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.” Its BRSL is reviewed and updated annually, and was last updated in March 2019.

In its 2018 sustainability report, released in April 2019, the company shared that: “More than 75 percent of these 600 products will be reformulated by the first quarter of 2019 and the remaining 25 percent will be reformulated by the end of the year.” It also shared that: “In 2018, we began removing oxybenzone and octinoxate from our store brand sun screens [sic] with SPF 50 and lower, and these products will be reformulated by the end of 2019.”

CVS’ website enables users to shop for beauty products free of parabens, formaldehyde donors, phthalates, and sulfate through a filter system on the left side of the webpage. Partial credit is awarded since these filters represent a step in the right direction. We encourage CVS to go further by ensuring all of the ingredients in its products are genuinely safer, not just that the products are free from a limited number of toxic chemicals.

The company has 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 went on to say: “Our product sustainability policies will include KPIs [key performance indicators] 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).”

The company has not shared any additional information about these KPIs or sustainable procurement efforts.

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 have a significant focus on chemicals management and chemicals transparency.

The company has not shared any details since then on how it plans to use the BPC criteria.

The company has also not shared how it will implement or utilize the new GC3 Statement on Chemical Innovation Priorities and Transparency Road Map.