CVS Health earned a letter grade of B, which is lower than its 2018 grade of B+. The company scored 71 out of 146.5 possible points, ranking 9th out of the 43 retailers evaluated this year.
The company has continued to implement its Cosmetic Safety Policy over the past year, disclosing that it continued to reformulate products containing chemicals of concern it had pledged action on in 2017. The company stated: “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 with SPF 50 and lower, and these products will be reformulated by the end of 2019.”
CVS Health first developed a Cosmetic Safety Policy and, in 2016, disclosed that it developed a list of Chemicals of Consumer Concern (CCCs). In 2017, CVS Health jointly announced with the Mind the Store campaign that it would remove parabens, phthalates, and the most prevalent formaldehyde releasers across nearly 600 beauty and personal care products from its store brands CVS Health, Beauty 360, Essence of Beauty, and Blade. The company also publicly released its beyond restricted substance list (BRSL) for the first time in 2017 and pledged to update it on an annual basis every May but has not followed through on publicly updating it in 2018 or 2019.
The company states: “[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 2016, CVS Health became the first major pharmacy chain in the country to become a signatory to the Chemical Footprint Project.
Opportunities for improvement: CVS Health can continue to improve its safer chemicals program by setting public quantifiable goals with clear timelines for reducing and eliminating other chemicals of high concern (CHCs), especially any per- and polyfluoroalkyl substances (PFAS) that may be present in the products it sells. The company should also expand the policy to cover brand-name suppliers and additional chemically intensive product categories, certify private-label cleaning products to credible third-party standards, such as EPA Safer Choice, Made Safe or Green Seal, and remove bisphenols from thermal receipt paper. CVS Health should pilot the Chemical Footprint Project with key private label suppliers. The company should also require suppliers to conduct testing in third-party laboratories and provide results to the retailer and conduct its own testing to ensure suppliers comply with its BRSL and cosmetics safety policy.
Summary of CVS Health’s Grade
10 out of 17.5 points
Policy: Adopted a retailer safer chemicals policy
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).
5 out of 5 points
Oversight: Established management responsibilities and incentives
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.”
5 out of 12.5 points
Accountability: Ensures supply chain accountability
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.
6 out of 13 points
Disclosure: Requires suppliers to report use of chemicals in products to retailer
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.”
15 out of 16 points
Action: Reduced or eliminated chemicals of high concern (CHCs) within the last three years
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.”
2 out of 13.5 points
Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes
However, the company has not disclosed additional details about how it ensures these chemicals are actually safer.
9 out of 18 points
Transparency: Demonstrates a commitment to transparency and public disclosure
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.
1.5 out of 7.5 points
Chemical Footprint: Evaluates its chemical footprint
0 out of 8.5 points
Third-party Standards: Promotes credible third party standards for safer products
0 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
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.”
2.5 out of 5 points
Safer Products: Program to promote safer products in stores and/or on website
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.
5 out of 5 points
Collaboration: Actively participates in collaborative process to promote safer chemicals
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.
0 out of 5 points
Impact Investment: Investing financial resources into independent research into safer alternatives and/or green chemistry solutions