Dollar Tree earned a letter grade of D+, which reflects a slight improvement from its D grade in 2018. The company scored 36.25 out of 146.5 possible points, ranking 24th out of the 43 retailers evaluated this year.
The company appears to have strengthened its safer chemicals policy and be taking action to implement it, albeit slowly, and with only limited transparency to-date about how it is supporting, measuring, or ensuring compliance, or about progress toward its current chemical phaseout goal. Key improvements this year include participating in the Chemical Footprint Project survey and posting a basic safer chemicals policy.
Dollar Tree first announced its Commitment to Eliminate Priority Chemicals in June 2017, although according to its recently posted “Chemical Policy,” the company implemented its “sustainable chemical plan” in 2016 (although it appears the implementation only began in that year, and not until late 2016). The commitment lists 17 priority chemicals or classes of chemicals that it expects its suppliers to reduce or eliminate from products by 2020, which is a reasonably aggressive timeline for a significant group of chemicals. However, in its Chemical Policy, Dollar Tree steps back from this goal by stating that it only applies to private-label products. Additionally, Dollar Tree asked suppliers to report products containing these priority chemicals by January 31, 2017, but the company did not publicly disclose the responses. In its Chemical Policy, the company stated that it is requiring suppliers to disclose “full ingredients for formulated products that contain chemicals as part of their base formulation” into WERCS but has not clarified its interpretation of “full ingredients.” Surprisingly, the company is requiring brand-name product suppliers to disclose ingredients online before it is requiring private-label suppliers to do this. In its 2018 Corporate Sustainability Report, Dollar Tree indicated that its products are being tested to determine the presence of those chemicals, even though suppliers were required to report on this in early 2017.
Dollar Tree does sell certain items on its website that are labeled as BPA-free, which we assume is connected with its policy to not carry food and beverage containers containing BPA.
Opportunities for improvement: Dollar Tree (including Family Dollar) should share its timeline for completing the testing of its products. More broadly, Dollar Tree can make progress by establishing and disclosing strong plans for holding suppliers accountable to its chemicals policy, publicly disclosing clear metrics and results, going back to its original plan of working toward eliminating priority chemicals from both private-label and brand-name products, ensuring oversight by senior management, and generally being more transparent about how its policies and commitments will be implemented and what progress is (or is not) occurring. The company should also expand its policy to cover chemicals used in packaging and manufacturing processes, and to per- and polyfluoroalkyl substances (PFAS), all toxic flame retardants, and all phthalates. We also urge the company to eliminate and safely replace toxic indirect food additives specifically in food contact materials, with special attention paid to any bisphenols (beyond BPA) and per- and polyfluoroalkyl substances (PFAS) that may be in in food packaging and other food contact materials as well as any phthalates that may be in food and food contact materials in its supply chain.
Summary of Dollar Tree’s Grade
7.5 out of 17.5 points
Policy: Adopted a retailer safer chemicals policy
As stated in Dollar Tree’s “Commitment to Eliminate Priority Chemicals,” containing its priority list of chemicals: “Dollar Tree is committed to the elimination of chemicals of high concern from our products by 2020. In December 2016 and January 2017, we sent letters to each of our suppliers communicating our commitment. We expect our suppliers to reduce and eliminate the use of all priority chemicals from our products.” The letter to suppliers stated: “Our goal is to eliminate the use of chemicals of high concern in our products by 2020.” The Commitment to Eliminate Priority Chemicals identifies “priority chemicals” to include 17 different chemicals or classes of chemicals, with some (lead, BPA, and asbestos) only considered “priority” when found in children’s products. The list includes chemicals that are not yet banned in the U.S.
The more recent Chemical Policy steps back slightly from this commitment by adding a qualification that the 2020 goal only applies to private-label products. As stated in the policy: “We have a goal of eliminating the chemicals identified on our priority chemical list from private label products by 2020 or sooner by working with suppliers on safer alternatives.”
However, the policy is somewhat vague, the company does not have a publicly available manufacturing restricted substance list (MRSL), and the policy does not appear to apply to operations, packaging, or locations outside the U.S.
0 out of 5 points
Oversight: Established management responsibilities and incentives
Dollar Tree does not appear to offer financial incentives for senior management to implement its safer chemicals policy.
2.5 out of 12.5 points
Accountability: Ensures supply chain accountability
Dollar Tree has not specifically disclosed that it incorporates its safer chemicals policy or reporting requirements in supplier contracts, that it trains suppliers on the company’s safer chemicals policy or reporting requirements, or that it requires suppliers to conduct testing in third-party laboratories and provide results to the retailer.
2.5 out of 13 points
Disclosure: Requires suppliers to report use of chemicals in products to retailer
The points awarded in this category reflect that Dollar Tree has not confirmed that this requirement applies to brand-name suppliers in addition to private-label suppliers, since the phaseout now only applies to private-label suppliers. The points also reflect that it is unclear whether the company is requiring suppliers to disclose (1) impurities in formulated products into WERCS, since those are not part of formulations, or (2) fragrance terms according to industry standards as opposed to using generic terms.
0 out of 16 points
Action: Reduced or eliminated chemicals of high concern (CHCs) within the last three years
2 out of 13.5 points
Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes
9.75 out of 18 points
Transparency: Demonstrates a commitment to transparency and public disclosure
Consumers can identify plastic food containers and baby products that do not contain BPA through online search filters on Dollar Tree’s website. According to its 2016 sustainability report (previously posted on its website), Dollar Tree set restrictions on BPA going beyond regulatory compliance.
Dollar Tree’s Chemical Policy states that the company “will encourage our suppliers of national brand products to disclose product ingredients online by product.” However, the term “product ingredients,” without more details about its interpretation, may not include impurities or dictate that industry naming standards, as opposed to generic terms, will be used. Furthermore, to receive 3 points for this encouragement, it would need to apply to product packaging in addition to product pages online and Dollar Tree would also need to formally encourage its suppliers to publish fragrance ingredients used in its products and fragrance ingredients that it restricts. Therefore, we are awarding partial credit.
4.5 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
7.5 out of 15 points
Continuous Improvement: Shows continuous improvement by steadily expanding safer chemicals policy
0 out of 5 points
Safer Products: Program to promote safer products in stores and/or on website
0 out of 5 points
Collaboration: Actively participates in collaborative process to promote safer chemicals
0 out of 5 points
Impact Investment: Investing financial resources into independent research into safer alternatives and/or green chemistry solutions