Lowe’s

In November 2018, Lowe’s launched a new safer chemicals policy, which states: “There has been a growing concern that there are hazardous chemicals that can be persistent and build up in the environment and have significant adverse human and environmental health effects. While regulations are being strengthened, certain concerns remain unregulated and may impact the health and safety of Lowe’s products.” It also states: “Lowe’s will develop a framework to systematize the process of assessing chemicals and managing chemical risks. Chemical risks can be managed in several ways and may include requiring disclosure of chemicals in Lowe’s products, reducing or eliminating toxic chemicals from Lowe’s products or packaging, better educating consumers on product safety, and/or driving innovation by encouraging suppliers to transition to safer alternatives and green chemistry solutions.” The policy references the company’s products, packaging, and operations and applies to all its stores. However, since the company’s key statement on packaging is tentative and the statement on operations does not indicate how it is addressing chemicals of concern in its operations (such as bisphenols in thermal receipt paper and flame retardants, PFAS, and ortho-phthalates in building materials used for new stores and renovations), partial credit is awarded for each of these components.

The company notes: “Lowe’s will review this chemical policy at least on an annual basis and report progress in its annual corporate responsibility report.”

In 2019, the company expanded its policy by adopting a BRSL with quantifiable goals. It includes restrictions on CHCs in various product categories. The company stated: “All indoor residential carpet and rugs purchased by Lowe’s will be free of PFAS chemicals by January 2020.” The company disclosed restrictions on phthalates, halogenated flame retardants, vinyl chloride, triclosan, organotins, coal fly ash, and other toxic chemicals in other notable product categories, including wall-to-wall carpet, paint, and fiberglass insulation.

In 2018, Lowe’s demonstrated impressive leadership by becoming the first major U.S.-based retailer to announce a global ban on the sale of paint strippers containing methylene chloride and NMP in all of its stores. Lowe’s has stores in the U.S., Canada, and Mexico. This helped spur a major ripple effect among other large home improvement, paint, and general merchandise retailers who joined the market shift away from toxic paint strippers. Lowe’s has also restricted chemicals such as ortho-phthalates in flooring.

Lowe’s does not have a publicly available manufacturing restricted substance list (MRSL).

A corporate manager has explicit responsibility for product safety related to chemical hazards in products.

In its most recent sustainability report, the company stated: “In the U.S., Lowe’s senior vice president, chief compliance officer & deputy general counsel oversees sustainability matters and reports quarterly to the sustainability committee and to the general counsel, a direct report to the CEO, and regularly updates the sustainability committee of the board. Additionally, the sustainability team meets monthly with our corporate responsibility council, consisting of vice presidents and directors from more than 14 functions across Lowe’s. Although Lowe’s takes a global approach to corporate responsibility, we adapt it to our local regions. Our Canadian director of corporate responsibility reports to the senior vice president of communications, public affairs and compliance, who is a direct report to the president of Lowe’s Canada. For the Canada region, we plan to implement a sustainability steering committee in 2019 and look for improved means to quantify sustainability progress and harmonize our metrics with Lowe’s U.S.”

Lowe’s does not appear to offer financial incentives for senior management to implement its safer chemicals policy.

In its new safer chemicals policy, the company states: “Lowe’s will continuously improve its engagement with supply chain partners to ensure requirements are understood and acted upon in a reasonable timeframe,” though it doesn’t provide additional guidance on how that will be executed.

In September 2019, the company stated: “Our chemical policy and current commitments have been communicated to our suppliers to ensure they comply. In addition, we are engaging across mutiple [sic] suppliers to evaluate potential commitments to reductions in CHCs in paint, flooring, insulation and cleaning products.”

In its most recent sustainability report, Lowe’s states: “We actively audit, test and inspect products where we are the importer of record. Our quality assurance (QA) team monitors product safety, quality and customer satisfaction across our product offerings. Annually, Lowe’s authorized third-party labs conduct product and transit/packaging tests to verify compliance with applicable industry standards and state and federal regulations. The third-party labs also conduct consumer testing and provide us with product test reports, which Lowe’s uses to make informed sourcing decisions. We implemented an enterprise QA program in 2018 to expand product testing and monitoring to our global operations. Simultaneously, we streamlined our product testing processes based on product risk profiles, reducing overall tests needed by removing unnecessary evaluation of extremely low-risk products.” It is, however, unclear to what extent Lowe’s engages in these efforts to ensure regulatory compliance or to go beyond regulatory compliance to implement its safer chemicals policy.

The company previously shared that it conducts annual testing for wood flooring (laminate/composite wood and bamboo) to ensure compliance with both CDPH 1350 for VOC’s and CARB requirements for formaldehyde nationally. The company noted: “when there are state-specific regulations on chemical composition, we test to ensure national compliance.” The company stated: “in 2016, more than 13,000 product tests were conducted in 87 third-party labs around the world. The Quality Assurance team also works closely with third-party agencies to conduct pre shipment product inspections prior to acceptance by Lowe’s. Products are inspected for proper labeling, functional operation and consistency across production samples to help ensure customer satisfaction. In 2016, factories were visited nearly 11,000 times to perform these pre shipment product inspections.”

Lowe’s 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.

In its safer chemicals policy, Lowe’s states: “Lowe’s will continue to foster supply-chain relationships and encourage suppliers to disclose chemicals to Lowe’s to better understand chemicals in the products and packaging Lowe’s sells and how they impact product and environment.” In September 2019, the company stated: “Lowe’s requires suppliers to submit product composition information to the UL WERCSMART system for the following product categories:
– aerosols
– batteries
– electronics
– pesticides
– all products that contain gels, powders, pastes, liquids or gases
– [fluorescent], halogen, and HID lamps”

The company went on to clarify: “The initial driver for collecting the information was to ensure that we were transporting and storing product in the right spots, and cleaning up spills correctly. That said, we are starting to work with UL to use the the [sic] database to query for the presence of specific chemicals in our products – which will help us ensure we are meeting our commitments, and can also help us identify which products contain CoCs that have not yet been addressed by our commitments. In short, we are leveraging an existing process & database to drive progress on the proactive side of the house.” Lowe’s has not confirmed whether it requires suppliers to disclose allergens or the components of generic ingredients through this program, and has not confirmed whether it requires this of all suppliers (private-label and name-brand), so we are awarding 2.5 points.

Lowe’s recently helped develop the Green Chemistry & Commerce Council (GC3) Retail Leadership Council (RLC) Statement on Chemical Innovation Priorities and Transparency Roadmap and should consider implementing the Transparency Roadmap with its suppliers.

In 2019, Lowe’s anounced new restrictions on classes of and individual toxic chemicals in numerous product categories. It announced that: “All indoor residential carpet and rugs purchased by Lowe’s will be free of PFAS chemicals by January 2020.” The company also disclosed new restrictions on phthalates, halogenated flame retardants, vinyl chloride, triclosan, organotins, coal fly ash, and other toxic chemicals in other notable product categories including wall-to-wall carpet, paint, and fiberglass insulation.

In 2018, Lowe’s demonstrated impressive leadership by becoming the first major U.S.-based retailer to announce a global ban on the sale of paint strippers containing methylene chloride and NMP in all of its stores. Lowe’s has stores in the U.S., Canada, and Mexico. This helped spur a major ripple effect among other large home improvement, paint, and big box retailers who joined the market shift away from toxic paint strippers. The company has followed through and implemented this commitment.

The company also noted in its most recent sustainability report: “We also continue to phase out volatile organic compound (VOC) paints. We sell a large selection of VOC-free paints in the U.S. and 100% low-VOC paints in Canada, in compliance with Canadian regulations.”

Finally, in a recent communication, Lowe’s Canada stated it is investigating the use of bisphenols in thermal receipt paper in its stores, stating: “we are currently evaluating different options to phase out the use of thermal paper containing bisphenols across our banners.”

In 2015, Lowe’s was the second major U.S. retailer to work with suppliers to eliminate all ortho-phthalates in residential vinyl flooring, one of the largest uses globally. Recent testing has confirmed Lowe’s followed through on that commitment. Lowe’s enforces the California formaldehyde restrictions for all laminate, engineered, and bamboo flooring categories. Points are not awarded for either of these efforts since they happened more than three years ago and outside the scope of our quantitative assessment. The company also restricts lead to 600 parts per million (ppm) in surface coating for all products, not just regulated items.

Lowe’s safer chemicals policy states: “Lowe’s will strive to protect the health of Lowe’s customers, employees, and environment by systematically identifying, reducing, and eliminating chemicals of concern and substituting them with safer alternatives wherever commercially feasible. Lowe’s will actively drive the identification and availability of safer alternatives to its entire operations, including Lowe’s stores and offices…Lowe’s will strive to enhance consumer confidence in the products Lowe’s sells in the United States and other countries through making available an increasing number of eco-products that incorporate safer chemicals.”

In its most recent sustainability report, the company notes it worked with the GC3 RLC to develop a new joint statement. This statement calls on chemical companies and suppliers to develop safer alternatives for flame retardants, plasticizers, water and stain repellents, and other chemicals in products sold at retail. It identifies the need to develop safer alternatives to dangerous chemicals in food packaging, electronics, personal care products, building materials, and other product categories.

Lowe’s was the first major retailer to phase out the sale of methylene chloride- and NMP-containing paint removal products, which helped spur a major market shift away from these hazardous products. However, recent research has found that Lowe’s is selling other paint removal products containing chemicals of concern that meet the GreenScreen Benchmark-1 criteria. Lowe’s must do a better job of ensuring substitutes for methylene chloride and NMP are safe.

Lowe’s published its safer chemicals policy in November 2018 and stated it: “will review this chemical policy at least on an annual basis and report progress in its annual corporate responsibility report.” The company has also publicized its limited BRSL of NMP and methylene chloride in paint strippers.

In October 2019, Lowe’s disclosed restrictions on toxic chemicals in carpet, paints, flooring, and insulation, essentially making a BRSL publicly available.

Lowe’s recently helped develop the GC3 RLC Statement on Chemical Innovation Priorities and Transparency Roadmap and should consider implementing the Transparency Roadmap with its suppliers.

Lowe’s does not appear to encourage or require suppliers to publicly disclose ingredients in products online or on product packaging and does not itself publicly disclose the identity of articles or formulated products that are free of CHCs going beyond regulatory compliance.

Lowe’s has not made any discernible progress on measuring its chemical footprint via the Chemical Footprint Project.

The company noted in its most recent sustainability report: “We continue to increase the number of products in our portfolio with safer product and environmental certifications — such as GreenGuard, EPA Safer Choice and GreenCircle — to help consumers identify and consider these products while shopping.”

Lowe’s requires that flooring products be certified to either Greenguard or FloorScore standards to meet CDPH-1350 standards for volatile organic compounds (VOCs). While these certification programs are primarily oriented around meeting a California regulatory standard, Lowe’s requires suppliers to meet this certification nationally.

Lowe’s briefed the Mind the Store campaign on its safer chemicals policy in advance of its public release. Lowe’s also briefed the campaign in advance of its public announcement banning methylene chloride and NMP in paint strippers in 2018 as well as toxic chemicals in carpet, paint, and insulation in 2019.

In 2019, Lowe’s continued to improve by disclosing restrictions on classes of and individual hazardous chemicals in numerous product categories. It announced that: “All indoor residential carpet and rugs purchased by Lowe’s will be free of PFAS chemicals by January 2020.” The company also disclosed restrictions on phthalates, halogenated flame retardants, vinyl chloride, triclosan, organotins, coal fly ash, and other toxic chemicals in other notable product categories, including wall-to-wall carpet, paint, and fiberglass insulation.

Lowe’s launched its safer chemicals policy in November 2018 after the 2018 retailer report card was published and followed through on its ban of toxic paint strippers (that it had announced in May 2018) by the end of 2018.

In its most recent sustainability report, Lowe’s stated: “Lowe’s strives to help customers reduce their environmental impact with a global focus on eco-products. Because customer needs and government regulations differ, our product portfolio varies across the U.S. and Canada. For more than 10 years, our RONA operations in Canada have leveraged the life cycle approach to identify and promote certain products as “eco-products,” formalized as the ECO product program. In 2018, we expanded the ECO product program across Canada and revamped our marketing efforts to promote the program. We are enhancing our processes in the U.S. to reflect these best practices.” The company has shared examples of some of the specifications or standards ECO products must meet that include reductions in certain chemicals of concern. However, the company has still not fully disclosed all of the third-party standards they meet. Partial credit is awarded.

The company also sells a large selection of VOC-free paints in the U.S. but has not taken action to thoroughly implement a program to feature and market these products online and sells 100 percent low-VOC paints in Canada (in compliance with Canadian regulations).

Lowe’s is active in the GC3 RLC and stated in its most recent sustainability report that to “manage chemicals in our products, we work with Health Canada and the Retail Leadership Council of the Green Chemistry & Commerce Council (GC3), where we collaborate with companies across multiple sectors to address chemicals of concern. In 2018, Lowe’s worked with the GC3 Retail Leadership Council to publish a list of green chemistry priorities and a transparency roadmap that drive progress in this important area.”