Office Depot

Policy:Adopted a retailer safer chemicals policy

10 out of 23.5 points

Office Depot issued a public written safer chemicals policy in 2019 that seeks to “phase out chemicals of concern.” The policy includes a beyond restricted substance list (BRSL) that was first published in early 2021 and restricts per- and polyfluoroalkyl substances (PFAS), most phthalates, and bisphenol A (BPA), and applies to the company’s operations and retail sales. The policy is applicable to both brand-name and private-label products and the company’s packaging in all locations where products are sold, although Office Depot notes it anticipates focusing efforts where it can have the most impact: in its private-label products. However, the retailer’s packaging policy restricts metals that are already restricted in at least 19 states and thus already rarely used. Therefore, we award partial credit. Additionally, since the operational restriction applies only to BPA, and not yet to other bisphenols, we recognize this with only partial credit. The retailer updated the policy in early 2021 and plans to expand the BRSL to include other bisphenols and add quats and other chemicals.

The retailer does not appear to have set specific public quantifiable goals for reducing and eliminating chemicals of high concern (CHCs) or plastics of environmental health concern (PEHCs), and does not have a publicly available manufacturing restricted substance list (MRSL) or beyond restricted material list (BRML) for plastics of environmental health concern (PEHCs).

Glossary of Terms

Oversight: Established management responsibilities and incentives

2.5 out of 5 points

Office Depot reported that it has a VP-level senior manager who oversees the environmental compliance and private-brand product groups and is responsible for the company’s safer chemicals policy.

Office Depot does not appear to offer financial incentives for senior management to implement its safer chemicals policy.

Glossary of Terms

Accountability: Ensures supply chain accountability

10 out of 15 points

Office Depot’s agreements for its private-label products require vendors to submit samples to third-party laboratories chosen by the retailer on a regular basis to assess compliance. Office Depot clarified that it tests each private-label product prior to introduction and it tests each product family again after introduction; this includes some testing beyond regulatory requirements. Office Depot states that it trains its suppliers in the policy and reporting requirements.

Glossary of Terms

Disclosure: Requires suppliers to report use of chemicals in products to retailer

6 out of 17.5 points

Office Depot requires its private label and brand name suppliers to submit product formulations to the WERCSmart system. The company screens this information against its beyond restricted substance list (BRSL). An extra credit point is awarded for this disclosure policy applying to multiple major product categories.

Glossary of Terms

Action: Reduced or eliminated chemicals of high concern (CHCs) or plastics of environmental health concern (PEHCs) within the last three years

3 out of 26 points

Office Depot noted that it successfully restricted chromium (VI) in leather products to below testing limits. While it has documented other aspects of its policy and work to make “most” of its private-label cleaning products aligned to a certification, the other accomplishments have not been quantified.

Office Depot has not publicly documented progress on reducing plastics of environmental health concern (PEHCs) beyond regulatory compliance in the last three years.

Glossary of Terms

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

2 out of 16 points

Office Depot provides its suppliers with a “recommendation” to substitute safer chemicals, but does not provide detailed guidance on how to evaluate alternatives.

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

7.5 out of 20 points

Office Depot’s safer chemicals policy and its beyond restricted substance list (BRSL) are publicly available.

Office Depot does not appear to encourage or require suppliers to publicly disclose ingredients in products online or on product packaging going beyond regulatory compliance.

Glossary of Terms

Third-party Standards: Promotes credible third-party standards for safer products

3 out of 8.5 points

Office Depot “recommends” that suppliers for its private-label products formulate with third-party recognized “safer chemicals standards,” including Safer Choice.

Glossary of Terms