Restaurant Brands International

Policy:Adopted a retailer safer chemicals policy

4.5 out of 23.5 points

RBI has no public written safer chemicals policy related to toxic indirect food additives and does not have a publicly available manufacturing restricted substance list (MRSL). The company receives partial credit for a company-wide beyond restricted materials list (BRML) for one plastic of environmental health concern, expanded polystyrene foam in food packaging, and for setting a goal to restrict this by 2021. RBI has not set public quantifiable goals for reducing and eliminating other chemicals of high concern (CHCs).

RBI has posted the following statement on its website: “As part of our commitment to safe ingredients, our product specifications require that all approved plastic toys and promotional drink wear not contain bisphenol A (“BPAs”), and prohibit the use of perfluorooctanoic acid (“PFOAs”) within our approved paper and packaging products.” The prohibition on PFOA does not go beyond regulatory compliance, as FDA already bans this chemical from food packaging. RBI staff clarified in September 2019 that the policy on BPA “covers Plastics or rubbers in toys intended for use by children under 36 months OR in toys intended to be placed in the mouth, as well as all plastics in items intended for food-contact.” RBI receives partial credit of 0.75 for a beyond restricted substances list (BRSL) of just one chemical, BPA, applying to a minor packaging category of plastics in items intended for food-contact.

RBI separately noted to us that it holds all toys (only Burger King offers toys out of the three RBI brands) to “the strictest global requirements” for not just BPA, but also 15 phthalates and around 25 additional chemicals of high concern (CHCs). This effort functions as a BRSL, in the countries that have a less strict standard compared with the strictest global regulation, for a minor product category of toys. RBI receives partial credit for this.

According to an article in WIRED, in response to the FDA’s announced phase-out of PFAS in food packaging, an RBI spokesperson noted: “We are looking forward to extending our safe ingredients policy to include the removal of the short-term PFAS recently identified by the FDA. We will work with our suppliers to remove them from all packaging by or, where feasible, earlier than the three years recommended by the FDA.” Credit is not awarded because RBI’s statement does not address the entire class of PFAS.

Glossary of Terms

Accountability: Ensures supply chain accountability

1.25 out of 15 points

The company states that “Burger King Global Premium Toy Programs sold or distributed by Burger King Corporation throughout the world … are subjected to a rigorous safety and quality assurance program. As part of this program, we perform Phthalate and BPA content analyses and can ensure the most stringent global regulatory limits and requirements are met.” RBI also noted separately that the company tests toys for the presence of around 25 additional chemicals to ensure compliance to the strictest global requirements in all locations (i.e., beyond regulatory compliance in some locations).

Since the testing is partly to ensure regulatory compliance, RBI is awarded partial credit for conducting routine testing.

RBI has not specifically disclosed that it incorporates its BRSLs or partial BRML in supplier contracts, that it trains suppliers on the company’s BRSLs or partial BRML, or that it requires suppliers to conduct testing in third-party laboratories and provide results to the retailer to ensure suppliers comply with its BRSLs or partial BRML.

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

2.5 out of 20 points

RBI received partial credit for publicly disclosing its policy to phase out expanded polystyrene foam in all guest packaging by 2021. RBI also receives partial credit for publicly disclosing some information about its BRSL by posting the following statement on its website: “As part of our commitment to safe ingredients, our product specifications require that all approved plastic toys and promotional drink wear not contain bisphenol A (‘BPAs’)” RBI noted to us in October 2019 that it also restricts 15 phthalates and around 25 additional CHCs only in toys, but this information is not disclosed on the company’s website.

RBI does not appear to encourage or require suppliers to publicly disclose all indirect food additives in food contact materials going beyond regulatory compliance.

Glossary of Terms