Restaurant Brands International (RBI), including subsidiaries Tim Hortons, Burger King, and Popeyes, is still failing to publicly address key toxic indirect food additives that may be in food contact materials. With a letter grade of F and a score of 7.75 points out of 146.5, it ranked 34th out of the 43 retailers evaluated this year.
While RBI has no significant public-facing commitments to address the safety of indirect food additives that can be in food contact materials, the company does receive credit for restricting BPA in children’s plastic toys and promotional cups, for having a multi-chemical BRSL (including 15 phthalates) for toys, and for testing to ensure compliance with the most stringent global regulation in all locations. However, recent testing has found that a tested PVC glove from a Burger King restaurant location contained ortho-phthalates.
Opportunities for improvement: RBI can make progress by developing a public written safer chemicals policy for toxic indirect food additives in food contact materials, addressing at least bisphenols (beyond BPA), per- and polyfluoroalkyl substances (PFAS) and additional phthalates, setting quantifiable goals with clear timelines, and eliminating and safely replacing any toxic indirect food additives that may be in food contact materials. RBI should also become a signatory to the Chemical Footprint Project and pilot it with key private label suppliers.
Summary of Restaurant Brands International’s Grade

1.25 out of 17.5 points
Policy: Adopted a retailer safer chemicals policy
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 beyond restricted substance list (BRSL) in the countries that have a less strict standard compared with the strictest global regulation.
RBI has no public written safer chemicals policy related to toxic indirect food additives (since the statement on its website is too limited to amount to a policy), has not set public quantifiable goals for reducing and eliminating these CHCs, and does not have a publicly available manufacturing restricted substance list (MRSL).

0 out of 5 points
Oversight: Established management responsibilities and incentives

2.5 out of 12.5 points
Accountability: Ensures supply chain accountability
Although the testing is partly to ensure regulatory compliance, since RBI states that it holds all Burger King toys to the highest global limit, we are awarding full credit for RBI conducting routine testing.
RBI 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.

0 out of 13 points
Disclosure: Requires suppliers to report use of chemicals in products to retailer

3 out of 16 points
Action: Reduced or eliminated chemicals of high concern (CHCs) within the last three years

0 out of 13.5 points
Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

1 out of 18 points
Transparency: Demonstrates a commitment to transparency and public disclosure
RBI does not appear to encourage or require suppliers to publicly disclose all indirect food additives in food contact materials and does not itself publicly disclose the identity of food contact materials that are free of CHCs that are indirect food additives going beyond regulatory compliance.

0 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
Extra Credit:

0 out of 5 points
Joint Announcement: Public commitment demonstrated through joint announcement

0 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