Ranking retailers on toxic chemicals

Ranking retailers on toxic chemicals

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Target

A
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Target earned a letter grade of A, the same letter grade that it achieved in 2018. The company scored 102.5 out of 146.5 possible points, ranking 2nd out of the 43 retailers evaluated this year.

Target has continued to implement its chemicals policy in 2019, building on progress it has made over the past few years. In 2019, it launched a new wellness icon, “Clean,” to market and feature products free of key chemicals of high concern (CHCs). The company also launched a new line of household products free of CHCs, such as phthalates, though these products do not fully disclose their fragrance ingredients. The company recently disclosed progress in getting more suppliers to disclose ingredients to Target, and in fall 2019, released new guidance for suppliers in evaluating alternatives to chemicals of concern.

In 2018, the company developed a BRSL and MRSL for textiles (adopting the ZDHC MRSL) and guidance to suppliers for disclosing ingredients in formulated products, publicly disclosed the identity of chemicals that it was restricting in beauty and personal care products by CAS #, publicly reported on progress in removing chemicals of concern from beauty and personal care products, launched a new wellness icons program to make it easier for customers to identify products free of certain chemicals of concern, and funded and co-sponsored the Green Chemistry & Commerce Council’s (GC3) Preservatives Challenge to drive innovation in the preservatives category.

In 2017, Target first announced an impressive new safer chemicals policy along with ambitious goals to increase transparency of chemicals in products; reduce and eliminate classes of harmful chemicals in textiles, beauty, baby care, personal care, and household cleaning products; and invest in green chemistry research into safer alternatives. The policy applies to the company’s “entire value chain, operations and every product” it sells, including both private-label and brand-name products. The policy includes clear goals and timeframes for reducing harmful chemicals, and the company has committed to expanding the policy to address other product categories and chemicals in manufacturing over time.

Last year, Target became a signatory to the Chemical Footprint Project (CFP) and more recently participated in the 2019 CFP survey.

Opportunities for improvement: Target can continue to improve its safer chemicals program by expanding the list of flame retardants and PFAS chemicals restricted in textiles, expanding the scope of textiles to include foam and infant/children’s car seats, and expanding the list of chemicals it is targeting for elimination in textiles and formulated household goods. As one of the largest grocery chains in America, Target should eliminate and safely replace any toxic indirect food additives that may be in food contact materials, with special attention paid to any bisphenols and per- and polyfluoroalkyl substances (PFAS) that may be 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. Over time, the company should also expand its policy to address other chemically intensive product categories such as electronics, baby, and children’s products/toys.

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Summary of Target’s Grade

13.75 out of 17.5 points

Policy: Adopted a retailer safer chemicals policy

Explanation of Points

In 2017, Target announced a chemicals strategy, policy, and goals, which state the company is “committed to driving transparency, proactive chemical management and innovation across all of [its] owned and national brand consumer products, and operations.” The policy applies to the company’s “entire value chain, operations and every product” it sells, including both private-label and brand-name products. The company states it: “will utilize hazard profiles to prioritize substances for restriction in products and processes, with an emphasis on the impact these substances could have on workers, guests, and communities…Target will utilize Restricted Substances Lists (RSLs) and Manufacturing Restricted Substances Lists (MRSLs) to minimize and, where possible, remove these prioritized chemicals from [its] products and processes.” The policy is accompanied by clear goals and timelines for reducing perfluorinated chemicals (but not all PFAS) and flame retardants in textiles, as well as parabens, formaldehyde-donors and nonylphenol ethoxylates (NPEs) in beauty, baby care, personal care, and household cleaning products.

While the policy applies to the company’s operations, only partial credit is awarded since the company has not yet disclosed how it is addressing CHCs 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.

The policy does not appear to apply to packaging.

5 out of 5 points

Oversight: Established management responsibilities and incentives

Explanation of Points

Target has multiple staff members that oversee and implement its Safer Chemicals Policy. Target employees working to implement the chemicals policy set annual goals. The company provided information demonstrating leaders are incentivized to implement the policy through financial incentives and mechanisms.

7.5 out of 12.5 points

Accountability: Ensures supply chain accountability

Explanation of Points

In 2018, Target published guidance for suppliers to comply with the chemicals policy for textiles, cleaning, baby, beauty, and personal care products. For textiles, the company notes in a guidance document that “the following table outlines the restricted chemicals, their limits as well as the required test methods. In order to be in compliance with Target’s RSL requirements, restricted substances must not exceed the RSL limits.” The tables provided include the specific chemicals currently restricted in textiles, but surprisingly, they do not currently include key flame retardants and all PFAS chemicals commonly used in textiles. Additionally, the scope of the guidance for furniture is limited to fabric, while flame retardants are commonly found in the foam, and it does not address infant/children’s car seats.

The company also stated: “We have and will continue to provide our vendors guidance on our RSL, MRSL and chemical management via our on-line supplier platform.” The guidance for formulated products in cleaning, baby, beauty, and personal care is primarily focused on business-to-business disclosure and does not currently include requirements around third-party testing. In 2019, it stated: “We delineate supplier expectations both publicly via our website as well as in their contracts. The Partners Online (POL) platform in itself serves as the contractual obligationst [sic] that suppliers must meet in order to do business with Target. All of our chemical policy goals and requirements are listed on POL and considered part of the supplier contracts.” Target went on to note: “We conducted vendor training on the RSL in 2018 and will also be planning vendor training in the end of 2019 for a variety of sustainability objectives, including chemicals and MRSL. ”

The company also requires third-party testing for private-label products that meet credible third-party safer chemicals standards such as Oeko-Tex.

Target has not specifically disclosed that it conducts its own testing to ensure suppliers comply with its safer chemicals policy.

7.5 out of 13 points

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

Explanation of Points

The company states: “Target will strive for full visibility to chemicals contained in and used to make the products we sell and use in our operations. Target will work toward the long-term goal of full material disclosure for all products and processes across all categories and in our operations. Target will approach transparency in the supply chain as an iterative process, continually adding more product categories and achieving increasing levels of transparency.” Along with the policy, in 2017, the company set a new goal to “achieve transparency to all ingredients, including generics such as ‘fragrance’, in beauty, baby care, personal care and household cleaning formulated products by 2020.”

In 2018, the company provided new specific guidance to suppliers on complying with this disclosure policy, which applies to all intentionally added ingredients, including fragrance ingredients, but does not include substances that may migrate from packaging or other unknown sources of contamination. The company set a deadline of December 31, 2018 for suppliers to grant permission via the WERCS for this data to be disclosed to Target. This guidance document is available online at https://corporate.target.com/_media/TargetCorp/csr/pdf/Target-Chemical-Policy_Formulated-Implementation-Guide.pdf. It is unclear what percentage of suppliers have complied with this deadline.

Target is being awarded an extra credit point for setting these deadlines.

In 2018, for the first time, the company publicly reported on progress in achieving transparency for the relevant product categories. The staff shared: “We have full transparency for 15 percent of items in beauty, baby care, personal care and household cleaning formulated products. We do not have full transparency to 23 percent of our products and do not have permission to screen 62 percent of our products.”

In September 2019, the company disclosed additional progress: “We have access to screen 76 percent of our in-scope assortment, and we know from that screening that at least 22 percent meet our transparency goal and at least 44 percent meet our chemical management goal as of 2018. That is up from at least 6 percent meeting the transparency goal and at least 7 percent meeting the chemical management goal in 2017.”

The company is also working on transparency for a new private-label line of goods, stating in September 2019: “With the launch of our Smartly brand of essentials and personal care products in October 2018, we are working toward our ambitious transparency and chemical management requirements. Smartly was made possible through our team’s engagement and collaboration with select fragrance houses. We were able to develop a process that allows screening of ingredients without revealing the intellectual property behind formulations, something that has been a roadblock to full transparency in the industry until now. We are evolving the full line of Smartly products to meet our requirements by the end of 2020.”

Target uses the UL WERCSmart and PurView platforms for collecting and evaluating information about chemical ingredients in consumables and other formulated products.

15 out of 16 points

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

Explanation of Points

In 2017, Target set ambitious new goals to reduce chemicals of high concern with clear timeframes and pledged to report on progress in implementing its policy annually, stating: “We’ll monitor our progress, starting February 2017, and report on it each year in our Corporate Social Responsibility Report.”

In its 2018 sustainability report, for the first time, the company publicly reported on metrics in implementing its chemicals policy, particularly for beauty, baby care, personal care, and household cleaning products. The company shared: “18 percent of items in beauty, baby care, personal care and household cleaning product categories are formulated without phthalates, propyl-paraben, butyl-paraben, formaldehyde, formaldehyde-donors or NPEs. We do not have 20 percent of our products formulated without these chemicals and do not have permission to screen 62 percent of our products.” For textiles, the company noted that it is still establishing the baseline for which textiles contain flame retardants and PFAS chemicals, but the current guidance document does not adequately address all flame retardants and PFAS chemicals of concern.

In September 2019, the company disclosed additional progress, stating: “We have access to screen 76 percent of our in-scope assortment, and we know from that screening that at least 22 percent meet our transparency goal and at least 44 percent meet our chemical management goal as of 2018. That is up from at least 6 percent meeting the transparency goal and at least 7 percent meeting the chemical management goal in 2017.”

The company recently stated that it is working to promote alternatives to flame retardants from children’s sleepwear. It stated in its most recent sustainability report that: “In March 2019, Target hosted a hackathon to bring the industry together to spark innovation on the removal of undesirable flame retardant chemicals from children’s loose-fit sleepwear. Together with brands, other industry partners and students, innovative proposals were developed that would meet regulatory requirements (e.g., flammability), guest preferences and sustainability goals. Target provided a stipend to the winning team and is working with the team to test the viability of its idea.”

The company stated in its recent sustainability report that it has launched “Everspring, a new household essentials owned brand, which combines efficacy, transparency and great design…The entire assortment of formulated products complies with Target Clean and was built on the foundation of our chemicals policy.”

8.5 out of 13.5 points

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

Explanation of Points

The company states: “Target will actively pursue and promote new approaches to chemicals development and the commercialization of safer alternatives. Target will contribute resources and expertise to initiatives working to develop safe alternatives for chemicals where no viable alternatives currently exist. Target will support innovation which utilizes green chemistry principles in the development, design, and manufacturing of consumer products.” The company has also noted, when eliminating CHCs, that: “Target will actively pursue the development of safer alternatives to achieve our goals. We will work to remove chemicals or find alternatives to those chemicals that could pose a risk to our guests, workers and community. When changes are made, we will ensure the integrity and safety of our products.”

In 2019, the company shared this notable update: “We are currently developing detailed guidance on safer alternatives which will articulate our preference as well as serve as a guide to suppliers.” The company has published this guidance on its vendor platform. It includes helpful tools such as the OECD Substitution and Alternatives Assessment Toolbox, BizNGO’s Chemical Alternatives Assessment Protocol, and the Lowell Center for Sustainable Production’s Alternatives Assessment Framework.

9 out of 18 points

Transparency: Demonstrates a commitment to transparency and public disclosure

Explanation of Points

Target’s safer chemicals policy is publicly available, and it has posted BRSLs for the relevant product categories. Target has publicly disclosed that it restricts phthalates, propyl-paraben, butyl-paraben, formaldehyde, formaldehyde-donors, and NPE’s in beauty, baby care, personal care, and household cleaning products. In 2018, Target published a spreadsheet of the chemicals it is targeting for reduction and elimination in these product categories with the specific names of chemicals in each class with CAS numbers.

The company has also disclosed that it is restricting perfluorinated chemicals (PFCs) and “added flame retardants that are potential carcinogens in textiles” and subsequently posted a guidance document identifying those the company was restricting. The ZDHC MRSL that Target utilizes is publicly available.

Target states: “Target will strive for full visibility to chemicals contained in and used to make the products we sell and use in our operations. Target will work toward the long-term goal of full material disclosure for all products and processes across all categories and in our operations. Target will approach transparency in the supply chain as an iterative process, continually adding more product categories and achieving increasing levels of transparency.” Along with the policy, in 2017, the company set a new goal to “achieve transparency to all ingredients, including generics such as ‘fragrance’, in beauty, baby care, personal care and household cleaning formulated products by 2020.”

This, however, appears to focus solely on business-to-business transparency, not business-to-consumer transparency. In its guidance document for suppliers of household formulated products, such as cleaning products and personal care products, the company states that it will not “publish product-level details (unless granted via additional Data Use Tiers).”

In 2019, the company shared this notable update: “We are in the process of updating our transparency guidance and expectations to include stated preference for full business-to-consumer transparency. It should be available via our public site by the end of September.” It states, “We encourage all supply chain partners to find paths allowing full material disclosure to consumers, and support those who are actively going above and beyond the current transparency regulations. View our three-page vendor guidance on meeting our current ingredient and transparency expectations, which represent a step-wise approach to the full consumer disclosure we ultimately seek.”

In 2019, Target launched a new line of eco-friendly products, Ever Spring, which do not include key CHCs, such as phthalates. Unfortunately, however, these products do not fully disclose their ingredients, as generic terms such as “fragrance” are still utilized on ingredient lists.

Target previously encouraged suppliers to publicly disclose ingredients on packaging and their websites, including nanomaterials, fragrance, allergens, and other generic ingredients, through its Sustainable Product Index (SPI), but that program has been sunset.

However, Target does provide filters under “Health Information” on its Beauty product pages, for example, that indicate which products are free of formaldehyde, formaldehyde donors, nonylphenol ethoxylate, parabens (as well as butylparaben & propylparaben), and phthalates. The company also highlights products that are free of these chemicals through its Wellness Icons program.

6 out of 7.5 points

Chemical Footprint: Evaluates its chemical footprint

Explanation of Points

Target is a signatory to the Chemical Footprint Project (CFP) and participated in the 2019 CFP survey.

5.25 out of 8.5 points

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

Explanation of Points

In 2017, Target announced: “aligning with this strategy to remove unwanted chemicals from our supply chain, all of our Target owned-brand towels are now Oeko-Tex certified, a global testing and certification system for textile products at all processing levels.” In 2017, Target also announced a new baby brand, Cloud Island, a line of nearly 500 products that meets the Oeko-Tex Standard 100, which restricts more than 300 CHCs. Target has also reformulated most of its Up & Up liquid hand soap products to meet the EPA Safer Choice criteria, and Target’s Cat & Jack organic pajamas meet the Global Organic Textile Standard (GOTS), which prohibits numerous CHCs.

Extra Credit:

0 out of 5 points

Joint Announcement: Public commitment demonstrated through joint announcement

Explanation of Points

Target has not made a discernible public commitment through a joint announcement or other coordination effort in advance of a major announcement within the time periods specified in the scoring rubric.

10 out of 15 points

Continuous Improvement: Shows continuous improvement by steadily expanding safer chemicals policy

Explanation of Points

In 2019, Target has continued to make improvements to implement and expand its policy, building off progress it has made over the past few years. The company launched a new Clean icon program to make it easier for consumers to identify and shop for safer products free of key CHCs in multiple product categories. This year, the company also released new guidance for suppliers in evaluating alternatives when removing CHCs and held a “hackathon” to identify alternatives to using toxic flame retardants in children’s pajamas.

The company has made progress in getting suppliers to disclose ingredients in products to itself. In September 2019, the company stated “for formulated categories, over the course of 2018, we doubled the number of products for which we can report data. We have access to screen 76 percent of our in-scope assortment, and we know from that screening that at least 22 percent meet our transparency goal and at least 44 percent meet our chemical management goal as of 2018. That is up from at least 6 percent meeting the transparency goal and at least 7 percent meeting the chemical management goal in 2017.”

In last year’s sustainability report, the company committed to expand the scope of its policy: “As we move forward, we will continue to iterate, update and set new goals as needed, expanding the categories we cover and chemicals addressed.” In September 2019, the company stated it still plans to expand its policy to other product categories that it plans to announce by the end of 2019.

In 2018, the company developed a BRSL and MRSL for textiles (adopting the Zero Discharge of Hazardous Chemicals MRSL), guidance to suppliers for disclosing ingredients in formulated products, publicly reported on progress in removing CHCs from beauty and personal care products, launched a new Wellness Icons program to make it easier for customers to identify products free of certain CHCs, and funded and co-sponsored the Green Chemistry & Commerce Council’s (GC3) Preservatives Challenge to drive innovation in the preservatives category.

5 out of 5 points

Safer Products: Program to promote safer products in stores and/or on website

Explanation of Points

In 2018, Target launched new Wellness icons. The company stated it is “a way to enhance our guests’ ability to make informed purchasing decisions. We have carefully curated our wellness products to try to make them better for our guests, their families and the planet through the minimum requirements of our Wellness Product Standards. If a product meets minimum requirements, the item is eligible to receive icons that highlight information we know is important to our guests, so they can more easily find the type of item they are searching for in our stores and on Target.com.”

To meet the criteria for the Essentials and Beauty category, the company states a product must meet the following criteria at a minimum: “formulated without the following unwanted chemicals: propyl-paraben, butyl-paraben, phthalates, formaldehyde, formaldehyde-donors or nonylphenol ethoxylates (NPEs). To understand the formulation and the chemicals therein, we also expect full ingredient transparency from our vendors of these products for screening purposes. This means that generic ingredients, like fragrance, must either be natural or have sub-ingredients listed.” Examples of icons include “phthalate free”, “paraben free”, “responsible” (citing 3rd party standards such as Safer Choice), and “no added fragrance.” However, one of the icons Target has developed is “non toxic,” which is for a product that “makes an unqualified on-pack non-toxic statement (the statement cannot be limited to humans or environment).” This could be misleading to Target customers, since it does not appear to be based on a credible third-party safer chemicals standard. Unfortunately, the company continues to use this potentially misleading icon in 2019.

More recently, in 2019, the company launched new “Clean” icons that Target stated started appearing: “on Target.com product pages in March and in stores in April. It’ll be featured in Household Essentials, Beauty and Personal Care and Baby and will identify products formulated without specific chemicals which vary based on the product category. For example, in cleaning products, Target Clean means the product’s formulated without phthalates, sodium laureth sulfate, propyl-paraben and butyl-paraben.” The company states customers “can find over 3000 Target Clean-designated products in Target stores nationwide in sections of your store with the Clean banner, or looking for the Clean icon next to the price tag for each product on the shelf. You can also search online for Clean products at www.Target.com/targetclean.” This new icon will make it easier for customers to identify products free of key chemicals of concern.

This program builds off of and essentially replaces Target’s Made to Matter program that was created in 2014 to promote and feature products online and on store shelves with key sustainability improvements.

In 2019, Target also launched a line of private-brand household products, Ever Spring, which are free of key chemicals of concern such as phthalates and meet the new “Clean” criteria. Unfortunately, however, these products do not fully disclose their ingredients, as generic terms such as “fragrance” are still utilized on ingredient lists.

5 out of 5 points

Collaboration: Actively participates in collaborative process to promote safer chemicals

Explanation of Points

Target is active in the Beauty and Personal Care Products Sustainability Project (BPC) and the Green Chemistry & Commerce Council’s (GC3) Retailer Leadership Council (RLC). In announcing its safer chemicals policy, the company stated: “Ultimately, we want to bring all stakeholders together to innovate and champion a consistent, industry-wide approach to greener chemistry.” The company noted on its website that “our work during the GC3 Preservatives Challenge to drive innovation in the preservatives category, has helped to advance greener chemistry in beauty and personal care products.”

Target has not yet disclosed how it plans to utilize the BPC criteria, which it helped develop.

5 out of 5 points

Impact Investment: Investing financial resources into independent research into safer alternatives and/or green chemistry solutions

Explanation of Points

The company states: “Target will actively pursue and promote new approaches to chemicals development and the commercialization of safer alternatives. Target will contribute resources and expertise to initiatives working to develop safe alternatives for chemicals where no viable alternatives currently exist. Target will support innovation which utilizes green chemistry principles in the development, design, and manufacturing of consumer products.” The company committed to “invest up to $5 million in green chemistry innovation by 2022.” In its most recent sustainability report, the company states: “we are co-sponsoring the GC3 Preservatives Challenge to support more sustainable solutions for preservatives in beauty and personal care products. We also made several investments in 2016 with organizations like Healthy Babies Bright Futures, Advancing Green Chemistry and Beyond Benign to further education and awareness of these issues.” Since then, Safer Made announced: “Target is making an investment in Safer Made, as a way to support safer chemistry innovation.” Target has published information about its grant recipients, which is available at https://corporate.target.com/_media/TargetCorp/csr/pdf/2018_Target-Green-Chemistry-and-Safer-Alternatives-RFP_Grant-Recipients.pdf.

In September 2019, the company stated: “Since 2017, we awarded nearly $2.5 million in green chemistry grants to nine organizations, putting us well on our way to our $5 million investment by 2022 goal. The grantees’ work will focus on four key areas: awareness, transparency, chemical assessment and safer alternatives.”

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Grade
A
Points
102.5
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Summary of Target’s Grade
2019 A
2018 A
2017 B+
2016 B

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