Target

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.

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.

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.

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.”

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.

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.

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.

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.

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