Target

In 2017, Target announced a new 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 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.

The company’s safer chemicals policy does not appear to apply to packaging.

Target has multiple staff that oversee and implement its Safer Chemicals Policy. Target employees working to implement the chemicals policy set annual goals. Staff are incentivized to implement the policy through a variety of mechanisms.

In its most recent sustainability report, the company stated that “The Board of Directors has delegated oversight responsibility over Target’s corporate responsibility matters to the Nominating and Governance Committee of the Board of Directors.” In last year’s report, the company noted that “Target’s EVP and Chief CSR Officer presents to the Board annually on CSR-related topics. Additionally, new directors participate in an orientation program that includes discussions with senior management, background materials on the Corporation’s plans, organization and financial statements, including CSR strategy, priorities and progress.”

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 include the specific chemicals currently restricted in textiles, but surprisingly it does 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 around business-to-business disclosure and does not currently include requirements around third-party testing.

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

The company has, however, not specifically disclosed initiatives to audit suppliers or conduct its own testing to assure conformance with its chemicals policy.

One of the three pillars of Target’s new safer chemicals policy is transparency. 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 which 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

In 2018, for the first time the company publicly reported on progress in achieving business to business transparency for the relevant product categories. 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.”

Target uses the UL WERCSmart and PurView platforms for collecting and evaluating information about chemical ingredients in consumables and other formulated products. Suppliers used to be graded on transparency and disclosure practices through Target’s Sustainable Product Index (SPI) but the company has appeared to sunset this tool after it developed its broader chemicals policy.

In 2017, Target set ambitious new goals to reduce chemicals of high concern with clear timeframes, and pledged to annually report on progress in implementing its policy: “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.

Innovation is one of three core pillars of Target’s new safer chemicals policy. 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 chemicals of concern 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.”

Target’s safer chemicals policy is publicly available. 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 “Unwanted 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 posted a guidance document identifying those they were restricting. However, it does not address key flame retardants and PFAS chemicals of concern. Target has previously publicly disclosed its authoritative lists of High Priority Chemicals and Chemicals of Concern that can be utilized to identify the more than 1,400 chemicals with high level health concerns in its Sustainable Product Index. However, the company has sunset that list.

Transparency is one of Target’s three pillars in its new safer chemicals policy, which 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 solely focus on business-to-business transparency, not business-to-consumer transparency. In its new 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.”

Target previously had 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 appears to have been sunset as no new information about the SPI has been shared over the past few years.

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. Target has also developed “wellness icons” to promote products in stores that are free of chemicals of concern such as phthalates.

Target serves on the Chemical Footprint Project Steering Committee and is a signatory to the CFP. Target staff states that the company plans to participate in the upcoming CFP survey.

In 2018, Target unveiled its new Wellness Icons to make it easier for customers to identify and purchase more environmentally friendly products. One of the new icons is the “responsible” icon, which is for products that meet Safer Choice or Cradle to Cradle certification. However, another icon 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, unless it was instead based on a credible third-party safer chemicals standard.

Last year, Target announced that “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 chemicals of concern. 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 chemicals of high concern.

No discernible public commitment via joint announcement.

Target has continued to make improvements to implement and expand its policy in 2018, building off progress it has made over the past few years. In 2018 the company developed an RSL and MRSL for textiles (adopting the ZDHC MRSL), guidance to suppliers for disclosing ingredients in formulated products, 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.

The company noted, “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. In 2018, we will continue to work with vendors to try to obtain permission to screen products and better understand which products meet our goal, and which need to be reformulated.”

In last year’s sustainability report, the company committed to continue 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 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, unless it was instead based on a credible third party safer chemicals standard.

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.

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.”

Innovation is one of the three core pillars of Target’s new safer chemicals policy. 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.”

In its most recent sustainability report, the company shared: “in 2017, we made investments in one impact Venture Capital Fund focused on green chemistry and four NGOs for a total commitment of $802,440. All investments fall within our Green Chemistry Innovation focus areas of Awareness; Transparency Infrastructure; Hazard Profiles & Other Safety Data; and Safer Alternatives to Market. We plan to invest the total $5 million along a bell curve with lesser dollar amounts in 2017 and 2021, with the bulk of funding in 2018-2020.” The company released an RFP for 2018 grant making this past spring.