Trader Joe’s

According to its December 31, 2018 “Packaging Improvements” announcement, Trader Joe’s created a sustainability framework to help the company and its vendor partners “identify packaging improvement opportunities.” This framework is based in part on the principle of “avoiding the use of harmful substances in packaging.” In the context of that framework, the company states it: “identified for our vendors the substances that we want to avoid in our packaging, including: Bisphenol A (BPA) & Bisphenol S (BPS); Nonylphenol Ethoxylates (NPEs); Per- and Polyfluoroalkyl Substances (PFAS); Polystyrene (PS); Styrene; Phthalates.” Trader Joe’s posted an update to the packaging improvements announcement on July 15, 2019, and the only progress the company reported related to chemicals in its packaging was that it replaced “all Styrofoam trays in [its] fresh meat section with PET1 trays that are highly recyclable.” The company had also relayed this commitment, as it related to PFAS, for an article by Bloomberg in response to the Mind the Store/Toxic-Free Future report discussing the results of testing grocery store food packaging for likely treatment with PFAS, posted on December 11, 2018. We note the company is only asking its vendors to avoid these chemicals, not requiring that they are eliminated.

Seeing only the level of detail that is publicly available, this list of chemicals to avoid in packaging only amounts to a beyond restricted substance list (BRSL), rather than an official, public written safer chemicals policy, and we have awarded credit accordingly.

The statements provided in Trader Joe’s November 2017 announcement, as updated in May 2018, also do not amount to an official policy, as they are only related to actions on specific chemicals. This announcement states: “…when concerns related to the use of BPA were starting to build, we evaluated where and how it was being used within our operation and identified steps to take: changing the receipt-paper used at cash registers to a non-BPA version and working on canned products (eliminating BPA where we could in many products’ packaging and clarifying for customers which product packages still make use of BPA).” In a May 2018 update, the company adds: “We identified receipt paper that is free of phenol chemicals (including BPA and BPS), which we will be rolling out to all stores in the next couple months.” The company continued in its 2017 statement: “We continue to reevaluate our Health & Beauty and Household products, developing and introducing new formulas made without chemicals such as parabens.”

Trader Joe’s has not set public quantifiable goals for reducing and CHCs (as the company has not stated a deadline by which it wants the chemicals listed above out of its packaging) and does not have a publicly available manufacturing restricted substance list (MRSL).

Trader Joe’s has not assigned senior management to implement the company’s safer chemicals policy (because the company has no public written safer chemicals policy).

Trader Joe’s has not made any discernible effort to assess supplier conformance with safer chemicals policy or RSL (because Trader Joe’s has no public written safer chemicals policy). The “New Vendor Requirements” page and “New Vendor Form” available on the company’s website do not mention the chemicals Trader Joe’s says it asks vendors to avoid in packaging.

Trader Joe’s has not taken any discernible action on suppliers disclosing ingredients to the retailer, going beyond regulatory compliance.

In response to testing by Ecology Center, Trader Joe’s stated on May 3, 2018: “We identified receipt paper that is free of phenol chemicals (including BPA and BPS), which we will be rolling out to all stores in the next couple months.” The company first disclosed that it was “pursuing receipt paper that is free of phenol chemicals (including BPA and BPS)” in January 2018. The company has not disclosed any progress in this area since May 2018.

In its December 2018 “Packaging Improvements” announcement, Trader Joe’s states that it: “identified for our vendors the substances that we want to avoid in our packaging, including: Bisphenol A (BPA) & Bisphenol S (BPS); Nonylphenol Ethoxylates (NPEs); Per- and Polyfluoroalkyl Substances (PFAS); Polystyrene (PS); Styrene; Phthalates. In its packaging improvements update released on July 15, 2019, the company reported that it replaced “all Styrofoam trays in [its] fresh meat section with PET1 trays that are highly recyclable.” Trader Joe’s should confirm that these trays are free of all chemical additives of concern.

TJ’s specifies on its website which private-label product packaging does not contain BPA. As of the writing of this report card and according to the company’s website list, however, only one product (canned olives) was switched to BPA-free packaging since the last report card was published, so it is clear that Trader Joe’s packaging BRSL (announced in December 2018) has not yet been fully implemented.

The company also notes that certain private-label products are free of chemicals, such as parabens and phthalates, but does not explicitly state whether this represents a “reduction” in chemical use. Trader Joe’s has also not disclosed any progress on reducing the other chemicals on its BRSL.

In its December 31, 2018 “Packaging Improvements” announcement, Trader Joe’s stated that it developed a sustainability framework based in part on the principle of “Avoiding the use of harmful substances in packaging.” This implies the company wants to use safer alternatives instead, but the company does not explicitly state that it intends to replace the harmful substances it identified with safer chemicals, so we are awarding only partial credit.

TJ’s does not specify what they’ve moved to in place of BPA (or BPS) for some packaging (although the 2016 report “BPA Buyer Beware” found that out of the cans tested, Trader Joe’s alternative liners were mostly polyester resin and a few PVC co-polymer materials). Additionally, in its “Packaging Improvements UPDATE” from July 2019, Trader Joe’s notes that it has replaced “all Styrofoam trays in [its] fresh meat section with PET1 trays.” While PET1 is generally considered safer than polystyrene, Trader Joe’s should confirm that these trays are free of all chemical additives of concern.

In its November 27, 2017 announcement, Trader Joe’s states: “We continue to reevaluate our Health & Beauty and Household products, developing and introducing new formulas made without chemicals such as parabens.” However, the company does not explicitly state that it intends to replace chemicals “such as parabens” with safer alternatives. In this announcement, the company discusses the topic of safety but not safer alternatives: “While there are aspects of our product supply-chain beyond our direct control, we will never leave to chance the safety of the products we offer…We take action quickly, aggressively investigating potential problems and removing product from sale if there is any doubt about its safety or quality….We won’t sell unsafe products.” Overall, Trader Joe’s indicates it will only take action after the fact, and not before a product is put on shelves, to investigate its safety.

Trader Joe’s packaging BRSL is publicly available.

Trader Joe’s discloses which products have packaging that is BPA-free, in line with its policy on BPA in packaging as specified in the Product Information FAQ on that topic (in place before its December 2018 announcement). Trader Joe’s also disclosed that its fresh meat trays have been converted from Styrofoam to PET1 in its July 15, 2019 “Packaging Improvements UPDATE.” The company does not appear to further encourage or require suppliers to publicly disclose ingredients in products online or on product packaging.

Although the company stated in 2018 that “None of our products contain hidden ingredients; all are clearly labeled,” some of the ingredient lists for personal care products include a reference to “fragrance” despite the fact that fragrance can have many components, some of which are potentially toxic. Additionally, the company does not appear to require suppliers to publicly disclose impurities.

Trader Joe’s has not made any discernible progress on measuring its chemical footprint via the Chemical Footprint Project.

Trader Joe’s has not shown discernible progress on credible third-party safer chemicals standards going beyond regulatory compliance.

Trader Joe’s 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.

Trader Joe’s improved its chemicals management over the past year by announcing a list of chemicals that it is asking vendors to avoid in packaging, including key chemical classes phthalates and PFAS, although in general, there is no indication of how the company is enforcing this BRSL or whether there is a deadline for vendors to comply. In its “Packaging Improvements UPDATE” from July 2019, Trader Joe’s notes that it has replaced “all Styrofoam trays in [its] fresh meat section with PET1 trays,” and should ensure that the PET1 trays are free from all chemical additives of concern.

TJ’s has no discernible program to feature and market safer products on store shelves and/or website.

The company highlights which products have BPA-free packaging under Product FAQs on its website (and notes whether a product is free of parabens, for example, on individual product pages), but this doesn’t amount to a program.

There is no indication that the retailer actively participates in a collaborative process or retains an independent expert body to promote safer chemicals or that it has created an external advisory board to provide input on implementation of any safer chemicals policy.