Trader Joe’s

Policy:Adopted a retailer safer chemicals policy

7 out of 23.5 points

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” based in part on avoiding 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 revised its 2018 Packaging Improvements announcement language on January 1, 2020 to clarify that it wants to “eliminate and/or avoid” these substances in its packaging. However, in its December 31, 2020 post entitled “Sustainability,” the company reverted to characterizing its framework as only “avoiding” the harmful substances in packaging. This amounts to a beyond restricted substance list (BRSL) for its packaging (for BPA/BPS, NPEs, PFAS, styrene, and phthalates), and a beyond restricted material list (BRML) for plastics of environmental health concern (PEHCs) (i.e. polystyrene) with respect to its packaging. It also appears that Trader Joe’s is tackling all polystyrene in products from a Recycling and Composting FAQ, as opposed to just limiting itself to foam/expanded polystyrene (sometimes labeled “Styrofoam”), since the FAQ states, “We are in the process of removing Styrofoam and Polystyrene from all of our products.” We are providing full credit for a BRML of addressing two PEHCs, since we consider expanded polystyrene and non-expanded polystyrene to be separate PEHCs.

The company also notes in the transcript of an Inside Trader Joe’s podcast dated March 2, 2020 that, “Moving forward, Trader Joe’s sunscreens will no longer have oxybenzone in them.” In a post entitled “The TJ’s Glow-Up: Nighttime Skincare with Trader Joe’s” from March 4, 2020, the company notes that “[m]any of our private-label products are comparable to what you’d find at a high-end beauty boutique…[p]lus, they’re all paraben & sulfate-free….” This statement appears to be limited to skincare products. Partial credit of 2 points is awarded for this limited BRSL for the company’s own-brand sunscreen portfolio (restricting oxybenzone in a major category) and skincare products (restricting parabens and sulfate in a category that is minor for Trader Joe’s).

In January 2018, Trader Joe’s announced it would be moving to phenol-free receipt paper and in May of 2018, the company further reported that it would be rolling out non-phenol receipt paper in the next few months. However, the company never confirmed that the rollout was completed and the company has taken down the announcements where this was reported.

In addition to not having an official public written safer chemicals policy, Trader Joe’s has not set public quantifiable goals for reducing and eliminating CHCs or PEHCs (as the company has not stated a deadline by which it wants the chemicals or materials listed above out of its packaging), does not have appear to have a current publicly available BRSL for at least one major aspect of operations, and does not have a publicly available manufacturing restricted substance list (MRSL). It is unclear if the company’s policy applies to beauty products of environmental justice concern (BPEJC). As Trader Joe’s seeks to use more recycled plastics such as for packaging, the company should explicitly apply its BRSL to recycled plastics and key additives that may be present in recycled plastics.

Glossary of Terms

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

8 out of 26 points

The company notes in the transcript of an Inside Trader Joe’s podcast dated March 2020 that “Moving forward, Trader Joe’s sunscreens will no longer have oxybenzone in them.” The implication is that this chemical of high concern (CHC) was removed from sunscreen since November 2017.

As noted above, the company mentioned in a Recycling and Composting FAQ that “[w]e are in the process of removing Styrofoam and Polystyrene from all of our products.” Trader Joe’s reported more specifically in its July 2019 “Packaging Improvements UPDATE” that it has replaced: “all Styrofoam trays in our fresh meat section with PET1 trays that are highly recyclable” and in its December 2018 Packaging Improvements announcement that it “eliminated any remaining Styrofoam packages in our produce section and replaced them with bio-based, compostable trays.” The company noted in a February 2019 podcast that the compostable produce tray “is made from renewable sources, plant based.” Trader Joe’s should confirm that both types of alternative trays are free of all chemical additives of concern, especially PFAS for the compostable plant-based tray.

The company receives credit for eliminating one CHC in a major product category and partial extra credit for also eliminating since November 2017 one plastic of environmental health concern (PEHC), polystyrene foam, from its meat and produce trays. These trays collectively amount to one major packaging category. The company also receives partial extra credit for reporting details on its substitute for the meat trays, PET.

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 some canned sardine packaging (i.e., aside from certain boneless-skinless sardine packaging that appeared to have already been in BPA-free packaging) was switched to BPA-free packaging since 2019. So, it is clear that Trader Joe’s packaging BRSL (originally announced in December 2018) has not yet been fully implemented.

In response to testing by Ecology Center, Trader Joe’s stated in May 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, and has since taken down the information posted about receipts and BPA/BPS from its website.

Glossary of Terms

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

1 out of 16 points

In its December 31, 2018 “Packaging Improvements” announcement, and reiterated in its January 1, 2020 “2019 Sustainability Progress” 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. The company also noted in the transcript for a March 2, 2020 podcast, “In terms of household cleaners … [o]bviously the number one goal here is to make sure that the product is safe for use,” but the company does not describe how it evaluates alternatives for the chemicals it doesn’t allow in these types of products. Therefore, we are awarding only partial credit.

TJ’s does not specify what they’ve moved to in place of BPA 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 replaced “all Styrofoam trays in [its] fresh meat section with PET1 trays” and in its December 31, 2018 Packaging Improvements announcement that it “eliminated any remaining Styrofoam packages in our produce section and replaced them with bio-based, compostable trays.” The company noted in a February 4, 2019 podcast that the compostable produce tray “is made from renewable sources, plant based.” Trader Joe’s should confirm that both types of alternative trays are free of all chemical additives of concern, especially PFAS for the compostable plant-based tray.

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

6.5 out of 20 points

Trader Joe’s packaging BRSL, partial product BRSL, and BRML are publicly available.

As stated in the transcript for Trader Joe’s March 2, 2020 podcast entitled “Trader Joe’s Beauty Routine is Pretty…:”
“Matt: We want to provide information to customers, we want to help customers make decisions that work for them, for their family and friends. So at this point, does that mean that for health and beauty products, household products, that whatever is in there is listed on the label? Jamie: Yes. Matt: You might have to go to a dictionary or some sort of plant guide to get the Latin name figured out, but it is there.” Because “whatever is in there” is vague and the company does not explicitly state that this ingredient disclosure is required, we are awarding 1.5 points for this statement.

Glossary of Terms