Trader Joe’s earned a letter grade of D-, which reflects an improvement from its F grade in 2018. The company scored 18 out of 146.5 possible points, ranking 29th out of the 43 retailers evaluated this year.
In early December 2018, the company made a public commitment on per- and polyfluoroalkyl substances (PFAS) in food packaging. It followed up later that month with a list of additional chemicals it is asking vendors to avoid in its packaging, amounting to a beyond restricted substance list (BRSL). The additional chemicals are: bisphenol A (BPA) & bisphenol S (BPS); nonylphenol ethoxylates (NPEs); polystyrene (PS); styrene; and phthalates. The only progress that Trader Joe’s has reported related to these chemicals since the December 2018 announcement was in July 2019, when the company stated that it replaced all styrofoam fresh meat trays with PET1 trays. While PET1 is generally considered safer than polystyrene, the company has not confirmed that these trays are free of all chemical additives of concern. The company also stated that it developed a sustainability framework based in part on “[a]voiding the use of harmful substances in packaging.”
Previously, in an online announcement dated November 27, 2017, the company explained its actions on BPA in receipt paper and can linings and noted an ongoing effort to reformulate Health & Beauty and Household products without certain chemicals. However, these statements are too limited to amount to an official safer chemicals policy. In January 2018, Trader Joe’s announced it would be moving to phenol-free receipt paper, and, in May of 2018, the company updated the November 2017 statement to notify the public that it would be rolling out non-phenol receipt paper in the next few months, but it has not reported on progress in this area since then.
Opportunities for improvement: Trader Joe’s can make progress by developing a comprehensive public written safer chemicals policy, developing and enforcing a public BRSL that applies to products (e.g., personal care) in addition to packaging, and setting public quantifiable goals with clear timelines for reducing and eliminating chemicals of high concern (CHCs). In particular, we urge the company to strengthen its BRSL and act on it swiftly to eliminate and safely replace toxic indirect food additives in food contact materials, with special attention paid to ALL bisphenols and PFAS that may be in food packaging (especially as Trader Joe’s moves to more compostable packaging, which studies show may contain PFAS) and other food contact materials as well as any phthalates that may be in food and food contact materials in its supply chain. The company should also confirm its progress on replacing phenol receipt paper with a safer substitute and confirm that the PET1 fresh meat trays are free from a broader list of chemical additives of concern than its packaging BRSL. Trader Joe’s should also become a signatory to the Chemical Footprint Project and pilot it with key private label suppliers.
Summary of Trader Joe’s Grade
2.5 out of 17.5 points
Policy: Adopted a retailer safer chemicals policy
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).
0 out of 5 points
Oversight: Established management responsibilities and incentives
0 out of 12.5 points
Accountability: Ensures supply chain accountability
0 out of 13 points
Disclosure: Requires suppliers to report use of chemicals in products to retailer
3 out of 16 points
Action: Reduced or eliminated chemicals of high concern (CHCs) within the last three years
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.
1 out of 13.5 points
Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes
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.
6.5 out of 18 points
Transparency: Demonstrates a commitment to transparency and public disclosure
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.
0 out of 7.5 points
Chemical Footprint: Evaluates its chemical footprint
0 out of 8.5 points
Third-party Standards: Promotes credible third party standards for safer products
0 out of 5 points
Joint Announcement: Public commitment demonstrated through joint announcement
5 out of 15 points
Continuous Improvement: Shows continuous improvement by steadily expanding safer chemicals policy
0 out of 5 points
Safer Products: Program to promote safer products in stores and/or on 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.
0 out of 5 points
Collaboration: Actively participates in collaborative process to promote safer chemicals
0 out of 5 points
Impact Investment: Investing financial resources into independent research into safer alternatives and/or green chemistry solutions