Whole Foods Market earned a letter grade of B+, the same letter grade that it achieved in 2018. The company scored 81.75 out of 146.5 possible points, ranking 6th out of the 43 retailers evaluated this year.
In December 2018, after the 2018 report card was released, Whole Foods Market made an initial commitment on PFAS in food packaging by removing certain food packaging of which samples had tested positive for likely treatment with PFAS in testing commissioned by the Mind the Store campaign and Toxic-Free Future. So far in 2019, the company has prohibited octinoxate in body care products (including sunscreen), becoming the first national retailer to do so, and the company banned 15 PFAS ingredients in all body care products it sells. The company also reported in 2019 that its register tapes were phenol-free as of August 2019. Whole Foods Market also discussed its plans for a refresh of its household cleaning products standards in 2020; it is unclear if the tiered nature of the current standard, which has played an important role in encouraging suppliers to move to safer ingredients, will be maintained behind the scenes. In September 2019, the company stated that its goal “is to eliminate as many of the orange tiered ingredients as possible in all household cleaning products.”
In 2018, the company had stated that it would begin requiring on-pack disclosure of fragrance components in household cleaning products according to CA SB 258 by October 2019 in all states, but in September 2019 did not confirm that this was still the plan. Last year, Whole Foods Market confirmed the absence of benzophenone in its body care products, becoming the first national retailer to do so. The company also reported continued progress in moving away from BPA in packaging.
Whole Foods Market has several policies around chemicals – including the Eco-Scale rating system (as it is currently known), the first cleaning product standard of any retailer; Body Care Quality Standards; and protocols for chemicals related to packaging, such as PFAS in food packaging and BPA in can linings. According to information provided by staff in 2017, the Eco-Scale rating system prohibits between 52 and 326 chemicals in products, depending on their rating, and requires nearly full ingredient disclosure on labels and third-party verification. This process also means that almost all ingredients must be disclosed to Whole Foods Market for a safety evaluation, and enzyme blends are vetted by a third-party auditor. Whole Foods Market evaluates the ingredients in the body care products it sells and, as of 2017, banned 117 chemicals in all products in this category and 471 chemicals for Premium Body Care products. Whole Foods Market has expanded both lists of banned chemicals in body care products over time, to prohibit ingredients previously found in these products.
Opportunities for improvement: Whole Foods Market can make progress by expanding its policy to cover additional product categories and chemicals in manufacturing processes, including specific public quantifiable goals with clear timelines for the reduction and elimination of chemicals of high concern (CHCs). We hope Whole Foods Market will take the next step by becoming the first American grocery chain to make a public commitment to ban PFAS in all food contact materials while ensuring that substitutes are safe and disclose its timeline for doing so. Additionally, we urge the company to eliminate and safely replace other toxic indirect food additives that may be in food contact materials, with special attention paid to bisphenols that may be in food packaging 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 can also augment its practices for holding suppliers accountable to its policy. Whole Foods Market should require full disclosure of fragrance ingredients to itself and to the public on labels. The company should also become a signatory to the Chemical Footprint Project and pilot it with key private label suppliers.
Summary of Whole Foods Market’s Grade
10 out of 17.5 points
Policy: Adopted a retailer safer chemicals policy
Through Eco-Scale, the first cleaning product standard of any retailer, all ingredients in all household cleaning products sold at Whole Foods Market are evaluated for safety, among other attributes, and the products are rated red, orange, yellow, or green. Red-rated products are not allowed to be sold at Whole Foods Market, because they contain any of 52 banned ingredients that were identified through these evaluations. Orange-rated products are not allowed to contain these 52 ingredients. A total of 134 chemicals have been banned in “yellow” rated products, and 326 have been banned in “green” rated products. Note that the number of chemicals banned are current as of 2017; Whole Foods Market staff mentioned there were no substantive additions in 2018 and has not provided an update so far in 2019. As of April 2013, Whole Foods Market had reviewed more than 500 ingredients in the household cleaning products sold in its stores. In 2020, Whole Foods Market plans to complete its update of this standard and rebrand it as “Quality Standards for Household Cleaning Products.” While the company plans to combine the tiers into one public-facing list of unacceptable ingredients, it is unclear if Whole Foods will still maintain the tiered list of banned ingredients behind the scenes. In September 2019, the company stated that its goal “is to eliminate as many of the orange tiered ingredients as possible in all household cleaning products.”
For body care, Whole Foods Market evaluates “the quality of personal care products in terms of ingredients, experience, and efficacy” and has prohibited more than 100 ingredients, some potentially harmful, in all body care products that it sells. In 2019, the company added 15 chemicals in the class of per- and polyfluoroalkyl substances (PFAS), as well as octinoxate (octyl methoxycinnamate), to the list of prohibited ingredients. The company also has a more stringent standard called “Premium Body Care” that prohibits more than 400 ingredients. Since June 2012, Whole Foods Market has required personal care products with an “organic” label to be certified organic.
Whole Foods Market has some policies related to chemicals in packaging. In December 2018, 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, the company announced: “…we have removed all prepared foods and bakery packaging highlighted in the report. We’re actively working with our suppliers to find and scale new compostable packaging options.” We hope Whole Foods Market will take the next step and be the first American grocery chain to make a public commitment to ban PFAS in all food contact materials while ensuring that substitutes are safe and disclose its timeline for doing so. As related to BPA in can linings, the company “is committed to minimizing the use of BPA in canned goods where functional alternatives exist” and is working with its suppliers on alternatives. Previously, Whole Foods Market had stated that the company does not accept “any new canned items with BPA in the lining material.”
Whole Foods Market has policies related to its operations. In 2017, staff stated that in constructing stores, the company uses safer materials, such as laminates, paint, and carpeting and that the soap provided in store bathrooms meets Premium Body Care standards. In 2012, the company reported switching to DEHP-free vinyl gloves and BPA-free scale labels and cash register tapes. In 2019, it reported that all of its cash register tapes were phenol-free and are utilizing Pergafast and the less preferable ascorbic acid as alternatives (because of short supplies of phenol-free paper). In 2008, Whole Foods Market discontinued single-use plastic grocery bags at checkouts. Staff also noted in 2017 that the company was in the process of ensuring cleaning products used in “back of house” are certified to either the orange level of Eco-Scale or Green Seal’s standards. In September 2019, staff reported that the company is working with UL Everclean to assess the chemicals approved for use in stores.
Whole Foods Market has not set public quantifiable goals for reducing and eliminating CHCs and does not have a publicly available manufacturing restricted substance list (MRSL). It is not clear if the policy applies to stores outside the U.S.
2.5 out of 5 points
Oversight: Established management responsibilities and incentives
Whole Foods Market does not appear to offer financial incentives for senior management to implement its safer chemicals policy.
3.75 out of 12.5 points
Accountability: Ensures supply chain accountability
The company does not appear to formally require suppliers to conduct testing in third-party laboratories and provide results to the retailer. Whole Foods Market requires suppliers with products labeled “paraben free” to “provide testing results from … raw material suppliers [that] supports this claim” but does not specifically require this testing in third-party laboratories. The company also requires body care and cleaning products that are labeled as “organic” to have third-party certification to that standard, but it’s unclear if the certification involves testing. For these reasons, we are awarding partial credit for the third-party testing component.
Whole Foods Market has not specifically disclosed that it incorporates its safer chemicals policy or reporting requirements in supplier contracts or that it conducts its own testing to ensure suppliers comply with its safer chemicals policy.
5 out of 13 points
Disclosure: Requires suppliers to report use of chemicals in products to retailer
15 out of 16 points
Action: Reduced or eliminated chemicals of high concern (CHCs) within the last three years
For example, in a letter to suppliers dated February 1, 2016, Whole Foods Market confirmed that it was banning certain chemicals – e.g., formaldehyde-releasing preservatives and oxybenzone – from products meeting its Baseline Body Care Quality Standards, effective January 1, 2017. The company stated: “These ingredients are found in a small percentage of our body care products. Growing concerns about the safety and environmental impact of these ingredients have led us to re-evaluate them, and we have determined that they are no longer acceptable to our Baseline Body Care Quality Standards.” Whole Foods Market told its suppliers the company preferred to keep selling their products but would do so only if the product was reformulated to be compliant. In 2018, Whole Foods Market staff confirmed that 0% of the company’s products contain the sunscreen chemical benzophenone (benzophenone-3 is another name for oxybenzone). According to a recent press release, in April 2019 Whole Foods became the first retailer to stop selling body care and sunscreen products in the U.S. containing octinoxate (octyl methoxycinnamate). Whole Foods Market staff also reported in September 2019 that the company added 15 PFAS to the list of ingredients banned in all body care products sold by the retailer.
In April 2016, Whole Foods Market stated it has “converted 70% of [its] store brand products that were in BPA-containing packaging to non-BPA alternatives.” Staff told us in 2018 that the company has almost completely moved away from BPA-containing epoxy liners for its 365 Everyday Value food and beverage cans, and will be finalizing the transition in 2019 for items with commercially available options. As of September 2019, the company has not confirmed whether this transition was finalized. In 2019, Whole Foods Market reported to us that as of August 2019, all stores use register tape that is phenol-free and utilizes Pergafast and the less preferable ascorbic acid as alternatives.
Note: Whole Foods Market had made progress on removing BPA from products other than packaging before 2015. The company switched to using DEHP-free vinyl gloves in the supply realm, as reported in its 2012 Green Mission report. Additionally, in 2008, Premium Body Care standards were launched with 277 banned ingredients. As of 2017, there were 471 banned ingredients, and Whole Foods Market has approved more than 4,000 products to meet this standard.
8.5 out of 13.5 points
Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes
More generally, Whole Foods Market employees stated in 2017: “When items are added to the unacceptable ingredients lists, any substitutions producers propose must be reviewed for acceptability. If there is indication of harm, the company would not deem the substitution acceptable and would add that ingredient to our unacceptable list.”
Additionally, Whole Foods Market employees stated in 2017: “Using the precautionary principle as a guide, every body care and cleaning ingredient that is allowed on our Quality Standards lists has been given a thorough review based upon safety, environmental impact and source. To make ingredient decisions, we consult published scientific and medical literature, reports from regulatory authorities and NGOs, data from manufacturers and suppliers, and guidance from chemists and industry technical experts. In this way, we have continually ensured that alternatives are safer for both our branded and private label products.”
In September 2019, Whole Foods Market reported that the company had moved away from phenol receipt paper to the alternatives of Pergafast and ascorbic acid. Staff stated that two different alternatives are being used because phenol-free paper is in short supply. The formulation associated with the ascorbic acid paper contains at least one chemical of concern, which underscores the need for Whole Foods Market to ensure substitutes are safe, although we realize that the short supply creates some difficulties.
10.75 out of 18 points
Transparency: Demonstrates a commitment to transparency and public disclosure
Also, the BRSLs on Whole Foods Market’s website are not the full lists of prohibited ingredients, according to Whole Foods Market’s statement on the “Information for Potential Suppliers” webpage, which says: “… the ingredient list on our public website is only a partial list intended for screening products.” Additionally, Whole Foods Market only lists 90 of its 100+ banned body care ingredients on this webpage: https://www.wholefoodsmarket.com/about-our-products/body-care-quality-standards. On a page dated July 2018, Whole Foods Market publicly discloses only 451 of the 471 ingredients that it said in 2017 were prohibited in Premium Body Care products.
We are awarding partial credit because the public disclosure of the policy and BRSL is not totally complete.
Whole Foods Market currently requires suppliers of all household cleaning products sold in stores to display all ingredients according to cosmetics nomenclature, except for fragrance and enzymes, and has required this disclosure since April 2012. (Note that in April 2013, the company stated: “the majority of our products should contain full disclosure ingredient listings on the package. However, there might be smaller, regional brands that are still undergoing the audit process.”)
In 2018, Whole Foods Market staff members told us the company was planning to begin requiring fragrance components to be publicly disclosed on-pack as a result of adhering to the California Cleaning Product Right to Know Act of 2017 in its stores across all states. However, staff did not confirm that this is still the case as of September 2019 and only stated that in 2020, the refresh of the quality standards for household cleaning products will require “fragrance ingredient disclosure in compliance with specifications the company has provided to the supplier in writing” (where the specifications “apply to our household cleaning products sold in all states”) and will also require compliance with applicable laws and regulations. Whole Foods Market does not plan to require public disclosure of enzymes. We are no longer awarding an extra credit point for the previously stated public deadline.
0 out of 7.5 points
Chemical Footprint: Evaluates its chemical footprint
3.75 out of 8.5 points
Third-party Standards: Promotes credible third party standards for safer products
Whole Foods Market partnered with Green Seal “in the development, launch and execution of Whole Foods Market’s Eco-Scale™ Rating System for household cleaners.” Green Seal has been the company’s third-party verifier. In 2017, Whole Foods Market staff members stated that they work to ensure certification either to Eco-Scale at the orange level or to Green Seal’s standards. Staff members stated in 2019 that they are continuing to engage Green Seal in ingredient auditing as part of the refresh of the company’s household cleaning products standard.
We are awarding partial credit in this category because Whole Foods Market does not require certification to credible third-party safer chemicals standards in multiple entire categories, but has gone beyond encouraging suppliers to achieve certification in at least one private-label product category because of its work with GreenSeal.
According to its website, Whole Foods Market mandates that all personal care products labeled organic be certified by a third party as meeting USDA Organic standards but does not certify all personal care products to organic standards. Additionally, Whole Foods Market staff noted in 2017 that the company helped found EPA’s Green Chill Partnership to reduce refrigerant gas emissions. Several Whole Foods Market stores have been certified to Green Chill’s Silver Level and the company received a 2016 Green Chill Achievement Award.
2.5 out of 5 points
Joint Announcement: Public commitment demonstrated through joint announcement
15 out of 15 points
Continuous Improvement: Shows continuous improvement by steadily expanding safer chemicals policy
Later in 2018, after the 2018 report card was released, the company made an initial commitment on PFAS by removing food packaging that tested positive for likely PFAS treatment in testing commissioned by the Mind the Store campaign and Toxic-Free Future. We hope Whole Foods Market will take the next step and be the first American grocery chain to make a public commitment to ban PFAS in all food contact materials while ensuring that substitutes are safe and disclose its timeline for doing so. In April 2019, Whole Foods Market became the first national retailer to ban octinoxate from all of its body care products, and in September 2019, the company reported that 15 chemicals in the PFAS class were added to the banned ingredients list for all body care products sold by the retailer. The company will be refreshing its standards for household cleaning products in 2020 and stated that the refresh will require “fragrance ingredient disclosure in compliance with specifications the company has provided to the supplier in writing” (and also stated that the specifications “apply to our household cleaning products sold in all states”), but it did not provide additional details about the specifications. In 2019, Whole Foods Market reported that its register tapes were phenol-free and that the company has moved to ascorbic acid and Pergafast alternatives as of August 2019.
Whole Foods Market first established quality standards for all body care products in 1988 by banning artificial colors, a few preservatives, and other ingredients. By 2016, 103 ingredients were banned via baseline body care standards, and as of 2017, that number was 117. In a letter to suppliers dated February 1, 2016, Whole Foods Market confirmed that it was banning specific chemicals – e.g., formaldehyde-releasing preservatives and oxybenzone – from its Baseline Body Care Quality Standards, effective January 1, 2017. In 2008, Premium Body Care standards were launched with 277 banned ingredients. As of 2017, there were 471 banned ingredients, and Whole Foods Market had approved over 4,000 products to meet this standard. Whole Foods Market formalized its standards for cleaning products with the Eco-Scale Rating System that was launched in 2011.
5 out of 5 points
Safer Products: Program to promote safer products in stores and/or on website
In 2019, the company also organized a “Whole Foods Market Better Beauty Swap” to educate customers about the company’s body care standards, “making it easier than ever for consumers to ‘clean up’ their routines and exchange current beauty items for trend-setting products that meet Whole Foods Market’s quality standards.”
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