Whole Foods Market, which was acquired by Amazon in 2017, earned a letter grade of B+, scoring 83.75 out of 135 possible points and ranking fifth out of 40 retailers evaluated. In 2017, Whole Foods Market scored a B+ due in part to its significant steps toward ensuring cleaning and body care products are free of certain toxic chemicals, and overall, the company continued to improve this year. Whole Foods Market has several policies around chemicals – including the Eco-Scale rating system, the first cleaning product standard of any retailer; Body Care Quality Standards; and protocols for chemicals not allowed in packaging, such as 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 last year, 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. Although there were no substantive additions to the Eco-Scale banned lists this year, the company is working toward a refresh of this standard and expects to add more ingredients next year. Whole Foods Market also plans to strenghten Body Care Quality Standards. Additionally, Whole Foods Market has reported continued progress in moving away from BPA in packaging, and confirmed the absence of benzophenone in body care products. Note that Whole Foods Market has removed the list of premium body care products that had been available on many stores’ webpages. Whole Foods Market will be requiring the disclosure of fragrance components on household cleaning products according to CA SB 258 in October 2019 in all states.
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 for the reduction or elimination of chemicals of high concern, and completely eliminating and safely replacing BPA and per- and polyfluoroalkyl substances (PFAS) in food packaging and food contact materials as well as phthalates in food and food contact materials in its supply chain. The company can also augment its practices for holding suppliers accountable to the policy. Whole Foods Market should require full disclosure of fragrance ingredients to itself, not just 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. As of April 2013, Whole Foods Market had reviewed more than 500 ingredients in the household cleaning products sold in its stores. In 2019, it appears that Whole Foods will still maintain the tiered list of banned ingredients behind the scenes, but for purposes of consumer materials, the company plans to combine the tiers into one list of unacceptable ingredients. Whole Foods Market also expects to ban additional ingredients in 2019.
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 it sells. 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. 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 has 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 2008, Whole Foods Market discontinued single-use plastic grocery bags at checkouts. Staff also noted in 2017 that the company is 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.
Whole Foods Market does not have a publicly available Manufacturing Restricted Substance List (MRSL) and the company has not set public quantifiable goals for reducing and eliminating chemicals of high concern. It is not clear if the policy applies to stores outside the U.S.
2.5 out of 7.5 points
Oversight: Established management responsibilities and incentives
Whole Foods Market does not appear to ensure board-level engagement in its chemical policy or offer financial incentives for senior management to implement safer chemical policies.
6.25 out of 10 points
Accountability: Ensures supply chain accountability
For the Premium Body Care review process, in a 2010 blog, the company stated: “Small manufacturers who may not have the technical expertise of a larger manufacturer have received guidance from us regarding testing protocols and compliant labeling.” Staff stated last year that “[a]ll suppliers of products to Whole Foods Market are provided clear information about [its] standards and unacceptable ingredients.” Staff added this year that they conduct supplier summits and provide information on the requirements through a supplier portal.
Whole Foods Market does not appear to test materials itself or to formally require suppliers to test in third-party approved laboratories.
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 approved 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.
6 out of 10 points
Disclosure: Requires suppliers to report use of chemicals in products to retailer
Because the company stated it would pull all products not meeting the “orange” tier on the Eco-Scale by April 22, 2012, and these ingredients had to be evaluated to receive a rating, it’s implied that the supplier disclosure to Whole Foods Market for cleaning products then on the shelves was due in advance of April 22, 2012.
15 out of 15 points
Action: Reduced or eliminated chemicals of high concern 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 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).
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.
Note: Whole Foods Market had made progress on removing BPA from products other than packaging prior to 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. Currently, there are 471 banned ingredients, and Whole Foods Market has approved more than 4,000 products to meet this standard.
6 out of 10 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.”
12 out of 15 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 89 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 were prohibited last year in Premium Body Care products.
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. In October 2019, the company will 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. Whole Foods Market does not plan to require public disclosure of enzymes.
The company has required its household cleaning products disclosure since April 2012, although 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.”
0 out of 7.5 points
Chemical Footprint: Evaluates its chemical footprint
6 out of 7.5 points
Third-party Standards: Promotes credible third party standards for safer products
The food bar container in many of Whole Foods Market’s stores has been “Cradle-to-Cradle Silver certified” according to the company’s 2012 Green Mission Report. Additionally, Whole Foods Market staff noted last year 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.
Whole Foods Market employees told us in 2017 that historically, the company created its own product and ingredient standards and accountability practices if third-party standards did not exist or were not adequate.
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 stated that they work to ensure certification either to Eco-Scale at the orange level or to Green Seal’s standards.
0 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
As background: 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
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