In addition to minor changes to clarify the criteria and to update the maximum points for a given category to reflect extra credit specific to that category, we made more notable changes that are summarized below:
1. Policy: Adopted a retailer safer chemicals policy
- We are expanding the scope of our evaluation of restaurant chains from only grading policies on bisphenol A, per- and polyfluoroalkyl substances (PFAS), and ortho-phthalates to now considering policies on indirect food additives (defined in the rubric) in food contact articles, while still highlighting all bisphenols, PFAS, and ortho-phthalates as important examples of chemical classes that should be prioritized for action. We also clarified that for any other retailer selling food products in addition to other products (e.g. big box stores, grocery stores, etc.), our evaluation also covers policies on indirect food additives in food contact articles in addition to policies on other non-food products or packaging sold.
2. Oversight: Established management responsibilities and incentives
- In our evaluation of a retailer’s oversight of its safer chemicals policy implementation, we are no longer considering whether a retailer has ensured Board-level oversight of the implementation of its safer chemicals policy. The related point of whether the policy is posted to the retailer’s corporate governance website was also eliminated. We have reduced the total number of points for this category from 7.5 to 5.
3. Accountability: Ensures supply chain accountability
- In place of considering whether a retailer audits its suppliers to verify the chemical data they submit, we are now evaluating whether the retailer includes in suppliers’ contracts the requirements associated with the safer chemicals policy or reporting requirements.
4. Disclosure: Requires suppliers to report use of chemicals in products to retailer
- We clarified that for restaurant chains, most of the lower point levels in this category only apply if the listed disclosure is made for at least one major category of packaging (which we are now interpreting as all food contact articles). However, for restaurant chains to be awarded 6 points in this category, since food contact articles are unlikely to contain fragrances and to more clearly distinguish the 6-point level from the 5-point level, restaurant chains must make the listed disclosures for two or more major categories of food contact articles.
- We clarified that we are only looking for retailers to encourage or require suppliers to disclose known
- Retailers will now only receive an extra credit point for setting a deadline for this disclosure if the deadline was in the past three years or in the next three years.
- Instead of considering nanomaterials as a type of ingredient that retailers should encourage or require suppliers to disclose to them as part of the base points for this category, we will award extra credit if companies choose to explicitly require disclosure of nanomaterial ingredients, as this would be a unique undertaking.
5. Action: Reduced or eliminated chemicals of high concern (CHCs) within the last three years
- A company may now receive an extra credit point if it shows its substitutes for chemicals of high concern have not received scores of GreenScreen List Translator-1 (LT-1) or Benchmark-1 (BM-1) in the last three years.
6. Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes
- We increased the overall value of this category (and the individual point levels) by 2.5 points, given the importance of retailers evaluating the safety of alternatives. This also makes up for taking 2.5 points away from the Oversight category.
- We made the language consistent between point levels to show that this category applies to products, packaging, or operations at each point level.
- We clarified that for the new 4.5-point level, the retailer’s preference for safer alternatives can be for either private-label or brand-name products rather than both.
7A. Transparency around safer chemicals policy
- We added references to “manufacturing restricted substance list” (MRSL) to show that if a retailer has an MRSL, it should be made public in the same way the RSL is made public.
7B. Transparency around consumer ingredient disclosure
- We clarified that these criteria involve the retailer formally encouraging or requiring suppliers to make public disclosures, meaning that the company would need to tell us this in writing or clearly document this in public materials.
- We also made more use of the glossary-defined terms; clarified that “full chemical ingredient information” means the use of industry naming standards, rather than generic terms, such as fragrance or parfum; clarified that contaminants and byproducts are included in the definition of impurities; made GreenScreen Benchmark-1 chemicals an option for disclosure along with List Translator-1 chemicals; and added more details to better distinguish the 4.5- and 3-point levels for formulated products.
- For the 1.5-point level, we clarified (a) the disclosure described here can be pursuant to the retailer’s policy or to its beyond restricted substance list (BRSL) and (b) that “packaging” did not need to be singled out, since packaging is a type of article.
- We clarified that we are only looking for retailers to encourage or require the public disclosure of known
- Retailers will now only receive an extra credit point for setting a deadline for this disclosure if the deadline was in the past three years or in the next three years.
- Instead of considering nanomaterials as a type of ingredient that retailers should encourage or require suppliers publicly disclose as part of the base points for this category, we will award extra credit if companies choose to explicitly require public disclosure of nanomaterial ingredients, as this would be a unique undertaking.
8. Chemical Footprint: Evaluates its chemical footprint
- We added a sub-criterion to the level of 4.5 points to reflect the situation in which a retailer has completed the Chemical Footprint Project survey for all of its products but is not a signatory to the CFP.
10. Joint Announcement: Public commitment demonstrated through joint announcement
- For the 5-point and 2.5-point categories, we added the qualifier that the public announcement, statement, or briefing needs to have happened in the last two years (since November 2017). We also clarified that the 1-point level only applies to a briefing within the last year in advance of a major announcement (since the announcement has yet to be made).