Dick’s Sporting Goods

Policy:Adopted a retailer safer chemicals policy

5 out of 23.5 points

Dick’s Sporting Goods states in its 2019 CSR report (“Purpose Playbook”) that was dated October 2020: “Chemical safety and the restriction of certain substances in our supply chain is a key area of focus.” In December 2020, DSG staff stated: “we use phthalate-free / PVC-free ink, chemicals used are REACH, and/or OEKO-TEX® compliant and adhere to the bluesign® standard in response to chemicals of concern with our chemical suppliers for vertical brands and most of our national brands [are] BLUESIGN® system partners.”

In addition, Dick’s Sporting Goods has developed a “Restricted Substances List,” dated June 18, 2019. In December 2020, Dick’s Sporting Goods staff stated that the RSL applies to all private-brand products and also states in its 2019 CSR report that “[t]he RSL is distributed to and acknowledged by licensed and vertical brand product manufacturers.” The RSL was initially established in 2018 and amounts to a BRSL for at least some of the chemicals that are listed. The BRSL addresses a range of individual chemicals and references entire classes of chemicals, for a total of 22 chemicals and classes. Examples include alkylphenol (AP)/alkylphenol ethoxylates (APEOs), “Flame Retardants (if finishing is applied),” certain heavy metals, “Perfluorinated and Polyfluorinated Chemicals (PFCs) (If water/oil/stain-repellant finish is applied),” and phthalates. The company stated in December 2020 that it restricts the use of all chemicals in the classes listed in its RSL, including “PFCs,” all repellent and finishes used are fluorocarbon-free/PFC and PFOA-free, and the company also restricts PFAS. The 2019 CSR report states that the company “will continually review the chemicals and requirements of the RSL and update based on legislation and new potential chemicals of concern.”

Between its RSL and adherence to the bluesign standard, we award partial credit for a safer chemicals policy. We also award partial credit for a manufacturing restricted substance list (MRSL) because the bluesign standard includes an MRSL.

In its 2018 CSR report, the company also referenced packaging, noting: “As a retailer, we also recognize the environmental implications of our packaging, and we are continuously exploring new ways to reduce packaging and employ sustainable solutions. In 2018, we worked with our vendors to encourage optimal ordering, decreasing the amount of packaging used before products reach our stores.” However, since these efforts do not indicate the company holds its packaging to a BRSL, no points are awarded for this component. The company’s 2019 CSR report stated that it moved away from single-use plastics in its “CSC headquarters” but has not specified whether these plastics were plastics of environmental health concern (PEHC).

Dick’s Sporting Goods has not set public quantifiable goals for reducing and eliminating chemicals of high concern (CHCs) and does not have a publicly available beyond restricted material list (BRML) for plastics of environmental health concern (PEHC).

Glossary of Terms

Oversight: Established management responsibilities and incentives

1.25 out of 5 points

Dick’s Sporting Goods has assigned senior management, the Vice President of Global Compliance, with responsibility for Dick’s Sporting Goods’ safer chemicals program. Since the company does not have a full policy, we award partial credit. The company does not appear to offer financial incentives for senior management to implement a company safer chemicals policy (in part because the company does not have a full policy).

Glossary of Terms

Accountability: Ensures supply chain accountability

6.25 out of 15 points

In its 2018 CSR report, Dick’s Sporting Goods states: “In 2019, we will begin random product testing to ensure our products comply [with the RSL]. Failures in validation will result in a corrective action plan and potential reformulation of the product.” In December 2020, staff confirmed that this testing is routine “draw testing” applied to its vertical brands to monitor compliance with the RSL on a “risk prioritized basis” and that it began in Fall 2019. Staff also noted that they will “incrementally increase the number of vertical brand products tested annually.”

In its BRSL, the company states: “DSG private brands require products or material testing prior to shipment to ensure that articles comply with this RSL” and “Dick’s Sporting Goods reserves the right to test or request testing to our suppliers on materials or products.” Since this shows some effort toward requiring suppliers to test, although does not specifically require testing in third-party laboratories, partial credit (1.25 points) is awarded for the supplier testing component of the rubric in this category.

Staff stated in December 2020 that “[w]e train suppliers on our RSL through general awareness training and require acknowledgement by suppliers that they will comply with the RSL requirements when producing products for us.” Partial credit is awarded for both the training and supplier contract elements since the training does not seem detailed and it is not clear whether an actual signature is required to acknowledge RSL compliance.

Glossary of Terms

Disclosure: Requires suppliers to report use of chemicals in products to retailer

1.25 out of 17.5 points

Staff reported in December 2020 that the company meets with chemical suppliers a few times a year to discuss “any change in chemicals used, review ingredients, and evaluate hazard assessments” and that vendors provide the company with “spec and technical data sheets.” Since this may go beyond regulatory compliance, but further details have not been provided, only partial credit is awarded.

Glossary of Terms

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

4.5 out of 26 points

Dick’s Sporting Goods staff stated in December 2020: “For some chemicals, such as lead, PFCAs, & azo dyes, we go beyond regulatory compliance by requiring the highest state standard in our private brand products resulting in the phaseout of some CHCs [beyond what is required by regulation in all areas where Dick’s Sporting Goods products are sold] within the last three years.” Given this statement, and since further details were not provided on whether the private brand products they’ve phased chemicals out of amounts to at least one major product category, we awarded partial credit for Dick’s Sporting Goods eliminating several CHCs from at least one minor product category.

The company has a process for vertical brand product chemical reformulation to remove harmful chemicals from those products: “Business Development Managers [are] charged with identifying opportunities for product reformulation when indications exist that harmful or highly regulated chemicals exist in products, whether through test results, vendor notification, or other forms of communication. Upon identification of a potential chemical reformulation opportunity, Business Development Managers engage the Compliance team. Compliance facilitates the risk assessment process as well as secures additional testing and outside expertise as necessary for reformulation options.”

The retailer noted in December 2020 that in 2019, the company “launched 6 styles that use PVC- and phthalate-free inks in our Alpine Design line” that has generated significant revenue, and the company is looking to grow and expand the line. It isn’t clear whether this represents an expansion of the company’s product offerings (in which case there would be no reduction or phaseout of PVC and phthalates in inks) or whether these products replaced other merchandise.

Additionally, Dick’s Sporting Goods sells products that it advertises as containing polyvinyl chloride and polystyrene. Since these are plastics of environmental health concern (PEHC), the company should work to swiftly phase out those materials and any other PEHC in all of the products it sells or packaging it uses.

Glossary of Terms

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

2 out of 16 points

Dick’s Sporting Goods stated in its 2019 CSR report: “Chemical safety and the restriction of certain substances in our supply chain is a key area of focus.” The company also told us in December 2020 that it follows a specific process for reformulating vertical brand products when they may have harmful chemicals, which involves a risk assessment and additional testing and outside expertise as necessary, so we award 2 points in this category.

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

5 out of 20 points

Dick’s Sporting Goods has made its BRSL public on its Corporate Social Responsibility webpage.

The company has no public safer chemicals policy, manufacturing restricted substance list (MRSL), or beyond restricted material list (BRML) and has not committed to disclosing any of those items in 2021 after the publication of the report card.

Dick’s Sporting Goods does not appear to encourage or require suppliers to publicly disclose ingredients in products online or on product packaging going beyond regulatory compliance.

Glossary of Terms

Third-party Standards: Promotes credible third-party standards for safer products

1.5 out of 8.5 points

Dick’s Sporting Goods stated in December 2020 that it encourages its “chemical suppliers for vertical brands and national brands to become bluesign® system partners.” Partial credit is awarded given the limitations of bluesign in addressing PFAS as a class. The company also states it uses chemicals that “are REACH, and/or OEKO-TEX® compliant.” Since it is not clear to how often the chemicals used are compliant with REACH versus OEKO-TEX, no additional partial credit is awarded.

Glossary of Terms