Amazon

Policy:Adopted a retailer safer chemicals policy

8.75 out of 23.5 points

On October 1, 2018, Amazon published a Chemicals Policy that stated: “Part of our commitment to quality is avoiding chemicals of concern in our products that can affect human health and/or the environment. We define chemicals of concern as those chemicals that: 1) meet the criteria for classification as a carcinogen, mutagen, reproductive, or other systemic toxicant; or 2) are persistent, bioaccumulative, and toxic. We strategically prioritize which chemicals of concern to focus on based on product type, customer concerns, and the availability of safer alternatives. The company expanded its Chemicals Policy in 2019 to cover an analogous set of products in the EU and in 2020 to restrict hazardous chemicals and unrecyclable plastics in certain private-label food packaging.

In 2018 the company also published its first-ever restricted substance list (RSL), which functions as a beyond restricted substance list (BRSL) for purposes of this report card, for certain private-brand product categories. Amazon states: “Our initial restricted substance list (RSL) applies to all consumer Private Brands baby (shampoo, lotion, wipes), household cleaning (all-purpose, kitchen, and bathroom cleaners), personal care (shampoo, sanitizers, moisturizers), and beauty products (makeup). It is based on the leading science and customer feedback, and includes a baseline list of chemicals of concern that all brands should work to phase out and eliminate. In particular, it focuses on paraben preservatives, formaldehyde donor preservatives, phthalate solvents, nonylphenol (NP) and nonylphenol ethoxylate (NPE) surfactants, toluene, and triclosan. The set of RSL chemicals will be reviewed and updated periodically. Our brands have and will continue to develop even more restrictive RSLs for their businesses.”

In late November 2018, Amazon disclosed it was completely phasing out all methylene chloride- and NMP-based paint strippers for sale on Amazon.com by March 2019.

In December 2020, Amazon significantly expanded its safer chemicals policy with a new Food Contact Materials Restricted Substance List that bans chemicals of high concern (CHCs) and plastics of environmental health concern (PEHCs) in the food packaging materials used for its Amazon Kitchen brand. CHCs including per- and polyfluoroalkyl substances (PFAS), phthalates, bisphenol A (BPA) and other bisphenols, and PEHCs including polyvinyl chloride (PVC), polystyrene (PS), and expanded polystyrene (EPS) are now restricted in certain private-label food contact materials. The CHC restrictions function as a packaging BRSL, and the PEHC restrictions amount to a beyond restricted material list (BRML). The BRSL and BRML apply to its Amazon Kitchen-brand products sold in Amazon Go, Amazon Go Grocery, Amazon Fresh, and Fresh grocery delivery. Partial credit is awarded since the packaging BRSL and BRML do not apply to other private-label or brand-name food-contact materials.

Amazon’s safer chemicals policy does not appear to apply to brand-name products sold on Amazon.com besides the paint strippers and does not appear to apply, as specified in the criteria, to its operations. Since the policy does not apply to other locations outside of the U.S besides the EU, we are awarding partial credit for this component. Amazon does not have a publicly available manufacturing restricted substance list (MRSL) and has not set public quantifiable goals for reducing and eliminating chemicals of high concern (CHCs) besides its past ban on methylene chloride and NMP in paint strippers, or plastics of environmental health concern (PEHCs). In contrast, the company has set public goals on climate, demonstrating they are capable of setting comprehensive public-facing sustainability goals. The company’s policy does not appear to apply to beauty products of environmental justice concern (BPEJC).

Glossary of Terms

Oversight: Established management responsibilities and incentives

3.75 out of 5 points

In 2017, the company shared that “Amazon’s sustainability organization has been strengthened with the addition of a director-level executive charged with leading a cross-functional and interdisciplinary team that is responsible for addressing sustainable chemistry issues. This team is advancing an internal process to develop a chemicals policy.” The company has since launched the policy. Additionally, Amazon has an executive with a goal on this, so meeting this goal is part of how the individual will be assessed. In 2020 with the establishment of The Climate Pledge, the scope of Amazon’s sustainability organization continued to expand. This included the addition of several Directors and teams responsible for various aspects of sustainability, including chemicals.

Amazon did not provide further information on financial incentives for senior management to implement its safer chemicals policy, so we are only awarding partial credit for this component.

Glossary of Terms

Accountability: Ensures supply chain accountability

2.5 out of 15 points

The Amazon Chemicals Policy states: “Amazon has developed mechanisms to drive product formulation improvements and policy compliance with our suppliers.” In terms of implementation, Amazon has begun training suppliers on its safer chemicals policy and reporting requirements. All relevant private-brand suppliers have been introduced to the Chemicals Policy. The Chemicals Policy and beyond restricted substance list (BRSL) have been integrated into supplier onboarding documents that go out to all prospective “Amazon-owned Private Brand suppliers” in the categories covered by the Chemicals Policy. As part of the product development process, suppliers are required to submit their product formulations to WERCSmart where proposed formulations will be screened for BRSL chemicals and the presence of generic ingredients. Amazon will audit these results before product launch and develop reformulation plans with suppliers for products that are not in compliance with the policy. Training materials describing the program were being distributed in the Fall of 2018. In 2021 the company shared that: “an entire team at Amazon is trained to review all documentation provided by suppliers to confirm compliance with the RSL.” Partial credit is awarded for training and for contracts.

Amazon has not disclosed that it conducts its own testing, or requires suppliers to conduct testing in third-party laboratories and provide results to the retailer, to ensure suppliers comply with its safer chemicals policy, BRSL, or beyond restricted material list (BRML).

Glossary of Terms

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

6 out of 17.5 points

Amazon private brand suppliers are required to submit full product formulations to WERCSmart. In 2019, the company stated: “Our private brand product managers ensure that all private brand suppliers in the relevant categories are informed that they need to register their formulations with WERCSmart as part of their product development and product launch processes. Amazon receives weekly participation reports from WERCSmart tracking product registrations by relevant private label suppliers.” In 2019, the company also stated: “Suppliers can, but are not required, to disclose fragrance ingredients as part of their submission to WERCSmart. RSL screening within WERCSmart has been set up to examine the constituents of third-party fragrance components, and it currently flags any product that contains generic ‘fragrance’ or other unscreenable generics. We currently allow specific private brands to adopt a range of approaches to ingredient transparency. Those that endorse full transparency can require their suppliers to replace generic fragrance in their formulations with registered third-party components.” On contaminants, the company stated: “We agree that non-functional byproducts and contaminants that are CHCs should be tracked, although this has not been the practice in regulatory systems focused on handling, transportation, storage and disposal of products. WERCSmart is being enhanced in Q4 2019 to enable suppliers to enter and tag non-functional ingredients in formulations, so we expect to have more access to this information in 2020.”

In 2020, the company disclosed progress and stated: “All suppliers producing Amazon-owned Private Brand baby, household cleaning, personal care, and beauty products in the US & EU are required to register their products in WERCSmart, where their formulations are screened for Amazon RSL chemicals. Since this requirement was introduced in Q4 2018, the number of private brand suppliers participating in the program has doubled and the number of in-scope products has increased 10x.” Extra credit is awarded for the disclosure applying to more than one major product category.

These disclosure practices do not apply to the hundreds of millions of other products sold on Amazon.com that are not covered by the policy.

Glossary of Terms

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

6 out of 26 points

In late 2018, Amazon disclosed it was phasing out the sale of methylene chloride- and NMP-based paint stripper products, effective March 2019. This action has helped drive the reduction of these hazardous chemicals across the industry. After the policy became effective, when non-compliant products were identified, the company moved swiftly to remove them, although non-compliant products were found on the company’s site as late as June 2019.

In its safer chemicals policy, Amazon disclosed 54 chemicals that are in its BRSL. The company “encourages manufacturers to phase out potentially hazardous chemistries and adopt green chemistry alternatives” and the policy currently applies to “all consumer Private Brand Baby (shampoo, lotion, wipes), Household Cleaning (all-purpose, kitchen, and bathroom cleaners), Personal Care (shampoo, sanitizers, moisturizers), and Beauty Products (make-up).” The company states: “It is based on the leading science and customer feedback, and includes a baseline list of chemicals of concern that all brands should work to phase out and eliminate. In particular, it focuses on paraben preservatives, formaldehyde donor preservatives, phthalate solvents, nonylphenol (NP) and nonylphenol ethoxylate (NPE) surfactants, Toluene, and Triclosan. The set of RSL chemicals will be reviewed and updated periodically. Our brands have and will continue to develop even more restrictive RSLs for their businesses.” However, the company has yet to disclose any progress in reducing these chemicals of concern since it launched its policy in 2018.

In 2020, the company published a new food packaging beyond restricted substance list (BRSL) and beyond restricted material list (BRML) restricting a number of key chemicals of high concern (CHCs) and plastics of environmental health concern (PEHC), respectively, from Amazon Kitchen brand food packaging.

In 2019, the company stated: “Amazon continues to launch Private Label brands that have chemical curation that goes beyond the RSL, including Belei, a beauty brand that contains no sulfates, parabens, or phthalates.” In 2017, the company shared that “avoiding chemicals of concern has become a part of the brand promise of several Amazon private-label brands. Elements-brand baby wipes, for example, do not contain phthalates, parabens, the formaldehyde donor bronopol, methylisothiazolinone (MIT) or dyes.” The company also noted that its Presto!-brand biobased household cleaners have product guidelines that restrict specific classes of ingredients, such as “no synthetic fragrances,” “no VOC’s,” and “no phosphates.” Presto! also restricts the use of ingredients if they exhibit any of the following hazard traits: carcinogenicity, mutagenicity, reproductive toxicity, endocrine disruption, neurotoxicity, or PBT. A variety of U.S. and international hazard identification lists are used to identify chemicals with these traits (e.g., Proposition 65, EPA IRIS neurotoxicants). The company has not indicated that these brands replaced any products containing chemicals of high concern, so no points are awarded for these efforts.

Amazon has otherwise not documented how its policy has led to the reduction of CHCs and has not publicly documented progress on reducing CHCs in beauty products of environmental justice concern beyond regulatory compliance in the last three years.

Glossary of Terms

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

4.5 out of 16 points

In its safer chemicals policy, the company states: “Amazon encourages manufacturers to phase out potentially hazardous chemistries and adopt green chemistry alternatives, such as those defined in U.S. EPA’s Safer Choice Safer [Chemical] Ingredients List, which can reduce impacts to human health and the environment.”

In 2020, the company shared: “Amazon is expanding its commitment to safer chemistry through its new Climate Pledge Friendly program, which recognizes and promotes products with improvements in at least one aspect of sustainability. The Climate Pledge Friendly program currently includes major multi-attribute certifications that contain limits on chemical composition, including Cradle to Cradle, UL Ecologo, Green Seal, [b]luesign, [OEKO-TEX], and GOTS. European multi-attribute certifications that limit chemical composition are included in the Climate Pledge Friendly program in the EU (Blue Angel, EU Ecolabel, Nordic Swan Ecolabel).”

Additionally, some Amazon private-label brands operate with guidelines that prefer safer alternatives. For example, Presto! and Mama Bear laundry detergents are all formulated with EPA Safer Choice and USDA Biobased ingredients.

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

8.25 out of 20 points

In October 2018, Amazon posted its Chemicals Policy and beyond restricted substance list (BRSL) on its sustainability website. In 2020, the company posted its Food Contact Materials Restricted Substance List (functioning as a packaging BRSL and packaging beyond restricted material list (BRML)) on its sustainability website.

The company’s safer chemicals policy states: “Our transparency efforts are grounded in the belief that Amazon should provide customers with information that helps them make informed purchasing decisions. Our goal is to make product health and sustainability data as easy for customers to access and interpret as price and customer reviews. This is why we are working on features for our store that will make it easier for customers to access comprehensive information about product ingredients and third-party certifications, including Safer Choice, Made Safe, Green Seal, and Cradle to Cradle. We hope that making this information more readily available for customers will encourage additional brands to move away from potentially hazardous chemistries in their products and adopt safer chemistries.”

The company goes on to note: “Recent innovations include Amazon Pages, which allow brands to tell their story directly to customers, and the A+ Enhanced Marketing Content on detail pages, which allows brands to explain product features and benefits to customers. This information can include the steps they are taking to ensure that their product selection is safe and healthy, with the backing of a robust set of guidelines to maintain a high bar of content quality to only include factual, easily verifiable, and objective information. To provide additional information on physical packaging, Amazon developed 2D codes through our Transparency service that are retailer agnostic and available to all brands. These codes can link to information about the products, their product supply chains, and any third-party certifications they have received. To further our commitment to transparency, Amazon will … work to achieve fuller ingredient disclosure on its Private Brands product detail pages.”

In 2020, the company shared this update: “Amazon is expanding its commitment to transpareny [sic] and public disclosure via the promotion it provides to certified products through the Climate Pledge Friendly program. Certifications that control chemical composition also have stringent business-to-business and business to consumer ingredient disclosure requirements. By spotlighting these products to Amazon customers, we are identifying them as models that other producers should follow.” However, thus far, this has not appeared to translate to information displayed about ingredients on Amazon.com. A company representative also noted: “All Amazon vendors and sellers must comply with all relevant laws, regulations, and Amazon policies when listing and describing their products, but we currently do not enforce a standardized method for how brands should disclose ingredient information beyond what is required by the regulations applicable to their product category.”

Glossary of Terms

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

3 out of 8.5 points

All Amazon Presto! and Mama Bear household cleaning products and laundry detergents meet the EPA Safer Choice and USDA Biobased standards. The company does not appear to require certifications to other credible third-party safer chemicals standards for other private-label products, such as electronics and apparel.

The company notes in its safer chemicals policy: “Amazon has begun work on features that will make it easier for customers to discover, identify, and purchase products with safer formulations and sustainable attributes. This work will include making safer chemistry third-party product sustainability certifications such as Safer Choice, Made Safe, Green Seal, and Cradle to Cradle more prominent.”

In 2020, Amazon announced a new “Climate Pledge Friendly” program to “help make it easy for customers to discover and shop for more sustainable products” that meet one of 19 different sustainability certifications. The Climate Pledge Friendly program currently includes a number of multi-attribute certifications that contain limits on chemical composition in formulated products and articles, including Cradle to Cradle, UL Ecologo, Green Seal, bluesign, OEKO-TEX, and GOTS. European multi-attribute certifications that limit chemical composition are included in the Climate Pledge Friendly program in the EU (Blue Angel, EU Ecolabel, Nordic Swan Ecolabel).

The company stated: “Amazon is making it far easier for customers to find certified products; and Amazon has created a program that surfaces not just a few, but tens of thousands of certified products to customers (the Climate Pledge Friendly program has over 45,000 products in the US). We believe our certified product promotion system makes Amazon the retail market leader in certification promotion. By engaging directly with the certifiers, Amazon ensures that only truly certified products are included in our program. Through mechanisms such as product badging and highly visible marketing placements, this program will change the shopping experience in ways that make it easier for customers to discover more sustainable alternatives.”

However, it does not include other standards, particularly Safer Choice and Made Safe, which Amazon had previously pledged to make more prominent for consumers. More recently the company clarified that: “Our initial launch focused on certifications that include climate change or energy standards among their evaluative criteria. As noted elsewhere, five of these certifications address multiple attributes, including restrictions on chemicals of concern. In the coming year, Climate Pledge Friendly will be expanded to additional certifications; as part of this, we are evaluating how chemical composition certifications may fit into the program.”

Glossary of Terms