Apple

Policy:Adopted a retailer safer chemicals policy

21 out of 23.5 points

Apple has a written safer chemicals policy that aims to avoid chemicals of high concern (CHCs). It has a few main components. The first is a Regulated Substances Specification(RSS) listing chemicals or materials that are restricted in or subject to reporting requirements in Apple products and accessories, certain Apple packaging, Apple’s manufacturing processes, and products provided to Apple by suppliers (per the Code of Conduct and Supplier Responsibility Standards). There are also supplementary specifications, including one entitled Apple Regulated Substances Specification for Prolonged Skin Contact Materials, 099-3470, which has been in place since 2015. The public version of this is the Restricted Chemicals for Prolonged Skin Contact Materials, and lists chemicals restricted in “materials in prolonged skin contact in wearable and non-wearable products…with a key focus on skin irritants and sensitizers.” An additional specification restricts volatile organic compound (VOC) use, although compliance with this is currently only required in China, not yet globally. The other component is a Full Material Disclosure (FMD) program, where suppliers are required “to provide the entire chemical composition of the parts and materials used in Apple products.” The 2020 Environmental Progress Report provided several updates on progress toward full material disclosure, which are noted below in the evaluation for category 4.

In addition to serving as a beyond restricted substance list (BRSL), the RSS also serves as a manufacturing restricted substance list (MRSL) for several chemicals. It prohibits substances including benzene, chlorinated organic solvents (e.g. methylene chloride (DCM) and trichloroethylene (TCE)), N-methylpyrrolidone (NMP), n-Propyl Bromide (nPB) (prohibited in 2018), and toluene when used in cleaning agents, degreasers, and demolder solutions in all manufacturing processes.

The RSS applies to packaging as well and applies globally: “This Regulated Substances Specification describes Apple’s global restrictions on the use of certain chemical substances or materials in … packaging used for shipping products to Apple’s end-customers.”

Additionally, the RSS also applies to in-house purchasing, as the Supplier Responsibility Standards state: “Supplier shall comply with Apple’s Regulated Substances Specification… for all materials and goods it manufactures for, or provides to, Apple.” In 2017, staff stated that in the company’s retail stores, Apple requires janitorial chemicals to comply with a Green Seal standard and follows a standard related to the design of high-performance green buildings that also requires environmental product declarations (ASHRAE 189.1). According to staff statements, Apple also sets limits on VOC emissions from building materials and related items in “back of house” under this standard.

After gathering data on compliance with the RSS, and from the FMD and “chemical mapping programs,” Apple uses programs such as Clean Production Action’s GreenScreen® or in-house board-certified toxicologists to “generate comprehensive assessments” on chemicals’ health and environmental impacts. Apple staff stated in 2020 that the company conducts “comprehensive assessments for all materials with the potential for prolonged skin contact, including materials with indirect skin contact,” and for cleaners and degreasers, and conducts “assessments for other materials of interest.” The company has also developed a Chemical Prioritization Protocol to provide “a framework for prioritizing chemicals of concern in the electronics industry” and identifying chemicals that may warrant chemical management actions by synthesizing “a wide range of relevant information about chemical hazard, use, exposure potential, and public concern into a simple set of quantitative indicators,” including the information provided through FMD and toxicological assessments. Apple has used the protocol, for example, as a tool to determine which chemicals to add to its Regulated Substances Specification.

Apple has set a goal to “Eliminate plastics in our packaging by 2025.” According to the Review Statement in the 2020 Environmental Progress Report, some of the plastic that Apple seeks to eliminate is high-impact polystyrene (HIPS). Staff also stated in January 2021 that the company’s goal also applies to other polystyrene (non-expanded), expanded polystyrene, and acrylonitrile-butadiene-styrene. At least some of this plastic is used in significant quantities in Apple’s packaging, and since Apple seeks to phase it out from all packaging (both finished goods packaging and protective shipper boxes) by a specific year (2025), we award full credit for both a beyond restricted material list (BRML) applying to more than two plastics of environmental health concern and for setting public quantifiable goals to phase out these plastics from all of its packaging.

Apple states in its 2020 Environmental Progress Report: “Our ambition is to: Use only recycled and renewable materials in our products and packaging.” As an example of progress toward this goal, the company noted: “We introduced more than 100 components with an average of 46 percent recycled plastic across products released in 2019.” The company stated that when it sources “content from the recycled materials market,” as opposed to recycling its own material, because the composition is unknown, Apple analyzes the materials’ composition to evaluate compliance with the RSS. The RSS includes key CHCs that may be in recycled plastics, including brominated flame retardants, heavy metals, and phthalates, so extra credit is awarded for Apple applying its BRSL to recycled plastics and key CHCs that may be in recycled plastics.

Glossary of Terms

Accountability: Ensures supply chain accountability

12.5 out of 15 points

Apple engages in four practices to assess and ensure supplier conformance with retailer chemical policies.

Apple’s 2020 Environmental Progress Report states: “We regularly conduct in-person, in-region training in native languages to educate suppliers on our RSS, Full Material Disclosure program, and Chemicals Management Program, as well as inform suppliers about evolving regulations. To date, we’ve conducted training sessions in China, Korea, and Japan, and have reached more than a thousand suppliers across our supply chain—from final assembly to raw material vendors.” In 2020, Apple staff indicated the company conducted virtual training for suppliers on the Apple Volatile Organic Compound (VOC) Specification when it was published in September 2020. From 2013 through 2016, EHS managers from over 270 supplier sites in China took courses and implemented projects, including on chemical management, through Apple’s Environmental Health and Safety Academy. Since 2017, this academy has operated independently at a university in China, and the course material is being developed into new interactive content that will be available globally to all Responsible Business Alliance member companies in 2020.

The Regulated Substances Specification states that “Apple requires test reports from certified labs as proof of compliance for [certain] substances [restricted per Apple’s policies] in homogeneous materials…[and for certain] manufacturing process chemicals [also restricted per Apple’s policies]…A nationally or internationally certified laboratory must issue the test report. Supplier-owned laboratories are acceptable if they are independently certified.”

According to the company’s 2019 Environmental Responsibility Report, Apple also runs its own environmental testing lab with state-of-the-art advanced equipment to “look for any potentially harmful substances and test products to evaluate compliance with the RSS.” Staff confirmed that to verify supplier data, the company uses both its internal lab and third-party labs. In the 2020 Environmental Progress Report, Apple notes: “All materials that will be in prolonged skin contact undergo material characterization testing to evaluate compliance with the RCW,” which is the list of restricted chemicals for prolonged skin contact materials. The introduction in the RCW states: “…both Apple and independent laboratories test materials for the concentration of restricted chemicals.”

Apple also requires its suppliers to comply with its safer chemicals policy via supplier contracts. Apple staff stated in 2019: “To do business with Apple, suppliers must agree to operate in full compliance with all applicable laws and regulations, and adhere to our Supplier Code and Standards,” which include a requirement to comply with its RSS. Apple also notes in its 2020 Environmental Progress Report that “[o]ur chemical restrictions [on materials that come into prolonged skin contact] are distributed to material suppliers and we have contractual requirements in place to obligate compliance.”

Apple takes “the extra step to analyze the chemical composition of … materials [from the recycled materials market] to evaluate whether they comply with Apple’s RSS,” according to the 2020 Environmental Progress Report. Extra credit is awarded for Apple itself routinely testing recycled materials in a major product category (e.g. those that it gets from the recycled materials market) for CHCs that may be in recycled materials.

Glossary of Terms

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

10.5 out of 17.5 points

Apple’s Regulated Substances Specification defines Full Material Disclosure (FMD) as an “initiative that requires suppliers to provide the entire chemical composition of the parts and materials used in Apple products to ensure compliance to regulatory requirements, corporate initiatives, and to support assessment of the impact to human and environmental health.” Its 2020 Environmental Progress report describes FMD as “a sort of human-genome project for the materials we use” and notes: “We must understand the chemical composition of each material used in Apple products to ensure they meet our strict standards.”

Staff confirmed that the definition of FMD in the RSS means Apple requires the disclosure of intentionally added substances and impurities. In 2017, Apple staff clarified that the company also collects information on the ingredients in packaging materials, not just in the products, and in the 2020 Environmental Progress Report, Apple noted that it includes “the materials used in very small quantities like inks, adhesives, and coatings.” According to the report, the company “established an advanced system that simplifies the process of collecting data from suppliers.” Because the company requires this disclosure for all Apple products (and packaging), which is more categories than the one category required to receive points from the rubric, we award extra credit.

The report also notes that after Apple collects the data, it goes “a step further than many other companies by carefully validating material composition information with the raw material manufacturers.”

As of October 2019, according to its 2020 Environmental Progress Report, the company had “collected and validated chemical information for more than 45,000 parts” in its products from more than 900 suppliers. The company also noted it “collected detailed chemical information on more than 82 percent, on average, of product mass for iPhone, iPad, and Mac products we released in fiscal year 2019,” with 94% by mass collected for the 21.5-inch iMac with Retina 4K display and 100% collected for “those materials that come under prolonged skin contact and require qualification from our biocompatibility team.” The data disclosed in the 2020 report represent progress from the 2019 Environmental Responsibility Report, where the company noted it collected “detailed chemical information for …over 75 percent of product mass for new iPhone, iPad, and Mac products.” Apple also noted in its 2020 Environmental Progress Report that it has collected the chemical composition of over 1,100 raw materials because of “direct relationships with more than 90 raw material suppliers.”

Extra credit is awarded for Apple reporting that it has achieved full material disclosure for all materials coming under prolonged skin contact that require qualification from the company’s biocompatibility team.

As of 2020, Apple has not yet expanded its FMD initiative to brand-name products sold in its stores.

Related to disclosure of chemicals used in manufacturing: in 2017, Apple staff mapped chemicals of concern used in the company’s final assembly facilities to determine the opportunities for greener alternatives. This effort evolved into the company’s Chemical Safety Disclosure Program, which quantifies actual chemical usage. Its success contributed to the development and implementation of the Clean Electronics Production Network Process Chemicals Data Collection (PCDC) Tool, which was launched in 2020. The company noted in its 2020 Environmental Progress Report: “We also developed a standardized process through which suppliers share information about the specific chemicals they use, what the chemicals are used for, and the measures taken to protect their employees. … The rollout of this tool expanded in 2019 to include 80 participating facilities.” Separately from this, since the company requires suppliers to report the substances that are listed in section 7 of its Regulated Substances Specification when used “in any manufacturing process used to create components or materials for Apple products,” the company receives extra credit for requiring the disclosure of manufacturing process chemicals.

Glossary of Terms

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

18.5 out of 26 points

According to Apple’s 2018 Environmental Responsibility Report, in 2017, after mapping chemicals in final assembly facilities, and evaluating all control measures, Apple replaced methanol, xylene, cyclohexane, acetone, and methyl ethyl ketone in cleaning products used during manufacturing with “safer alternatives including ethanol, isopropyl alcohol, glycerol, and water.” The 2018 Supplier Responsibility Report stated that these cleaners represented three GreenScreen Benchmark 1 and 26 Benchmark 2 cleaners and degreasers, and it meant that all Benchmark 1 and 2 cleaners were eliminated from 18 of Apple’s final assembly facilities in 2017. According to the 2019 Supplier Responsibility Report, Apple expanded this program in 2018 so that “36 suppliers achieved the elimination of all GreenScreen Benchmark 1 and Benchmark 2 cleaners and degreasers.” The 2020 Environmental Progress Report notes that “[s]ince the inception of this effort, all supplier final assembly sites have utilized only these safer alternatives” that were developed “utilizing rigorous methodologies such as GreenScreen, SciveraLENS Screened Chemistry, and EPA Safer Choice.”

Apple staff also confirmed that none of the alternatives replacing the Benchmark 1 and 2 cleaners and degreasers contain GreenScreen List Translator-1 chemicals, and disclosed the identity of a few of the replacements, so we awarded extra credit for both of these achievements.

Additionally, Apple revised its Regulated Substances Specification in March 2018. The company added or strengthened restrictions for a number of chemicals in products, including polyaromatic hydrocarbons (PAHs) in all external materials, chlorine and chlorinated compounds in fiber-based packaging, and chemicals on the REACH Candidate List for Substances of Very High Concern (unless pre-approved by Apple). The company also changed content restrictions for several chemicals used in certain products and in all manufacturing processes to “non-use” and included a ban on n-Propyl Bromide. Apple staff stated in 2018 that it believes these changes demonstrate reductions or eliminations of chemicals of high concern.

Apple has made progress in eliminating specific plastics of environmental health concern from its packaging. This includes both finished goods packaging and protective shipper boxes, according to staff statements in January 2021, which we assume amount to multiple major packaging categories. In Apple’s Global Commitment Progress Report to the Ellen MacArthur Foundation for the 2020 reporting cycle, the company notes that 2,300 metric tonnes of polystyrene (including high-impact polystyrene), representing 46% of all of Apple’s packaging, were eliminated through substitution by paper in 2019, and acrylonitrile-butadiene-styrene (ABS) plastic was reduced by 58% from 2018 to 2019. For this effort, combined with its elimination of CHCs from at least one major manufacturing process and restriction of CHCs in major product or packaging categories as described above, we award partial extra credit.

Additionally, in March 2018, as part of its expanded Full Material Disclosure program, Apple identified one plastic part in three products in the same product category that contained a GreenScreen Benchmark 1 flame retardant. The company identified a safer alternative and took action to replace the material.

The introduction to the list of “Restricted Chemicals for Prolonged Skin Contact Materials” released in 2020 states: “To evaluate safety, toxicologists review the test results and the chemical formulation of each material that may come in prolonged contact with the skin. Only materials that pass these reviews are acceptable for use in Apple products.” This implies that all of these materials (that will/may be in prolonged contact with skin) are in compliance with the restrictions in the list, although we note that the level of the restrictions is not specified, and it is not clear whether compliance was achieved at some point within the last three years or longer ago.

Glossary of Terms

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

13.75 out of 16 points

Apple’s March 2018 Regulated Substances Specification states: “For substances that are restricted or regulated and have been replaced with an alternative substance, the supplier is required to ensure the alternative substance is an environmentally responsible substitution. Substitutions should be selected based on minimizing unintended consequences that might occur in phasing out a potentially hazardous substance. Suppliers shall conduct alternative assessments or obtain these assessments from their raw materials suppliers prior to making a replacement. Contact Apple at [email protected] for more information on conducting alternative assessments.” The Apple Supplier Responsibility Standards require each supplier to “ensure that its selection processes for all new Hazardous Chemicals include a thorough evaluation of non-hazardous alternatives.”

The 2020 Environmental Progress Report states: “We’re not only evaluating the chemicals that go into our products and those used to manufacture them, but also developing alternatives that help reduce and remove substances we’ve determined to be potentially harmful. Sometimes this requires innovation. If a safer alternative doesn’t exist, we work with our suppliers to create one.” According to staff statements in 2017, Apple had paid for approximately 500 GreenScreen assessments.

Discussing its effort to substitute safer chemicals for hazardous cleaning chemicals used in manufacturing, Apple stated in its 2020 Environmental Responsibility Report: “[s]ince 2017, utilizing rigorous methodologies such as GreenScreen, SciveraLENS Screened Chemistry, and EPA Safer Choice, we have been developing a list of safer cleaners and degreasers for use at final assembly sites. Since the inception of this effort, all supplier final assembly sites have utilized only these safer alternatives.” According to a 2020 EPA press release, in 2019 Apple assessed 33 new cleaners and has approved more than 50 safer cleaner and degreaser alternatives for use in its supply chain. Apple also worked with Clean Production Action to develop criteria for assessing safer cleaners to be used by others in the electronics industry and separately helped develop the public Clean Electronics Production Network Alternatives Assessment guide, which helps companies identify and evaluate substitutes for CHCs in electronics manufacturing processes.

In 2020, Apple staff relayed that the company has sponsored hazard assessments conducted by ToxServices for one flame retardant and one plasticizer to identify safer alternatives and these have been submitted to the ChemFORWARD portal and will be posted on ChemFORWARD’s shared platform after they are verified. Partial extra credit is awarded for this since this does not represent a significant number of assessments.

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

7.5 out of 20 points

Apple’s safer chemicals policy, BRSL, a version of its supplementary BRSL (for materials in prolonged contact with skin), MRSL, and BRML are publicly available.

Apple does not appear to encourage or require suppliers to publicly disclose ingredients in products online or on product packaging going beyond regulatory compliance.

Until recently, the “Product Environment Reports” for Apple products described in general terms the weight of the materials used – e.g., stainless steel, glass, and plastics – and of the components – e.g., the battery, although the type of plastic was not specified. In the new version of the Product Environment Reports, Apple has transitioned away from providing the general weight of the materials.

Apple employees noted in 2017 that while the company is working toward understanding all ingredients in its products, since “[t]here are tens of thousands of different parts used at Apple, each one with a highly complex chemical make-up … [public] [d]isclosure of all ingredients in a complex, assembled product is unlikely to be achievable right now.”

In its 2020 Environmental Progress Report, Apple noted one of its goals is to “Drive 100 percent transparency of chemical use in our supply chain and products.” However, this appears to be transparency to Apple rather than transparency to the public.

Glossary of Terms

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

7.5 out of 8.5 points

Apple has obtained an active EPEAT registration, Gold rating, for all of the private-label products that it appears to actively sell in the following categories that fall within the scope of EPEAT: iMac, iPad, iPhone, Mac, MacBook, and Pro Display XDR. EPEAT registration is not available for the Apple Watch.

Apple currently has 16 product types, for 26 products total, registered to this standard in the following categories: cell phones (iPhone 11, iPhone 11 Pro, iPhone 11 Pro Max, iPhone SE, and iPhone Xr); desktops (iMac, iMac Pro, Mac mini, Mac Pro); displays (Pro Display XDR); notebooks (MacBook Air, MacBook Pro); and tablets (iPad, iPad Air, iPad mini, iPad Pro). (Note: only those with “Active” status in the EPEAT database are listed.)
The company mentions the gold EPEAT rating for these products in their Product Environment Reports, although in most cases the designation is only mentioned in small print in an endnote.

In 2019, Apple noted that it had played a key role in shaping an optional criterion of the standard for computers and displays originally adopted by EPEAT.

Glossary of Terms