Best Buy

Policy:Adopted a retailer safer chemicals policy

10 out of 23.5 points

In August 2017, Best Buy released its Chemical Management Statement, which discusses how it will “phase out chemicals of concern and improve the general management of chemicals.” The policy applies to its “private label and direct import products,” and outlines “supplier requirements regarding the use of chemicals in products as well as those used in the manufacturing process.” The policy notes the company maintains what amounts to a beyond restricted substance list (BRSL), specifying “chemicals restricted based upon regulations or known hazards,” and a manufacturing restricted substance list (MRSL) for the manufacturing process of those products. The policy also states that the RSL includes “chemicals suppliers are required to report usage to us” and notes how vendors are made aware of the requirements.

In early 2020, Best Buy finally published its BRSL and MRSL, as well as its list of reportable chemicals. These lists were evaluated in detail in our blog here: https://saferchemicals.org/2020/05/20/toxic-tvs-best-buys-step-in-the-right-direction-should-go-further/

While it is good that the BRSL restricts heavy metals, short-chained chlorinated paraffins, and several ortho-phthalates, one key shortcoming is that it doesn’t go far enough to restrict organohalogen flame retardants and other toxic flame retardants in its TVs and other electronics. This was illustrated through research previously commissioned by Toxic-Free Future and the Mind the Store campaign, which found that three private-label TVs from Best Buy contained toxic flame retardants. Best Buy staff later noted to us that the TVs that tested positive were discontinued, although the company has not confirmed whether the replacement TVs have been tested to be free of toxic flame retardants.

The current MRSL is a start, but the listed chemicals should be banned entirely, and several other hazardous solvents should also be banned. It is notable that the list of reportable substances requires reporting of brominated flame retardants and several other chemicals, but it should be expanded to apply to brand-name products as well as to entire classes or groupings of chemicals (including all ortho-phthalates, all types of flame retardants, and all PFAS).

Staff members confirmed that the policy applies to all store locations.

Best Buy has not set public quantifiable goals for reducing and eliminating chemicals of high concern (CHCs) and the policy does not appear to apply, as specified in the criteria, to operations or packaging. The company does not have a publicly available beyond restricted material list (BRML) for plastics of environmental health concern (PEHC). The company has placed polyvinyl chloride and styrene (as a proxy for polystyrene or other styrene-containing plastics) on its list of substances to be reported, but not restricted.

Glossary of Terms

Oversight: Established management responsibilities and incentives

2.5 out of 5 points

There are a number of Best Buy employees on corporate responsibility & sustainability and product compliance teams, including the Env. Management Lead and the Director of Corporate Responsibility & Sustainability, who have job responsibilities that include delivering on the company’s chemical management program in the U.S.

Best Buy does not appear to offer financial incentives for senior management to implement its safer chemicals policy.

Glossary of Terms

Accountability: Ensures supply chain accountability

5 out of 15 points

The Chemical Management Statement asserts that Best Buy “provides trainings to help factories improve their chemical management processes, including understanding of risks and the importance of taking proper precautions.” Best Buy’s chemical suppliers are required to report their usage of chemicals on the BRSL and MRSL as related to private-label and direct-import products and “[e]ach of our product specification documents include chemical requirements, and increasingly rigorous assurances and testing of products are required based upon the level of risk.” Best Buy staff clarified in December 2020 that this testing is only to determine regulatory compliance, so no points are awarded for requiring suppliers to conduct testing in third-party laboratories and provide results to the retailer to ensure compliance with the safer chemicals policy, BRSL, or MRSL.

Staff also confirmed in 2019 that the company’s RSL “is included in all supplier product specifications.”

In describing the pilot of its Chemicals Management Program, Best Buy stated in its 2018 CSR report that it “administered a survey and training to 22 private-label suppliers in various product categories” and added in its 2019 report that the program was expanded “to all other private label product categories.” However, the 2020 CSR report did not provide an update on the implementation of its program.

In 2019, Best Buy staff stated: “Best Buy trains our suppliers annually regarding our chemicals management statement (policy) and expectations. New suppliers are trained as they are brought on board and then participate in the annual training cycle. We also provide remedial training for suppliers based on any findings that arise from our supplier auditing program.”

Best Buy has not disclosed that it conducts its own testing to ensure suppliers comply with its safer chemicals policy, BRSL, or MRSL.

Glossary of Terms

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

4.5 out of 17.5 points

Best Buy requires suppliers of private-label and direct-import products (a category similar to private-label suppliers) to report their usage of certain chemicals specified on pages 5-6 of Best Buy’s chemical policy document. The list includes brominated flame retardants, organotins, numerous ortho-phthalates, PVC plastic, and many other substances of concern, including those being regulated by California, Washington, and the EU. Although this list is in most cases distinct from Best Buy’s BRSL, since the list is extensive especially because of its references to California’s Proposition 65 list, Washington List of Chemicals of High Concern to Children, and the REACH lists, we are still awarding 2.5 points.

Its 2018 CSR report stated that the company piloted its Chemicals Management Program with 22 private-label suppliers and “moved forward with launching the program with all nine of our TV suppliers” in FY2018. The 2019 CSR report added: “In FY19, we expanded this program to all other private label product categories [beyond TVs] and continue to provide support to our suppliers on their chemicals management.” Best Buy staff confirmed in December 2020 that the disclosure requirement does apply to all Best Buy private-label product categories, so extra credit is awarded for the policy applying to more than one major product category.

Regarding the disclosure of process chemicals in manufacturing: in its 2020 CSR report, Best Buy notes that it adopted the Clean Electronics Production Network (CEPN) “Process Reporting Template and [has] surveyed all of [its] suppliers using this tool.” The company “shared results from key suppliers with [the Responsible Business Alliance] so that they, along with the CEPN, can begin to assess the landscape of process chemicals across the electronics industry.” Best Buy goes on to note: “This transparency will directly contribute to the development of a prioritized list of chemical substitutions for the electronics industry.” Extra credit is awarded for Best Buy requiring its suppliers to disclose manufacturing process chemicals.

Best Buy should report on the percentage of major product categories, of products within the scope of the company’s disclosure policy, and/or of suppliers for those products that have achieved the level of disclosure the company requires.

Glossary of Terms

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

5 out of 26 points

In 2019, Best Buy announced it had replaced 100% of its gift cards (sold in US stores and online) that were made of polyvinyl chloride (PVC) with gift cards made of FSC-certified paper and water-soluble glue and ink. For this, we award partial credit of 4.5 points, since gift cards are a minor product category. Since Best Buy also disclosed its replacement, we award partial extra credit of 0.5 points (because the action was in a minor category). On a related note, the company’s 2020 CSR report notes that the company has started using “polystyrene densifiers, which break apart and condense polystyrene into cubes.” The installation of this equipment represents a step in the opposite direction from a phaseout of polystyrene.

The company’s 2018 CSR report discussed launching its chemicals management program for its 9 TV suppliers but concluded that all complied with the limits of the chemicals on the BRSL and/or MRSL, implying that no reduction was needed. However, as shown by research published in 2019, finding that three private-label TVs from Best Buy contained toxic flame retardants, and from our recent analysis of Best Buy’s BRSL and MRSL, these lists do not go far enough to restrict toxic flame retardants and other hazardous substances. Best Buy staff later noted to us that the TVs that tested positive were discontinued, although the company has not confirmed whether the replacement TVs have been tested to be free of toxic flame retardants. The 2019 CSR report noted that the program was expanded to all other private-label product categories, but the company has not yet reported on any reductions achieved as a direct result of the program.

In March 2015, Best Buy announced it had eliminated 100% of BPA and BPS in thermal receipt paper and moved to phenol-free paper (but did not disclose the specific alternative it had implemented). Additionally, in November 2016, Best Buy received an award from Office Depot for an increase in the rate at which it was purchasing green products “like greener janitorial chemicals and lower flame retardants in furniture.”

Glossary of Terms

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

4.5 out of 16 points

According to the August 2017 Chemical Management Statement, “Within our corporate, retail, service and distribution operations, Best Buy actively looks for opportunities to reduce the use of chemicals. Whenever possible, we work to transition to safer alternatives, with a preference for EPA Safer Choice chemicals. … For our private label and direct import products … we partner with suppliers to identify opportunities to transition to preferred chemicals.”

In September 2019, Best Buy staff told us that for some categories of chemicals, the company gives suppliers a list of examples of safer alternatives that it encourages them to use. The company also notifies suppliers of chemicals that it is planning to restrict through its RSL. Overall, the company relies on suppliers’ expertise to decide what is best for their operations. These pieces of information do not amount to detailed guidance.

In its 2020 CSR report, Best Buy stated: “We are actively working to protect our customers and employees through providing safer alternatives or by eliminating potentially harmful chemicals” and “Within our corporate, retail, service and distribution operations, we look for opportunities to reduce chemicals or transition to safer alternatives…”

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

7.5 out of 20 points

Best Buy released its safer chemicals policy in August 2017, and in 2020 finally published its BRSL, MRSL, and list of chemicals that it requires suppliers to report.

The company stated in 2017: “Being in electronics, Best Buy is focuses [sic] on OSHA Safety Data Sheet requirements, CA ROHS reporting, Prop 65 and other compliance purposes.”

Best Buy 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

Best Buy identifies, marks, and promotes EPEAT-registered products for its business customers. The company stated in its 2018 CSR report that: “In calendar year 2017, Best Buy customers purchased more than 6.4 million EPEAT-registered products, which collectively helped avoid the disposal of 6,000 metric tons of hazardous waste, equivalent to the weight of more than 48,000 refrigerators.” The company did not provide similar figures in its 2019 or 2020 CSR reports but still mentioned identifying, marking, and promoting EPEAT products for its business customers, although EPEAT products do not appear to be highlighted on the “For Your Business” portion of the website. Best Buy has dedicated a webpage to EPEAT (www.bestbuy.com/epeat) that links to product pages for laptops, desktop computers, monitors, printers, and cell phones with a search filter to show only EPEAT-registered products.

Glossary of Terms