Costco

Policy:Adopted a retailer safer chemicals policy

12.5 out of 23.5 points

In 2017, Costco announced a Chemical Management Policy, which states the company goes: “beyond the boundaries of regulatory compliance, in an effort to reduce or remove potential chemical harm to humans and to the environment.” The company encourages suppliers to: “[1] identify chemicals of concern (COCs) utilizing comprehensive testing programs; [2] remove or apply the process of informed substitution for any identified COCs; [3] identify ways to change their manufacturing processes to reduce hazardous chemical use; and [4] review and attain qualified third-party green certifications.” Additionally, Costco’s “Smart Screening Program” identifies and reduces or removes chemicals of concern in multiple product categories, including chemicals not yet restricted by laws. The Smart Screening Program applies to both products and packaging.

Costco has developed a list of “chemicals of concern” for multiple product and packaging categories including “children’s and adult apparel, bedding, home textiles, pet beds, furniture, luggage, handbags, sporting goods, personal care products, cleaning products, Kirkland SignatureTM food packaging, non-foods packaging, Kirkland Signature Baby Wipes, and Kirkland Signature Diapers.”

In 2018, Costco disclosed that it adopted a beyond restricted substance list (BRSL) for textiles. The company states: “The Costco Smart Screening Program also includes textiles. This portion of the testing program is based on the Apparel and Footwear International RSL Management (AFIRM) Working Group. The AFIRM Restricted Substance List (RSL) has been adopted with third-party … labs testing Costco’s textile and footwear products. Examples of products tested include apparel and footwear, sporting goods, luggage, handbags, and home textiles like blankets, sheets, rugs, and towels…Costco encourages its textile suppliers to implement in their supply chains the Zero Discharge of Hazardous Chemicals (ZDHC) Manufacturing Restricted Substance List (MRSL).” The company has not shared any progress on its implementation since then. Partial credit is awarded for the MRSL since it is encouraged, not required.

In 2018, the company expanded its work on packaging and has since stated: “The labeling and packaging of Costco items are tested for chemicals of concern as follows: Products that are part of the Costco Smart Screening Program use the AFIRM Group packaging RSL. Examples of packaging components include paper, wood, cartons, stickers, plastic wrap, finishing dyes, inks, coatings, metal, tape, textiles and desiccants…Labeling and packaging for Kirkland SignatureTM foods items also are required to participate in the Costco Smart Screening Program…Food contact materials and containers sold in the Costco meat department, bakery, deli and food court are tested with the Costco Smart Screening Program. Examples of this type of packaging include meat trays, bakery containers, deli tins, and pizza boxes. Additional supplies used in these departments such as hair nets, food wrap and gloves are also tested.”

The company has also shared that it is working to eliminate expanded polystyrene. The company stated: “Costco has made a 10-year effort to eliminate expanded polystyrene from inner packing materials and replace it with recyclable or compostable fiber-based options. This continues to be a focus area. Costco switched the fresh chicken packaging from polystyrene trays to saddle-pack bags. This solution uses less plastic and allows more efficient packaging.” Partial credit is awarded for this beyond restricted material list (BRML) for one plastic of environmental health concern (PEHC).

In late 2019, the company stated that: “as of September 2019, all U.S. and Canadian locations have converted to [bisphenol A (BPA)/bisphenol S (BPS)]-free register tape inside the buildings and are in the process of converting the register tape at the gas station pumps.” Partial credit is awarded for a BRSL for operations, since this does not appear to apply to all bisphenols. Partial credit is also awarded for the locations element, since it seems that the BPA/BPS restriction is the only restriction that applies outside the U.S.

Costco’s policy does not appear to apply to beauty products of environmental justice concern (BPEJC). Costco has also not set public quantifiable goals for reducing and eliminating chemicals of high concern (CHCs) or PEHCs.

Glossary of Terms

Oversight: Established management responsibilities and incentives

2.5 out of 5 points

In September 2017, Costco established a Green Chemistry management team that has been developing and implementing its Chemical Management Policy.

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

Glossary of Terms

Accountability: Ensures supply chain accountability

7.5 out of 15 points

Costco has an impressive testing program in place.

In 2017, Costco announced its Smart Screening Program, a robust program to test products for what it refers to as “chemicals of concern (COCs).” The company has stated: “The Costco Smart Screening Program identifies and reduces chemicals of concern in different product categories. This program utilizes independent third parties to pull samples of consumer goods during Costco production to conduct analytical testing for both regulated chemicals and chemicals of concern (COCs) that are not restricted by law. Products, labels and packaging are physically tested using product specific Costco Smart Screening protocols. These protocols are used to perform physical testing against a list of over 300 COC’s, including those from the EU REACH program and the U.S. Toxic Substances Control Act (TSCA). These items also are tested against the State of California Proposition 65 list of chemicals of concern. Costco partners with suppliers to review results and to help them find qualified resources to assist in removing chemicals of concern from their items.”

In 2017, Costco stated that its children’s and adult apparel, bedding, home goods, pet beds, furniture, personal care products, cleaning products, Kirkland Signature food packaging, Kirkland Signature Baby Wipes, and Kirkland Signature Diapers are physically tested against a list of more than 300 COCs. In 2018, the company clarified that the following product categories were added to the program: home textiles, luggage, handbags, sporting goods, and non-foods packaging.

Since the 2019 report card, the company updated its website stating: “Food contact materials and containers sold in the Costco meat department, bakery, deli and food court are tested with the Costco Smart Screening Program. Examples of this type of packaging include meat trays, bakery containers, deli tins, and pizza boxes. Additional supplies used in these departments such as hair nets, food wrap and gloves are also tested.” The company’s website also notes that Kirkland Signature cleaning and beauty aid formulated products are also tested.

The company intends to add more product categories over time.

The company previously noted on its website: “In fiscal year 2018 we performed over 5,000 individual product tests and when chemicals of concern were identified, we worked with our suppliers to either remove or reduce these chemicals.” The company has not yet publicly reported on how many tests it conducted in fiscal years 2019 or 2020.

Extra points are awarded for Costco having a major testing program.

The company provides training for suppliers, and previously stated: “For each new product category introduced to the program, Costco trains its International buyers and suppliers around the world on the processes and expectations for the packaging and the product.” In 2018, the company further clarified that training for the Smart Screening program is “completed biannually at a minimum.” The Costco Smart Screening User Guide provides information on training opportunities for suppliers and is available online at https://mobilecontent.costco.com/live/resource/img/static-us-landing-pages/Costco-Smart-Screening-guide-V7.pdf

Costco has not disclosed that it incorporates its safer chemicals policy, beyond restricted substance list (BRSL), partial beyond restricted material list (BRML), or reporting requirements in supplier contracts.

Glossary of Terms

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

7 out of 17.5 points

In December 2020, Costco shared this update on its disclosure and chemical assessment efforts: “Costco works with Scivera and its SciveraLENS® software platform to gather bills of substances (BOS) and generate chemical assessments for all formulated products as well as other product categories. The SciveraLENS platform allows Costco and its suppliers to better understand the chemicals used in products and allows suppliers to prescreen chemical ingredients against the Costco Smart Screening Program list (as well as hundreds of other lists), assess how chemicals impact human health and the environment using Scivera’s GHS+ chemical hazard assessment (CHA) framework. These chemical lists include chemicals from the EU Cosmetic Regulation, EU REACH Substances of Very High Concern (SVHC), fragrance allergens, and others. When chemicals of concern are identified, suppliers are encouraged to utilize toxicologists to identify preferred alternatives.”

Costco’s consultant at Scivera stated: “The disclosure of ingredients and impurities to Scivera via SciveraLENS for screening and assessment is required for Costco formulated product suppliers for both branded and private label products. When these ingredients are provided by the Costco supplier, or their sub-suppliers, these ingredients and their impurities are checked via SciveraLENS against Costco’s Smart Screening Program List and assessed by Scivera toxicologists using the Scivera GHS+ Chemical Hazard Assessment Framework. This additional insight from SciveraLENS supports safer alternatives exploration and other corrective action when listed chemicals are present in a formulation. The Costco program is currently focused on formulated products with potential to expand to articles in the future.”

Extra credit is awarded for the disclosure applying to more than one major product category.

Glossary of Terms

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

13.5 out of 26 points

The company has reported that Costco has reduced chemicals of concern in non-foods items using the Costco Smart Screening testing program. Costco shared: “In fiscal year 2018 we performed over 5,000 individual product tests and when chemicals of concern were identified, we worked with our suppliers to either remove or reduce these chemicals.” However, Costco did not disclose which specific chemicals or product categories this has impacted or provide any quantitative metrics related to the reduction of chemicals of concern.

In late 2019, Costco disclosed progress in eliminating bisphenol A (BPA) and bisphenol S (BPS) in thermal-receipt paper in stores, and is working to complete this transition at gas station pumps. The company stated: “…as of September 2019, all U.S. and Canadian locations have converted to BPA-/BPS-free register tape inside the buildings and are in the process of converting the register tape at the gas station pumps.” However, it is unclear whether this applies to all bisphenols.

The company is working to eliminate expanded polystyrene in packaging and states: “Recyclability and compostability can be increased through the elimination of polystyrene (commonly known as Styrofoam®). … Costco has made a 10-year effort to eliminate expanded polystyrene from inner packing materials and replace it with recyclable or compostable fiber-based options. This continues to be a focus area. Costco switched the fresh chicken packaging from polystyrene trays to saddle-pack bags. This solution uses less plastic and allows more efficient packaging.” Partial credit is awarded.

Glossary of Terms

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

8.5 out of 16 points

Costco encourages suppliers to “remove or apply the process of informed substitution for any identified [chemicals of concern]; identify ways to change their manufacturing processes to reduce hazardous chemical use; and review and attain qualified third-party green certifications.” The company also notes that “the Costco Smart Screening Program also provides information for suppliers to use and develop safe replacement chemicals and processes within The Smart Screening User Guide” and “Costco will continue to provide guidance for preferred chemical choices by product category through collaboration with our suppliers.” The guide provides resources for suppliers to consult when making substitution decisions.

In 2020, Costco shared this update on how it is evaluating alternatives: “The SciveraLENS platform allows Costco and its suppliers to better understand the chemicals used in products and allows suppliers to prescreen chemical ingredients against the Costco Smart Screening Program list (as well as hundreds of other lists), assess how chemicals impact human health and the environment using Scivera’s GHS+ chemical hazard assessment (CHA) framework. These chemical lists include chemicals from the EU Cosmetic Regulation, EU REACH Substances of Very High Concern (SVHC), fragrance allergens, and others. When chemicals of concern are identified, suppliers are encouraged to utilize toxicologists to identify preferred alternatives.” Costco’s consultant at Scivera stated: “When these ingredients are provided by the Costco supplier, or their sub-suppliers, these ingredients and their impurities are checked via SciveraLENS against Costco’s Smart Screening Program List and assessed by Scivera toxicologists using the Scivera GHS+ Chemical Hazard Assessment Framework. This additional insight from SciveraLENS supports safer alternatives exploration and other corrective action when listed chemicals are present in a formulation.”

The company recently eliminated bisphenol A (BPA) and bisphenol S (BPS) in thermal-receipt paper in the U.S. and Canada but has not disclosed the alternative it is switching to.

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

7 out of 20 points

Costco’s Chemical Management Policy and Smart Screening Program Guide are both publicly available. The company’s beyond restricted substance lists (BRSLs) are still not fully publicly available, though the company disclosed its BRSL and manufacturing restricted substance list (MRSL) for textiles, BRSL for non-foods packaging, and partial BRSL for operations.

The company stated: “The Costco Smart Screening Program also includes textiles. This portion of the testing program is based on the Apparel and Footwear International RSL Management (AFIRM) Working Group. The AFIRM Restricted Substance List (RSL) has been adopted with third-party … labs testing Costco’s textile and footwear products. Examples of products tested include apparel and footwear, sporting goods, luggage, handbags, and home textiles like blankets, sheets, rugs, and towels…Costco encourages its textile suppliers to implement in their supply chains the Zero Discharge of Hazardous Chemicals (ZDHC) Manufacturing Restricted Substance List (MRSL).”

On packaging, the company stated: “Products that are part of the Costco Smart Screening program use the AFIRM Group packaging RSL. Examples of packaging components include paper, wood, cartons, stickers, plastic wrap, finishing dyes, inks, coatings, metal, tape, textiles and desiccants…Labeling and packaging for Kirkland SignatureTM foods items also are required to participate in the Costco Smart Screening program.”

In 2017, the company described some of the authoritative lists of chemicals it restricts and tests against, disclosing that it includes “300 COCs, including those from the State of California Proposition 65, the EU REACH program, and the U.S. Toxic Substances Control Act (TSCA).” The company has also listed examples of chemicals of concern it screens for, such as flame retardants, phthalates, organotins, and per- and polyfluoroalkyl substances (PFAS), but it still has not disclosed its full BRSL.

The company has also disclosed a partial beyond restricted material list (BRML) for restricting expanded polystyrene in fresh chicken packaging.

The company states: “Suppliers of Non-foods branded products are encouraged to provide Costco with ingredients either on the packaging, on their website, or with a third-party chemical management tool.” This statement, however, does not clarify the scope of ingredient disclosure, and the disclosure can be on-pack, online, or with a third-party chemical management tool, so partial credit is awarded.

Glossary of Terms

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

1.5 out of 8.5 points

As part of its Chemical Management Policy, in 2018 Costco stated that suppliers should “review and attain qualified third-party green certifications.” Since then, the company updated its website to say: “Costco recognizes and accepts third-party certifications into its Smart Screening Program, which aim to provide safe, traceable and sustainable products.” The company references “STANDARD 100 by OEKO-TEX®,” the “LEATHER STANDARD by OEKO-TEX®,” and “Blue Way by BLUESIGN®.” Partial credit is awarded because these standards do not go far enough to restrict all PFAS and all flame retardants.

Glossary of Terms