CVS Health

Policy:Adopted a retailer safer chemicals policy

12.5 out of 23.5 points

CVS Health has a Cosmetic Safety Policy that states the company is committed to: “developing action plans to replace ingredients of concern in our branded and private label products when safer alternatives are available and prompting similar action by our suppliers.” The company has developed a list of “chemicals of consumer concern (CCCs),” which amounts to a beyond restricted substance list (BRSL) for chemicals of high concern (CHCs). CVS has stated that: “we actively identify and prioritize the replacement of CCCs with safer alternatives in certain CVS Brand categories, including beauty, baby and personal care, and food products. As new, conclusive research is published on how certain chemical ingredients are linked to health and environmental risks, and safer alternatives are made available, we apply our Cosmetic Safety Policy. This policy outlines our commitments to customer safety, scientific research, supplier collaboration and continuous improvement as well as the evaluation and replacement of CCCs in CVS Brand products.” The company’s BRSL applies to its CVS store brand baby, beauty, personal care, child, foods, and sun care products but does not apply to brand name products it sells. CVS Health’s Cosmetic Safety Policy and BRSL apply to all CVS Pharmacy locations.

The company achieved the goal it set for itself to reformulate by the end of 2019 nearly 600 private-label beauty and personal care products. In doing so, CVS Health eliminated numerous parabens, phthalates, and formaldehyde releasers. In 2020, the company reported it was removing two chemicals of concern in sunscreens SPF 50 and lower nationwide, in advance of legislation going into effect in the states of Hawaii and Florida.

In 2020, the company announced it had eliminated bisphenol S (BPS) and all other bisphenols in thermal receipt paper. This is a significant development addressing the chemical footprint of the company’s operations.

In the past, the company eliminated bisphenol A (BPA) in all private-label packaging. However, the company’s safer chemicals policy does not explicitly apply to packaging, and the company has not disclosed any recent efforts to restrict CHCs, such as PFAS or ortho-phthalates, in packaging. The company stated in its sustainability report issued in 2019 that “in 2019 we will be developing our criteria for CVS Pharmacy store brand printed packaging to create more sustainable packaging for our products,” but did not clarify whether this would address CHCs in packaging. In 2019, the company shared that it was planning to engage its suppliers around packaging through the Beauty and Personal Care (BPC) Products Sustainability Project survey for packaging, but has not disclosed any updates on this since then. The company shared in its most recent sustainability report, issued in 2020, that it: “will complete a packaging audit of our plastic packaging to better understand our footprint. As part of this work, we are engaging with WWF on systems-based innovation for sustainable packaging. We are also partnering with WWF on its ReSource Plastic program as a Retail Principal Member. Following the packaging audit, we will roll out guidelines to all supplier partners for both national and store brand products.” It is unclear whether these guidelines will address CHCs in packaging or plastics of environmental health concern (PEHCs) such as polyvinyl chloride (PVC) and polystyrene.

In its most recent sustainability report, issued in 2020, the company noted, “Cosmetics formulated for people of color can be difficult to find, and CVS Health is committed to increasing product options in our stores to better meet the needs of our customers.” In a statement, the company clarified: “We are working with minority-owned businesses (to) add new products to our shelves, including textured hair care products. All products sold at CVS Pharmacy would meet our quality assurance standards, including our restricted substances list.” However, the BRSL does not include some notable CHCs such as hydroquinone and the policy does not apply to brand-name products, so extra credit is not awarded.

The company’s Cosmetic Safety Policy does not appear to apply to other products beyond its own private-label beauty and personal care products or apply to packaging as specified in the criteria, and the company does not have a publicly available manufacturing restricted substance list (MRSL) or beyond restricted material list (BRML) for PEHCs.

Glossary of Terms

Accountability: Ensures supply chain accountability

7.5 out of 15 points

The company noted in its 2019 sustainability report issued in 2020 that: “Our suppliers adhere to our Store Brands Quality Assurance Agreement, which includes information about our restricted substances list and other requirements, which communicates our expectations to suppliers.”

The company also noted in its sustainability report that: “Across all store brand products, we conduct regular tests and assessments to promote adherence to the guidelines set forth in our restricted substances list and to confirm that selected suppliers are adhering to requirements.”

CVS Health shared in the past that it regularly conducts supplier training on adhering to its safer chemical policy and beyond restricted substance list (BRSL) through on-site training classes, webinars, and printed materials. For example, in 2017, the company held a webinar series with all suppliers covered by its commitment to eliminate parabens, phthalates, and the most prevalent formaldehyde releasers to discuss processes and timelines and answer questions around implementation. The company noted in 2018 that: “we also host on-going engagements with our suppliers to ensure that they understand our goals and commitments and understand how we can support them.” In 2020, the company shared this update: “We work closely with our suppliers and offer them education and training support for working with CVS Pharmacy. This includes education and trianing [sic] on our restricted substances list.”

In the company’s 2016 sustainability report, CVS Health stated it has: “made advancements in ingredient and labeling transparency and verification.” CVS Health stated: “In 2016, we increased the rigor of our label claim substantiation process to give consumers more confidence in product label information. We completed additional due diligence on certifications that appear on labels to ensure reliability. We also began a process of partnering with our suppliers to validate the label claims on all of our store brand products in every category—more than 4,000 products. For example, suppliers who make claims based on studies must provide us with validation of the studies’ methodology and results; this is a more robust review than required under industry standards. This label claim substantiation process is in addition to the required registration and monitoring of product ingredients through WERCSmart, our supply chain compliance tool, as well as our ongoing product testing regime.” For example, if a supplier says a product is “free of Parabens,” that claim requires substantiation.

CVS Health has not disclosed that it requires suppliers to conduct testing in third-party laboratories and provide results to the retailer to ensure suppliers comply with its safer chemicals policy or BRSL.

Glossary of Terms

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

5 out of 17.5 points

In its 2019 sustainability report, CVS Health stated: “We use technology like the WERCSmart tool to capture supplier ingredient information for all chemical-based products. This helps us screen for restricted chemicals, monitor suppliers’ compliance with our procedures and track our performance toward achieving our goals.”

CVS previously shared that it “requires suppliers to disclose chemical-based ingredients in certain product categories and for new or reformulated products.” The disclosure is used, in part, to “identify non-compliant products that contain restricted ingredients or are on [its] list of [chemicals of consumer concern].” This allows CVS Health to screen both publicly disclosed ingredients and any proprietary blends, which are not disclosed to the public but are put into WERCS for screening while protecting suppliers’ “trade secrets.” The company went on to say the “CVS team receives a notification from WERCSmart when a product is identified as containing one of our restricted chemicals, so discussions can be initiated with the supplier and merchant for the product to determine the path forward.”

In 2020, the company further clarified: “While we do not currently require our Store Brand suppliers to disclose the complete formulation details for any fragrance ingredients or other generic ingredients in WERCSmart, we highlight [sic] encourage disclosure. We require our Store Brand suppliers to confirm all fragrance ingredients or other generic ingredients used in the products do not contain any of the applicable restricted substances list.”

The company previously noted that it utilizes (UL) PurView “to screen all store brand food ingredients,” but it is unclear if PurView is used to screen for indirect food additives, such as per- and polyfluoroalkyl substances (PFAS), ortho-phthalates, and bisphenols, in food packaging or other food-contact materials.

It is unclear if this disclosure specifically addresses known impurities.

Glossary of Terms

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

16 out of 26 points

In April 2017, CVS set public quantifiable goals to reformulate nearly 600 private-label products for phthalates, parabens, and the most prevalent formaldehyde donors from its CVS Health, Beauty 360, Essence of Beauty, and Blade product lines by the end of 2019. In its 2018 sustainability report, the company stated: “More than 75 percent of these 600 products will be reformulated by the first quarter of 2019 and the remaining 25 percent will be reformulated by the end of the year.” More recently, the company shared that it completed this reformulation, a notable achievement.

In 2020, the company also announced it had eliminated bisphenol S (BPS) and all other bisphenols in thermal receipt paper. This is a significant development to address the chemical footprint of the company’s operations. The company disclosed the alternative it has switched to: “We are working with the vendor Iconex and using their Pergafast paper.” This earned the company extra credit.

Sunscreens containing the chemicals oxybenzone and octinoxate have been banned in Hawaii starting in 2021. In 2018, the company began removing these chemicals from its store-brand sunscreens with SPF 50 and lower, and in its 2019 sustainability report shared that “[t]hese new compliant sunscreens are already shipping to CVS Pharmacy locations and we expect to have products fully rolled out in 2020.” The company confirmed that reformulation occurred nationally.

CVS Health has not publicly documented progress on reducing chemicals of high concern in beauty products of environmental justice concern, or plastics of environmental health concern, beyond regulatory compliance in the last three years.

Glossary of Terms

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

2 out of 16 points

The company has stated that its staff “actively identify and prioritize the replacement of [chemicals of consumer concern] with safer alternatives in certain CVS Brand categories, including beauty, baby and personal care, and food products.” CVS states it “use[s] clear guidelines with supplier partners to ensure that when an ingredient is removed, it is not replaced by a regrettable substitution.” The company goes on to state: “We ask suppliers to leverage industry resources such as hazardous chemical lists (including the Hazardous 100+) to evaluate alternative ingredients.”

However, the company has not disclosed additional details about how it ensures the replacement chemicals are actually safer.

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

8.5 out of 20 points

CVS’ Cosmetic Safety Policy is publicly available, as is its beyond restricted substance list (BRSL), which was first posted to its website in April 2017. The list, which the company has pledged to update every May, identifies CVS’ restricted chemicals by product category. The company last updated it in March 2019.

In late 2020, the company stated: “CVS Health updates our restricted substances list each spring with the release of our annual CSR report. The list was reviewed in early 2020 and no updates were identified at that time. The list will be reviewed again for opporutnties [sic] to update in early 2021.”

The company also stated: “Additionally, our Store Brands team is currently reviewing of checmical [sic] restrictions for Adult Care, Feminine Care, Oral Hygiene and Personal Intimacy items. We also anticipate expanding the restricted substances list to including restrictions on PFAS in our Spring Water products, and Glyphosate.”

CVS Health stated in 2020: “We are working with suppliers to ensure our Store Brands household cleaning products meet the California requirements for both online and on-product disclosures, and upon completion these products will be distributed nationwide. Similarly, we are working with our suppliers to ensure our Store Brand menstrual products meet the New York ingredient disclosure requirements, and upon completion these products will also be distributed nationwide. Additionally, we are also currently working on an initiative with SkinSafe for both Store Brand and non-Store Brand personal care products to provide more information to our customers.” The company receives an extra credit point for applying the disclosure required by California law to all relevant private-label cleaning products.

Glossary of Terms

Chemical Footprint: Evaluates its chemical footprint

1.5 out of 7.5 points

CVS Health became a signatory to the Chemical Footprint Project in 2016 and was the first major national pharmacy chain to do so. In its 2017 sustainability report, the company stated this signals “a commitment to chemical transparency across [its] supply chain.” However, since then, the company has not made any additional discernible progress on measuring its chemical footprint via the Chemical Footprint Project.

Glossary of Terms