Dollar General

Policy:Adopted a retailer safer chemicals policy

10 out of 23.5 points

In November 2019, Dollar General shared with us a written safer chemicals policy, which states: “[w]here practicable and in keeping with the Company’s obligation to create long-term value for its shareholders as a whole, the Company will endeavor to go beyond what is required by law and take additional steps to reduce or eliminate certain high priority chemicals (the ‘Chemicals’) … in and from its private label core formulated products in certain departments (initially, Home Cleaning and Beauty & Personal Care) (the ‘Products’).” The company’s 2020 Serving Others report (its sustainability report) states that the policy was announced in fall 2019, although the policy was first published by the company in this Serving Others report that is dated “as of June 2020.”

This policy references a beyond restricted substance list (BRSL) of eight chemicals: formaldehyde, toluene, triclosan, nonylphenol ethoxylates, butylparaben, propylparaben, trichloroethylene, and triclocarban and notes that Dollar General will require these chemicals to be eliminated from the target product categories by December 2022, although the summary of the policy in the report frames this as an expectation as opposed to a requirement. The report quotes the Executive Vice President and Chief Merchandising Officer as saying: “… we look forward to working collaboratively with our vendor partners to remove identified chemicals from our supply chain.” The company will also encourage national brand suppliers of products in these categories “to reduce or eliminate their use of the Chemicals in products sold to Dollar General.” Dollar General pledged to “[r]eview and evaluate the list of products and chemicals covered by this policy on an annual basis.” At the May 2020 shareholder meeting, Dollar General reiterated that the company “will be revising the list of products and chemicals covered by this policy on an annual basis.” Similarly, the 2020 Serving Others report also notes that after the covered formulated private brand suppliers register their products’ formulation with WERCSmart, the company expects “to evaluate the expansion of the Restricted Substances list to other chemicals.” In February 2021, the company stated: “We intend to evaluate additional chemicals for addition to our RSL, with any additions likely not taking place until after we have achieved our 2022 elimination goal.”

Dollar General does not have any locations outside the U.S.

Dollar General does not have a publicly available manufacturing restricted substance list (MRSL) or a publicly available beyond restricted material list (BRML) for plastics of environmental health concern (PEHCs). The policy does not appear to apply, as specified in the criteria, to operations or packaging.

The company sells products marketed primarily to women of color, such as through the “Multicultural Hair Care” category. According to staff statements in February 2021, Dollar General’s policy and BRSL applies to these beauty products of environmental justice concern (BPEJC), but the company’s public BRSL does not appear to address key CHCs such as hydroquinone in these products.

Glossary of Terms

Oversight: Established management responsibilities and incentives

2.5 out of 5 points

Dollar General’s VP of Government & Public Relations has been assigned responsibility for the company’s safer chemicals policy.

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

Glossary of Terms

Accountability: Ensures supply chain accountability

3.75 out of 15 points

Dollar General stated in February 2021 that its safer chemicals policy requirements are integrated into supplier terms and conditions on vendor quote sheets, and also notes that “our business contracts reference these obligations.”

The company noted in February 2021 that it has communicated to its own-brand suppliers about the elimination of chemicals on the BRSL by the end of fiscal 2022, and disclosed that it conducts training, presumably on its 2022 elimination commitment, “via email communications and informal communications with vendors.” Partial credit is awarded.

Dollar General has not specifically 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 or BRSL.

In February 2021, the company confirmed that it only partners with third-party testing laboratories to conduct testing to ensure regulatory compliance, and this “has not yet been extended to testing [beyond regulatory compliance] to validate the results of the RSL screening we conduct on the WERCSmart platform.”

Glossary of Terms

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

4.5 out of 17.5 points

Dollar General staff told us that as of February 2021, the company’s safer chemicals policy “currently encourages suppliers to disclose [via WERCSmart] full chemical ingredient information, including the constituents of generic ingredient components,” and added that “[o]wn-brand suppliers of formulated products are our current focus.” Half credit is awarded relative to the 6.5-point level.

The version of Dollar General’s policy shared with us and with Chemical Watch last year included a deadline of March 31, 2020 for suppliers to register product formulations in WERCSmart. While the version of the policy published in the 2020 Serving Others report did not note this deadline, the company indicated to us in February 2021 that it maintained the deadline internally, so partial extra credit of 0.25 points is awarded.

Partial extra credit of 0.5 point is also awarded because the policy to encourage disclosure applies to formulated products in two major categories of private-label products: health & beauty and cleaning supplies. The company also reported metrics on the implementation of its disclosure policy: 97% of private-brand suppliers of formulated products in the relevant categories have provided Dollar General with the consents required to screen their formulations. 0.5 point of extra credit is awarded for this as well.

The company stated: “Note that we are also using WERCSmart as a resource for assessing the prevalence of RSL chemicals in our overall assortment and the level of ingredient transparency achieved by our suppliers.” Staff told us that 70% of “other brand” suppliers have given the company the consent necessary to screen those products, showing that the company is also making progress outside its private-label products.

Glossary of Terms

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

3 out of 26 points

At its annual shareholder meeting in May 2020, Dollar General stated in response to a question: “We do not carry any baby powder products that contain talcum, including Johnson & Johnson-branded products.” Dollar General later confirmed that the company removed products with talc “as well as anti-bacterial soaps containing triclosan from our assortment” in the last three years. Since FDA appears to have banned the marketing of triclosan-containing antibacterial soap products, we cannot award credit for that portion of the statement. Since the products with talc may not add up to an entire product category (even minor), we award 3 points for Dollar General reporting that it removed products with talc. Talc may be contaminated with asbestos, a chemical of high concern.

Dollar General has not publicly documented progress on reducing plastics of environmental health concern beyond regulatory compliance in the last three years.

The company notes in its 2020 Serving Others report that “[i]n 2019, Dollar General updated the material composition of its DG Home™ Premium Plate products… [to be made] of compostable sugarcane and bamboo pulp…” Molded fiber products made from sugarcane waste may be treated with PFAS for grease or water resistance, so the company should conduct testing and inquire with its supply chain to ensure the products are PFAS-free.

Glossary of Terms

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

4.5 out of 16 points

In February 2021, Dollar General confirmed that the company encourages own-brand suppliers “to avoid regrettable substitutions and to select ingredients that are on EPA’s Safer Chemical Ingredient List” when communicating with those suppliers about the BRSL elimination goal.

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

8.25 out of 20 points

Dollar General has published its safer chemicals policy and its BRSL in its 2020 Serving Others report, dated “as of June 2020.”

Dollar General’s new safer chemicals policy states that the company intends to “[e]ncourage core private label suppliers in the [home cleaning and beauty and personal care] departments to improve transparency with consumers regarding the ingredients in their products.” Partial credit is awarded as it is unclear how close this will come to achieving any of the levels of public disclosure specified in the rubric.

Glossary of Terms