Dollar Tree

Policy:Adopted a retailer safer chemicals policy

7.5 out of 23.5 points

Dollar Tree posted a Chemical Policy on the Corporate Governance and Merchandise Vendors sections of its website that describes its plan for managing chemicals of high concern (CHCs) in its products and notes that the plan is meant to go “above and beyond regulatory requirements.” The policy states: “We implemented our sustainable chemical plan in 2016 as an initiative to identify and reduce chemicals of high concern in our products. We are working with our suppliers to identify and implement safe alternatives to chemicals of high concern.” Dollar Tree clarifies in the policy that it primarily applies to chemicals on its priority list, stating: “We encourage our suppliers of national brand products and private label goods to find alternatives to chemicals listed on our priority chemical list.” Dollar Tree published this list on its website in August 2017.

Dollar Tree’s Commitment to Eliminate Priority Chemicals, containing its priority list of chemicals, states: “Dollar Tree is committed to the elimination of chemicals of high concern from our products by 2020. In December 2016 and January 2017, we sent letters to each of our suppliers communicating our commitment. We expect our suppliers to reduce and eliminate the use of all priority chemicals from our products.” The letter to suppliers stated: “Our goal is to eliminate the use of chemicals of high concern in our products by 2020.” The Commitment to Eliminate Priority Chemicals identifies “priority chemicals” to include 17 different chemicals or classes of chemicals, with some (lead, BPA, and asbestos) only considered “priority” when found in children’s products. The list includes chemicals that are not yet banned in the U.S.

The more recent Chemical Policy steps back slightly from the 2017 commitment by adding a qualification that the 2020 goal only applies to private-label products. As stated in the policy: “We have a goal of eliminating the chemicals identified on our priority chemical list from private label products by 2020 or sooner by working with suppliers on safer alternatives.”

However, the policy is somewhat vague, and the company 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 (PEHC). In addition, the policy does not appear to apply, as specified in the criteria, to operations, packaging, or locations outside the U.S. According to staff statements in 2020, Dollar Tree’s policy applies to beauty products of environmental justice concern (BPEJC) because it covers all cosmetics, but the company’s public BRSL does not appear to address key CHCs in these products.

Glossary of Terms

Oversight: Established management responsibilities and incentives

2.5 out of 5 points

Dollar Tree staff stated in 2020: “The Company’s Senior Vice President, Global Sourcing is specifically responsible for Dollar Tree’s Chemical Policy and its robust testing and product safety programs (‘Product Safety Program’).”

Dollar Tree 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

According to staff statements in 2020, despite statements that suggest otherwise in the 2020 Corporate Sustainability Report, “Dollar Tree’s testing [of its products] is continuous and ongoing,” and includes testing “to some but not all, of our priority chemicals on the list.”

The company’s Code of Vendor Conduct also states, in the “Environmental” section: “Vendors must, at a minimum, be fully compliant with all applicable environmental regulations…In addition, vendors must comply with any additional guidelines provided by Dollar Tree which may exceed standards set forth in existing laws and regulations.” Additionally, the Code notes: “this Code sets forth the basic requirements that all Vendors must meet in order to do business with our Company.” Staff confirmed in 2020 that the Vendor Code of Conduct is incorporated into supplier contracts and the additional guidelines referenced above do include Dollar Tree’s Chemical Policy.

Dollar Tree has not disclosed if it trains suppliers on the company’s safer chemicals policy, BRSL, or reporting requirements, or if 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. Dollar Tree staff stated in 2020 that the company does not allow suppliers to submit samples on their own for testing.

Glossary of Terms

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

8.5 out of 17.5 points

Dollar Tree’s Chemical Policy states: “We are challenging our suppliers and will require that they disclose full ingredients for formulated products that contain chemicals as part of their base formulation. Examples include but are not limited to categories such as household cleaning products, health and beauty products, and hardware products. All ingredients will be disclosed by suppliers and entered into The WERCS for formulated products containing chemicals as part of the base formulation.” In 2020, Dollar Tree staff confirmed that this disclosure requirement for all formulated products applies to both private label and brand name suppliers as well as to impurities and fragrance components.

An extra credit point is awarded for the company applying this disclosure to several major product categories, which is greater than the number of major product categories specified in the rubric. Staff noted in 2020 that product categories addressed, beyond those listed above, include household fragrances, writing instruments, automotive oils and chemicals, vitamins, batteries, adhesives, and candles.

The company has not yet disclosed metrics in implementing this disclosure.

Glossary of Terms

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

17 out of 26 points

In February 2021, the company stated that it had phased out the 17 priority chemicals that it set a goal in 2017 to eliminate from its private-label products: “Dollar Tree has eliminated the priority chemicals from our active private label products.” At least some of these chemicals include those that are not yet banned in the U.S., so Dollar Tree receives credit for eliminating multiple CHCs from multiple major product categories.

The company also noted in December 2020 that, for children’s products, it has banned lead and BPA “for many years” and “has banned asbestos since 2015.”

Furthermore, on a related note, the New York Department of State’s Division of Consumer Protection found extremely high (24.6%) levels of a phthalate in violation of federal law in a fashion doll sold at a Dollar Tree store. This shows the need for Dollar Tree to expand its policy beyond its 17 initial priority chemicals (still going beyond regulatory compliance) and act swiftly to phase them out.

Dollar Tree reported a few alternatives, DOTP (Dioctyl terephthalate) and DINCH (Hexamoll), that it had been working on with suppliers to replace phthalates. Extra credit is awarded for the company reporting on the alternatives it moved to and for choosing alternatives that do not appear to be rated GreenScreen Benchmark-1 or List Translator-1.

Glossary of Terms

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

2 out of 16 points

Dollar Tree’s Chemical Policy mentions an explicit preference for safer alternatives but provides no details on how the company evaluates alternatives. The policy states: “We are working with our suppliers to identify and implement safe alternatives to chemicals of high concern” and “[w]e have a goal of eliminating the chemicals identified on our priority chemical list from private label products by 2020 or sooner by working with suppliers on safer alternatives.” The company stated in 2020 that it is “working with suppliers to incorporate natural ingredients for base formulations and fragrances” but did not verify how it is confirming these natural ingredients are safer.

The company needs to affirmatively ensure all of its substitutes are safer and not regrettable.

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

8.25 out of 20 points

Dollar Tree’s safer chemicals policy (entitled Chemical Policy) and beyond restricted substance list (BRSL) are publicly available on the company’s corporate governance website. The company has no MRSL or BRML.

Dollar Tree’s Chemical Policy states that the company “will encourage our suppliers of national brand products to disclose product ingredients online by product.” Because the company does not explicitly state that national brand products should disclose all ingredients going beyond regulatory compliance, and the statement does not address disclosure on product packaging, we awarded partial credit.

Glossary of Terms

Chemical Footprint: Evaluates its chemical footprint

4.5 out of 7.5 points

Dollar Tree participated in the Chemical Footprint Project (CFP) survey in 2019 (covering its 2018 activities) and participated again in 2020 for a portion of its product portfolio but did not indicate any plans to disclose its survey results and score for 2020. The company plans on participating going forward. Dollar Tree has also become a signatory to the CFP.

Glossary of Terms