REI

Policy:Adopted a retailer safer chemicals policy

13.75 out of 23.5 points

REI has a Sustainable Chemistry Guide and Restricted Substances List (RSL), amounting to a beyond restricted substance list (BRSL), for its private-label REI Co-op and REI Co-op Cycles brands, and also has a set of Product Impact Standards, which includes additional guidance, and a BRSL for both private-label and brand-name suppliers. The document containing the guide and RSL states: “[t]o control hazards, our goal is to identify chemicals of concern and replace them with better alternatives where they exist.” The company states that the guide and RSL are aligned with bluesign.

REI’s Sustainable Chemistry Guide and Restricted Substance list (RSL) was last updated in November 2019, and sets out requirements that private-label suppliers are required to meet as a prerequisite for doing business with REI. The new expectations in this version “must be implemented by January 1, 2020.” The RSL is based on the bluesign system RSL. The company states that “[a]ll REI Co-op Brand suppliers must comply with the RSL for finished products. We also encourage suppliers to comply with the RSL,” which is a “larger, comprehensive list that includes all global substance restrictions beyond finished products.”

The private label RSL identifies five categories of “priority chemicals” that REI has identified as “top priority for elimination or replacement”: 1) Antimicrobials and biocides; 2) flame retardant chemicals; 3) PFAS; 4) PVC; and 5) solvents of high concern. This is all in addition to other chemicals of high concern (CHCs) on its BRSL. The company states it is “committed to eliminating FR chemicals where they are unnecessary and partnering with standard-setting organizations and regulators to reform outdated flammability requirements.” The company prohibits long-chain PFAS but still allows short-chain PFAS, which is a concern especially as the company considers short-chain PFAS as “a positive stepping stone.” At the same time the company states, “We avoid application of water repellant chemicals where they are not needed for a performance benefit and are exploring PFAS-free alternatives for apparel and gear.” PVC is prohibited in private-label gear and apparel except where alternatives have not been identified for certain bicycle subcomponents and it has eliminated PVC from all of its Co-op Brand apparel and camping products. The company has a goal to eliminate solvents that are carcinogenic, mutagenic, or reproductive toxicants (CMRs).

REI’s private label RSL also includes a “usage ban” of many chemicals that are prohibited in manufacturing, essentially amounting to a private label MRSL.

REI’s Product Impact Standards includes a BRSL for brand-name products stating the company expects (these expectations are actually requirements) suppliers to restrict approximately 20 flame retardants in camping shelters sold at REI, BPA in all products supplied to REI that come into contact with food or liquids for human consumption, long-chain PFAS in all apparel products, and oxybenzone in sunscreens and formulated sun-protection products. The expectations for flame retardants in camping shelters, long-chain PFAS in apparel, and oxybenzone in sunscreens and formulated sun-protection products go into effect for Fall 2020 product lines. The company also states that brand partners are encouraged to align with each applicable expectation as soon as possible. For “new brand partners,” the company allows an 18-month transition period from the time of first purchase order. In December 2020 the company clarified: “Brands sign an agreement with REI where they agree to abide by these expectations.”

The restrictions on hazardous chemicals in the Product Impact Standards apply to specific product categories – not all categories where the hazardous chemicals may be used, and the restrictions don’t always cover a full class of chemicals. For example, the company does not restrict PFAS as a class or flame retardants in other products where they may be found such as apparel. The company unfortunately states that it believes the transition to short-chain PFAS represents a “positive stepping stone as alternatives are developed and become commercially viable.” The company also notes that brands that sell products in categories regulated by the U.S. FDA or U.S. Department of Agriculture do not need to have a separate RSL for products in these categories. This is problematic given the FDA’s very poor track record in restricting toxic chemicals such as phthalates, bisphenols, and PFAS in food contact materials.

In November 2020 the company stated, “We have focused the scope of REI’s Product Impact Standards on the product categories where we know we have a significant opportunity to drive positive change. In some categories where we make up only a small part of the market and/or have a limited degree of influence, we know that our ability to drive change is less significant. As a result, we have focused the scope of our standards on those areas where we believe we can have the most meaningful positive impact. We intend to expand the scope of our standards over time as our ability to influence in other categories grows.”

In December 2020 the company updated and rebranded the standards. The updated standards include a new restriction stating that “all ski wax products and gear and clothing treatments supplied to REI be free of long-chain and short-chain PFAS” by spring 2023. The company also stated that “footwear, packs, sleeping bags, and tents supplied to REI be free of long-chain PFAS” by spring 2023.

REI also has Sustainable Packaging Guidelines for both private-label and brand name suppliers which recommend, though do not require, suppliers avoid PVC and polystyrene (rigid or foam) in plastic packaging. This amounts to a beyond restricted materials list (BRML) for plastics of environmental health concern (PEHCs) and partial credit is awarded because suppliers are only recommended to avoid it. The company also recommends avoiding PVC in polybags, and the company’s shipping and receiving requirements state suppliers should not use plastics including expanded polystyrene. The company’s packaging guidelines also provides guidance for adhesives, coatings, inks, and bleaching process for packaging, though does not outright restrict any chemicals of high concern in these functional uses for packaging and so no credit is awarded for a packaging BRSL.

The policy appears to apply to all locations.

REI’s safer chemicals policy does not appear to apply, as specified in the criteria, to operations.

Glossary of Terms

Oversight: Established management responsibilities and incentives

2.5 out of 5 points

REI has at least one sustainability manager in charge of implementing its chemicals policy.

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

Glossary of Terms

Accountability: Ensures supply chain accountability

8.75 out of 15 points

REI’s Sustainable Chemistry Guide provides a set of clear supplier responsibilities for private brands and states that “[c]omplying with this policy by adhering with these responsibilities is a prerequisite of doing business with REI.” Suppliers must fill out a document acknowledging receipt and understanding of the RSL confirming they accept the terms. The company states that it “reserves the right to cancel orders and terminate a business relationship if the Supplier fails to meet any of these requirements.” In November 2020 the company explained, “our contracts with our private brands suppliers include the expectation that suppliers are in alignment with REI’s expectations, including those related to chemicals management practices. Also, each year when REI updates our RSL, suppliers must sign and return a document that confirms their receipt and understanding of REI’s chemicals management expectations.”

The guide states that suppliers must “[u]pon request, provide REI with existing compliance documentation or laboratory test results” and that “[m]aterial, component, and product testing may be required by REI at any stage of manufacturing to demonstrate compliance with the [RSL]. Testing may be random or part of REI’s scheduled testing program.” The guide also provides recommendations, though not requirements, on specific chemicals to test in various product categories. Testing of certain substances on the RSL is either “recommended” or “strongly recommended” and suggestions on specific test methods are provided. Partial credit is awarded for testing.

In November 2020 the company further explained: “For REI’s private brand, we conduct risk-based chemical testing with every product season. We evaluate risk based on a variety of factors, including material type, end use, chemical treatments, and others. PFOA, PFOS, and the list of prohibited flame retardants are among the substances we test for as part of our RSL program, and they are subject to a usage ban.”

The company helped create the Outdoor Industry Association’s Chemicals Management Guide & Training for Manufacturers. In November 2020 the company also stated, “In addition, we conduct regular trainings with suppliers that include the topics of chemicals management and RSL testing, and we require that suppliers have in place a Compliance Control Plan (CCP), which outlines how they will manage compliance with REI’s RSL requirements and how they’ll promote continuous improvement of their practices on an ongoing basis. We review the CCP with suppliers annually.”

Glossary of Terms

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

6 out of 17.5 points

The company states that “our approach to sustainable chemistry is rooted in transparency and partnerships with suppliers…to learn about the chemistry involved in every aspect of manufacturing.”

In November 2020, the company also explained: “We take the following actions for all private-label products. Since we don’t sell formulated products under our own brand, we are limited in our ability to require suppliers to disclose full ingredient information for our products. That said, we do require that our private-branded suppliers submit chemical inventory lists (CIL) to REI bi-annually and that they maintain up-to-date Safety Data Sheet (SDS) records for each chemical in their inventory. In addition, many of our suppliers are bluesign System Partners, and many of the materials we use for our privately branded products are bluesign approved. bluesign has robust requirements regarding transparency to the chemistry used in a facility, including that the input chemistry be screened and approved. It could be argued that requiring suppliers to provide a comprehensive CIL for all chemicals in use in their facility is the equivalent of requiring full chemical ingredient disclosure.”

In January 2021, the company further clarified: “The chemical inventory list includes intentionally used process chemicals. REI’s RSL testing program helps prevent impurities or byproducts from making their way into finished materials and products. In addition, we conduct audits either directly or via verification of a facility’s Higg Index Facility Environmental Module assessment. In both cases, the facility’s chemicals management practices are assessed and the facility is required to address any noteworthy issues that are identified…bluesign requires that manufacturing sites establish and maintain a chemical inventory list of all chemical products or hazardous materials handled, transported, used, and stored at the site. Each chemical used at the site must also be approved by bluesign. bluesign has strict requirements for quality assurance and requires that suppliers undergo a chemical assessment that evaluates the chemical inventory and gives advice and a rating to each chemical, with the goal of driving continuous improvement of the chemical inventory being used at the site. Overall, the bluesign system helps avoid impurities by requiring that chemicals be approved, and it helps avoid undesired byproducts by evaluating suppliers’ quality assurance practices and chemical inventories.”

An extra credit point is awarded for this disclosure applying to multiple major private label product categories.

Glossary of Terms

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

15 out of 26 points

REI stated that in 2017 it voluntarily eliminated “certain flame retardants from REI Co-op and Co-op Cycles products,” which it completed with its Fall 2018 product lines.

REI also shared that in 2019, it completed the “phase-out of long-chain PFAS across all REI Co-op and Co-op Cycles products” and began “adopting a new flammability test method that will allow certain REI Co-op tents to avoid the use of flame retardant treatments.” REI also stated that in 2020, it “will bring to market, with the Fall 2020 product season, our first flame retardant-free tent since before it became the norm many years ago for outdoor brands to apply flame retardant finishes to tents.” The first tent is now available for sale and the company plans to replace all other tents as soon as they are able.

In December 2020 the company launched new standards for brands including new restrictions on ski wax and gear, stating: “REI expects that all ski wax products and gear and clothing treatments supplied to REI be free of long-chain and short-chain PFAS” by spring 2023. The company also stated, “REI expects that all footwear, packs, sleeping bags, and tents supplied to REI be free of long-chain PFAS” by spring 2023.

Additionally, in 2019 the company added a number of new chemicals to its beyond restricted substance list for its REI Co-op and Co-op Cycles products, which must have been implemented by January 1, 2020.

Glossary of Terms

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

3.25 out of 16 points

The guide and RSL states: “[t]o control hazards, our goal is to identify chemicals of concern and replace them with better alternatives where they exist. Where alternatives do not exist, we seek out new opportunities for innovation to fill the void…[o]ur ambition to adopt green chemistry innovations plays a growing role in how we design products and partner with existing and new suppliers.”

More specifically, the company states for its private-label BRSL that “[s]uppliers can find preferred, RSL compliant chemicals through the bluesign FINDER chemical database,” which the company notes “provides a list of approved chemicals that have been reviewed for hazards to people and the environment and exposure potential during manufacturing.” The company states that all chemicals in the database can be used to meet its sustainable chemistry goals, but the database includes many hazardous chemicals, particularly more than 100 short-chain PFAS, which is concerning given the persistent toxic hazards of these chemicals. This is not aligned with the company’s stated goals to eliminate PFAS. Partial credit is awarded.

REI has also shared guidance or other information for alternatives for certain categories of chemicals. For antimicrobials used for odor control in private-label products, they “use only bluesign certified options to ensure treatments have undergone evaluation for toxicity and efficacy.” On PFAS, they are “exploring PFAS-free alternatives for apparel and gear.” On solvents: “REI is pursuing water-based coatings, alternative cleaning agents for equipment and material preparation, and training of factory workers around proper chemical selection, handling, and disposal.”

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

7.5 out of 20 points

REI’s safer chemicals policy, beyond restricted substance lists (BRSL), manufacturing restricted substance list (MRSL), and beyond restricted material list (BRML) are all publicly available on its website.

REI 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

5.25 out of 8.5 points

REI encourages private-label and brand-name suppliers to meet credible third-party safer chemicals standards for apparel such as bluesign and the Leather Working Group certification. The company states it “will highlight these attributes for our customers. We ask that brands communicate to REI which of their products have these attributes.” The company also stated in 2020: “REI is a bluesign System Partner and bluesign approved materials are used in REI Co-op and Co-op Cycles products wherever they are available. bluesign is the leading system for managing the chemical inputs to manufacturing process for textiles-based products.” Partial credit is awarded given the limitations of bluesign in addressing PFAS as a class.

Glossary of Terms