Key Findings
- Subway receives credit for a BRSL for cleaning products used in all restaurants.
- Despite substantial public attention to toxic indirect food additives, including PFAS, phthalates and bisphenols as well as to plastics of environmental health concern (PEHCs), there is no indication that Subway is taking action to address these challenges.
Recommendations for Subway
- Subway can make progress by developing a public written safer chemicals policy covering any toxic indirect food additives that may be in food contact materials, addressing at least bisphenols, per- and polyfluoroalkyl substances (PFAS), and phthalates.
- We urge the company to set public quantifiable goals with clear timelines to eliminate and safely replace both PEHCs in its packaging and any toxic indirect food additives that may be in food contact materials. Subway should also publicly disclose the alternatives used to replace chemicals of high concern (CHCs), after eliminating them.
- The company should become a signatory to the Chemical Footprint Project and pilot it with key private-label suppliers.
Grade History
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How does Subway compare to its competitors?
Analysis of Subway
Oversight: Established management responsibilities and incentives
Disclosure: Requires suppliers to report use of chemicals in products to retailer
Action: Reduced or eliminated chemicals of high concern (CHCs) or plastics of environmental health concern (PEHCs) within the last three years
Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes
Transparency: Demonstrates a commitment to transparency and public disclosure
Third-party Standards: Promotes credible third-party standards for safer products
Extra Credit:
Joint Announcement: Public commitment demonstrated through joint announcement
Continuous Improvement: Shows continuous improvement by steadily expanding safer chemicals policy
Collaboration: Actively participates in collaborative process to promote safer chemicals
Impact Investment: Investing financial resources into independent research into safer alternatives and/or green chemistry solutions