Target

Policy:Adopted a retailer safer chemicals policy

18.25 out of 23.5 points

In 2017, Target announced a chemicals strategy, policy, and goals, which state the company is “committed to driving transparency, proactive chemical management and innovation across all of [its] owned and national brand consumer products, and operations.” The policy applies to the company’s “entire value chain, operations and every product” it sells, including both private-label and brand-name products. The company states it: “will utilize hazard profiles to prioritize substances for restriction in products and processes, with an emphasis on the impact these substances could have on workers, guests, and communities…Target will utilize Restricted Substances Lists (RSLs) and Manufacturing Restricted Substances Lists (MRSLs) to minimize and, where possible, remove these prioritized chemicals from [its] products and processes.” Since announcing the policy, the company has adopted the Zero Discharge of Hazardous Chemicals (ZDHC) MRSL.

The policy is accompanied by clear goals and timelines to remove:
* phthalates, propyl-paraben, butyl-paraben, formaldehyde, formaldehyde-donors, and NPE’s from beauty, baby care, personal care and household cleaning product categories by 2020;
* added Perfluorinated Chemicals (PFC’s) from textile products by 2022; and
* added flame retardants that are potential carcinogens or pose harm to the guest, workers, or communities from textiles by 2022.

Target has a goal to: “work to eliminate expanded polystyrene foam from our owned-brand packaging by 2022” and reported in 2019 that it has “developed an approach that we plan to roll out in 2020 to build momentum toward our 2022 goal.” In 2020, Target announced that it will: “(w)ork toward elimination of the following problematic plastics in owned-brand packaging: polystyrene, [polyvinyl chloride (PVC)], [polyvinylidene chloride (PVDC)], and carbon black” by 2025. In 2007, the company first announced a commitment to systematically reduce PVC in products and packaging, but the company has not publicly disclosed progress on this in many years.

In 2020, Target announced it was eliminating bisphenols in thermal receipt paper: “(b)y end of year 2020, Target expects to fully convert to phenol-free receipt paper for use in all standard and mobile-device checkout lanes.” This is a significant step to address chemicals of concern in its operations.

Target shared that its policy applies to all beauty products, including those marketed to or made for women of color. The company stated: “We continue to explore the unique challenges that certain beauty products present within our assortment, and in 2021 will be evaluating the overall effectiveness and rate of adoption of our chemicals policy goals and Target clean standard of multicultural beauty compared to the entire assortment.” The company also shared that it is currently screening its formulated essentials assortment for a list of chemicals of concern and is interested in helping to drive alignment around a list of chemicals of concern for beauty products of environmental justice concern. Partial credit is awarded for these efforts.

The policy applies to all store locations.

The chemical strategy does not appear to meaningfully apply to chemicals of high concern (CHCs) in packaging.

Glossary of Terms

Accountability: Ensures supply chain accountability

7.5 out of 15 points

In 2018, Target published guidance for suppliers to comply with its safer chemicals policy for textiles, cleaning, baby, beauty, and personal care products. For textiles, the company notes in a guidance document that “the following table outlines the restricted chemicals, their limits as well as the required test methods. In order to be in compliance with Target’s [restricted substance list (RSL)] requirements, restricted substances must not exceed the RSL limits.” The tables provided include the specific chemicals currently restricted in textiles, but surprisingly, they do not currently include key flame retardants and all PFAS chemicals commonly used in textiles. Additionally, the scope of the guidance for furniture is limited to fabric, while flame retardants are commonly found in the foam, and it does not address infant/children’s car seats. The company also requires third-party testing for private-label textiles products that meet credible third-party safer chemicals standards such as OEKO-TEX.

In 2020, the company expanded its RSL for textiles by including all PFAS as a class, updated the guidance to address long-chain PFAS, continued to roll out its MRSL with its strategic business partners in apparel, and set a goal to complete all apparel training by the end of 2020.

In 2019, the company stated: “We delineate supplier expectations both publicly via our website as well as in their contracts. The Partners Online (POL) platform in itself serves as the contractual obligations [sic] that suppliers must meet in order to do business with Target. All of our chemical policy goals and requirements are listed on POL and considered part of the supplier contracts.” Target went on to note: “We conducted vendor training on the RSL in 2018 and will also be planning vendor training in the end of 2019 for a variety of sustainability objectives, including chemicals and [manufacturing restricted substance list].”

The company has also stated: “We have and will continue to provide our vendors guidance on our RSL, MRSL and chemical management via our on-line supplier platform.” The guidance for formulated products in cleaning, baby, beauty, and personal care is primarily focused on business-to-business disclosure and does not currently include requirements around third-party testing.

Target has not specifically disclosed that it conducts its own testing to ensure suppliers comply with its safer chemicals policy.

Glossary of Terms

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

9.5 out of 17.5 points

The company states: “Target will strive for full visibility to chemicals contained in and used to make the products we sell and use in our operations. Target will work toward the long-term goal of full material disclosure for all products and processes across all categories and in our operations. Target will approach transparency in the supply chain as an iterative process, continually adding more product categories and achieving increasing levels of transparency.” Along with the policy, in 2017, the company set a goal to “achieve transparency to all ingredients, including generics such as ‘fragrance’, in beauty, baby care, personal care and household cleaning formulated products by 2020.” The company has not disclosed whether it has met this 2020 goal.

In 2018, the company provided new specific guidance to suppliers on complying with its disclosure goals, which applies to all intentionally added ingredients, including fragrance ingredients, but does not include substances that may migrate from packaging or other unknown sources of contamination. The company set a deadline of December 31, 2018 for suppliers to grant permission via the WERCS for this data to be disclosed to Target. The document says suppliers “must” disclose the chemical information to WERCSmart.

In September 2020, the company disclosed that the: “percentage of SKUs in beauty, baby care, personal care and household cleaning formulated products to which we have access to screen ingredients” in 2019 was 76%, the same percentage as the year prior. It also shared that the percentage of SKUs with transparency for all ingredients, including generics such as fragrance, had increased from 22% in 2018 to 35% in 2019. The company did not describe how it planned to achieve its 100% disclosure goal by 2020.

The company is also working on transparency for a new private-label line of goods. Target stated in September 2019: “With the launch of our Smartly brand of essentials and personal care products in October 2018, we are working toward our ambitious transparency and chemical management requirements. Smartly was made possible through our team’s engagement and collaboration with select fragrance houses. We were able to develop a process that allows screening of ingredients without revealing the intellectual property behind formulations, something that has been a roadblock to full transparency in the industry until now. We are evolving the full line of Smartly products to meet our requirements by the end of 2020.”

Extra credit is awarded for this disclosure policy applying to multiple major categories and for the company disclosing the percentage of suppliers meeting its disclosure goals and setting a deadline for suppliers to disclose ingredients to Target.

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

In September 2020, the company announced progress in meeting its goals to address chemicals of concern in formulated products and textiles. It reported that in 2019, 47% of SKUs in beauty, baby care, personal care and household cleaning product categories were formulated without phthalates, propylparaben, butylparaben, formaldehyde, formaldehyde donors or nonylphenol ethoxylates (NPEs). This is up from 44% in 2018 and 7% in 2017. The company did not describe how it would meet its 100% elimination goal by the end of 2020.

In 2020, Target announced progress in addressing PFAS in textiles since 2019: “(f)or owned-brand textiles, we were able to remove PFCs from our apparel products. As we make progress on removing PFCs from additional categories, we are expanding the scope of chemistry that we are evaluating to a broader class of chemistry that PFCs are a part of: perfluorinated alkyl substances (PFAS).”

Also in 2020, the company disclosed it was working to address toxic flame retardants in children’s car seats: “(i)n 2019, we reviewed opportunities among children’s product categories. As a result, we are seeking to expand our selection of car seats without flame retardants and hosted a dialogue with our toy suppliers at the NY Toy Fair to identify common challenges and opportunities.”

The company stated in its 2019 sustainability report that it has launched “Everspring, a new household essentials owned brand, which combines efficacy, transparency and great design…The entire assortment of formulated products complies with Target Clean and was built on the foundation of our chemicals policy.”

In 2020, Target announced it was eliminating bisphenols in thermal receipt paper: “(b)y end of year 2020, Target expects to fully convert to phenol-free receipt paper for use in all standard and mobile-device checkout lanes.” This is a significant step to address chemicals of concern in its operations. The company also announced that it will: “(w)ork toward elimination of the following problematic plastics in owned-brand packaging: polystyrene, PVC, PVDC and carbon black.”

Target has not publicly documented progress on reducing chemicals of high concern in beauty products of environmental justice concern.

Glossary of Terms

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

8.5 out of 16 points

The company states: “Target will actively pursue and promote new approaches to chemicals development and the commercialization of safer alternatives. Target will contribute resources and expertise to initiatives working to develop safe alternatives for chemicals where no viable alternatives currently exist. Target will support innovation which utilizes green chemistry principles in the development, design, and manufacturing of consumer products.” The company has also noted, when eliminating chemicals of high concern (CHCs), that: “Target will actively pursue the development of safer alternatives to achieve our goals. We will work to remove chemicals or find alternatives to those chemicals that could pose a risk to our guests, workers and community. When changes are made, we will ensure the integrity and safety of our products.”

In 2019, the company shared this notable update: “We are currently developing detailed guidance on safer alternatives which will articulate our preference as well as serve as a guide to suppliers.” The company has published this guidance on its vendor platform. It includes helpful tools such as the OECD Substitution and Alternatives Assessment Toolbox, BizNGO’s Chemical Alternatives Assessment Protocol, and the Lowell Center for Sustainable Production’s Alternatives Assessment Framework.

In 2019, Target stated that it is working to promote alternatives to flame retardants from children’s sleepwear. It stated in its 2019 sustainability report that: “In March 2019, Target hosted a hackathon to bring the industry together to spark innovation on the removal of undesirable flame retardant chemicals from children’s loose-fit sleepwear. Together with brands, other industry partners and students, innovative proposals were developed that would meet regulatory requirements (e.g., flammability), guest preferences and sustainability goals. Target provided a stipend to the winning team and is working with the team to test the viability of its idea.” More research has been conducted since the hackathon, but unfortunately none of the hackathon ideas have proved commercially viable.

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

10 out of 20 points

Target’s safer chemicals policy is publicly available, and it has posted beyond restricted substance lists (BRSLs) for the relevant product categories. Target has publicly disclosed that it restricts phthalates, propyl-paraben, butyl-paraben, formaldehyde, formaldehyde-donors, and NPE’s in beauty, baby care, personal care, and household cleaning products. In 2018, Target published a spreadsheet of the chemicals it is targeting for reduction and elimination in these product categories with the specific names of chemicals in each class including CAS numbers.

The company has also disclosed that it is restricting perfluorinated chemicals (PFCs) and “added flame retardants that are potential carcinogens in textiles” and subsequently posted a guidance document identifying those the company was restricting. The Zero Discharge of Hazardous Chemicals manufacturing restricted substance list (ZDHC MRSL) that Target utilizes is publicly available.

Target states on its website: “We encourage all supply chain partners to find paths allowing full material disclosure to consumers, and support those who are actively going above and beyond the current transparency regulations. View our three-page vendor guidance on meeting our current ingredient and transparency expectations, which represent a step-wise approach to the full consumer disclosure we ultimately seek.” Target has not disclosed progress since then.

An extra point is awarded for the retailer applying the most stringent ingredient transparency standard adopted by a U.S. state to all of its relevant private-label cleaning products sold in North America, both online and on product packaging. Target is applying the California Cleaning Product Right to Know Act of 2017 (SB 258) to all owned-brand cleaning products.

Glossary of Terms

Chemical Footprint: Evaluates its chemical footprint

6 out of 7.5 points

Target is a signatory to the Chemical Footprint Project (CFP) and participated in the 2019 and 2020 CFP surveys.

Glossary of Terms

Third-party Standards: Promotes credible third-party standards for safer products

5.25 out of 8.5 points

In 2017, Target announced: “aligning with this strategy to remove unwanted chemicals from our supply chain, all of our Target owned-brand towels are now [OEKO-TEX] certified, a global testing and certification system for textile products at all processing levels.” In that year, Target also announced a new baby brand, Cloud Island, a line of nearly 500 products that meets the OEKO-TEX Standard 100, which restricts more than 300 chemicals of high concern (CHCs). Target has also reformulated most of its Up & Up liquid hand soap products to meet the EPA Safer Choice criteria, and Target’s Cat & Jack organic pajamas meet the Global Organic Textile Standard (GOTS), which prohibits numerous CHCs. Partial credit is awarded given the limitations of OEKO-TEX.

The company has not publicly disclosed progress in certifying its owned brands to credible third-party safer chemicals standards in 2020.

Glossary of Terms