The Home Depot

Policy:Adopted a retailer safer chemicals policy

11.25 out of 23.5 points

In 2017, The Home Depot announced its Chemical Strategy, the first comprehensive safer chemicals policy of a North American home improvement chain. It includes commitments to restrict hazardous chemicals such as flame retardants, PFOA and PFOS, phthalates, vinyl chloride, and triclosan from key product categories, including paints, vinyl and laminate flooring, wall-to-wall carpet, and fiberglass insulation. The company stated in a 2017 press release: “The chemical strategy includes commitments to increase the assortment of products that have transparency of product ingredients and third party certification of chemical ingredients. Additionally, the company is committed to working with suppliers to improve chemicals in categories with the greatest potential impact to indoor air quality, and will conduct annual reviews of product categories to track progress and drive innovation.” The policy includes public quantifiable goals through a commitment to eliminate alkylphenol ethoxylates (APEOs) and nonylphenol ethoxylates (NPEs) in paint by 2019 and to ensure that all of its paints contain zero or low amounts of volatile organic compounds (VOCs) by December 2020. In April 2018, the company expanded its Chemical Strategy by announcing restrictions on nine chemicals from household cleaning products sold online and in The Home Depot stores by the end of 2022.

In June 2018, the company announced it was phasing out the sale of paint strippers containing methylene chloride and NMP by the end of 2018 in all of its stores throughout the U.S., Canada, and Mexico.

In 2019, the company announced it was banning per- and polyfluoroalkyl substances (PFAS) in all carpets and rugs sold in the U.S., Canada, and online. It plans to expand this commitment to Mexico but has not disclosed a timeline to do so. The company did not expand its chemicals policy in 2020.

The Home Depot states it is: “committed to eliminating expanded polystyrene (EPS) foam and polyvinyl chloride (PVC) film from our private-brand products by 2023,” which we assume means the company wants to eliminate those plastics of environmental health concern (PEHCs) from the packaging of private-label products. The company has encouraged suppliers to use recycled plastics and stated that: “Suppliers will utilize recycled content whenever possible within the limits of product efficacy and while avoiding chemicals of concern in their products,” but has not identified the specific chemicals of concern it expects suppliers to avoid in recycled materials.

Some of its Chemical Strategy appears to only apply to the U.S. and Canada, so only partial credit is awarded for this component.

The policy does not appear to apply, as specified in the criteria, to operations, and the company does not have a publicly available manufacturing restricted substance list (MRSL).

Glossary of Terms

Oversight: Established management responsibilities and incentives

2.5 out of 5 points

The Home Depot has multiple staff members who work on sustainability, including implementing the company’s safer chemicals policy. The Chief Sustainability Officer presents the company’s progress on chemical management and reports updates on the safer chemicals policy to the Board of Directors each year during a quarterly meeting.

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

Glossary of Terms

Accountability: Ensures supply chain accountability

7.5 out of 15 points

The company stated on the topic of accountability: “The Home Depot has Global Operations Managers that help enforce the chemical policy during the supplier set-up process. Home Depot has a (CCP) Chemical Compliance Program that is updated on an annual basis and includes all suppliers that provide product that is covered by our chemical policy. The program requires written compliance signatures from the suppliers.” They went on to note that: “Each of the programs have a compliance date. All suppliers are expected to be in compliance as of the compliance date. Those that cannot comply are removed from our active supplier list if they cannot comply.”

The company provides some training to implement its policy. The Home Depot notes: “Depending of [sic] the complexity of the requirements the notifications range from in person training classes with HD personnel to policy letters with instructions and follow up contacts.”

For some products and product categories under its Chemical Strategy, The Home Depot requires suppliers to meet certain third-party standards that require third-party laboratory testing. For example, “All indoor wall-to-wall carpet sold through The Home Depot U.S. and Canada has a third-party verification of transparency through DECLARE® Label or Environmental Product Declarations (EPDs), or certification of material health through Cradle to Cradle™ Products Innovation Institute or CRI Green Label Plus®.” Laminate flooring is: “verified by either GREENGUARD® Gold or FloorScore® certification to contain 0.0073 ppm or less of formaldehyde, which is a stricter standard than the CARB 2 standard
of 0.05 ppm.”

The Home Depot has not disclosed that it conducts its own testing to ensure suppliers comply with its safer chemicals policy, beyond restricted substance list (BRSL), or beyond restricted material list (BRML).

Glossary of Terms

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

8.5 out of 17.5 points

The Home Depot’s Chemical Strategy states: “The Home Depot is committed to increasing our assortment of products that have transparency of product ingredients and third-party certification of chemical ingredients, and that meet high environmental standards.” We note that the company’s commitment to transparency seems to be muted when restated in the 2019 and 2020 Responsibility Reports, as “transparency of product ingredients” is omitted in the report’s version of the strategy.

In 2019, the company shared: “[The] Home Depot mandates that its suppliers use the WERCSmart program that requires chemical ingredient transparency for products sold to Home Depot. This requirement goes above the regulatory requirements for chemical transparency. The company uses this data in various practices to review and monitor chemical ingredients.” The company states this disclosure applies to: “all products that contain chemicals and are in a non-solid physical state,” including both private-label and brand-name products, and applies to “all chemicals,” including fragrance ingredients and likely contaminants. Extra credit is awarded for this disclosure applying to multiple major product categories. This disclosure does not apply to articles.

Glossary of Terms

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

19.5 out of 26 points

The Home Depot’s Chemical Strategy sets restrictions on numerous chemicals of high concern (CHCs) in household cleaning products, paint strippers, paints, vinyl flooring, laminate flooring, wall-to-wall carpeting, and fiberglass insulations. In 2019, the company reported new metrics for implementing its policy and that the company is on track to meet the goals it has set for reducing hazardous chemicals in cleaning products, paints, carpet, and insulation. It reported the reduction is 65% complete for paint, 95% complete for carpet, 90% complete for insulation, and 99% complete for cleaning products. The company has not disclosed new metrics for 2020.

In September 2019, The Home Depot announced that it would phase out the sale of all carpets and rugs containing per- and polyfluoroalkyl substances (PFAS) and would stop purchasing for distribution any carpets or rugs containing PFAS chemicals by the end of 2019. The company followed through on these plans. The Home Depot earned extra credit for being the first major home improvement retailer to announce such a commitment. This decision applies to all of its stores in the U.S. and Canada and to online sales. The company plans to address carpets and rugs sold in its Mexican stores next, but has not provided an update on this.

In 2018, the company announced commitments to remove toxic chemicals from paint strippers and household cleaning products. The company was the third major retailer to announce restrictions on methylene chloride and NMP in paint strippers. In early 2019, the Mind the Store campaign identified paint strippers still being sold at The Home Depot containing methylene chloride and NMP. A few weeks later, a representative of The Home Depot told us that the company was removing its remaining inventory of methylene chloride- and NMP-containing paint removal products from shelves. Additionally, The Home Depot configured its register systems to block the sale of any methylene chloride- or NMP-containing paint removal products.

In 2017, the company announced it was working with its suppliers to reduce and eliminate nonylphenol ethoxylates (NPEs) and other alkylphenol ethoxylates (APEOs) in paints by 2019. The company has not confirmed whether it met this timeline.

The Home Depot was the first major home improvement retailer to commit to phase out all ortho-phthalates in its vinyl flooring within one year, setting a major precedent for other home improvement chains and flooring retailers that followed suit in 2015. This was very significant, as flooring was one of the biggest uses of phthalates worldwide. Testing by the Ecology Center and Mind the Store campaign confirmed The Home Depot followed through on its commitment to phase out ortho-phthalates in vinyl flooring.

The company has also reported progress in reducing some plastics of environmental health concern (PEHCs) in packaging. In its 2020 sustainability report, the company reported that in: “In 2019, we removed over 19,000 cubic feet of [expanded polystyrene (EPS)] from our packaging — enough to fill eight school buses” and also added: “we eliminated enough [polyvinyl chloride (PVC)] film to cover 99 football fields” which is equivalent to 5.7 million square feet. The company earned extra credit for this action.

Over the years, the company has reported that it removed and reduced volatile organic compounds (VOCs) from interior paint sold at The Home Depot, reducing indoor pollutants by 27 million pounds per year.

Glossary of Terms

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

4.5 out of 16 points

The Home Depot has not developed clear public guidance for evaluating the safety of alternatives, but the company has stated: “we are committed to offering products that are safer for the environment and our customers.” In its Sustainable Product Standards, the company noted that: “Suppliers will commit to continuous improvement toward sustainable chemistry alternatives to traditional chemical ingredients.”

The company is also promoting safer alternatives by indirectly encouraging suppliers to manufacture products to credible third-party standards, such as Cradle to Cradle and Safer Choice, through its Eco Options program.

The company committed to phase out the sale of paint removal products containing methylene chloride and NMP by the end of 2018. However, research in 2020 found that The Home Depot was selling other paint removal products containing chemicals of concern that meet the GreenScreen Benchmark-1 criteria. The Home Depot must do a better job of ensuring substitutes for methylene chloride and NMP are safe.

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

9 out of 20 points

In 2017, The Home Depot published its Chemical Strategy on its website and in its Responsibility Report. The strategy initially included lists of ingredients that the company restricts in paints, vinyl flooring, laminate flooring, wall-to-wall carpeting, and fiberglass insulation. In 2018, the company expanded the Chemical Strategy by disclosing chemicals it was newly restricting in cleaning products and paint strippers. The company committed to evaluate its Chemical Strategy “annually to ensure [its] approach, goals and disclosure are appropriate and meet the needs of [its] stakeholders.” The Home Depot updated the policy in September 2019, but did not update the policy or beyond restricted substance list (BRSL) in 2020. The company has posted a beyond restricted material list (BRML) for two plastics of environmental health concern (PEHCs), polyvinyl chloride (PVC) and expanded polystyrene (EPS).

The company states in its Chemical Strategy: “The Home Depot is committed to increasing our assortment of products that have transparency of product ingredients and third-party certification of chemical ingredients and that meet high environmental standards.” The company states that “all indoor wall-to-wall carpet sold through The Home Depot U.S. and Canada has a third-party verification of transparency through DECLARE® Label or Environmental Product Declarations (EPDs), or certification of material health through Cradle to Cradle™ Products Innovation Institute or CRI Green Label Plus®.”

The company also notes in its 2019 Responsible Product Standards the following “preference” for suppliers: “Home Depot recognizes suppliers who demonstrate a commitment to ingredient transparency. Suppliers should disclose product ingredients in their own communications or on packaging, or through a third party organization including, but not limited to: Cradle to Cradle Products Institute; HPD; UL Product Lens; Declare Label.” The company also states this “expectation” for suppliers: “Suppliers will indicate plastic type number on products with limited life-span.”

Ingredient information recorded through these programs can be challenging for consumers to find. Additionally, while this is notable, environmental product declarations do not always provide sufficient information about chemicals in products. Partial credit is awarded as these disclosures are not required and is unclear how far The Home Depot’s strategy will promote the public disclosure of 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

3 out of 8.5 points

The Home Depot sells and features numerous products on its website that meet credible third-party standards, such as Safer Choice, Cradle to Cradle, and GreenGuard Gold, through its Eco Options program. In its 2019 Responsible Product Standards, the company states this “expectation” for suppliers: “Suppliers will provide proof of certification for products to qualify for our Eco Options program:
+GREENGUARD® Gold
+Cradle to Cradle Material Health Certification Silver level or higher
+U.S. EPA SaferChoice®…”

The company also states that “Suppliers of textiles should pursue OEKO-TEX® Standard 100 certification for products” and “We give preference to products that contain certified organic cotton, and encourage suppliers to obtain certification from the Global Organic Textile Standard to ensure their cotton textile products meet responsible ecological and social criteria.”

Through these statements, the company is incentivizing suppliers to meet credible third-party standards.

Glossary of Terms