Walmart

Policy:Adopted a retailer safer chemicals policy

13.75 out of 23.5 points

Walmart and Sam’s Club have a written safer chemicals policy, known as the Sustainable Chemistry Policy, along with an Implementation Guide for Suppliers. The policy contains three primary pillars: Transparency, Advancing Safer Formulation, and Advancing our Assortment. The policy was updated and expanded in 2017 with new commitments and public goals and lists the company’s sustainable chemistry principles, which includes the 12 principles of green chemistry. The company states that by “2022, Walmart aims to reduce its consumables chemical footprint for Walmart U.S. and Sam’s Club U.S. stores by 10 percent.” In 2019, Walmart reported there were a baseline of 215.9 million pounds of “priority” chemicals present in their suppliers’ products (based on 2017 data) so its 10% reduction goal would translate into a reduction of 21.59 million pounds of toxic chemicals.

Walmart has developed a list of 16 “high priority” chemicals and more than 2,700 “priority” chemicals of concern that it is challenging suppliers to reduce and eliminate. The policy now includes a greater focus on the larger list of 2,700 chemicals, and in 2017, the company expanded the list of chemicals to which its policy applies by adding two new lists of fragrance chemicals of concern. The company states that “[a]ll suppliers are expected to reduce, restrict and eliminate use of priority chemicals using informed substitution principles.” The policy encourages both private-label and brand-name suppliers to certify their products to credible third-party standards, such as EPA Safer Choice. The policy applies to cleaning products, cosmetics and personal care products, infant products, and pet supplies, covering approximately 90,000 products and 700 suppliers.

In 2016, the company unveiled a “Sustainable Packaging Playbook.” It encourages suppliers to identify, remove, reduce, and restrict the company’s “priority” chemicals and materials in packaging “that may present human health and environmental toxicity risks,” which includes carcinogens, mutagens, reproductive toxicants, and PBTs. Partial credit is awarded for a packaging BRSL.

The company has set goals to eliminate all PVC and polystyrene in Walmart’s own Private Brands packaging by 2025, both of which are plastics of environmental health concern (PEHCs). Walmart first set a goal to eliminate PVC in private-label packaging back in 2005. The company is surveying its private label suppliers and plans to publicly report on the presence of PVC and polystyrene in its private-label packaging through the Ellen MacArthur Foundation’s New Plastics Economy Global Declaration.

In 2019, Walmart expanded the Sustainable Chemistry Policy to target chemicals of concern in apparel, footwear, and soft home textile products for the first time. The company set a goal “to reduce the discharge of priority chemicals from the manufacturing process for apparel, footwear, and soft home textiles by 2025.” The company has still yet to finalize and disclose what those priority chemicals are. Walmart stated, “Walmart will work with private, proprietary, and national brand suppliers to Walmart U.S. stores to identify priority chemicals discharged in the textile manufacturing process and establish best practices to limit and reduce their use.” The company has also set a new goal in 2019 so that “by 2022, Walmart U.S. stores will endeavor to source apparel and home textile products only from suppliers working with textile mills that use the Sustainable Apparel Coalition’s Higg Index Facility Environmental Module (FEM) to measure and help improve environmental performance.” The Higg Index includes various criteria for chemicals management. The company states, “Walmart U.S. asks all private, proprietary, and national brand suppliers of apparel and soft home textile products to provide transparency to their textile mill operations, report and verify performance by completing a Higg FEM self-assessment annually with 3rd party verification every other year, and establish plans for continuous improvement of environmental performance.”

However, Walmart’s sustainable chemistry policy does not apply to operations. The company has not yet developed a publicly available manufacturing restricted substance list (MRSL), though given the company’s pledge, partial credit for having an MRSL was awarded. Additionally, outside the transparency portion of the policy and its recent work to restrict toxic paint strippers, the policy does not appear to apply to products sold in stores outside of the United States, so partial credit was awarded for this component as well.

The company’s policy does not appear to apply to beauty products of environmental justice concern (BPEJC).

Glossary of Terms

Oversight: Established management responsibilities and incentives

2.5 out of 5 points

Walmart has multiple staff members who oversee and implement its Sustainable Chemistry Policy, including executive-level engagement with suppliers implementing the policy. Associates from the company’s sustainability, compliance, and merchandising teams all work together to advance the policy. Merchants and executives drive conversations with suppliers when they use “High Priority” chemicals, discussing and asking for supplier plans to reduce, restrict, and/or remove those chemicals of concern.

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

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Accountability: Ensures supply chain accountability

2.5 out of 15 points

Walmart has created a detailed Sustainable Chemistry Implementation Guide, which is available online, to provide guidance to suppliers on implementing its policy. The company notes it has engaged suppliers through “summits, surveys and meetings that have enabled an open dialogue through this (sustainable chemistry) process.” The company stated it hosted “a workshop in September 2019 for Walmart and Sam’s Club national and private brand consumables suppliers in the U.S. Guest presenters shared examples of best practices, and suppliers were encouraged to set chemical footprint reduction goals and measure their progress against those goals.”

Walmart has not specifically disclosed that it incorporates its safer chemicals policy, BRSL, BRML or reporting requirements in supplier contracts, that it requires suppliers to conduct testing in third-party laboratories and provide results to the retailer, or that it conducts its own testing to ensure suppliers comply with its safer chemicals policy, BRSL, or BRML.

Glossary of Terms

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

8 out of 17.5 points

Walmart uses the WERCSmart platform to collect and evaluate information about chemical ingredients in consumable products across multiple product categories. Walmart states in its policy that it asks “all Walmart U.S. and Sam’s Club U.S. stores national and private brand suppliers to: 1. Disclose full product formulations to The WERCS through WERCSmart, above and beyond what is required by law.”

Walmart is measuring the percentage of products (by number of UPCs) with fully disclosed formulation by supplier to The WERCS. In a 2021 update to the Sustainable Chemistry Implementation Guide, the company stated that in 2019, 71.7 percent of suppliers had disclosed ingredients for screening, a 13.5 percentage-point change since 2017. At the same time, it reported 17 percent of suppliers had fully disclosed ingredients, a 6 percentage-point change since 2017. While we applaud Walmart’s transparency, this demonstrates more work is still needed by Walmart suppliers to fully disclose ingredients for screening against the company’s list of Priority and High Priority chemicals.

The company had previously disclosed that Walmart suppliers reported over 215.9 million pounds of Walmart priority chemicals in “in-scope” consumables in 2017.

In 2017, the company announced it was asking suppliers to ensure contaminants of concern are not present in the final product (for example, in ingredients such as petrolatum). Walmart stated it will be asking suppliers to “verify purity of ingredients where contaminants of concern may exist, starting in 2019” and that it will annually measure “weight volume of ingredients, known to often harbor contaminants of concern, that are verified to meet purity standards” starting in 2019. For suppliers that are not ensuring contaminants are not present, the company will encourage them to remove priority chemicals or ensure contaminants are not present.

In an earlier sustainability report, the company described how the data it collects can not only help it understand chemical hotspots, but also how suppliers compare with one another, stating, “Suppliers can see how they rank relative to the field, and gain insight into improvement opportunities for each of the categories they supply. For example, suppliers of laundry detergent can see how they are progressing relative to all other suppliers on chemicals of concern.”

The company’s commitments on textiles also include expectations for suppliers on completing the Higg Index.

The company has previously stated it is evaluating how it can utilize blockchain technology to increase transparency of products and packaging and noted that it could be utilized for chemicals in food and food packaging.

Extra credit awarded for this applying to multiple major product categories, disclosing the percentage of suppliers’ UPCs meeting its disclosure goals, and measuring contaminants in products.

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

Walmart has set a clear goal to reduce the use of chemicals of concern in a number of major product categories by 10 percent by 2022. In 2020, Walmart reported there were a baseline of 215.9 million pounds of “priority” chemicals present in these suppliers’ consumables products (based on 2017 data). In January 2021, Walmart reported a 5 percent reduction in the use of “priority” toxic chemicals (by weight) between 2017 and 2019. That eliminated 10 million pounds of hazardous chemicals from beauty, personal care, and household cleaning products, among others. The company also disclosed a 24 percentage-point change in the number of products (by UPC barcode) containing priority chemicals and the weight of priority chemicals as a proportion of total product formulated weight declined by 12 base points.

In 2019, Walmart expanded the Sustainable Chemistry policy to target chemicals of concern in apparel, footwear, and soft home textile products. Walmart has set a goal “to reduce the discharge of priority chemicals from the manufacturing process for apparel, footwear, and soft home textiles by 2025.” The company has not disclosed progress in meeting this goal.

The company has also set a goal to eliminate all PVC, PVDC, PS, and EPC in private label packaging by 2025 in the U.S. In 2020 it reported 2019 data: “98.75% of all Walmart Inc. private brand primary plastic packaging is free of PVC…98.28% of all Walmart Inc. private brand primary plastic packaging is free of EPS.” The company also has global sustainable packaging goals to eliminate PVC by 2025.

In 2018, Walmart announced it was phasing out the sale of methylene chloride- and NMP-based paint strippers in all of its stores in the United States, Canada, Mexico, and Central America, and on walmart.com, becoming the fourth major retailer to take action on these harmful chemicals. In early 2019, the Mind the Store campaign identified paint removers containing these chemicals still for sale on Walmart.com. After we brought these to the company’s attention, Walmart removed them swiftly. Unfortunately Walmart is now selling paint strippers that contain other chemicals of concern. The company has not taken any public action on these regrettable substitutes.

In 2017, Walmart publicly reported on metrics in implementing its Sustainable Chemistry Policy, including reporting on the presence of and reductions of Walmart’s “priority” and “high priority” chemicals by weight, percentage of products containing chemicals of high concern (CHCs), and percent of suppliers selling products containing CHCs for both Walmart and Sam’s Club. The company has reported on additional metrics in 2019 (see the disclosure section).

In 2017, the company reported that since 2014, Walmart suppliers have reduced the use of its “high priority” chemicals by 96% by weight, translating to a reduction of these chemicals by more than 23.6 million pounds. The company noted that “a small number of suppliers used the largest volumes of all high priority chemicals (HPCs), with one supplier, in particular, using the majority of HPCs in only a few select products. We have encouraged these suppliers to reformulate their products to remove the high priority and priority chemicals. While we have removed 96% of HPCs by weight, there is still a long way to go before removing all HPCs, and we will continue to actively encourage suppliers to advance safer formulations.” It has also reduced the use of “priority” chemicals by 49 percent by weight since 2014.

Sam’s Club suppliers achieved a reduction of the company’s “high priority” chemicals of 68 percent (by weight) since 2014. However, the weight of “priority” chemicals sold by Sam’s Club increased by 13 percent (by weight) since 2014. The company attributed this to a mix of increased sales of products containing CHCs and new chemicals added to authoritative and regulatory lists.

Walmart has not publicly documented progress on reducing chemicals of high concern in beauty products of environmental justice concern, beyond regulatory compliance in the last three years.

Glossary of Terms

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

8.5 out of 16 points

Walmart is encouraging its suppliers to avoid regrettable substitution by evaluating the hazards of replacement chemicals and encouraging suppliers to follow informed substitution and alternatives assessment principles. The company’s policy states, “Safer chemicals are chemical products designed to preserve efficacy of function while reducing toxicity. As part of the 12 Principles of Green Chemistry, Walmart embraces use of the principles of green chemistry and encourage[s] informed substitution to mitigate, reduce, and eliminate potential hazards associated with product formulations.”

Walmart’s Implementation Guide states, “Informed substitution is the considered transition from a chemical of particular concern to safer chemicals or non-chemical alternatives. Using informed substitution principles will mitigate hazard risks associated with product formulation and achieve compliance with Walmart’s Policy on Sustainable Chemistry in Consumables…In the aim of advancing safer formulated products and promoting informed substitution, Walmart recommends the major tenets of Alternatives Assessment, a process for identifying, comparing and selecting safer alternatives to priority chemicals (including those in materials, processes or technologies) on the basis of their hazards, performance, and economic viability.”

In its Implementation Guide, the company cites many great resources, such as the GreenScreen, CleanGredients, Pharos Chemical and Material Library, BizNGO’s Chemical Alternatives Assessment Protocol, U.S. EPA Safer Chemical Ingredient List (SCIL), and the Lowell Center for Sustainable Production’s Alternatives Assessment Protocol. It is unclear how the staff is tracking or evaluating suppliers’ use of these tools and practices.

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

11.25 out of 20 points

Walmart’s Sustainable Chemistry Policy and Implementation Guide are both publicly available, the company’s list of 16 “high priority” chemicals is publicly available, and its list of authoritative lists that comprise its 2,700+ “priority” chemicals is publicly available. Walmart has also disclosed the two plastics of environmental health concern (PEHCs) it is phasing out in private-label packaging. However the company has not disclosed the list of priority chemicals it is addressing in the manufacture of textiles, so partial credit is awarded.

Walmart is encouraging suppliers to disclose ingredients to consumers, both on-pack and online. The company states, “Walmart will create more transparency about ingredients contained in the products on its shelves by requiring all suppliers to provide full online ingredient disclosure beginning January 2015 and Walmart Priority chemicals on pack beginning January 2018. Walmart expects online public disclosure to be publicly accessible from the supplier’s website and to be displayed at the per-product level.” Walmart states that since 2013, it “has encouraged full ingredient transparency, including transparency on the following: ingredients typically protected under trade secrets (e.g., fragrances); allergens; known residuals, contaminants, and by-products; hazard information; and identification of ingredient function” but does not require this disclosure. The company is tracking supplier public disclosure practices through “the Sustainability Index to capture data on supplier practices regarding product ingredients disclosure online” and publicly reported on the results of this tracking online in early 2019. In September 2017, the company announced that it is asking suppliers to disclose ingredients to consumers across the globe, not just in the United States, for the first time.

It is unclear whether Walmart is 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.

Glossary of Terms

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

4 out of 8.5 points

In September 2017, Walmart announced it is asking private-label and brand-name suppliers of consumables to certify their products to Safer Choice, Cradle to Cradle (Silver or above), or EWG Verified. The company also announced that, beginning in 2019, it will annually measure the number of suppliers with credible certifications and number of products certified to one of these standards. The company stated, “We want to encourage private and national brand suppliers to lead on sustainable chemistry by leveraging third-party certifications that assess and recognize leadership in line with the principles of green chemistry and safer substitution. Third-party certifications can help lend credibility and verification for how products are made and can provide a signal of leadership to customers. For these reasons, Walmart U.S. and Sam’s Club U.S. stores encourage suppliers to obtain such certifications where applicable.” An extra point is awarded for this commitment.

However, since making this commitment in 2017, Walmart has not reported on any quantitative metrics or recent progress in implementing this goal.

In its 2019 commitment on textiles, the company states, “Walmart also encourages suppliers to lead on sustainable chemistry in apparel, footwear, and soft home textile products and leverage third party certifications that assess and recognize leadership in line with the principles of sustainable chemistry. Third party certifications can help lend credibility and verification for how products are made and can provide a signal of sustainability leadership to customers, such as OEKO-TEX Standard 100.” Full credit is not awarded since this is encouraged, not required.

Glossary of Terms