Whole Foods Market

Policy:Adopted a retailer safer chemicals policy

16.25 out of 23.5 points

Whole Foods Market has a written safer chemicals policy in the form of two key Quality Standards related to chemicals in products that apply to all stores where products are sold: (a) Household Cleaning Quality Standards and (b) Body Care Quality Standards. Cleaning and beauty/body care products sold at Whole Foods Market must meet these Quality Standards. Whole Foods Market staff noted in 2017 that the company “continually improves [its] standards as safer alternatives become available or new research comes to light” and that its “[t]ransparent quality standards have been moving the market away from toxic chemicals since the company was founded.” Notably, in December 2020 and January 2021, Whole Foods Market staff stated that the company has adopted a restricted substance list (RSL) for packaging, as described further below.

The Household Cleaning Quality Standards are partly based on the previous standard, Eco-Scale, which was the first cleaning product standard of any retailer. Through Eco-Scale, Whole Foods Market evaluated all ingredients in household products sold at Whole Foods Market for safety, among other attributes, and assigned the products different ratings based on how many chemicals they did not contain. As of 2017, green-rated products were free of 326 chemicals, yellow-rated products were free of 134 chemicals, and orange-rated products were free of 52 chemicals. Red-rated products, containing any of the 52 ingredients banned in the other ratings, were not allowed to be sold in-store. By contrast, the new standard only bans over 100 ingredients, “including phosphates, phthalates, FD&C colors and optical brighteners,” in all household cleaning products sold by Whole Foods Market. One-hundred and eighteen of these banned ingredients are listed on the company’s website. The company does imply that it vets all ingredients shown on product labels (which are all except proprietary fragrance and enzyme blends). The company rebranded this system because of “consumer and supplier challenges with a multi-tiered system.” Especially important because of increased usage of disinfectants during the COVID-19 pandemic, according to staff statements in December 2020, the company prohibits quaternary ammonium compounds (“quats”) and bleach in disinfectants as part of this standard. On a related note, the company also established standards for the face masks it sells in stores that ban added antimicrobial substances, including quats.

For body care, Whole Foods Market reviews “the latest research on beauty and body care ingredients for many factors including possible impacts on the environment and human health” and has prohibited more than 100 ingredients, including parabens, phthalates, formaldehyde donors, oxybenzone, and EDTA in all body care products that it sells. The company noted that between “2019-2020,” 39 ingredients were added to the banned list. The company stopped using its more stringent standard called “Premium Body Care” that had prohibited more than 400 ingredients because of “consumer and suppliers challenges with a multi-tiered system.” Since June 2012, Whole Foods Market has required personal care products with an “organic” label to be certified organic.

Regarding beauty products primarily marketed to women of color that may raise environmental justice issues, we applaud Whole Foods for including hydroquinone, hexylresorcinol, formaldehyde, and mercury, key chemicals of high concern (CHCs) in skin lightening or hair straightening products, in its list of banned ingredients (note that mercury is already banned by FDA in these kinds of products). Partial extra credit is awarded for this effort.

In December 2020 and January 2021, Whole Foods Market staff stated that the company has adopted an RSL for “all Food Service and Exclusive Brand packaging…that prohibits intentionally added PFAS, ortho-phthalates, bisphenols, heavy metals, perchlorate, benzophenone, and residual solvents” as well as arsenic, and is in the process of assessing compliance. “Food Service” packaging is what is used by Team Members or customers to package items within the store; “Exclusive Brand packaging” includes food and non-food items. The company also plans to set goals for removal.

Whole Foods Market has a BRSL for at least one major aspect of operations, since in 2019 the company reported that its cash register tapes were phenol free and the company had started using Pergafast and the less preferable ascorbic acid as alternatives (because of short supplies of phenol-free paper). In 2012, the company reported switching to DEHP-free vinyl gloves. In 2008, Whole Foods Market discontinued single-use plastic grocery bags at checkouts and in 2019 announced it was banning plastic straws. Staff also noted in 2017 that the company was in the process of ensuring cleaning products used in “back of house” are certified to either the orange level of Eco-Scale or Green Seal’s standards but did not provide an update on this in 2020. In September 2019, staff reported that the company is working with UL Everclean to assess the chemicals approved for use in stores and as of December 2020, it appears this work is ongoing, although in the context of “organic practices.”

The company is “also implementing a policy to ban nonrecyclable materials, including PS, PVC, PVDC, polycarbonate” in Food Service and Exclusive Brands packaging. Since the banned materials are all plastics of environmental health concern (PEHCs) and it applies to more than one major category of packaging, full credit is awarded for the BRML element. The company noted in a May 2019 press release that it “recently eliminated all polystyrene/Styrofoam meat trays in all stores in the U.S. and Canada” and in December 2020 confirmed that the company has “eliminated polystyrene/Styrofoam from all food service packaging.”

Whole Foods Markets’ new packaging RSL, its BRML, and its Quality Standards apply to all stores, so full credit is awarded for the location component, even though the implementation of these policies may only be progressing in certain locations. Whole Foods Market has not set public quantifiable goals for reducing and eliminating CHCs and 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

According to staff statements from 2020, Whole Foods Market has a staff of 17 Team Members on its Quality Standards team, which is responsible for researching, determining, and maintaining the company’s strict standards for ingredients, including the Household Cleaning Products and Body Care Quality Standards. This team is overseen by “Executive Leader of Quality Standards and Vice President of Food Safety and Quality Assurance, both of whom are involved with chemical policies.” The company also reiterated in 2020 that Whole Foods Market’s “executive leadership team…reviews and approves all major changes and additions” to the company’s Quality Standards, and the President and Chief Merchandising Officer oversees all quality standards. Additionally, the company formed an internal “Packaging Standards Coalition of crossfunctional leaders from In-Direct Procurement, Merchandising, Marketing, Legal, Communications, and our Exclusive Brands Packaging Design teams” to discuss related matters.

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

Glossary of Terms

Accountability: Ensures supply chain accountability

6.25 out of 15 points

Staff stated in 2017 that “[a]ll suppliers of products to Whole Foods Market are provided clear information about [its] standards and unacceptable ingredients.” Staff added in 2018 that they conduct supplier summits and provide information on the requirements through a supplier portal. The company reiterated these statements in December 2020, and noted that they offer supplier trainings and work “with suppliers to develop innovative new products in compliance with our standards.” Whole Foods Market staff also noted that in updating its Household Cleaning Products Quality Standards, the company “shared detailed information with our suppliers to ensure our new standards are understood and our suppliers are able to effectively meet them.”

The company does not appear to formally require suppliers to conduct testing in third-party laboratories and provide results to the retailer to ensure suppliers comply with the policy, although the company noted in December 2020 that it continues “to actively explore opportunities to affirm suppliers comply with our packaging requirements, including third-party testing and certification.” Whole Foods Market requires suppliers with products labeled “paraben free” to “provide testing results from…raw material suppliers [that] supports this claim” but does not specifically require this testing in third-party laboratories. The company also requires beauty and body care products that are labeled as “organic” to have third-party certification to that standard, but it’s unclear if the certification involves testing. For these reasons, we are awarding partial credit for the third-party testing component.

The company disclosed in December 2020 that requirements for complying with the Quality Standards are included in supplier contracts.

Whole Foods Market has not disclosed that it conducts its own testing to ensure suppliers comply with its safer chemicals policy, BRSLs, or BRML.

Glossary of Terms

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

8.25 out of 17.5 points

According to statements by staff in 2017, the company requires both private-label and brand-name suppliers to report all ingredients, except for fragrance and enzymes, in household cleaning products and body care products so they can be evaluated for safety. Whole Foods Market requires fragrance questionnaires to be submitted for household cleaning products that have natural fragrances, but the questionnaire doesn’t ask for the full list of fragrance ingredients. Green Seal reviews enzyme blends in cleaning products to determine compliance with Eco-Scale. For this vetting, the supplier provides full enzyme ingredient information directly to Green Seal under a non-disclosure agreement. The company receives partial credit for requiring the disclosure of ingredient components for enzymes, since an enzyme is a minor category of generic ingredients. Extra credit is awarded for the company applying this disclosure to two major product categories rather than one as specified in the rubric, and for Whole Foods Market confirming that 100% of household cleaning products have achieved the disclosure the company requires, verified by Green Seal.

Glossary of Terms

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

20.5 out of 26 points

Cleaning products sold at Whole Foods Market must meet the company’s Household Cleaning Quality Standards and beauty and body care products sold by the company must meet Body Care Quality Standards. Whole Foods Market’s setting of restrictions on hundreds of toxic ingredients has likely driven suppliers to reduce and eliminate key chemicals of high concern (CHCs).

For example, in a letter to suppliers dated February 1, 2016, Whole Foods Market confirmed that it was banning certain chemicals, including oxybenzone, from its body care products effective January 1, 2017. The company also stated in that letter that “[t]hese ingredients are found in a small percentage of our body care products.” In 2018, Whole Foods Market staff confirmed that 0% of the company’s products contain the sunscreen chemical benzophenone (a.k.a. oxybenzone). According to a press release, in April 2019 Whole Foods became the first retailer to stop selling body care and sunscreen products in the U.S. containing octinoxate (octyl methoxycinnamate). Additionally, Whole Foods Market notes on its website that it is the first retailer to ban optical brighteners from its cleaning products. Extra credit is awarded for these achievements. Whole Foods Market staff also reported in December 2020 that between “2019-2020,” 39 ingredients were added to the banned list.

The company told us in December 2020 that in the past year, 61 additional ingredients were prohibited through the Household Cleaning Quality Standards, including the preservative methylcholoroisothiazolinone and the optical brightener disodium distyrylbiphenyl disulfonate.

The company also sells face masks, and told us in December 2020 that it has banned added antimicrobial substances, including quats, from these masks.

Whole Foods Market reported to us that as of August 2019, all stores use register tape that is phenol-free and utilizes Pergafast and the less preferable ascorbic acid as alternatives. Extra credit is awarded for Whole Foods Market disclosing its alternative for bisphenol-containing receipt paper.

On food packaging, staff told us in 2018 that the company has almost completely moved away from BPA-containing epoxy liners for its 365 Everyday Value food and beverage cans and will be finalizing the transition in 2019 for items with commercially available options. In December 2020, the company noted that it had finished moving all 365 Everyday Value canned food and beverage products to “packaging that does not contain epoxy liners made with BPA, where commercially available options exist.” However, the company has not disclosed its substitute for BPA in can linings. The company also noted that in 2020, it rolled out molded fiber plates and bowls in all prepared foods departments in the U.S. and Canada that do not rely on PFAS to achieve grease resistance and the company also “discontinued or reformulated any food service packaging where it was disclosed or determined that PFAS may have been intentionally added,” but did not disclose the alternative it moved to in these items either. In January 2021, the company announced it would transition to phthalate-free versions of two products’ cap gaskets that previously had phthalates according to testing commissioned by the Toxic-Free Food Campaign.

Related to plastics of environmental health concern (PEHCs), staff told us in December 2020 that in early 2019, the company eliminated all polystyrene/Styrofoam meat trays in all stores in the U.S. and Canada, and has also “eliminated polystyrene/Styrofoam from all food service packaging.” Partial extra credit is awarded because the company eliminated one PEHC from a major category of food packaging in addition to eliminating several CHCs from two major product categories and a major aspect of operations since November 2017.

Note: Whole Foods Market had made progress on removing BPA from products other than packaging before 2015. The company switched to using DEHP-free vinyl gloves in the supply realm, as reported in its 2012 Green Mission report.

Glossary of Terms

Safer Alternatives: Evaluates safer alternatives, avoids regrettable substitutes

8.5 out of 16 points

In a 2011 blog, Whole Foods Market indicated a component of its Eco-Scale rating system was “safer alternatives to conventional ingredients.” Although the Eco-Scale system and its tiers have been replaced, in September 2019 the company stated that its goal “is to eliminate as many of the orange-tiered ingredients as possible in all household cleaning products” so the company is still attempting to push suppliers to safer alternatives. On its current webpage on the cleaning standards, the company also noted, “[w]e revamped our standards and did our research to eliminate certain ingredients and find better alternatives for you and the planet,” but did not use the term “safer.” Also on that webpage, the company noted, “you can trust that when you see a hard-to-pronounce ingredient on one of our labels, we’ve done the homework.”

In 2017, Whole Foods Market employees noted that the differentiation between baseline and then-premium body care standards encourage suppliers of body care products to work toward offering safer alternatives. However, it appears that the premium body care standards have been eliminated.

More generally, Whole Foods Market employees stated in 2017: “When items are added to the unacceptable ingredients lists, any substitutions producers propose must be reviewed for acceptability. If there is indication of harm, the company would not deem the substitution acceptable and would add that ingredient to our unacceptable list.” Additionally, Whole Foods Market employees stated in 2017: “Using the precautionary principle as a guide, every body care and cleaning ingredient that is allowed on [the positive version of] our Quality Standards lists has been given a thorough review based upon safety, environmental impact and source. To make ingredient decisions, we consult published scientific and medical literature, reports from regulatory authorities and NGOs, data from manufacturers and suppliers, and guidance from chemists and industry technical experts. In this way, we have continually ensured that alternatives are safer for both our branded and private-label products.” The company confirmed these statements were still true in December 2020 and added that “chemicals of high concern that are not currently found on [the positive versions of] our lists would be considered unacceptable.”

In September 2019, Whole Foods Market reported that the company had moved away from phenol receipt paper to the alternatives of Pergafast and ascorbic acid. Staff stated that two different alternatives are being used because phenol-free paper is in short supply. The formulation associated with the ascorbic acid paper contains at least one chemical of concern, which underscores the need for Whole Foods Market to ensure substitutes are safe, although we recognize the supply chain challenges the company has faced.

Glossary of Terms

Transparency: Demonstrates a commitment to transparency and public disclosure

10.25 out of 20 points

The policy and at least part of the beyond restricted substance lists (BRSLs) for household cleaning and body care products are publicly available. The BRSLs on Whole Foods Market’s website do not show the full list of prohibited ingredients, according to Whole Foods Market’s statement on the “Information for Potential Suppliers” webpage, which says: “…the ingredient list on our public website is only a partial list intended for screening products.” The company has posted more of the ingredients it bans in its beauty and body care products (138) than in the past (in 2019, only 90 were listed). The company lists only 118 of the 100+ chemicals it bans in its new Household Cleaning Quality Standards.
The packaging RSL and BRML have not yet been publicly disclosed.

We are awarding partial credit because Whole Foods Market has not fully disclosed its BRSLs and BRML to the public.

According to its website, Whole Foods Market currently requires suppliers of all household cleaning products sold in stores to list ingredients on the label, except for proprietary fragrance and enzyme blends, according to the on-label disclosure required by the California Cleaning Product Right to Know Act of 2017 (SB 258). Whole Foods Market is applying this disclosure to all of its relevant cleaning products sold in the U.S. and Canada, and extra credit is awarded to recognize that.

Glossary of Terms

Chemical Footprint: Evaluates its chemical footprint

4.5 out of 7.5 points

Whole Foods Market completed the Chemical Footprint Project survey in 2020 for its body care and household cleaning products. The company has also become a signatory to the CFP.

Glossary of Terms

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

3.75 out of 8.5 points

Whole Foods Market employees told us in 2017 that historically, the company created its own product and ingredient standards and accountability practices if third-party standards did not exist or were not adequate.

Whole Foods Market partnered with Green Seal “in the development, launch, and execution of Whole Foods Market’s Eco-Scale™ Rating System for household cleaners.” Green Seal has been the company’s third-party verifier. In 2017, Whole Foods Market staff members stated that they work to ensure certification either to Eco-Scale at the orange level or to Green Seal’s standards. Staff members stated in 2019 that they are continuing to engage Green Seal in ingredient auditing as part of the refresh of the company’s household cleaning products standard and indicated in 2020 that they are still working with Green Seal.

We are awarding partial credit in this category because Whole Foods Market does not require certification to credible third-party safer chemicals standards in multiple entire categories, but has gone beyond encouraging suppliers to achieve certification in at least one private-label product category because of its work with Green Seal.

According to its website, Whole Foods Market mandates that all personal care products labeled organic be certified by a third party as meeting USDA Organic standards or a related standard but does not certify all personal care products to organic standards. Additionally, Whole Foods Market staff noted in 2017 that the company helped found EPA’s GreenChill Partnership to reduce refrigerant gas emissions. The company received a 2016 GreenChill Achievement Award. The company’s website also notes: “[a]s of 2018, dozens of our stores have GreenChill certifications.”

Glossary of Terms