Consumer products companies are faced with a new chemical agenda. The market expectation has shifted from outdated regulatory compliance to greater ingredient transparency and more stringent health and environmental protection. Companies have traditionally siloed their chemical policies and programs in legal or regulatory departments, but these teams can’t manage the new rules of the game on their own. They need a new framework with an overarching direction and purpose that engages the business to understand, assess, improve and disclose chemical information and hazards. In short, they need a new game plan for chemical management.
The New Game Plan
The State of California has enacted unprecedented regulations to improve the safety of consumer products aimed at driving “chemicals of concern” (COCs) — ingredients that have health and environmental hazards such as those considered carcinogens, reproductive toxins or persistent in the environment — out of products. Additional market pressures are coming from every direction, including consumers, retailers, customers and competitors, to advance transparency and safer chemicals in consumer products. Whole Foods Market has a list of unacceptable ingredients across the store from food to personal care products and other retailers have moved in that direction. Many companies are realizing that they lack an integrated, corporate-level program that can meet the new market and regulatory demands around chemicals. An effective game plan must involve all corners of the company, from R&D to procurement and communications, to work collaboratively with suppliers to create new ingredient strategies.
A common strategy involves designing out select COCs, including more than those restricted by regulations. Typical considerations for identifying what should be addressed, and put on a restricted list, are emerging regulations, customer requirements and consumer demands. Beginning in 2000, Levi Strauss & Co. was one of the first companies to bring this restricted substances list (RSL) strategy into their game plan. Their proactive approach was geared to upholding the health and safety of their products. Levi’s RSL covers materials such as polyvinyl chloride (PVC) and chemicals, including phthalates and problematic dyes, among others. The list is updated regularly to continuously improve and address new information about chemical safety.
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While regulatory departments can shape the RSL, they cannot work in isolation to execute this strategy. The regulatory group must collaborate with its partners in R&D and procurement to design and source safer products and ingredients. This can involve thousands of products or parts for some companies, such as Levi’s. Suppliers are also key members of the team. Levi’s RSL strategy includes supplier training and tools to effectively avoid and limit restricted substances. In June, Levi's, Nike, H&M and several other members of the Zero Discharge of Hazardous Chemicals Group (ZDHC) committed to publishing a list of chemicals targeted for phase out or research by 2015 as part of a plan to eliminate hazardous chemicals from their supply chains by 2020.
With the effective implementation of a restricted substances list, companies can then move to a more proactive strategy — using ingredient guidelines that go beyond avoiding a targeted list of COCs and instead require evaluation of each ingredient choice to ensure selection of the safest options.
Seventh Generation, a Pure Strategies client, requires all ingredients to pass a review of health and environmental safety concerns. Martin Wolf, Director of Product Sustainability and Authenticity, stresses that, “Any substance that is carcinogenic, mutagenic, neurotoxic, reprotoxic or estrogenic cannot be used as an ingredient in our products.” Yet, Seventh Generation goes a step further to ensure that unwanted chemicals do not creep into their products through processing or contamination. They have independent, third-party laboratories screen their products annually for chemicals of concern. If issues arise, they work through the supply chain to address them.
While in 2008, Seventh Generation was taking industry-leading steps to keep levels of a carcinogenic ingredient contaminant, 1,4-dioxane, low in its products, Wolf pointed out that, “Our consumers, however, didn’t want low levels of 1,4-dioxane in the products they purchased. They wanted “zero” levels. So, for the next two years we worked with our suppliers to eliminate 1,4-dioxane from our products and in 2010 we introduced liquid dish and liquid laundry detergents with no detectable levels of 1,4-dioxane.”
Ingredient transparency is another new rule in the game. While there are many products in the stores where current laws do not require disclosure of ingredients, retailers and consumers are demanding this information. Ingredient disclosure is a key component of the new Sustainable Product Standard launched in October by Target. This has further prompted leaders in the market to provide consumers — and now retailers — information on potentially hazardous ingredients.
“Consumers have a fundamental right to know what is in products so they can make informed decisions when making purchases,” Wolf says. As a result, Seventh Gen lists all ingredients on its packages and website, including fragrance ingredients.
Evolving market expectations have led to new rules for chemical management. Forward-looking innovation combined with hard work can help to change internal mindsets, uncover safe and effective substitutes and determine responsible souring strategies. Leading companies have shown that the new game plan can result in wins across the board — for companies and for consumers.