Guidance

The scope of this KPI includes company-level activities for manufacturers that sell beauty and personal care products in the United States.  Company-level activities for products sold in other regions are not to be considered.


Intentionally and unintentionally added ingredients in final formulations are in scope for this KPI.


  • For E, public disclosure of goals and progress must have occurred within 12 months of the date you respond to this question.
  • For F, the policy must exclude chemicals on the stewardship list from formulations or must exclude them from exceeding a threshold level of 100 ppm in final formulations.


For this KPI, the "Stewardship List" is comprised of all of the chemicals on the following published lists:


  • CA EPA Prop 65 - Reproductive and Developmental Toxicants, Carcinogens
  • EPA Toxics Release Inventory PBTs
  • EU - Cosmetics Regulation Annex II
  • EU - Priority Endocrine Disruptors (Categories 1, 2)
  • EU REACH - Annex XVII CMRs (Appendices 1-6)
  • IARC - Categories 1, 2A, 2B


These published lists have been referenced in public retailer chemical policies.  Where a chemical is accompanied by a specific route of exposure on these published lists, and the exposure route is relevant to the product during consumer use or foreseeable misuse, then the chemical is relevant to this KPI.


Resources that can be used to identify, prioritize and perform alternatives assessments on chemicals on the Stewardship List include, but are not limited to, those listed in the Resources section.


Resources

BizNGO Chemical Alternatives Assessment Protocol:  This protocol provides a decision framework that can be used to identify chemicals of concern and effectively choose economically viable alternatives that have reduced impact on human health and the environment.


The Globally Harmonized System of Classification and Labeling of Chemicals (GHS):  GHS provides specific human and environmental health criteria along with physical hazard criteria for chemicals in industry. These criteria are used for hazard communication and labeling of chemicals.


EPA - Safer Choice:  The EPA Safer Choice program (previously Design for the Environment) provides a voluntary standard for product designers who wish to choose ingredients based on established criteria. In this program, all ingredients are reviewed and must meet strict criteria for various impacts (e.g., human health and the environment, carcinogenicity, reproductive/developmental toxicity).  Products meeting the standard are able to carry the Safer Choice label.


GreenScreen for Safer Chemicals:  GreenScreen is a “Chemical Hazard Assessment” method that can be used to identify chemicals of high concern and determine safer alternatives. The tool was developed and is administered by Clean Production Action.


EPA - Safer Choice, Alternatives Assessments:  EPA developed the Safer Choice program in which companies can voluntarily participate by researching and reformulating their product to meet Safer Choice standards in order to earn the Safer Choice Label on their products.  Safer Choice uses alternatives testing to encourage industry to move to safer alternatives, complement regulatory action by showing that safer and higher functioning alternatives are available, or point out the limitations to chemical substitution for a particular use.


BizNGO - The Commons Principles for Alternatives Assessment:  The Common Principles for Alternatives Assessment is a document developed by BizNGO that provides a common definition for chemical alternative assessment and acts as a guide for enhanced decision making for safer chemical substitution.


Definitions

Goals: Goals should be specific, measurable, achievable, relevant, and time-bound.


Informed substitution: Informed substitution implies that factors such as cost and performance, technical feasibility, life cycle impacts, economic and social accountability, and potential to result in lasting change have been taken into consideration to ensure that substitutes and the final product are safer based on their health and environmental profiles (Adapted from United States Environmental Protection Agency Design for Environment Program Alternative Assessment information).


Intentionally added ingredient: A chemical that provides a function to the final formulation during consumer use or is present as a result of formulating a product for safe use by consumers (e.g., pH balancing by acids or bases). 


Public disclosure: Voluntary corporate reporting, sustainability reporting programs, or reporting as part of regulatory compliance. 


Unintentionally added ingredient: An ingredient that provides no function in a final formulation and is not present as a result of formulating a product for safe use by consumers (e.g., pH balancing by acids or bases). Unintentionally added ingredients include chemical contaminants (naturally occurring impurities present in procured raw materials that are unintentionally incorporated into final formulations where they provide no function) and incidental chemicals (chemicals in raw materials present as a result of processing or for stabilization such as catalysts, solvents, residual monomers, reactive by-products, and raw material preservatives).