Guidance

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


  • For B1, intentionally added chemicals on the stewardship list below 100 ppm are not to be considered.
  • For B2, when SCCS and CIR have both established safe use thresholds, use the more conservative threshold.
  • For B3, communication can occur electronically or on label.  Electronic disclosure includes, but is not limited to, websites, mobile apps, SmartLabel, and QR codes.  Electronic disclosure via these means must occur though manufacturer-based efforts and not via third party websites or services.
  • For B4, B5 and B6, chemicals on the stewardship list must not be present above a threshold level of 100 ppm in final formulations.
  • For C, the criteria for certification must be publicly available from a third party and must limit the use of chemicals on the stewardship list.  Valid certifications include, but are not limited to, EPA Safer Choice and Cradle to Cradle Certified Product Standard.


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

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.


Cradle to Cradle Certified Product Standard:  Cradle-to-Cradle product Certification provides a standard of performance for manufacturers regarding product sustainability and material safety.  Individual product assessments are performed by independent and trained third parties and certifications are made by the Cradle-to-Cradle Products Innovation Institute.


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.


Definitions

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).


Note:  BPC participants did not reach agreement regarding the use of the stewardship list for assessing product sustainability. Retailers will independently score Key Performance Indicators (KPIs) #3 and #5 under the human health cluster.