As an increasing number of retailers adopt Restricted Substance Lists (RSLs) as a component of their assortment curation programs, many suppliers need to strengthen their own chemical policy programs to help guide their formulation decisions. Developing an in-house program to monitor existing products and evaluate the new product pipeline will enable suppliers to avoid market access constraints at their largest customers and meet growing consumer demand for “safer” formulated products. 


For a supplier, developing and implementing an RSL provides an opportunity to rationalize chemical management and integrate regulatory requirements alongside market-driven ingredient selection considerations. Proactively screening products for chemicals that are included on retailer RSLs can manage future risk by providing clear indicators of a product’s market readiness.


This article reviews:


1.  RSL development

2. Three types of RSLs

3. Alternatives assessment





RSL development


Developing an RSL without assistance could seem like a daunting task, particularly for already stretched thin regulatory and sustainability staff that may not be well acquainted with how ingredient selection is conducted during product development. However, getting started is often easier than expected because retailer RSLs typically target a consensus group of chemicals of concern to consumers, so comprehensive assessments of all input chemicals are not necessary to identify the chemicals that add reputational or market access risk if they are included in products.


There are three complementary types of RSLs utilized in the supplier and retailer communities:  


 Regulatory: This approach selects a relatively small set of chemicals which are the subject of regulatory requirements, with chemical selection driven by applicable state, federal or international regulations for the relevant product categories.  While these RSLs provide an essential foundation for a company’s product safety and compliance program, they are generally retrospective in nature by focusing attention on known hazardous chemicals, rather than on emerging chemicals of concern for external stakeholders.


 Product Curation: This approach selects a relatively small set of chemicals which are the focus of consumer concerns (e.g., phthalates, parabens, etc.), with chemical selection driven by retail stakeholder concern about consumer acceptance or desire for product differentiation (particularly for own-brand products). Relatively short RSL lists are preferred because they are easy to communicate to suppliers and easy to operationalize - these are the retail sector’s top priorities for being replaced by safer alternatives. 

Target’s Clean Program (https://www.target.com/c/target-clean/-/N-p4n12) is the market-leading example of a product curation program, though there are similar  programs at a growing number of other retailers who have adopted RSLs to guide their assortment decisions. Additional examples include: Rite-Aid (https://www.riteaid.com/corporate/chemical-policy), CVS (https://www.cvs.com/content/tested-trusted) and Sephora (https://www.sephorastands.com/wp-content/uploads/Sephora-Public-Chemicals-Policy-2019.pdf). 


• Chemical Footprinting: This approach selects a relatively large set of chemicals which are of concern based on potential human health or environmental effects. These lists are generally built by combining authoritative lists from regulatory or hazard identification agencies, leaving less room for variability between retailers.  These RSLs are not generally used to identify ingredients that are prohibited or restricted in products.  Instead, they are used to generate aggregate chemical usage reports that characterize the physical mass of chemicals embedded in products sold by a retailer.  Similar to carbon footprinting, retailers may adopt time-bound reduction goals, such as reducing the total mass of their priority chemicals by 10% over 5 years.   Examples of chemical footprinting RSLs include: Walmart’s Priority Chemicals (https://www.walmartsustainabilityhub.com/sustainable-chemistry/implementation-guide/appendices) and two RSLs from sector NGOs : Chemical Footprint Project (https://www.chemicalfootprint.org/learn/measuring-a-chemical-footprint) and Beauty and Personal Care Stewardship List (https://www.sustainabilityconsortium.org/projects/bpc-rating-system/).




Alternatives assessment

These various approaches to developing an RSL create a complementary need for information about safer alternatives to targeted chemicals.  Leading-edge suppliers typically adopt some type of alternatives assessment framework as part of their chemical policy.  This can be as simple as a commitment to maximize use of ingredients that have been designated as “safer” by authoritative sources, such as US EPA’s Safer Chemical Ingredients (https://www.epa.gov/saferchoice/safer-ingredients) or third-party certification services, such as Cleangredients (https://cleangredients.org/).  


However, since these lists are not available for all product categories, suppliers may also develop an internal ingredient rating systems that help formulators select the safest ingredient for a given  functional purpose. These selection systems focus on identifying ingredients with the lowest hazard profile (e.g. GreenScreen List Translator - https://www.greenscreenchemicals.org/learn/greenscreen-list-translator) or become embedded in more comprehensive evaluations (e.g. Method’s Compass of Clean - https://methodhome.com/benefit-blueprint-compass/).  In addition, largest multinational formulated product suppliers typically utilize sophisticated multi-component assessments of their ingredients and products (e.g., Unilever - https://www.unilever.com/brands/Our-products-and-ingredients/Our-approach-to-the-safety-of-products-and-ingredients/).


As the demand for safer alternatives to RSL chemicals has increased, several ingredient information hubs have emerged to support the supplier ingredient selection use-case, including: 

•    EPA Safer Choice https://www.epa.gov/saferchoice/safer-ingredients lists chemicals that are safe alternatives grouped by functional-use class.

•    UL Prospector https://www.ulprospector.com/en/na enables searching through thousands of materials from global suppliers by keyword, properties, certifications and more.

•    Chemforward (https://www.chemforward.org/) aggregates peer-reviewed, scientific data on safer chemical ingredients and how to substitute them for chemicals of concern.  Its MaterialWise service (https://www.materialwise.org/) consolidates global regulatory and authoritative lists to help suppliers quickly identify known chemicals of high concern.  

•    The ChemSec Marketplace (https://marketplace.chemsec.org/) gathers green chemistry innovation data in one place, making it easier for companies to choose safer solutions that have been developed for the market.




With an increase in market demand for a chemical policy, developing and implementing a RSL can provide additional clarity for within the product development process and reduce market readiness risk. The process to create a chemical policy can be built upon the work other trusted organizations have done to develop public RSLs which enables a faster industry and/or customer-aligned chemical policy development and implementation. Several chemical alternative reference tools are also available to assist in evaluating safer chemical alternatives.



The WERCSmart program provides a secure, permission-based platform that facilitates the safe exchange of product information between manufacturers and retailers with the highest standards of confidentiality and service.