We don’t use any facilities which have been determined as having significant environmental violations by the Institute of Public and Environmental Affairs (IPE).
Our Environmental and Chemical Policy (ECP) Minimum Standards – Due Diligence for Chemical Compliance sets out our expectations on systems of checks and controls to enable us to show that we’ve taken appropriate steps to meet our MRSL and product RSL requirements. It also sets out the actions that should be taken by the supplier should they identify a non-conformance.
In 2017, we invited all our wet processors to sign up to using the ZDHC Chemical Gateway enabling them to actively identify ZDHC MRSL compliant chemicals and dyestuffs at source. We have also commenced a CleanChain pilot with four of our factories in Sri Lanka. During 2018/19, we plan to roll out the use of CleanChain to a further 20 facilities with a live dashboard feed to monitor input chemical conformance against our MRSL. We will explore how we can make this public as part of our wider transparency programme.
Our Sourcing Offices carry out risk based due diligence testing of chemical compliance in each of our major sourcing regions against our product RSL every season. We also carry out risk based due diligence against our MRSL on top of facility testing and are currently piloting the use of the ChemIQ methodology.
We have adopted the ZDHC Wastewater Guidelines which provide a unified set of expectations on wastewater quality for the textile and footwear industry that goes beyond regulatory compliance. We require our suppliers to test their wastewater in accordance with these guidelines which are part of our ECP suite of documents.
We also carry out periodic due diligence testing of wastewater at our facilities to the ZDHC Wastewater Guidelines (see below).
Case Study: Substitution of long and short chain Perfluorinated (PFC) Chemical Finishes from Clothing, Footwear & Accessories
M&S were using both long and short chain PFC finishes to impart durable water and oil repellent properties across a number of our product offer – including outerwear, footwear and schoolwear.
We began with a targeted phase out of C8 long chain PFCs and then moved onto the phase out of C6 short chain PFCs.
To help in this transition we worked closely with our chemical suppliers to identify the alternative chemistries available and to pull together a PFC substitution guideline for our buying teams and suppliers to help them make the switch. Fortunately, we identified several alternative chemistries from a number of suppliers which were applicable to all the various substrates we use. The alternative chemistries also needed to be compliant with our existing Environmental and Chemical Policy and associated Restricted Substance Lists.
Each year we carried out an audit of all relevant product as we progressed towards our policy deadline.
We have switched to alternative chemistries such as waxes, dendrimers, silicon finishes, botanical extracts, paraffin, fat modified resins, cationic polymers and hydrophilic co-polymers. We did not employ the use of nanotechnology as we currently take a precautionary approach to the such technologies in apparel and footwear.
Some product areas were especially challenging for instance we were not able to find an alternative PFC free oil repellent finish for certain products (e.g. school wear). However, for these product types (which account for about 20% of our offer) we transitioned to an alternative technology that enabled an acceptable level of performance but was not based on poly or perfluorocarbon chemistry. For example, in our core ‘Back to School’ programme we worked very closely with our suppliers to find PFC-free alternative performance finishes that satisfied the expectations of our customers.
We successfully met our deadline of a complete ban on using PFC chemical finishes by 1st July 2016 and maintain due diligence checks to ensure we continue to be PFC free
Allowing for sales of existing stock we would expect to be completely PFC free by the end of 2018.
If any stakeholders would like to know if a particular product contains PFCs or any other chemicals they can contact us directly using the ‘Product quality – clothing and home’ email option.
As the datasets grew we started to see 'hotspots' and where our input controls were having a positive impact on effluent release. This was later extended to full Detox parameters and in the last quarter of 2017 we have begun requiring our wet processing facilities to test their wastewater against the ZDHC Wastewater Guidelines and publish to the ZDHC Gateway Wastewater Module.
Product level testing
We have historically carried our random unannounced due diligence testing of product in our stores against our product RSL.
We are now conducting chemicals due diligence on finished product and fabrics in our manufacturing regions on a risk-based approach each season. We believe this is a more proactive approach to product RSL testing any follow-up action will be taken up immediately with the supplier by our specialist Regional Office teams. We carry out a higher proportion of testing in our China region.
If any product is found to be non-compliant a fine may be payable by the supplier, which may be passed on to the wet processor. We reserve the right to return the product at the suppliers cost. In instances where non-compliance leads to a product recall associated responsibilities or charges will be applied to the supplier.
The Sustainable Apparel Coalition if the apparel, footwear and textile industry’s leading alliance for sustainable production. We have been members of the Sustainable Apparel Coalition since 2015.
The Coalition’s main area of focus is on developing a standardised supply chain measurement approach for all industry participants to enable them to understand the environmental and social impacts of making and selling their products and services. This exists as a suite of self-assessment tools – known as the Higg Index.
In December 2017, we invited our top 100 processing facilities (which equates to around 80% of fabric/leather supplier turnover) to complete their Higg Facility Environmental Module. This allows them to develop an environmental baseline in six key impact areas (energy and greenhouse gas emissions; water use; wastewater; solid waste; air emissions and chemicals management) and track improvements over time.
Following the publication of a report on the viscose fibre production by the Changing Markets Foundation in 2017, we publicly committed to including the key principles on responsible viscose production as set out in the Changing Markets Foundation’s Roadmap Towards Responsible Viscose & Modal Fibre Manufacturing. The roadmap aims to move viscose manufacturers to closed-loop production system by 2023-25.
We are now working collaboratively alongside ZDHC, our suppliers and other brands and retailers to deliver in accordance with the roadmap.
Find out more about our approach to protecting forests.
Whilst we do not have direct contracts with any of the dyehouses within our supply chain we wanted to help develop and showcase environmental best practice for the wider industry. In 2010, we committed to support the development of three Model Eco Dyehouses within our supply chain by 2012. The purpose of which was to demonstrate how environmental best practice for the colouration of textiles can help drive improvements in water use, energy consumption, reduce chemical impacts as well as deliver commercial benefits.
We first introduced our first Model Eco Dyehouse in 2010. By 2012 we had three facilities in Turkey and one in China. Our aim was to work with these suppliers to deliver a leading standard of sustainable manufacturing.
For example, a pilot trial of cold pad batch dyeing of cotton and blends took place at one facility in Turkey highlighted environmental savings in terms of water, chemicals, salt and effluent loading as well as inputs such as dyestuffs on basic cotton fabrics. The results were independently verified by Istanbul University.
The Model Eco Dyehouse programme identified a number of Plan A product attributes such as Eco Dyeing (cold pad batch technology) (see below).
The programme also helped inform the development of our ECP suite of documentation (see above).
Find out more about our approach to capacity building initiatives.