Responsible Chemicals Management

Chemicals are part of our daily lives and used to help make the products we all use and interact with. They offer certain benefits and qualities but also must be used responsibly by manufacturers. There is a wide range of legislation and safety standards that governs their use to protect customers and the environment and many brands and retailers go above and beyond these standards. 

Many types of chemicals are used throughout the sourcing and production of our Clothing & Home products. For example, chemicals are used to manufacture fabric, to dye or print fabrics and to wash and dry the finished product. And chemical ingredients are also used in our range of Beauty products too. 

We always strive to do the right thing and the M&S approach to chemical management has never stood still. To ensure the safety of our customers, people who work in our supply chains and the environment we were the UK’s first major retailer to launch a chemical compliance policy in 1998 and we have continued to evolve and improve our approach since this time.

Commitments and targets
We want to lead our sector in sustainable production and consumption, offering our customers the great value, high quality products and services that they expect from us while respecting our planetary boundaries and need for social equity. 

We aspire to eliminating any chemicals of concern from our Clothing & Home supply chain and are progressively working towards this goal. We are committed to achieving zero discharge of hazardous chemicals from the manufacture of our textile and apparel products by 2020. With the launch of Plan A 2025 in 2017, we’ve made further commitments around measuring water efficiency in our garment and textile factories and setting targets for reduction by 2025 and establishing minimum independent standards for our processing facilities to achieve by 2025. 

Approach
We were the first UK major retailer to launch a chemical compliance policy in 1998. This banned the use of hazardous chemicals such as alkylphenol ethoxylates (known as APEOs) and heavy metals and was gradually extended to cover textile printers, finishing facilities, laundries and tanneries as well as dyehouses. 

We updated our standards in 2011 with the introduction of our Environmental and Chemical Policy (ECP) which introduced new guidance and best practice for our suppliers. For the first time, we also included modules on environmental management. 

In 2012, we signed up to Greenpeace’s Detox 2020 campaign and worked with them to develop our new chemical commitments which have strengthened our ECP. And in 2014, we launched our Manufacturing Restricted Substances List (MRSL) to complement our existing product Restricted Substances List (RSL). We are continually evolving and improving our ECP and approach to chemical management. Find out more about our agreement with Greenpeace and how we are progressing against this commitment

We believe the elimination of hazardous chemicals needs not only collaboration and partnership with our industry peers, but also a holistic and integrated approach, working with material suppliers, the broader chemical industry, NGOs and other stakeholders to achieve this goal. We joined the Zero Discharge of Hazardous Chemicals (ZDHC) in 2012 an industry initiative tasked with advancing towards zero discharge of hazardous chemicals in the textile and footwear sector. We’re also working collaboratively with the Sustainable Apparel Coalition and in December 2017 we invited our top 100 processing facilities (which equates to 80% of fabric/leather supplier turnover) to complete their Higg Facility Environmental Module

Much of our focus has been on apparel and textiles which makes up the largest proportion of our Clothing & Home offer. However, we also restrict and prohibit what is used in our packaging and Beauty products. We are currently exploring how our ECP approach can be extended to cover all our Clothing & Home products. 

We support the right to know principle and have always tried to be open and transparent – both in the information we make public and the way we share it. We are committed to continue to track and report annually on our progress towards our chemicals commitments and targets on this website and through our Plan A Report.

Our approach to responsible chemicals management focuses on:

Understanding and communicating how chemicals are used within our supply chain and products
Supply chain due-diligence
We are committed to improving our understanding of how and where chemicals are used in our supply chain and to make our products.

Hazard is the basis for our approach to reviewing chemicals. However exposure also has to be considered in order to understand where the most urgent and critical actions must be taken. Scientific understanding of the impact of chemicals also continues to evolve.

Our actions are guided by transparency, fact-based decision-making and based on a precautionary and integrated approach to chemicals management.

By having a clear picture of the chemicals used in our products, even those not currently covered by legislation, we will be better placed to respond if new chemicals of concern are identified. With thousands of Clothing & Home products sold in our stores, this is hugely challenging. This is compounded by fact that in many instances we represent a small proportion of what is produced at our clothing factories and wet processing facilities (i.e. dyehouses, printers, laundries, tanneries and finishing facilities) compared to other brands.

The main (but not exclusive) area for exposure is wet processing and the hazardous chemicals mostly likely to be used in these processes are listed in our Manufacturing Restricted Substances List (MRSL) and product Restricted Substances List (RSL).

As of the end April 2018 we sourced from 1,079 wet processing facilities over 85% of which are located in China, India, Turkey, Bangladesh and Sri Lanka (see Figure 1 below).

We require all of these sites to be fully disclosed to us as well as fully disclosing their chemical inventories and is a condition of supply.

Figure 1: Location of wet processing sites by fabric/leather supplier turnover
Note: 'Other' countries are Taiwan, South Korea, Italy, Pakistan and Mauritius (7%) and UK, Mexico, Slovenia, USA, Germany, Netherlands, Serbia and Japan (1%).


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).

Transparency

We support the right-to-know principle and believe that trust is established and maintained by doing business in the right way. We have always strived to be as open as possible – both in the information we provide and the way in which we share it. 

We want to be a retail leader on transparency by being as open as possible on the issues that matter most to our stakeholders. 

In May 2016, we published for the first time an interactive map which features the locations of our active first tier clothing manufacturing sites and is updated twice a year. Find out more about our clothing supply chain. With the launch of Plan A 2025, we aim to add further Food and Clothing & Home supply chain details by April 2019 and details of raw materials suppliers by April 2022. 

If any stakeholder would like to know whether a particular product contains substances of very high concern, perfluorocarbons (PFCs) or other chemicals they can contact us directly using the ‘Product quality – clothing and home’ email option.

Pollution Release and Transfer Register Data (PRTR) and Corporate Information Transparency Index (CITI)

We recognise the positive impact that public data sharing platforms can have on chemicals use. 

We use the Institute of Public and Environmental Affairs (IPE) platform to upload Pollution Release and Transfer Register data (PRTR) from our Chinese wet processors.

Since July 2017, it has been a mandatory requirement that all our Chinese wet processing facilities must upload their PRTR data onto the IPE website. This represents 33% of our wet processing sites based on fabric/leather supplier turnover. 

M&S is committed to extending this public disclosure initiative to other manufacturing regions outside of China and will work with the relevant stakeholders to help provide a suitable data sharing platform (e.g. ZDHC Gateway Wastewater Module).

This mechanism has now been incorporated into our Dyehouse Audit approval and renewal process so that all Chinese wet processing mills are now required to register and complete all tasks to fulfil all areas in the Corporate Information Transparency Index (CITI)

In 2017, we were ranked 4th overall out of 65 brands within the textiles category and 6th overall out of all 267 brands which were assessed across all sector categories. Find out more about the CITI Index 2017 Annual Evaluation.
Establishing and maintaining clear minimum standards
Minimum standards

We were the first UK major retailer to launch a chemical compliance policy in 1998. This banned the use of hazardous chemicals such as alkylphenol ethoxylates (known as APEOs) and heavy metals and was gradually extended to cover textile printers, finishing facilities, laundries and tanneries as well as dyehouses. 

We updated our standards in 2011 with the introduction of our Environmental and Chemical Policy (ECP) which introduced new guidance and best practice for our suppliers. For the first time, we also included modules on environmental management.

It is the responsibility of our suppliers to ensure they are compliant with both our Manufacturing Restricted Substances List (MRSL) and the product Restricted Substances List (RSL) (see below). This is a minimum requirement for overall compliance to our Environment and Chemical Policy (ECP).

The ECP comprises the following modules:

We also have clear policies on the following:

  • Perfluorinated chemicals (PFC)
  • Polyvinyl chloride (PVC)
  • Nickel
  • Nanotechnology
We have developed chemical guidance and best practice for our suppliers on how to implement the MRSL and our wider ECP. For example, as part of our commitment to phase out PFCs by July 2016 we developed PFC Substitution Guidance and Non-PFC Application Best Practice. Many of our ECP modules refer to best practices for which wet processing facilities can adopt to help them move towards a “clean factory” approach.
Manufacturing Restricted Substances List (MRSL)

We launched our Manufacturing Restricted Substances List (MRSL) in December 2014. The MRSL forms a core focus for our Environmental and Chemical Policy (ECP) and reinforces the requirement for clean input chemistry. 

Our MRSL applies to textiles and leather and is based on the Zero Discharge of Hazardous Chemicals (ZDHC) MRSL but with some additional details around heavy metals and pesticides. We have banned the intentional use of all 11 chemical priority groups except flame retardants which are required for upholstery and some heavy metals where alternatives to pre-metalised dyes are not available. 

The ZDHC Research List contains those chemicals for which alternatives that are safer and provide acceptable performance are not yet available, and as such serve as a call for more research to look for alternatives. By virtue of our commitment to the MRSL, we are committed to not only the 11 priority chemical groups identified in the ZDHC joint road map but also the idea of continuous improvement and revision of the MRSL. This will be done in alignment with the annual MRSL revisions conducted by ZDHC

We updated our MRSL in May 2016 to include preferred test methods and elimination status. We will continue to work with the chemical industry to seek alternatives to both halogenated and TEPA flame retardants and those dyestuffs that include heavy metals. We've recently made further updates to our documentation identifying PFC CAS Numbers on our MRSL and added the requirement for our wet processing facilities to adhere to the ZDHC Wastewater Guidelines to our MRSL/RSL Module and Environmental Management Module

For each substance, our MRSL sets out the CAS number, preferred testing methodology and elimination status. We list those chemicals which are used in the textile and leather supply chain and for which alternative safer chemistries with acceptable performance are available. 

Detection Limits for the MRSL are based on whether chemicals are intentionally used in our supply chain. These detection limits are the lowest commercially available to support our global textile supply chain.

We have developed a MRSL risk matrix to ensure our suppliers are testing the relevant formulations against the relevant chemicals. These tests must be done through independently accredited laboratories to the testing requirements listed in the MRSL. 

Product Restricted Substances List (RSL)

We first launched our product Restricted Substances List (RSL) for textile processing in the late 1990s – the first major retailer to do so. Details are provided of the chemical, its risk, acceptable levels of presence in the finish product and preferred test method for identification and quantity present. The legal status of a particular substance is also highlighted – for example if it is classified as a Substance of Very High Concern (SVHC) through the EU Registration, Evaluation, Authorisation and restriction of Chemicals (REACH) Regulation

The RSL is not restricted to the initial 11 priority chemical groups identified in the Zero Discharge of Hazardous Chemicals (ZDHC) joint road map. We’ve made good progress against these 11 chemicals. In 2015, we also extended the ban on phthalates to all clothing, footwear and accessories. 

Wet processors should ensure that their own chemical suppliers are clear about our requirements and can supply proof of compliance in relation to deliveries. We require Material Safety Data Sheets (MSDS) to be checked against the RSL requirements for each product. 

There are many thousands of chemicals that are not mentioned in the RSL that are known to be harmful to human health or the environment. They are not mentioned because there is little chance they would ever be used in connection with the type of products we sell. However, we do not expect any harmful chemicals to be present in our products. We will continue to review and update the RSL and promote the minimisation of harmful chemicals in our products and the responsible use of safer technology. 

Elimination of perfluorocarbons (PFCs)
In February 2013, we committed to eliminate PFC chemicals from all of our production by 1st July 2016 through substitution to non-PFC technologies which we achieved. These chemicals are now banned from use. 

Our current performance is as follows:

  • As of December 2015, we were 100% free of long chain PFCs (C8 finishes) and 77% free of short chain PFCs (C6 finishes)
  • No PFC finishes have been specified on any M&S clothing product since 1st July 2016 
See below for a case study on how we approached the substitution of PFCs to support wider industry learning.

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.

Checking compliance with our standards

Wet processing facilities
We require every dyehouse, printer, finisher, laundry and tannery that supplies on behalf of M&S to be disclosed to us (see above), to have read the Environmental and Chemical Policy (ECP) suite of documents and have fully completed a Self-Audit prior to any production taking place. We’ve also made our Self-Audit protocols available in Turkish and Chinese. 

Completion and approval of this Self-Audit is mandatory and is a formal acknowledgement that the factory complies with our ECP requirements. This status is repeated every 18 months to ensure that our records of factories reflect current best practice and capability.  

Our specialist Regional Office teams located in the UK, Turkey, India, Sri Lanka, Bangladesh, China, Cambodia and Vietnam carry out follow-up visits to wet processing facilities during the year to check the validity of information disclosed by our suppliers.

Monitoring of discharges
Whilst wastewater testing is in important aspect of our due diligence we believe it's important to focus on delivering clean input chemistry through our MRSL and other tools to ensure our fabrics and textiles are manufactured in an environmentally appropriate way.

During 2017, we conducted pilots with a number of our wet processing facilities in India and Bangladesh to assess data collection using the newly published ZDHC Wastewater Guidelines. The below table provides a summary of results of our testing in India.

Table 1: ZDHC Wastewater Guidelines / ZDHC Gateway: Wastewater Module Pilot - India, 2017


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.

Supporting programmes that further our understanding and build capacity within our supply chain
Sustainable Apparel Coalition (SAC)

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.

Zero Discharge of Hazardous Chemicals (ZDHC)

We joined the Zero Discharge of Hazardous Chemicals (ZDHC) in 2012 an industry initiative tasked with advancing towards zero discharge of hazardous chemicals in the textile and footwear sector. ZDHC currently represents a number of leading brands committed to working together drive industry-wide change.

Through our collaboration with ZDHC and its signatories we are helping to raise the standards of chemical management within the facilities we share and the wider textile industry. 

For example, we are collaborated with ZDHC and other stakeholders on the development of their Wastewater Guidelines which we have now formally adopted as part of our ECP suite of documentation.

We provide ongoing training to our technical teams and are working with ZDHC to deliver a global chemical management training programme to the textile and leather supply chain. 

In 2017, we invited all our wet processing facilities to sign up to using the ZDHC Chemical Gateway enabling them to actively identify ZDHC MRSL compliant chemicals and dyestuffs at source.

Roadmap Towards Responsible Viscose & Modal Fibre Manufacturing

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.

Model Eco Dyehouses Programme

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.

Plan A product attributes

We are committed to improving the sustainability of our products. We want every one of our products to have a Plan A attribute by 2020 – a characteristic or inherent quality or feature of a product which has a positive or lower environmental and/or social impact.

Our suppliers are required to progressively improve the sustainability credentials of our products. All should have at least one Plan A product attribute by 2020 and we have targets in place every year to increase this number. In 2017, we extended this commitment so that by 2025 every one of our products will have Plan A attribute that address every single one of its material social and environmental impacts. For example, covering the key raw materials, factory, use and disposal stages in a product's lifecycle.

We’ve used our Plan A product attributes programme to promote the use of better technologies such as cleaner processes for making denim and printing fabrics. There are a number of Plan A product attributes of relevance to chemicals, such as:

  • Leather where the tannery completing the final stage(s) of processing has achieved at least Bronze rating and have a traceability score via the Leather Working Group auditing protocol
  • Cruelty Free
  • M&S Eco Factory
  • WWF Low Carbon Manufacturing Programme
  • OEKO-TEX® Sustainable Textile Production (STeP)
  • Bluesign® certification
  • Ozone Technology
  • Eco Dyeing
  • Water-Based Polyurethane
  • Spun Dye Man-Made Fibres
  • Environmental Impact Measuring (EIM) Software for Denim Wet Processing
  • Sublimation Printing
During 2017/18, over 37% of Clothing & Home products sold had a fabric/textile related Plan A product attribute. 

More information about Plan A attributes for Clothing & Home products can be found in the document How We Define Plan A Product Attributes, which you can download on this page. Find out more about our approach to product sustainability.
Research and innovation

Through Plan A 2025, we're aiming to make our entire business model zero waste - not just our own operations but also our supply chains and our products too, putting circular thinking at the heart of our business model. We are committed to improving the sustainability of our products by promoting alternative and cleaner technologies and putting the circular economy into practice. This is a bold goal, one which means we need to simplify the materials we use, help create markets for recycled materials, build partnerships to give products and packaging a second life and launch new types of business model

Each year we typically invest at least £100,000 into Clothing & Home specific programmes and initiatives which aim to help us in this task.

For example, we know that extending the average life of clothes by just three months of active use can lead to a 5-10% reduction in the product footprint (carbon, water and waste). Over the last 12 months we’ve sold 15 million M&S products treated with Stay New Fabric technology that reduces pilling and colour fade. 30% of these products use enzyme technology, but anti-pill fleece and vortex / compact spun yarns are used too. 

We're also actively involved in a number of industry and multi-stakeholder collaborative initiatives. We were founding members of the Waste & Resources Action Programme's (WRAP) Sustainable Clothing Action Plan (SCAP). As part of our membership of the Ellen MacArthur Foundation's CE100 we are members of the Circular Fibres Initiative. We are also members of Cradle to Cradle's and Fashion Positive's Circular Innovation Working Group which is looking at mechanical recovery and chemical recycling of cotton and cotton polyester blends as well as being members of Fashion Positive's PLUS initiative

Working with others
Listening, learning, responding and working in partnership is an important part of how we do business. 

To develop our approach to chemicals, we’ve worked with many partners, including Greenpeace, Zero Discharge of Hazardous Chemicals (ZDHC), British Retail Consortium, Changing Markets Foundation and the Sustainable Apparel Coalition. Operationally, we’re supported by our suppliers and expert organisations such as specialist consultants and independent test laboratories who are helping us ensure the safety and integrity of our products. 

Through ZDHC and the Leather Working Group we’re engaging in global efforts to tackle industrial releases of all hazardous chemicals into the environment. 

Key documents

Interactive supply chain map

Find out more about our supply base


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Product Sustainability

Find out about our approach to product sustainability


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Protecting Forests

Find out about our approach to protecting forests


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Waste & Circular Economy

Find out about our approach to waste and the circular economy


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