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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.

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. In 2015, Greenpeace rated M&S as a Detox ‘Leader’. Find out more about our agreement with Greenpeace

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 WWF and the Sustainable Apparel Coalition. For example, we’re liaising with WWF to understand how leather tanneries are impacting the Ganges River Basin and how we can use these learnings to improve practices in tanneries elsewhere in our supply chain. 

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 (dyeing, finishing, tanning, printing, garment washing etc) 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 Restricted Substances List (RSL).  

We require our dyehouses and tanneries to fully disclose their chemical inventories to us and is a condition of supply. 

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 RSL requirements. It also sets out the actions that should be taken by the supplier should they identify a non-conformance.
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. Find out more about our clothing supply chain

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.

We have extended the number of dyehouses that have taken part in the public disclosure initiative to 71 – this currently represents 80% of M&S Chinese fabric supplier turnover. Around 39% of our dyehouses are located in China. 

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.

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 2015, we were ranked 4th overall out of 31 brands within the textiles category and 5th overall out of all 167 brands which were assessed across all sector categories. Find out more about the CITI Index 2015 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, we’ve 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. 

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 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 2012, we made a commitment to eliminate PFC chemicals from all of our production by 1st July 2016 through substitution to non-PFC technologies. 

We adopted a phased approach to elimination which has been supported by the following:

  • Rigorous systems of control to ensure that no traces of PFCs find their way into our supply chain
  • Reviewing all uses of PFC based finishes in our products
  • Working in partnership with our supply chain and wider industry to accelerate a move to specifying non-PFC technologies
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)
  • After 1st July 2016 no PFC finishes will be specified on any M&S clothing product. 
We have switched to alternative chemistries such as waxes, dendrimers and silicon finishes. However, M&S currently takes a precautionary approach to using any nanotechnology in clothing and apparel.

To date we have not yet found an alternative PFC free oil repellent finish for certain products (e.g. school wear and upholstery). However, for those product types (which account for about 20% of our offer) we are transitioning to an alternative technology that will still deliver an acceptable level of performance but not based on poly or perfluorocarbon chemistry. For example, in our core ‘Back to School’ programme we have worked very closely with our suppliers to find PFC-free alternative performance finishes that will satisfy the expectations of our customers.

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 have read the Environmental and Chemical Policy (ECP) suite of documents and 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
Ten of our Chinese wet processors have undertaken Detox testing at various stages during processing and uploaded these test results onto the IPE website (see above). Whilst wastewater testing is in important aspect of due diligence M&S focuses on delivering clean input chemistry through its MRSL and other tools to ensure our fabrics and textiles are manufactured in an environmentally appropriate way.

Product level testing
We have historically carried our random unannounced due diligence testing of product in our stores against our RSL. 

From this year we are now conducting chemicals due diligence on finished product and fabrics in our manufacturing regions. We believe this is a more proactive approach to RSL testing any follow-up action will be taken up immediately with the supplier by our specialist Regional Office teams. We plan to 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

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 21 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 collaborating with ZDHC and other stakeholders on the development of Global Wastewater Standards. These will published and incorporated into our MRSL by September 2016.

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 later in 2016. 

Eco Dyehouses

We introduced the Model Eco Dyehouse programme in 2012 and began with three facilities in Turkey and one in China. The aim was to work with these suppliers to deliver a ‘gold standard’ of sustainable manufacturing. Significant savings were made in the amount of water, energy and chemicals used as well as reductions in waste. 

M&S will launch a further Model Eco Dyehouse programme by 2016 to focus on developing best practice for chemical and effluent management. The best practice will help to define new standards to be extended across our supply base. We have already identified and are working with four Model eco dyehouses (one in China, three in Turkey), to develop best practises chemical management, water usage and waste.

We’re also testing an improved audit method that will allow us to develop an Eco Dyehouse Plan A product attribute (see below).
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. 

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 2015/16, over 7 million 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

We are committed to improving the sustainability of our products by promoting alternative and cleaner technologies and putting the circular economy into practice. In the last year alone we've invested over £350,000 into 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 members of the EMF Circular Innovation Working Group which is looking at mechanical recovery and the chemical recycling of cotton and cotton polyester blends.

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, WWF 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

Find out about our approach to waste and the circular economy


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Find out more about our supply base


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