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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 dye or print fabrics. 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. 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  2020 we invited our top 20 fabric suppliers to complete the Higg Index FEM (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.

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 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. 


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 2019, we were ranked 2nd in the retailer category of the Green Supply Chain CITI Evaluation. Find out more about the 2019 CITI 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:
  • 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. 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 March 2020 to coincide with the ZDHC MRSL Version 2.0. 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 require all our wet processors to register with the ZDHC Chemical Gateway to help our suppliers source safer chemistry solutions.

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 intentional use in apparel and footwear. 

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.


As part of the onboarding process for Chinese Wet Processors, we check the IPE platform to assess whether a supplier has had any previous pollution violations. We also then require all approved Chinese Wet Processors to upload their PRTR (Pollutant Release & Transfer Register )data onto the IPE platform.

From 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 January 2020, we invited our top wet processing facilities 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.

The ZDHC solutions and platforms include, amongst others the newly released ZDHC MMCF Guidelines, composed of, ZDHC MMCF Interim Wastewater GuidelinesZDHC MMCF Interim Air Emissions Guidelines, and ZDHC MMCF Responsible Fibre Production Guidelines

The ZDHC MMCF Guidelines outline integrated expectations for discharge wastewater quality, emissions to air, and chemical recovery for manufacturing facilities producing Man-Made Cellulosic Fibres. Through a three-level (foundational, progressive, aspirational) approach for the limit values and/or recovery rates of the proposed parameters, facilities can implement a driven, continuous improvement plan to reduce their impacts

We are implementing these ZDHC (Zero Discharge of Hazardous Chemicals) tools within our supply chain, and MMCF Producers will be assessed on their environmental performance going forward.

See our Responsible Sourcing Policy for Manmade Cellulosic Fibres.

Find out more about our approach to protecting forests.

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
  • 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
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

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


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.