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
'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).