Responsible Chemicals Management
Find out about our approach to responsible chemicals management
Understanding and communicating how chemicals are used within our supply chain and products
Note: 'Other' countries are Italy, Pakistan, Korea, Vietnam, United Kingdom, Taiwan, Thailand, Cambodia, Myanmar, Egypt (12%) and Brazil, Madagascar, Belgium, Indonesia, Malaysia, Mauritius, Romania, Argentina, Bulgaria, Czech Republic, Israel, Japan, Mexico, Portugal and Spain (3%)
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).
Establishing and maintaining clear minimum standards
- ECP Introduction
- MRSL and RSL
- REACH (Registration, Evaluation, Authorisation and restriction of Chemicals)
- Minimum Standards and Best Practices for Textile Wet Processing
- Minimum Standards and Best Practices for Tanneries
- Environmental Management
- Due Diligence for Chemical Compliance
- Self-Audit: Textile Wet Processing (available in English, Chinese and Turkish)
- Self-Audit: Tanneries (available in English and Chinese)
- Polyvinyl chloride (PVC)
- Nickel
- Nanotechnology
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
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 2021, 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.
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.
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 Guidelines, ZDHC 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.
Key documents
