Appendix 1: Walmart reference list of priority chemicals

Appendix 1: Walmart Reference Lists of Priority Chemicals (as of Feb. 21, 2014)

The following authoritative and regulatory lists may be used as resources to identify Walmart Priority Chemicals for reduction, restriction, or elimination in accordance with Walmart's Policy on Sustainable Chemistry in Consumables.

Note: The policy excludes active ingredients that provide therapeutic benefit when present in a product approved by the FDA New Drug Application process.

European Union

· Endocrine Disrupters – Ranked Priority List - Human Health Categorizations 1 and 2.
· Interim Strategy for Management of Persistent Bioaccumulative Toxic (PBT) and very persistent bioaccumulative (vPvB) substances.
· SCCS Fragrance Allergens
European Union - REACH (1907/2006)

· Annex II – Cosmetics Regulation
· Annex XIV – Substances Subject to Authorisation
· Annex XV – Candidate List of Substances of Very High Concern for Authorisation
· Annex XVII Appendices 1 and 2 – Carcinogens Categories 1A and 1B.
· Annex XVII Appendix 4 – Mutagens Category 1B
· Annex XVII Appendices 5 and 6 – Reproductive Toxicants Categories 1A and 1B

International Agency for Research on Cancer
· Groups 1 (Carcinogenic to Humans) and 2A (Probably Carcinogenic to Humans) and 2B (Possibly Carcinogenic to Humans)
U.N. Environment Programme
· Stockholm Convention Secretariat Stockholm Convention on Persistent Organic Pollutants (POPs)
U.S. EPA
· Priority PBT List
· Toxic Release Inventory (TRI) PBT Chemicals
· National Waste Minimization Program – Priority Chemicals
U.S. National Toxicology Programme
· Report on Carcinogens – Known to be Human Carcinogens and Reasonably Anticipated to be Human Carcinogens
U.S. State of California
· Proposition 65 – Developmental/Reproductive Toxicants
U.S. State of Maine
· Chemicals of High Concern
· Priority Chemicals
U.S. State of Minnesota
· Chemicals of High Concern
· Priority Chemicals
U.S. State of Washington
· Chemicals of High Concern to Children (CHCC)
· Persistent Bioaccumulative Toxins
Appendix 2: US EPA and CSPA Recognized Elements of Public Online Disclosure


[1] Generally, for ingredients protected as trade secrets, a manufacturer may use chemical-descriptive name, for example, the EPA Premanufacture Notice generic name or the CSPA Dictionary name, in lieu of the specific chemical name; however, the name must be as specific as possible without revealing trade secret information.

Appendix 3: Guides for Alternatives Assessment

The following is a non-exhaustive list of publicly known methods, tools, and databases aligned with The Commons Principles of Alternatives Assessment that suppliers may use to advance the safer formulation of products using informed substitution.

Alternative Assessment Paradigms

Appendix 4: Overview of Safer Choice process

Figure 1: Reproduced from How to Partner, Get the Safer Choice Label on a Product.

Appendix 5: Notification of Walmart Priority Chemicals and Walmart High Priority Chemicals within WERCSmart Portal

Going forward, the WERCSmart website will be modified so that when a supplier enters the formulation of a product, the supplier will be notified if a particular component of your product is a Walmart Priority Chemical and/or Walmart High Priority Chemical.

Appendix 6: Key Stakeholders

Walmart U.S. and Sam's Club have worked with Environmental Defense Fund and a range of other NGOs, suppliers, academics, government and industry stakeholders to develop a company policy on sustainable chemistry for the formulated consumable products that we sell. Through close collaboration with Environmental Defense Fund, we have applied an initial framework for evaluating our chemical footprint using UL's WERCSmart™ platform for in-scope formulated consumable products.

Appendix 7: Guidance for On-Pack Ingredient Disclosure

Walmart expects suppliers of formulated consumables to Walmart U.S. and Sam’s Club U.S to disclose all Walmart Priority Chemicals on pack beginning January 2018.

Guidance on how suppliers can comply with Walmart’s On Pack Disclosure

Appendix 8: WERCSmart Data Tier Implementation

Subject: Worldwide Environmental Regulatory Compliance Solution (WERCSmart) Terms of Use Revision/Data Tier Implementation

Attention: Formulated Product Suppliers
On Oct. 16, UL’s WERCSmart platform will include an additional question that requires suppliers of formulated products to grant tier 2.1 and tier 2.2 permissions for national brand suppliers, and tier 2.1, 2.2 and 4.2 permissions for private brand suppliers.

Tier 2.1 and tier 2.2 permissions:

  • Will authorize UL to use confidential supplier data to track chemical usage and prevalence in formulated products.

Tier 4.2 permissions:

  • Only apply to private brands, and authorizes Walmart/Sam’s Club to publish a product’s publicly disclosed ingredient list online.

Suppliers are asked to grant permissions at no additional cost.

This represents a change in the process but does not represent a change in policy and is business as usual per the existing Walmart programs.

Contacts:
For supplier questions, contact Frank Schroeder at UL/WERCS

Thank you,
Walmart Sustainability
Walmart Environmental Health & Safety


Walmart Chemicals Best Practices Webinar

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Frequently Asked Questions


Does online public disclosure include fragrances?

With regard to online ingredient disclosure, Walmart recommends at a minimum that suppliers follow ingredient disclosure guidelines provided by the U.S. EPA Design for the Environment (DfE) Standard for Safer Products1 or CSPA's Consumer Product Ingredient Communication Initiative.2 These guidelines do not explicitly mandate disclosure of specific ingredients in fragrances that are trade secret. However, the DfE standard states that,


Scent ingredients may be listed as "fragrance," on the label, but the formulator must indicate where detailed information can be found; for example, the Web site list, or subset of the list, of fragrance materials authored by the International Fragrance Association (IFRA) and available on IFRA's Web site (http://www.ifraorg.org/). Alternatively, if not a matter of trade secrets, the product formulator may state on its Web site the ingredients in the fragrance or the palette of fragrance materials used in its products, and may include, at the formulator's discretion, ingredients not used in the fragrance.

The CSPA Consumer Product Ingredient Communication Initiative states that,

All chemicals present as components of fragrances may be listed as "Fragrances," but the Manufacturer must then refer to the availability of more detail elsewhere. Such detail may include, but is not limited to:

  • a link to the list or a subset of the list of fragrance materials authored by the International Fragrance Association (IFRA); or
  • a list disclosing the ingredients that the Manufacturer uses in its fragrances.

The Implementation Guide indicates that best-in-class online ingredient disclosure means full disclosure of all ingredients, including those typically protected under trade secrets. Walmart strongly encourages and will recognize those companies for fully disclosing all product ingredients.

[1] http://www.epa.gov/dfe/pubs/projects/gfcp/standard-for-safer-products

[2] http://www.cspa.org/images/stories/PDF_Documents/Voluntary_IC_Model_Amended_2011_FINAL.pdf

How can I tell if a chemical in my product is prioritized for reduction, restriction or elimination by Walmart?

For existing formulations, The Wercs has notified suppliers which products and chemicals (including CAS numbers) to prioritize as a starting point.

For new and ongoing formulations, suppliers will be notified upon entering their formulation in WERCSmart for compliance review. Suppliers are encouraged to use this free tool as early as possible in their development process.

At the Product Data Entry > Composition page, suppliers are notified if the chemical in the entered formula is "Regulated". If the user hovers over and clicks on "yes", a window opens. That window lists all Regulatory lists on which that component resides.

If you've selected a Walmart Priority Chemical or a High Priority Chemical, this window would include the classifications "List of WM Priority Chemicals Feb 2014" or "List of WM High Priority Chemicals Feb 2014".