Sustainable Chemistry Implementation Guide Section 6: Appendices

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 Commitment to 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.

Walmart tracks policy elements related to the list of Walmart Priority Chemicals through information provided by UL. UL utilizes LOLI Chemical Registry Database to track the Reference Lists of Priority Chemicals. The LOLI Database does not maintain a record of inactive authoritative or regulatory lists. The Walmart Reference Lists of Priority Chemicals originally included two additional lists from the U.S. EPA (Priority PBT List and National Waste Minimization Program – Priority Chemicals). Though these two lists remain useful references of authoritative determinations of certain chemicals of concern, these lists are no longer included in the Reference list below because they are no longer maintained by the source regulatory organizations.

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	· Toxic Release Inventory (TRI) PBT 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

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.

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.

· CleanGredients
· GreenScreen List Translator
· Pharos Chemicals and Material Library
· U.S. EPA Safer Choice Chemicals List
· ChemSec Marketplace
· Scivera
· Alternative Assessment Paradigms
· BizNGO's Chemical Alternatives Assessment Protocol
· GreenScreen™ Methodology
· University of Lowell's Alternatives Assessment Protocol
· U.S. EPA's DfE Alternatives Assessment Methodology

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 commitment 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 consumables chemical footprint using UL's WERCSmart™ platform for in-scope formulated consumable products.

Walmart expects suppliers of formulated consumables to Walmart U.S. and Sam’s Club U.S to disclose ingredient information on-pack beginning January 2018.

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

In October 2017, UL’s WERCSmart platform changed their terms of use and licensing and introduced four Data Use Tiers to give retailers an opportunity to request additional information from their suppliers.¹ All Walmart suppliers for in-scope formulated, consumable products were encouraged to grant Walmart permission to access Tier 2.1 and 2.2 data. Additionally, Walmart encouraged in-scope Private Brand suppliers to grant permission to Tier 4.2. Below is the formal communication from Walmart to suppliers requesting Tier access.

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:

• Tier 2.1 authorizes UL to use confidential supplier data to provide WMT with reports on chemical usage and prevalence in formulated products.
• Tier 2.2 authorizes UL to provide WMT with the chemical identities of publicly disclosed ingredients in a product and a product’s transparency ratios.

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 encouraged 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
Webinar Recording
Chemistry Information Session
Tuesday, October 31, 2017
This meeting does not require a password
Play recording

¹ UL’s WERCSmart® Terms of Use, including the Data Use Tier Disclosure, are available here: https://secure.supplierWERCS.com/Help/TermsService#dutd.

With regard to online ingredient disclosure, Walmart recommends at a minimum that suppliers follow ingredient disclosure guidelines provided by the U.S. EPA Safer Choice program.¹ These guidelines do not explicitly mandate disclosure of specific ingredients in fragrances that are trade secret. However, the Safer Choice 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.

¹ https://www.epa.gov/sites/production/files/2013-12/documents/standard-for-safer-products.pdf