From legal requirements to emerging issues, restricted substances lists (RSLs) (PDF) manage materials and chemicals of concern in products and supply chains.
While RSLs are nearing universal uptake, their ability to advance better ingredient choices requires more than creating the list.
Where to start?
An RSL is a tool that should flow from the company’s priorities such as risk avoidance and meeting market demands and align with sustainability commitments.
The lists can be a key part of an overall chemicals management strategy.
Sometimes an RSL is simply used to manage compliance with regulatory and customer requirements. Increasingly, they are employed as a starting point for a sustainable chemicals management approach that aims to enhance the safety and transparency of products and supply chains.
RB, a global health, hygiene and home company with brands including Clearasil, Lysol, Amope and Woolite, established its RSL in 2001. (Disclosure: RB is a former client of the author’s company, Pure Strategies).
This action supported the company’s vision of a “world where people are healthier and live better” and its goal to reach over 200 million people to improve their health and hygiene.
Jennifer Duran, global head of product sustainability at RB, pointed out that “RB created the Restricted Substances List to minimize the health and environmental impact from our products, and it has been instrumental in helping deliver better health to our consumers.”
What goes on the restricted list?
RSLs typically address a combination of health and environmental issues. RB reviews existing and emerging global regulations, market and stakeholder considerations and scientific evidence to update the materials on its RSL each year.
These are the main areas to consider in identifying potential chemicals of concern. Notably, RSLs, including RB’s, typically go beyond regulatory requirements due to growing market demands, such as customer programs and the value they provide in driving a sustainable chemicals management program.
A critical step in developing an effective restricted chemicals list is considering what will be used instead, because replacements may be just as much of a concern as the original substance.
Many companies include additional materials that are similar to a primary chemical of concernand carefully evaluate alternatives in order to avoid a regrettable substitution.
However, companies may determine that a material does not have a safer or effective alternative and should not be replaced yet.
RB’s RSL has a global scope and includes over 50 ingredients such as formaldehyde donors, polyethylene beads, parabens, glycol ethers and alkylphenol ethoxylates. RSLs may include materials and contaminants to remove as well as those that may be restricted to certain applications or use limits for the product, package and process.
RB removed polyvinyl chloride (PVC) from packaging and household products in 2009 across most of its business, but Duran acknowledged that “healthcare products are excluded from this ban due to limited alternatives in packaging that prevent tampering and provide appropriate product protection.”
How to gain the most from an RSL
The list helps communicate expectations internally and externally. Product development teams need to know what they can and can’t use and procurement departments have to understand supplier requirements.
To ensure compliance, the list should clearly state any testing needs. RB runs training programs with the R&D, regulatory and procurement organizations on the RSL to ensure that all staff with responsibilities for selecting or approving ingredients are fully aware of the company’s approach.
Ensuring supplier compliance to the RSL and gaining the needed disclosure on chemicals can be challenging. RB is working to include requirements in contracts with suppliers. The company also shares highlights of the list with stakeholders to provide transparency.
Most important, the RSL drives improvement.
“When we were removing formaldehyde, we determined how we can also remove formaldehyde donors, making us one of the first to stop using these ingredients in our products in 2009,” Duran said.
More recently, RB committed to reducing and removing parabens from the global product portfolio. This required an internal team of scientists and collaboration with key suppliers to identify alternative preservatives that could replace the parabens with preferable options.
RB also uses the RSL as a foundation for its broader sustainable innovation program that aims to drive one-third of net revenue from more sustainable products. Compliance with the RSL is a requirement for this program, as well as a part of the company’s 2020 commitments.
“The restricted substances list is a part of our efforts to develop responsible products,” Duran said. “With this and other ingredient strategies, we are building our capacity to better select, manage, use and provide information about the ingredients that we put in our products.”
What comes next?
RSLs too often fall short of enabling a more proactive material selection approach that facilitates teams choosing the most preferred ingredient options with broader health and environmental profile improvements such as a positive ingredient list.
With so many companies using this tool, there is a notable opportunity to incorporate an RSL into a sustainable chemicals management strategy.
Such a list can help build to a program driven by better ingredient choices that support broader corporate sustainable product goals.
For more information, view a recording of the webinar “Sustainable Chemicals Management: Tools and Trends.”