Chemicals, meanwhile, are an essential ingredient in many of our products. We employ strict standards and take great care to ensure that they don’t cause harm in how they are extracted, manufactured or used in our products and our customers’ products.
Since 2015, we have maintained an enterprise-wide restricted substance list (RSL) program to guide us in the transition to chemicals with fewer environmental and health impacts. The first phase of our program focused on avoiding the use of RSL chemicals as we design new products. We’re now evaluating the use of these chemicals in our legacy products to consider better alternatives that are technically and economically feasible, with the evaluation expected to be complete by the end of 2018. In 2017, we’re working with our suppliers to identify where these chemicals may be present in our products and engaging them as partners in evaluating alternatives.
At the business-unit level, our RBIS business, in keeping with apparel industry standards, has a longstanding RSL program that requires its chemical suppliers to conform to a list of restricted substances that is even more extensive than our enterprise-level list. The list also delineates chemical concentration limits to avoid health hazards, harm to the environment and negative impact on the quality or performance of our products.
RBIS does not sell any products containing RBIS RSL substances. As part of its product development process, raw materials and finished products are tested against the RSL before being released. All of its raw materials suppliers are required to sign an agreement stating that they will comply with the RSL and policies for product testing. RBIS regularly audits suppliers to ensure compliance.
In compiling our RSL, we assess our products against a broad number of global regulations, such as European REACH, Restriction of Hazardous Substances, Waste Electrical and Electronic Equipment (WEEE), the U.S. Toxic Substances Control Act and hundreds of other regulations enforced by the U.S. Consumer Product Safety Commission and the U.S. Food and Drug Administration, along with similar regulatory agencies in the other countries where we do business.
We consider regulatory compliance to be the bare minimum standard, and we look for ways to go beyond compliance to ensure the safety of our products. For example, our RBIS business is seeking bluesign® certification for several of its factories—the first, Collitex, in Italy, will be certified in 2017. The bluesign system sets stringent standards for the safe and environmentally sustainable manufacture of textiles, including strict criteria for chemical inputs.
Our RBIS business also tests products before they ship to ensure that they have not inadvertently been contaminated by harmful substances listed in their RSL—a risk in any chemical-intensive manufacturing operation. In 2016, we conducted over 3,100 tests of our products and recorded only 13 failures. The rest of our company will begin testing products against the Avery Dennison RSL in 2018.
During 2017, we also began implementing manufacturing restricted substances lists (MRSLs) in several RBIS facilities. Our RBIS business will test against them at several facilities. An MRSL goes one step further than a product RSL; it restricts substances present in finished products and any that might be discharged into the air, water or ground during manufacturing or the operation and maintenance of our facilities. In implementing our MRSLs, RBIS is following a process developed by the ZDHC Foundation (roadmaptozero.com), an NGO dedicated to achieving zero discharge of hazardous chemicals in the textile and footwear value chain. We intend to have MRSLs in place at all RBIS facilities by 2020 and at facilities enterprise-wide soon afterward.