A restricted substances list (RSL) is one part of a comprehensive and effective approach to chemicals management. But the value of a RSL will be curtailed when implemented in isolation. So we recommend to that companies use their RSL as one tool in the implementation of effective chemicals management across the product lifecycle. A comprehensive approach ingredient safety and chemicals management should involve the following:

• Knowing what is in the products you make and/or sell

• Defining and sharing your approach to ingredient safety through statements of policy, standards, and guidelines

• Building and routinely updating tools to implement your safety policy including a RSL, process for managing contaminants of concern, and assessing ingredient hazard

• Publicly disclosing ingredients including the individual components for ingredients that are in complex mixtures like fragrances and natural flavors

• Assessing chemicals and ingredients based on inherent hazard first, then based on the potential for exposure in exceptional circumstances

• Using safer alternatives and investing in green chemistry

One thing about effective chemicals management that is the same no matter what industry, company, or product you’re working with is that it requires cross-functional engagement and a clearly defined process. More on key questions to answer through stakeholder engagement below.  With that in mind, it’s also worth noting that if your company sells products made by other companies you’ll want to assess the landscape of brand chemicals management approaches for the relevant product categories, including any existing RSLs they may be using. It may also make sense to plan and execute an external stakeholder engagement process that includes affected brands since changes to your RSL may impact which products you carry and sell. There are some other nuances the come along with developing and implementing a RSL as a retailer as well.

Restricted substances lists are sometimes called “black lists” or “red lists” depending on the company and industry - but the take home is that these are chemicals (sometimes groups or “classes” of chemicals) that should not be intentionally added to products or formulations. The RSL is an implementation tool that is a direct reflection of the internal safety policy and standards of an organization. As such, we typically recommend to our clients that they create a statement of policy as well as implementation guidelines or standard operating procedures that can serve as the foundation for managing chemicals. You’ll notice that we’re talking about creating AND maintaining or revising a RSL - that’s because these tools should be routinely updated based on evolving science, regulations, and consumer expectations. Once those pieces are in place, here are the steps we generally use when were are building an RSL for a company:  

1. Defining the scope of ingredient safety or chemicals management

We need to determine what aspects of the business will be governed by the RSL. At a minimum, we believe it should include chemicals or ingredients used in all products, parts, or components. We often encourage companies to expand the scope to include chemicals used to process raw materials and to manufacture components, parts, and/or products. In some cases, it makes sense for company to also include chemicals used in packaging. A truly comprehensive scope will also include chemicals used in facilities, operations, and maintenance in the RSL when appropriate.

2. Identifying sources for the list

Many companies start by using legal and regulatory compliance as the basis for their RSL. We prefer to include those chemicals or ingredients as part of a separate but related compliance list for a number of reasons. We prefer to use two other sources as the primary inputs for our RSLs: 1) Market demand (e.g. customer requirements, certification requirements, industry generated lists, and NGO generated lists), and 2) hazard information (i.e. authoritative government or scientific body lists, screening lists, and unbiased scientific research).

3. Prioritizing the list for action

There are several types of criteria that we commonly use to help companies prioritize chemicals on their RSL for action. We don't include legal or regulatory compliance as a criteria for prioritization in our RSLs because the ingredients or chemicals included on a compliance-based list should already be a top priority for the company and considered the starting point. But we often use criteria related to company values or goals, business risks and opportunities, and market considerations like consumer concern or NGO advocacy.

Mistakes to avoid:

Many companies just take a “list of lists” approach to compiling an initial RSL or simply assemble a bunch of "free-from" claims and call it good. While this can be better than nothing, it has limited utility when it comes to informing action.

With a sense of which ingredients or chemicals to prioritize for action your company can start to more effectively manage risk and capitalize on opportunities. We find that the chemicals included on an RSL often land in one of several categories of action. Some of those chemicals will simply be tracked, some will be targeted for reductions in use, others will be classified as good options for redesign or reformulation process to replace with safer alternatives. And many of the chemicals on your RSL will likely end up being restricted in specific ways (i.e. concentrations, types of products) or banned (i.e. not intentionally added to a product). Here's some examples for each of these types of actions:

Tracking

• Collecting information on current chemical use
• Identifying chemicals for possible future action
• Informing suppliers of company preferences and intent to restrict

Reducing

• Working with suppliers to identify safer alternatives
• Working with customers to choose safer alternatives from existing product portfolio
• Selecting suppliers that do not use listed chemicals
• Avoiding use in newly designed or formulated products

Redesign & Reformulation

• Redesigning or reformulating existing products to exclude the use of specific chemicals and use safer alternatives

Restricting

• Restricting listed chemicals to specific levels or concentrations (sometimes called "de minimus" levels) or not allowing them to be used in specific products

Banning

• Stating that specific chemicals must not be present or intentionally used under any circumstances, sometimes identified as "do not use" or "not intentionally added" chemicals at a specific de minimus level

Cross-functional engagement in creating and revising a RSL will play a big role in determining how effectively it is implemented. There are a number of key decisions that should be made about the process itself related to who, what, when, and why. We often convene an internal stakeholder engagement process including cross-functional leadership to develop consensus on the following (and other) topics related to the RSL creation and revision process:

Process ownership

Determine who has the authority to initiate and manage the process of revising the RSL including but not limited to identifying candidate chemicals, making preliminary recommendations, etc. (i.e. who can be a “process lead” for revising the RSL).

Key stakeholders

Determine which functions should be engaged in the process when existing product formulations may be impacted by adding a new chemical(s) to the RSL i.e. require reformation of an existing product.

Internal approval by decision-maker(s)

Need to establish clear decision-making authority related to who gets the final decision on adding or removing chemicals to the RSL.

There are also key questions to answer related to timeline and other topics.

Chemicals management and ingredient safety impacts the sustainability and circularity of brands and products, particularly as it related to packaging. You can learn about how decisions related to chemicals in packaging materials may be blocking your efforts to improve the circularity of your products here.