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:

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

• Define and share your approach to ingredient safety through statements of policy, standards, and guidelines

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

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

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

• Use safer alternatives and invest 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 for creating and revising a RSL:  

1. Identify RSL candidate chemicals

Many companies just take a “list of lists” approach to compiling an initial RSL.

While this can be an effective first step, we often recommend looking beyond existing regulatory, brand, and retailer lists.

You should also pay attention to NGO watch lists and conduct a literature review.

2. Application of safety policy or standard

This is where things can get complicated: deciding how to apply your safety policy to the list of candidate chemicals you’ve identified for your RSL.

At a conceptual level, this is where you implement decisions about the science on chemical hazard and risk.

We recommend taking a precautionary approach to chemicals management because it helps future-proof a company and product.

Relying on a compliance-based strategy has numerous risks.

3. Preliminary RSL recommendation

The person leading your RSL creation or revision process develops a preliminary recommendation for removing a chemical(s) to the RSL for external validation and/or internal approval.

4. External validation (as necessary)

External review of preliminary recommendation by a vetted toxicologist.

We recommend working with someone that is familiar with and subscribes to a precautionary approach to chemicals management.

5. Final recommendation development

Process lead determines if there is sufficient scientific evidence to remove a chemical from the RSL and builds a recommendation presentation to decision-maker(s) for internal approval.

6. Internal approval of RSL

Presentation of final recommendation by process lead to relevant stakeholders and the designated decision-maker(s).

More on this important process question below.

7. Update relevant materials (as necessary)

If necessary, make updates based on RSL to internal guidance, supplier agreements, contracts, public facing communications, etc.

8. Reformulate (as necessary)

If newly added chemical is currently present in current formulations or products, initiate a reformulation process to remove intentionally added ingredients on the RSL from those products.

It’s important to not that typically a RSL is good at addressing intentionally added chemicals or ingredients in products.

But some chemicals may be present in finished products that were not intentionally added due to contamination.

There are often a number of potential sources of contaminants in finished products and they depend on the raw materials, manufacturing processes, and other factors.

Some companies end up developing manufacturing restricted substances lists (MRSL) to address sources of contamination for chemicals used in their manufacturing processes.

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.