Communication and Transparency are Essential
Communication and transparency are essential in building trust with consumers – and the same can be said for the relationship between retailers and consumer product manufacturers. Finding a surprising lack of manufacturer awareness of individual retailer requirements for disclosure of certain chemicals as well as the lack of consistency with the recently enacted California ingredient disclosure law (SB 258, The Cleaning Product Right to Know Act), HCPA has taken the lead in working collaboratively with retailers and manufacturers to show the benefits of practical approaches to ingredient communication.
Collaboration with Retailers on Label Requirements
HCPA recently coordinated with Walmart to provide recommendations for implementing its 2018 on-package labeling requirements in ways that aligned with compliance plans for recent California ingredient communication legislation. In September 2017, Walmart agreed to modify its 2014 policy to include several of the HCPA work group’s recommendations. In October, Walmart issued guidance outlining the agreed-upon changes that include:
- Allowing companies to meet the on-package labeling of Walmart’s identified priority chemicals as companies makes label changes (a “rolling refresh”) , instead of requiring all new labels by January 1, 2018
- Permitting companies to use either the Walmart list of priority chemicals or the California SB 258 designated lists to identify chemicals requiring on-package disclosure
- Allowing FIFRA-regulated products to delay compliance with Walmart’s on-package labeling requirement until a manufacturer completes its regular label review process for that product, which requires EPA review
Working with UL in Concert with Other Trade Associations
In July 2017, the Retail Engagement Work Group partnered with allied trade associations and a task force with the Research & Regulatory Management Council to encourage UL to delay implementation of its revised “Terms of Use” for the WERCSmart platform. Over the course of the summer, UL twice delayed the effective date while it considered HCPA members’ comments and concerns. In August, the trade association CEOs recommended the formation of an Advisory Committee that would include retailers and suppliers, and requested further delay on implementing the revised Terms of Use.
In response, UL committed to establishing an Advisory Group, but was unwilling to further delay implementation of its revised Terms of Use for WERCSmart. At HCPA’s annual meeting, UL announced the Advisory Group would be established in January 2018 and would have its first in-person meeting in early March 2018. Early indications are that several HCPA member companies will be on the Advisory Group. HCPA’s Retail Engagement Work Group will continue to work in cooperative partnership with retailers and UL to understand and support retailers’ use of the WERCSmart system to obtain accurate product information that the retailers need for regulatory compliance and sustainability programs. The goal is to increase efficiency and accuracy of the data submission process and to reduce costs for retailers, suppliers and UL.
Building Stronger Relationships with Retailers
HCPA’s 2017 Annual Meeting featured a panel discussion that brought a range of stakeholders together to address relationships between manufacturers and retailers. Tom Flicker, Principal, Sustainable Product Development, Target; Ashley C. Hall, Sustainability, Walmart; Kieran Callahan, Supply Chain and Sustainability, UL; Boma Brown-West, Environmental Defense Fund (EDF) and Monica Becker, Co-Director and Collaborative Innovation Project Lead, Green Chemistry and Commerce Council (GC3) participated.
