Chemicals Aiming for safe chemistry and zero discharge

Chemicals surround us in daily life. They are used by a variety of industries to make everything from plastics to cosmetics, buildings and cars, as well as our clothes. The chemical industry is responsible for producing more than 90,000 synthetic chemicals [SOURCE: Bioneers: Good Chemistry podcast]. Not surprisingly, they are also an integral component in making and washing garments – from helping to grow raw materials like cotton, to processes like dyeing, or the laundry products our customers use. There are many opportunities to make the chemicals we use safer and less impactful on the environment.

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We know that garment production processes account for the majority of chemical use along our value chain. Our suppliers use thousands of different types of chemicals to dye, wash, print, and treat fabrics for fire, odour, stain, water or wrinkle resistance. For that reason, this is where we must focus our attention.

Although many of those chemicals have no immediate impact on human health or the environment, not all of them are harmless or free from risk. For example, the World Bank estimates that up to 20% of water pollution from industry as a whole is caused by textile dyeing and treatment [SOURCE: Natural Science paper].

At C&A, we want to make sure every product we make and sell is good for people and for the planet. That’s why we are committed to a supply chain that aspires towards zero discharge of hazardous chemicals. Each year we demonstrate our public commitment to the communities where apparel production occurs - and to Greenpeace - by reporting in detail on our progress in this report. Along with a full explanation of our chemicals management approach and the progress we make, we also present the challenges we face. Year-on-year performance data is available on the chemical audits and regular wastewater testing we carry out as part of our Sustainable Chemicals Management (SCM) programme.

Read our public commitment to ZDHC

Our approach

Because the majority of chemical use in our value chain occurs during production processes (particularly at wet processing units), this is where we focus our work on chemical management. In practice, this means helping our business partners improve how they deal with chemicals in their own production units and supply chains.

We train our suppliers to understand why chemical management matters and what it involves, and to develop the infrastructure they will need to reduce their impact. This capacity building covers many different areas, but includes training about which chemicals to use, how to select better alternatives and how to safely manage chemicals in their operations.

C&A specifies safe alternatives in our designs and applies those choices during our ordering process. We have started to do this by designing and developing products that abide by our Restricted Substances List (RSL)/Manufacturing Restricted Substances List (MRSL), thereby avoiding the use of restricted chemicals from design stage. Our GOLD level Cradle-to-Cradle Certified™ T-shirts are completely compostable in home compost within 11 weeks. This is only possible because they are made with 100% organic cotton and fewer, safer chemicals in the production process. This is our first clear example of how a product can be entirely produced with no hazardous chemicals and no discharge of wastewater into the environment.

Read more about circular fashion products

We also need to work with chemical producers and suppliers to incentivise them to create safer alternatives. By tackling this problem in collaboration with other brands, as well as working at a supplier and facility level, we can start to create systemic change within the apparel industry. Only by working together can we keep harmful chemicals out of our products and the environment - for good.

Working together towards zero discharge of hazardous chemicals

C&A is a founding member of ZDHC, a coalition of 23 global brands and retailers with a shared commitment to zero discharge of hazardous chemicals in their supply chains. The ZDHC Foundation oversees implementation of the ZDHC programme. For C&A, the implementation of the programme involves work in the following areas:

  • Developing and updating the Manufacturing Restricted Substances List (MRSL) and accompanying guidance on conformity.
  • Identifying safer alternatives for chemicals that are included on the MRSL.
  • Developing a robust chemical audit protocol and reporting on progress.
  • Monitoring the quality of wastewater from production units and reporting publicly on results.
  • Working towards full transparency of chemical discharge in our supply chain.
  • Empowering our suppliers to move towards zero discharge of hazardous chemicals through capacity building and training.

By using our global size and scale to deliver results in these six areas, our company is going beyond compliance. Ultimately, we are seeking to normalise good practice at C&A suppliers’ factories and across the rest of the industry.

Our Sustainable Chemical Management Programme (SCM)

Our Sustainable Chemical Management team is responsible for the roll-out of the Sustainable Chemicals Management (SCM) programme across C&A. The programme began in 2012 when we made our public commitment. Starting in Asia, it now includes China, Bangladesh, Pakistan, India, Cambodia, Taiwan, Thailand, Mexico and Brazil.


Sustainable Chemicals Management approach

How we define our supply chain tiers

Tier 1 - Cut and sew production units
Tier 2 - Printing, laundries, and embroidery
Tier 3 - Fabric mills, spinning mills, and dye houses

The 6 elements of our SCM programme

In line with our chemical management roadmap, the SCM programme has evolved from planning and development to implementation across the following areas:


1. Chemical screening

By proactively identifying hazardous chemicals before they’re used, we can eliminate them more easily. This involves making chemical identification a standard requirement for production units, a process that is grounded in the Manufacturing Restricted Substances List (MRSL). This list is continuously developed and improved by ZDHC members, and the latest version will be published in 2017. It guides suppliers in avoiding hazardous chemicals and finding safer alternatives.

2. Chemical audit 

Our SCM audit provides a robust assessment of chemical management performance at a production unit level. With insights on each suppliers’ current issues and challenges, our SCM team can develop more effective solutions. We report our audit results to meet our ZDHC commitments on transparency. 



Nearly all regions are on track. We have experienced challenges in Mexico, where local infrastructure and technical competencies are behind. C&A is one of the only international brands implementing a SCM approach in Mexico. We are working with third parties to strengthen the level of auditing, technical expertise and lab capabilities for wastewater testing to get back on track by the end of 2017.

Read our complete review of the audit findings for driving change here.

3. Wastewater testing

We regularly test wastewater from our suppliers’ production units because it’s a good way to validate their performance against the ZDHC’s MRSL. Again, we report results as part of our ZDHC transparency commitments.

Our initial results demonstrate, in many instances, that the wastewater leaving the factory is ‘cleaner’ than the water entering from the public water supply. Nonetheless, we are still concerned by the high levels of heavy metals and phthalates found in the incoming water samples. Perfluorinated Chemicals (PFCs) were also detected in 11 raw wastewater samples, with more than half being traced back to incoming municipal water contamination. Phthalates, Halogenated Solvents, AP & APEOs and Azo Colorants represent the biggest challenges in our supply chain. 

Read our complete discharge summary report here.

4. Capacity building

We are continuing to develop the knowledge and infrastructure for safer chemical management throughout our supply chain. Our training programme supports our suppliers in their journey towards meeting ZDHC standards, and offers guidance on our ongoing auditing processes. When a supplier fails to meet our standards, we support them in creating and implementing Corrective Action Plans.

“The Chemical Management Training was very informative, it has given in-depth knowledge for practical implementation of the system. Understanding safety data sheets, supplier communication, product screening, inventory management, chemical safety …etc., was very well discussed and understood, which will add value to our system and provide continual improvements. We are sure that this training will ensure we are more compliant in terms of chemical management systems, safe working environment, sustainable business etc. We are happy to be part of your supply chain.”

M Mohan, General Manager Operations, Anugraha Fashions Pvt. Ltd.
on behalf of attendees Devraj and Muthuraman

5. Data management systems

Accurate, validated, well-managed data is fundamental to managing progress. C&A is currently working to develop and implement several data management systems, including our wastewater disclosure platform, Higg 3.0 FEM and the ZDHC’s Chemical Gateway. These data management systems will work together and help suppliers make better decisions and allow for effective monitoring of their progress.

6. Collaboration

Collaboration is key to ensuring our industry reduces its use of hazardous chemicals. At C&A, our collaborative practices include our active implementation of the ZDHC programme, as well as our work with other brands and third-party organisations to standardise and converge audits and assessments for chemical management, and broader environmental issues across our industry. 

Focusing on screened chemicals

Chemical screening is the biggest overall component of our SCM programme. The framework assesses and rates chemicals and chemical substances to identify best-in-class chemicals or better alternatives. 

Read C&A's chemical policy

Read more about product safety and quality



Transparency leads to progress

We disclose the results of our audits and reports – particularly for wastewater – here, in this report, and on the Institute of Public and Environmental Affairs (IPE) platform as part of our commitment to Greenpeace DETOX and ‘Public Right to Know’ programmes. The SCM team regularly conducts unannounced shadow audits to ensure the quality and consistency of our findings.

Read more in where next

See the public disclosure of our supplier list

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Our 2016 performance

Aligning assessment across our industry

A single, consistent industry-wide tool to assess the environmental and chemical performance of suppliers will increase the pace of change across our industry. In 2016, we actively supported the convergence of the ZDHC Chemical Management Audit and the Sustainable Apparel Coalition’s Higg Index tool to create the Higg Index 3.0 Facility Environment Module, due to launch in late 2017. This is an important step towards making chemical management more accessible to more suppliers, reducing costs across our supply chain and improving the impact of our work.

Raising awareness of hazardous chemicals

We engaged with the Chinese National Textile and Apparel Council (CNTAC) and the German and Netherland textile alliances to raise awareness about hazardous chemicals used in our supply chain. In March 2017, the Sustainable Chemicals Management programme formed a key part of our Global Supplier Summit, in preparation for accelerating our efforts to scale up the programme rapidly over the next two years.

Promising outcomes from ZDHC partnership

As part of our partnership with the ZDHC Foundation, we supported the development of new, safer alternatives to hazardous chemicals and helped increase the scope of the MRSL to include leather. We implemented a wastewater standard and, as described above, helped align members behind the potentially transformative Higg Index 3.0 tool.

Greenpeace Detox Catwalk

In the annual 2016 Greenpeace Detox Catwalk, C&A was listed fourth and praised for our work on transparency and disclosure. We also learned where we need to improve our performance by progressing our hazardous chemicals screening methodology – which we plan to explore further through our focus on Screened Chemistry in 2017.


The challenges that we face around meeting our commitment to zero discharge of hazardous chemicals mostly stem from a lack of understanding of chemical management across the industry. In order to incorporate this commitment fully into our business practices as normal behaviour, we need to work with many parts of the system at once to drive change. We also need to work in partnership with multi-stakeholder initiatives like SAC and ZDHC to implement industry agreed approaches without internal nuance or modification. 

Developing third-party auditing

Although some good progress is being made – particularly towards the Higg Index 3.0 module - third-party resources for chemical auditing and wastewater testing are still in their infancy. High costs and a lack of resources and collaboration are currently slowing down the kind of progress we need to meet our targets as an industry.

Skills and knowledge gap

Following results from our ongoing assessments and audits, we have greater insight into how much capacity building for chemical management is required along our supply chains. Most of the mills, laundries and printers we work with have only a basic understanding of chemicals issues, and lack the skills and information to make the necessary changes to their systems. Our focus on training and infrastructure development is designed to meet this challenge.

Scaling research and development

The ZDHC commitment requires us to eradicate the use of hazardous chemicals throughout our entire supply chain, rather than just eliminate their discharge. This means we need new chemical formulations for dyeing, finishing, printing and washing, many of which are not yet available, let alone being produced at scale. One way to overcome this challenge is to collaboratively support research and development from multiple chemical suppliers and formulators around the world.

Convergence is key

Fulfilling the ZDHC commitment means going above and beyond any existing legal requirements. Although 23 brands and retailers have signed the ZDHC agreement, we have a way to go before the actions we are required to make start to take effect and deliver clear results in line with the full extent of the commitment. We feel that the best approach is for convergence and believe that the issues the ZDHC Foundation is working on should be part of that effort, and that brands should avoid creating bespoke or alternative programmes to create the change that we all want for the industry.

Why collaboration is necessary for system change in chemicals management

Collaboration is the best way to change how we manage chemical use across our industry and along its supply chains. With several partners working together we can increase our scale and influence to create greater leverage. For example, brands need to collaborate with chemical producers in the development of safe alternatives for hazardous chemicals, so that we can increase the rate of progress in solving this one, key challenge.

Another advantage of collaboration on chemical issues is to drive the improvement and adoption of new standards and practices. If multiple brands use the same set of tools (as opposed to different ones), they reduce the burden on suppliers and increase both the accuracy and efficiency of the assessment and improvements that can be made.

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Who we’re working with



Where next

Rapid scaling to meet ZDHC commitments

As part of our ZDHC commitment, in 2017 we will continue to roll out our Sustainable Chemical Management (SCM) programme to all vertical and nominated fabric and spinning mills. We will increase the number of production units that undergo chemical audits from 111 in 2016 to more than 400 in 2018, working towards our target to audit 80-90% of our nominated fabric mills and vertical mills, and beyond – including laundries, printers and suppliers’ own sources. With such a complicated supply chain, we have limited visibility of all supplier sources at present. We aim to address this in 2017 by identifying and working with suppliers to consolidate their sources with the goal of including these in our scope in 2019. Disclosure is the first step; to achieve the ZDHC commitment our chemicals management must reach all production units with wet processing facilities.

Supporting industry-wide convergence

We are piloting the new Higg 3.0 Facility Environment Module in 2017 to determine its effectiveness and scalability. We hope to launch the Higg Index 3.0 assessment tool to replace our SCM audit system and other related systems in 2018. We will share our findings next year to support the development and adoption of one industry-wide standard.

Continuing transparency of waste water testing results
We will continue to disclose our wastewater test results on the Institute of Public and Environmental Affairs (IPE) platform, and we commit to testing and auditing our laundries, with the aim of reaching 70-80% of our nominated laundries by the end of 2017. In 2018, we plan to launch the Wastewater Disclosure Platform to empower suppliers to improve their performance and increase transparency across the supply chain. This will be launched alongside the ZDHC Wastewater Guidance that sets out a standardised testing methodology.

Strengthening capacity, guidance and oversight

We will continue to build capacity for chemical management throughout our supply chain. After we have successfully piloted our SCM training programme in India, we will scale up and implement training to other countries. Our SCM team will follow up on a monthly basis via email/telephone and conduct twice-yearly on-site visits to support root-cause analysis, as well as providing any guidance or oversight that may be needed in cases of remediation, delivered through the Corrective Action Plan (CAP) management process. Every production unit in the SCM programme has an individual CAP that strives towards greater, more efficient chemicals management. The SCM Audit Team works with suppliers, through technical experts who provide support on the ground, in each of our major sourcing countries.

Identification of safer, alternative chemicals

We will help launch the ZDHC Chemical Gatewaythe world’s first database of safer chemicals and chemistry practices to help brands, suppliers and chemical producers make better, more sustainable sourcing decisions.

Designing products with zero discharge of hazardous chemicals

Our vision is for the global apparel industry to become a circular system, where clothes are designed with their next use in mind. Our newly launched GOLD level Cradle-to-Cradle Certified™ T-shirt plays a vital role in the certification of safe chemistry. The T-shirt is designed and made with fewer, safer chemicals, and complements our overall approach to better chemical management by demonstrating that zero discharge of hazardous chemicals is possible.

Read more about our circular fashion T-shirt

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