Chemicals Progressing towards zero discharge of hazardous chemicals

Chemicals surround us in our daily life. Not surprisingly, they are also an integral component in making and washing garments – from helping grow raw materials like cotton, to processes like dyeing or as key ingredients in the laundry products our customers use. At C&A, we want to make sure chemicals used in making C&A products are safe for people and the planet. To that end, we are 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.

Each year we demonstrate our public commitment to the communities where our apparel is produced – and to Greenpeace – by reporting our progress in this detailed 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 also 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 to Sustainable Chemicals Management

C&A’s holistic approach to chemical management revolves around three areas:

  1. Input management – identify safer chemicals, drive adoption and eliminate the usage of hazardous chemicals.
  2. Process management – assess and verify on-site chemical management systems and performance.
  3. Output management – validate the elimination of hazardous chemicals from wastewater and publicly disclose our performance.

We recognise that our vision of a supply chain with zero discharge of hazardous chemicals cannot be achieved alone. Only with industry efforts including brands, NGOs, academics, chemical suppliers and manufacturers can we drive permanent change. Within each of the above three areas, C&A has focused on developing industry standards, tools and methodologies such as our efforts in developing the Sustainable Apparel Coalition’s Higg 3.0 Facility Environmental Module (FEM) and the ZDHC Gateway.

We have also created a Minimum Performance Standard as a tool to communicate our expectations in chemical management to our supply chain. All of our facilities under the SCM programme are provided with a rating that encourages them to meet or conduct remediation to ensure the expectations are adhered to. The Standard is updated annually to drive continuous improvement towards ZDHC.

Input management

Input management is the cornerstone of the SCM programme. The objective of input management is simple: for C&A suppliers to procure chemicals that meet ZDHC requirements. In practice, this means screening and testing chemical products against the requirements of the ZDHC Manufacturing Restricted Substances List (MRSL) and registering the results on the ZDHC Gateway. The Gateway acts as a global database for safer chemistry for C&A suppliers and the industry at large.

To support the identification of safer chemistry, C&A implements a hazard-based Screened Chemistry program with several other brands to identify best-in-class and better alternative chemicals. Together, along with the ZDHC Gateway, we provide our suppliers with information on safer chemicals so they can make informed decisions when procuring chemicals.

We are also working globally to engage with key chemical suppliers and formulators to increase the awareness of ZDHC and its requirements, with the aim of increasing knowledge of safer chemistry and driving research and innovation to find suitable alternatives.

Process management

Process management is key to ensuring each of our supply chain partners has the necessary personnel, management systems, tools and expertise to reach ZDHC requirements. To do this, we have developed the SCM Audit, in which we send in technical experts to each of our wet production units to assess their current level of performance and create a joint action plan to drive continuous improvement.

Output management

C&A is committed to report publicly on its progress towards ZDHC. We conduct regular wastewater testing at our production units against the ZDHC Wastewater Guidelines to validate the elimination of hazardous chemicals. By testing raw wastewater for chemicals listed on the ZDHC MRSL, we validate the elimination of hazardous chemicals at individual facilities. If a detection is found, a phase-out plan is created with the facility to replace the chemical with a sustainable alternative within the shortest possible timeline.

Additionally, all C&A suppliers communicate their wastewater testing results publicly on the Institute of Environmental Affairs (IPE) website as well as the ZDHC Gateway. This ensures that all relevant stakeholders have access to the progress we are making year-on-year.

Capacity building

We train our suppliers to understand why chemical management matters and what it involves, and to develop the infrastructure they 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.

On-the-ground experts conduct frequent site visits to provide any support required and to assess remediation progress and timelines as part of our corrective action plan (CAP) process. C&A also hosts regular meetings at our local offices, at an operational level to discuss common issues in the supply chain and develop solutions, and also at a top management and owner level to raise awareness of our requirements.

Working together towards zero discharge of hazardous chemicals

The SCM programme was built on a foundation of collaboration. From the very beginning, we realised that no brand can achieve zero discharge of hazardous chemicals alone. To that end, we were a founding member of the Zero Discharge of Hazardous Chemicals Foundation, established in 2012 with the goal of eliminating the use of priority chemicals by:

  • 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 assessment process.
  • 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.

C&A engages with industry stakeholders such as the Institute of Public and Environmental Affairs (IPE). As part of this engagement, C&A is regularly screening our supply chain for environmental violations listed on the IPE website and working jointly to drive remediation across our supply chain in China.

Working with C&A Foundation to drive improvement

C&A Foundation brings together brands, initiatives and people who collectively have the power to create a fair and sustainable fashion industry. A core focus area of the Foundation is Circular Fashion, including chemicals. C&A Foundation has been working extensively with the ZDHC to accelerate, further scale and drive impact on eliminating the use of hazardous chemicals across global apparel and footwear supply chains.

The foundation has three active grants with the ZDHC:

  1. ZDHC Gateway – Wastewater Module. One of the barriers to better chemical management is a lack of data to inform and drive wastewater improvement. The Wastewater Module is a disclosure platform for wastewater discharge information that helps factories to disclose timely and accurate information, allows brands to monitor progress throughout the supply chain, and demonstrates accountability to industry stakeholders.
  2. Five-year strategic growth plan. This plan will enable ZDHC to prioritise actions and document important milestones, supporting its vision of ‘widespread implementation of sustainable chemistry and best practices in the textile, leather and footwear industries to protect consumers, workers and the environment’.
  3. ZDHC InCheck Tool. Suppliers do not always know how to access alternative chemicals for their production processes. This tool allows manufacturers to create and update a chemical inventory, complete a self-assessment, and source better chemicals.

C&A Foundation also supports MaterialWise, a multi-industry value chain collaboration led by the Cradle to Cradle Product Innovation Institute. MaterialWise is a database of verified chemical hazard data that will enable suppliers, manufacturers and brands to advance better chemistry in product design and manufacturing.


Our 2017 performance

The C&A SCM Programme covers 81% of our global business volume, from our wet processing units in tier-1 and tier-2 to all nominated fabric mills. To date, our SCM programme has achieved:

  • 348 chemical management audits conducted
  • 348 corrective actions plans created that work towards meeting the requirements of the SCM programme
  • Over 500 wastewater tests conducted to identify hazardous chemicals in our supply chain
  • 600 staff from our supply chain completed an external two-day training on chemical and wastewater management
  • 17 dedicated experts within C&A working to eliminate hazardous chemicals from our supply chain
  • Over 750 factory visits completed by the SCM team to assess progress and address issues in achieving its requirements
  • 1 strategic partner to analyse performance in C&A’s supply chain, via chemical audits and wastewater testing, and build capacity to enable the achievement of the SCM programme objectives globally

C&A’s SCM minimum performance standard, introduced at the end of 2017, is a holistic scoring mechanism that transparently aggregates a facilities performance across the three pillars of the programme: Input, Process and Output. The standard also covers remediation, to ensure facilities are continuously working to improve their performance.

The requirements listed on the standard are categorised into the following: Zero Tolerance, Critical and Major. Depending on the number of requirements it has met, each the facility is given a score from Gold to Unacceptable.

Sustainable Chemicals Management performance 2017


Number of production units

% of production units










Needs Improvement









2017 represents the first year that our facilities were given a SCM performance score, based upon a standard that was communicated during the second half of the year. As such, the results above represent facilities that were assessed against the new standard for the first time. 29% of facilities were already meeting our requirements, and the remaining facilities were given a clear timeframe for raising their performance to ensure they can continue to work with C&A. Our focus in 2018 will be on raising awareness, developing expertise and knowledge, and providing expert technical support to raise the performance of these facilities. The SCM Minimum Performance Standard becomes more exacting each year, so facilities will be held accountable for the new 2018 requirements as well as their remediation against the 2017 standard.

Input management

We made significant progress in 2017 in better understanding the challenges of input management as well as advancing industry solutions.

During 2017, C&A conducted a pilot project to better understand what chemicals our suppliers purchase and where they come from. The project, conducted at 31 facilities globally, revealed a long and complex chemical supply chain. These facilities sourced from 557 chemical formulators and purchased 4,365 chemical products. Encouragingly, half of these chemical products had existing chemical conformance results, demonstrating they meet ZDHC standards.

In 2017, ZDHC launched the Gateway, a global database of safer chemistry that enables chemical formulators to securely share chemical information with brands and textile, footwear and leather suppliers, in line with the ZDHC standards. The number of chemical products registered on the ZDHC Gateway remains a challenge – however, it continues to grow daily as the go-to place to identify safer chemicals. C&A continues to engage with and encourage chemical suppliers and formulators to register their chemical products on the Gateway to enable the widespread adoption of safer chemistry.

This demonstrates why industry collaboration is essential. If 31 facilities are sourcing from 557 chemical formulators, we need an industry-wide response to send a clear signal to our supply chain. The ZDHC Gateway can become the channel for that and will become the focal point of our SCM programme in 2018.

Process management

In 2017, C&A audited 237 facilities for the first time using its SCM Audit. The audit, which acts as a stepping stone to Higg 3.0 Facility Environmental Module (FEM) once adopted, assesses a facility’s on-site chemical management system and performance.

The audit covers the following aspects:

  • Environmental Management Systems
  • Energy Consumption
  • Water Use
  • Wastewater
  • Waste Management
  • Chemical Management

In 2017, C&A continued to focus on expanding the scope of SCM, with many facilities audited against C&A/ZDHC standards for the first time.

The top five non-conformances identified in 2017 were:

  1. Facility not properly managing hazardous waste (including sludge).
  2. Facility not implementing a plan for the proper handling, use, storage and disposal of chemicals.
  3. Facility not conducting a chemical risk assessment of all the chemicals used.
  4. Facility not having a policy for monitoring and controlling banned and restricted substances for all chemicals used in the facility.
  5. Facility not having a phase-out plan for chemicals listed in the MRSL/RSL that are used in production.

Many of the above issues are related to this being a first-time audit for several facilities. Once all the non-conformances are identified, the SCM team works with the facilities to implement a corrective action plan and provide technical support wherever needed. To date, the C&A SCM Programme has created over 300 corrective action plans that all contribute to the elimination of hazardous chemicals.

A major challenge in process management remains the existing skills and knowledge gap. Following results from our ongoing assessments and audits, we now 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 only have 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.

Another challenge is third-party resources. 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.

Output management

In 2017, C&A conducted wastewater testing at 234 facilities across 14 countries using the methodology listed in the ZDHC Wastewater Guidelines. C&A tests wastewater samples at three points: incoming water, raw wastewater and discharged wastewater.

Wastewater detections by chemical group and sample point

C&A uses the raw wastewater sample to validate a facilities conformance to the ZDHC MRSL. Phthalates and Alkylphenol (AP) & Alkylphenol Ethoxylates (APEOs) are the most frequently detected chemical groups at this sampling point with 65 and 63 detections respectively. However, it is important to note that they are also the most frequently detected chemicals in contaminated incoming water, at 33 and 39 respectively.

We apply the ‘clean factory’ approach, encouraging the elimination of hazardous chemicals across production for all brands, not just C&A’s production. From 2018, all our facilities will be required to disclose their wastewater test reports on both the IPE website and ZDHC Gateway.


Where next

Input management

C&A will continue to map out its chemical supply chain to better understand what chemical products are being used and where they are coming from. In addition, we will work with key chemical suppliers to drive the adoption of the ZDHC Gateway. We will also start to set requirements on the usage of chemicals registered in the Gateway for our supply chain from 2019 onwards. The focus in 2018 is on preparing for these requirements and populating the Gateway.

Throughout 2018, we will also pilot the ZDHC InCheck. InCheck is a tool that will standardise the industry’s approach to monitoring input chemistry. By collecting a facility’s chemical inventory list and screening it against safer chemicals listed in the ZDHC Gateway, it will identify the facility’s level of conformance to the MRSL. Each facility will be given an InCheck report, which will be used by C&A to identify and manage progress towards the elimination of hazardous chemicals.

Process management

C&A will continue to drive impact. Many of the facilities audited for the first time in 2017 will be provided with expert technical support to remediate all key issues. We will also start the process of adopting the SAC Higg FEM 3.0 with full adoption expected in 2019. Once achieved, C&A’s SCM Audit will become redundant as we continue to adopt industry standards and tools.

We will also continue rolling out the SCM Capacity Building to ensure we close the skill and knowledge gap that exists within the textile supply chain today.

Output management

Wastewater testing serves as validation that we are making progress towards ZDHC. With many facilities having conducted their first ever wastewater testing in 2017, the focus is now on root-cause analysis – identifying the failing chemical detection back to its original source and looking for alternatives. C&A will continue to create phase-out plans for each facility with a detection and support them in finding alternatives via the ZDHC Gateway.

At the same time, we remain committed to the public disclosure of wastewater test results and will adopt the ZDHC Gateway Wastewater Module at launch. This platform, funded by C&A Foundation, serves as a global portal for verified wastewater results tested against the ZDHC Wastewater Guidelines. It provides suppliers (manufacturing facilities) with an easy way to disclose secured and verified wastewater and sludge data to their clients (brands/retailers), reduce unnecessary testing and focusing on improving the quality of discharge.

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 GOLD level Cradle-to-Cradle Certified™ t-shirts play a vital role in the certification of safe chemistry. These products are designed and made with fewer, safer chemicals, and complement our overall approach to better chemical management by demonstrating that zero discharge of hazardous chemicals is possible.

Read more about our Cradle-to-Cradle Certified™ products