What is a Restricted Substances List?
The terms most often used for list-based screening are restricted substance lists (RSLs) and more recently manufacturing restricted substance lists (MRSLs). For the sake of brevity, the term “M/RSL” will be used as the generic reference. Despite the important progress that has been made using M/RSLs, manufacturers are realizing that list-based screening is not enough to ensure they can achieve their sustainable chemistry goals.
Over the past 20 years industry has relied on the use of databases and lists to screen chemicals for compliance with market-specific regulations. In the same period, companies who were aspiring to develop more sustainable chemical management practices started using other list sources that identified chemicals of concern that were not yet being regulated. Today, many companies use list-based screening from a variety of sources – regulatory, market (industry associations) and advocacy (scientific and non-profit communities).
To learn more about the application of M/RSLs in the beauty and personal care space, read our previous blog.
Though insufficient, M/RSLs have merits including:
Accessibility: For many companies, using an RSL is the most immediate and feasible method for chemical screening. M/RSL screening is simple, less technical, and requires fewer resources to implement in global supply chains. This is especially true for retailers that have little control over the manufacturing of the products they sell.
Collaboration: M/RSLs are also a very effective outcome of pre-competitive collaboration among companies within an industry sector to identify and prohibit or restrict chemicals of concern within their common supply chain. This coordination amongst end users produces a more consistent message and demand signal to suppliers. The apparel and textile industry has deployed this strategy and co-created the Zero Discharge of Hazardous Chemicals (ZDHC) platform and collectively use the same M/RSL in their supply chains.
Greater Supplier Engagement: Most downstream suppliers (makers of materials, components, assemblies) have poor visibility into the chemicals in their products and must rely on their upstream suppliers to share information. Often, companies will ask their suppliers to declare whether their products contain any listed chemicals, though increasingly they are asking suppliers to declare all intentionally added chemicals and are using third party service platforms to verify the accuracy of the information provided. A good example is Walmart’s chemical management program which uses UL’s WERCSmart platform to communicate with manufacturers about sensitive product information.
Shortcomings of list-based chemical management strategies:
- Lists change frequently based on new policies and evolving science causing companies to implement costly and inefficient updates to existing M/RSLs, and potentially costly disruptions to their supply chains.
- M/RSLs that use chemical classes are challenging for suppliers to interpret and implement. For example, the class of chemicals known as Per and Polyfluoroalkyl Substances (“PFAS”) contains over 5000 chemicals. If a manufacturer wants its suppliers to report on specific PFAS, they should list the specific substances. Otherwise, suppliers will interpret it as any or all PFAS. More importantly, suppliers, attempting to replace listed chemicals will often select alternative chemicals that are similar in structure and characteristics of concern to those on the M/RSL but with a different name and CAS RN. Suppliers often assume that chemicals not listed on a customer’s M/RSL are deemed to be safe, leading to regrettable substitutions.
- M/RSL compliance is a pass/fail approach to chemicals management and does not incentivize suppliers to innovate toward constant improvement with safer and more sustainable ingredients.
RSLs are a useful first step in building greater transparency into chemical usage in supply chains and are most effective when applied collectively to eliminate known chemicals of concern. However, because M/RSLs are limited in scope, manufacturers must use robust tools and methods to build more effective chemicals management programs. In our next blog, we outline six chemical management strategies to move beyond M/RSLs.
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