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Amazon Issues Restricted Substance List

Dec. 14, 2018
Retailer encourages manufacturers to adopt green chemistry alternatives

Big retailers strive to source products responsibly. This typically includes recognition of chemicals in the products they market (see: “Achieve the Transparency that Consumers Demand”). As part of its commitment to responsible sourcing, Amazon recently posted its Chemicals Policy, which includes its first Restricted Substance List (RSL). This column discusses this milestone.



Amazon’s policy defines “chemicals of concern” as those that: (1) meet the criteria for classification as a carcinogen, mutagen, reproductive, or other systemic toxicant; or (2) are persistent, bioaccumulative, and toxic. Amazon “strategically prioritize[s]” upon which chemicals of concern to focus based on “product type, customer concerns, and the availability of safer alternatives.” The baseline list of chemicals of concern included on the RSL are those chemicals that Amazon seeks to avoid in its private brand baby, household cleaning, personal care and beauty products in the U.S.


Amazon’s Chemicals Policy includes the following actions:

Reduce usage of chemicals of concern. Amazon encourages manufacturers to phase out potentially hazardous chemicals and adopt green chemistry alternatives, such as those defined in the U.S. Environmental Protection Agency’s (EPA) Safer Choice Safer Chemical Ingredients List, “which can reduce impacts to human health and the environment.” Amazon states that it began its reformulation efforts towards this goal with private-brand formulated products because it has the most control over how these products are developed; and

Enable transparency. According to Amazon, its transparency efforts are “grounded in the belief that Amazon should provide customers with information that helps them make informed purchasing decisions.” Amazon’s goal is to make product health and sustainability data as easy for customers to access and interpret as price and consumer reviews. Amazon states this is why it’s working on website features that will facilitate customer access to comprehensive information about product ingredients and third-party certifications, including Safer Choice, Made Safe, Green Seal, and Cradle to Cradle. Amazon “hope[s] that making this information more readily available for customers will encourage additional brands to move away from potentially hazardous chemistries in their products and adopt safer chemistries.”

Current Initiatives

Amazon’s current initiatives include implementing its first RSL, enhancing transparency with stakeholders, promoting third-party certifications, and joining retail-sector safer chemistry initiatives. Amazon will review the set of RSL chemicals and update them periodically. The current focus is on paraben preservatives, formaldehyde donor preservatives, phthalate solvents, nonylphenol (NP) and nonylphenol ethoxylate (NPE) surfactants, toluene and triclosan.

Recent changes to Amazon’s website include Amazon Pages, providing brands an opportunity to address customers directly, and the A+ Enhanced Marketing Content on detail pages, allowing brands to explain to customers product features and benefits and to provide additional information on physical packaging, Amazon has developed 2D codes through its transparency service that are “retailer agnostic” and available to all brands. These codes can link to information about the products, their product supply chains, and any third-party certifications they have received. To further its commitment to transparency, Amazon states that in 2019, it will continue to work on additional product category RSLs under this Chemicals Policy, and work to achieve fuller ingredient disclosure on its private brand product detail pages.

Amazon is working on features intended to make it easier for customers to discover, identify, and purchase products with safer formulations and sustainable attributes. This work will include making safer chemistry third-party product sustainability certifications such as Safer Choice, Made Safe, Green Seal, and Cradle to Cradle more prominent. Amazon has joined the Retail Leadership Council of the Green Chemistry and Commerce Council (GC3) and the Beauty and Personal Care Products Sustainability Project (BPC). Amazon states that it “supports the retail sector’s collaborative effort to encourage national brands to use safer formulations and produce more sustainable products.”


Amazon’s entry into this space is not surprising given its significant market influence and profile. The addition of yet another RSL, however, complicates matters for commercial entities. The growing number of disparate policies and approaches to product formulation, ingredient communication, and “restricted substances” places enhanced pressure on product manufacturers to be even more mindful of the product composition choices being made by themselves and by entities within their supply chains. As laudable as these policies are, how they align with the role the EPA and other federal and state agencies have with respect to product review, approval and safety remains unclear. Consumers may well be asking the same question. The hope is Amazon and other influential retailers work closely with the EPA, state regulators, and other stakeholders to ensure product messaging is clear and informative. Achieving less invites significant confusion among consumer audiences.

LYNN L. BERGESON is Chemical Processing's Regulatory Editor. You can e-mail her at [email protected]

Lynn is managing director of Bergeson & Campbell, P.C., a Washington, D.C.-based law firm that concentrates on conventional, biobased, and nanoscale chemical industry issues. She served as chair of the American Bar Association Section of Environment, Energy, and Resources (2005-2006). The views expressed herein are solely those of the author. This column is not intended to provide, nor should be construed as, legal advice.

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