Chemicals Management

Addressing hazardous discharge


Stacked denim

The global apparel industry accounts for high amounts of manufacturing chemicals use, and the discharge of these chemicals can threaten local water sources and affect people living in surrounding communities.

We aim to eliminate the discharge of hazardous chemicals within our supply chain to reduce our environmental impact and improve access to clean, safe water in the communities where our suppliers and mills operate.

We are addressing chemical use and discharge within our supply chain. 

We have set an ambitious goal: to work toward zero discharge of hazardous chemicals in our supply chain by 2020.

In 2019 we also committed to eliminating all PFC-based finishes from our supply chain by 2023.

Our Women + Water strategy is focused on the intersection between our industry's significant use of water and the human right to clean safe water and is targeted in three key areas:

Our Approach

1. Industry partnerships: We partner with industry groups, including Zero Discharge of Hazardous Chemicals (ZDHC), the Apparel and Footwear International RSL Management AFIRM Group and the Sustainable Apparel Coalition (SAC) to implement a consistent set of tools and processes to support best practices, monitor supplier performance and encourage use of safer chemicals. In addition to helping us achieve our water and sustainability commitments, these industry partnership help advance progress across the industry.

Gap Inc. chemical restrictions are informed by global regulations, as well as hazard- and risk-based considerations. They include our Restricted Substances List (RSL) and our Manufacturing Restricted Substances List (MRSL). Since 2008, Gap Inc. suppliers have been expected to comply with our RSL. Since 2015, we have asked all of our suppliers to comply with the ZDHC MRSL, and we are aligned with the AFIRM Group RSL.

2. Working with suppliers: We communicate chemical safety and usage requirements to our suppliers in our Code of Vendor Conduct (COVC) and Mill Minimum Expectations, and we require our suppliers to acknowledge and comply with these conditions. These requirements have been incorporated into our existing supply chain programs like our Water Quality Program and Mill Sustainability Program.

3. Compliance and monitoring: Through third-party testing of products, product components and wastewater effluent, as well as the use of industry data platforms, we monitor the performance of our supply chain and verify compliance with global chemical regulations and Gap Inc. chemical restrictions. Performance in our chemistry programs informs facility evaluation.

Alignment with Industry Initiatives Across All Stages of Production

Input management: Selection of better chemical inputs and starting materials is an essential part of reducing the use and discharge of hazardous chemicals. As a ZDHC Signatory Brand, we require our suppliers to follow the ZDHC Roadmap to Zero Programme, which includes registering with the ZDHC Gateway, maintaining a chemical inventory list, and using input chemicals that comply with the ZDHC MRSL. We are also working to go beyond MRSL conformance by identifying and increasing our use of “preferred” chemicals. We also have additional policies related to specific chemical formulations that go beyond the MRSL. In 2019, we publicly announced our commitment to phase out all PFC-based finishes.

Process management: Adherence to chemicals management best practices during manufacturing is critical for reducing human and environmental risks. To support best practices in our supply chain, our COVC and Mill Minimum Expectations outline a number of expectations for chemical use and handling. We require all Tier 1 cut-and-sew suppliers and strategic Tier 2 fabric mill suppliers to respond to the Higg Index FEM 3.0, which enables us to evaluate suppliers based on whether they follow specific chemicals-management practices. In 2019, we adopted third-party chemicals-management platforms to monitor and evaluate suppliers’ chemical inputs and support best practices. We also use this data to inform the evolution of Gap Inc.’s chemicals management strategy.

Output management: Outputs of apparel and footwear manufacturing include finished products as well as wastewater discharge. Managing these outputs is a foundational component of reducing discharge of hazardous chemicals. Finished products manufactured for our brands should comply with the AFIRM RSL; we test products to ensure they meet regulatory standards established by the countries where we sell our products. To address wastewater discharge, we have adopted and integrated ZDHC tools and resources for output management, including the ZDHC Wastewater Guidelines and ZDHC Gateway. Our strategic mills and laundries are required to test their wastewater to ZDHC Wastewater Guidelines and publish the results through the ZDHC Gateway, a data-sharing platform that allows brands to monitor supplier wastewater data. ZDHC Gateway is also a repository for information on chemical formulations’ MRSL conformance.

Implementation Strategy

We integrate tools and resources from the AFIRM Group, ZDHC and SAC into Gap Inc. programs like our Water Quality Program (WQP) and Mill Sustainability Program, as well as in policies and agreements like our COVC and Mill Minimum Expectations. We have adopted new platforms to support the collection and analysis of chemical inventory data from 150 of our strategic vendors and mill facilities. These platforms provide Gap Inc. and our suppliers insight on conformance to the ZDHC MRSL. 

We also leverage industry initiatives to facilitate and advance our supply chain’s engagement with sustainable chemistry. For instance, as a founding member of the Apparel Impact Institute, we nominated three of our supplier facilities in India to participate in the 2019 Chemicals and Wastewater Pilot, which focused on determining opportunities to reduce environmental and human-health impacts relevant to wastewater compliance and hazardous chemical formulations. The goals of this program are twofold: to optimize and reduce chemicals used within the facility and to improve monitoring and operations at the wastewater-effluent treatment plant. Initial results are promising, and we are eager to expand the program to additional facilities in the coming years.

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