The facility implements a due diligence system for evaluating and selecting commodity chemical suppliers for restricted substance risk.
Due to the challenges in engaging commodity chemical suppliers in ZDHC MRSL conformance, and the fact that ZDHC MRSL risks mainly relate to contaminations in commodity chemicals, the supplier should adopt responsible practices in the procurement of these chemicals to reduce possible ZDHC MRSL risks from these inputs.
The following requirements should be included when purchasing commodity chemicals:
- Formulate a commodity chemical purchasing policy which includes establishing long term purchasing relationships with CC sellers and purchasing required quantity in bulk from a single lot.
- Evaluate CC suppliers for ZDHC MRSL risks to make a purchasing decision.
- Collect and record chemical-related documentation such as current Safety Data Sheet (SDS), Technical Data Sheet (TDS).
- Collect and record information on batch/lot numbers, expiry dates.
- Issue purchase order or contract to the CC supplier that contains clear communication about ZDHC MRSL requirements.
List of commodity chemicals in scope of ZDHC MRSL.
ZDHC MRSL substances are not expected to be intentionally added to commodity chemicals as they are usually manufactured as a single chemical substance. The risk of contamination comes mainly through impurities from packaging or transportation or if it has been sourced as a recycled product or a by-product from other industries.
The potential ZDHC MRSL risks in the commodity chemicals listed above can be categorised into two groups:
- Virgin commodity chemicals - those which have low ZDHC MRSL risks.
- Non-virgin commodity chemicals - those that have higher ZDHC MRSL risks.
Segregating commodity chemicals into these two groups can support in making informed purchasing decisions. As well as in the preparation of a due diligence risk matrix to screen commodity chemicals as part of a wastewater non-conformities Root Cause Analysis.
Virgin commodity chemicals (V):
- Manufactured from raw materials and sold in a pure state, with quality checks by the manufacturer.
- Cannot be obtained as recycled or by-products from other industries or diluted from concentrated solutions obtained from other industrial sources.
- It is not possible to recycle them in textile, apparel, leather, and footwear production with the same efficiency or performance.
- The risk of ZDHC MRSL substances in virgin commodity chemicals is low or negligible.
Non-virgin commodity chemicals (NV):
- Can be manufactured/synthesised but are mostly obtained or sourced from other industries as concentrated products or by-products/waste products/ recycled products. These are then diluted or standardised to offer cheaper products to price-sensitive industries, such as textile and leather.
- The source of this type of commodity chemical is not exactly known and may not always be the same. As such, the potential ZDHC MRSL contamination in them cannot be predicted.
- The risk of ZDHC MRSL substances in non-virgin commodity chemicals is higher and unknown in comparison to virgin commodity chemicals.
Suppliers are advised to check if the non-virgin commodity chemicals used at their facility are being sold to them by traders or resellers. Where they are they should make an effort to switch and purchase these from manufacturers or their distributors/dealers. In case this is difficult due to commercial or logistical issues, the supplier should adopt the best practices of evaluation of CC suppliers as part of their purchasing policy.