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FEM 2025 - Chemical Management Level 2

  • Updated

Table of Contents

Chememgagecontractors

Does your facility engage contractor(s) or subcontractor(s) on MRSL / RSL? (Ref Id: chememgagecontractors)

Answer Yes if: Your facility has engaged contractor(s) or subcontractor(s) on MRSL/RSL, and this engagement includes:

  • Formal process to communicate the facility’s MRSL/RSL policy and requirements to contractors.
  • Procedures to evaluate and improve MRSL/RSL management programs at contractor/subcontractor facilities. This may include any of the following:
    • Assessment or audit of MRSL/RSL management programs at the contractor/subcontractor. 
    • Requirements to complete and share Higg FEM.
    • Requirements to purchase chemicals from positive lists.
    • Where applicable, documented support to help contactors/subcontractors improve MRSL/RSL management (e.g., training, improvement plans).   

Answer Not Applicable if: Your facility does not use any contractors or subcontractors.

Note: Contractors/Subcontractors are defined as contracted business partners that support the manufacturing process of final products (e.g., screen printing, washing/dyeing, or other product embellishments).

If you select Yes, you will be asked the following sub question(s):

  • Please describe how you engage your contractor or subcontractor in the process.
  • Please upload documentation, if available

Suggested Uploads:

  • Documentation that shows how the facility engages with contractors or subcontractors on MRSL/RSL (e.g., contracts/agreements that cover MRSL/RSL engagement and requirements, records of MRSL/RSL communication, assessments/audit reports and/or improvement plans from contractor/subcontractor engagement, records of Higg FEM completion and sharing, etc.)

What is the intent of the question?

The intent of the question is for facilities to demonstrate that they proactively engage contractors or subcontractors on MRSL/RSL.

Technical Guidance:

Manufacturing processes performed at contractor or subcontractor facilities can present risks related to a facility’s MRSL/RSL compliance program as they have the potential to use banned or restricted substances if they are not aware or negligent with the requirements of the facility’s MRSL/RSL policy and programs. Facilities should seek to proactively engage with any contractors or subcontractors to communicate and promote responsible MRSL/RSL management. 

When engaging with contractors or subcontractors on MRSL/RSL management, facilities should communicate clear expectations and guidance to ensure compliance and adherence to MRSL/RSL requirements and good practices for MRSL/RSL management. This can be achieved through contractual agreements, ongoing communication to ensure all parties are aware of their roles and responsibilities in maintaining MRSL/RSL compliance.

Facilities should have procedures to outline the specific activities and responsibilities related to MRSL/RSL for contractor or subcontractor. This may include:

  • Assessment or audit of contractor/subcontractors MRSL/RSL management programs. 
  • Requirements for contractor/subcontractors to complete and share Higg FEM.
  • Requirements for contractor/subcontractors to purchase chemicals from positive lists. 

Facilities can also engage contractor/subcontractors by providing any necessary support to help contractor/subcontractors improve their MRSL/RSL management such as training/capacity building and/or support on developing or implementing improvement plans.

Resources:

Chememgagecontractors Verification And Scoring

How This Will Be Verified:

Full Points:
Full points will be awarded to facilities that have engaged with contractor(s) or subcontractor(s) on MRSL/RSL and this engagement includes:

  • Formal process to communicate the facilities MRSL/RSL policy and requirements to contractors.
  • Procedures to evaluate and improve MRSL/RSL management programs at contractor/subcontractor facilities. This may include any of the following:
    • Assessment or audit of MRSL/RSL management programs at the contractor/subcontractor. 
    • Requirements to complete and share Higg FEM.
    • Requirements to purchase chemicals from positive lists.
    • Where applicable, documented support to help contractors/subcontractors improve MRSL/RSL management (e.g., training, improvement plans).   

Documentation Required: 

  • Documentation that shows the facility has engaged with contractors or subcontractors on MRSL/RSL. This may include.
    • Contracts/agreements that cover MRSL/RSL engagement and requirements.
    • Records of MRSL/RSL communication. 
    • Assessments/audit reports or improvement plans from contractor or subcontractor engagement.
    • Records of Higg FEM completion and sharing by contractors/subcontractors.
    • Records of training or capacity building with contractors/subcontractors. 

Interview Questions to Ask: 

  • Staff responsible for the MRSL/RSL engagement activities can describe how the facility engages with contractors/subcontractors on MRSL/RSL.

Inspection - Things to Physically Look For:

  • Where applicable, observations onsite are consistent with any reported contractor/subcontractor use and engagement. 

Partial Points: N/A

Chemengagesuppliers

Does your facility engage upstream supplier(s) on MRSL / RSL? (Ref ID: chemengagesuppliers)

Answer Yes if: Your facility has engaged upstream suppliers on MRSL/RSL, and this engagement includes:

  • Formal process to communicate the facility’s MRSL/RSL policy and requirements to upstream suppliers.
  • Procedures to evaluate and improve MRSL/RSL management programs at upstream supplier facilities. This may include any of the following:
    • Assessment or audit of MRSL/RSL management programs at the upstream supplier. 
    • Requirements to complete and share Higg FEM.
    • Requirements to develop/provide positive lists (for chemical suppliers).
    • Requirements to source chemicals from positive lists (for material suppliers)
    • Where applicable, documented support to help upstream suppliers improve MRSL/RSL management (e.g., training, improvement plans).   

Note: Upstream suppliers are defined as an entity that provides raw materials to manufacturers that ultimately process the materials. (e.g., Chemical suppliers. Fabric mills, zipper and button suppliers are common upstream suppliers for a cut-sew garment factory).

If you select Yes, you will be asked the following sub question(s):

  • If yes, please describe which upstream supplier(s) you engage with.
  • Please describe how you engage your upstream supplier in the process.
  • Please upload documentation, if available.

Suggested Uploads:

  • Documentation that shows how the facility engages with upstream suppliers on MRSL/RSL (e.g., contracts/agreements that cover MRSL/RSL engagement and requirements, records of MRSL/RSL communication, assessments/audit reports and/or improvement plans from upstream supplier engagement, records of Higg FEM completion and sharing, etc.)

What is the intent of the question?

The intent of the question is for facilities to demonstrate that they proactively engage upstream suppliers on MRSL/RSL.

Technical Guidance:

Materials provided by upstream suppliers can present risks related to a facility’s MRSL/RSL compliance program as they have the potential to supply materials that contain banned or restricted substances if they are not aware or negligent with the requirements of the facility’s MRSL/RSL policy and programs. Facilities should seek to proactively engage with any contractors or subcontractors to communicate and promote responsible MRSL/RSL management. 

When engaging with upstream suppliers on MRSL/RSL management, facilities should communicate clear expectations and guidance to ensure compliance and adherence to MRSL/RSL requirements and good practices for MRSL/RSL management. This can be achieved through contractual agreements, ongoing communication to ensure all parties are aware of their roles and responsibilities in maintaining MRSL/RSL compliance. 

Facilities should have procedures to outline the specific activities and responsibilities related to MRSL/RSL for upstream suppliers. This may include:

  • Assessment or audit of upstream supplier MRSL/RSL management programs. 
  • Requirements to complete and share Higg FEM.
  • Requirements to develop/provide positive lists (for chemical suppliers).
  • Requirements to source chemicals from positive lists (for material suppliers).

Facilities can also engage upstream suppliers by providing any necessary support to help them improve their MRSL/RSL management such as training/capacity building and/or support on developing or implementing improvement plans.

Resources:

Chemengagesuppliers Verification And Scoring

How This Will Be Verified:

Full Points:
Full points will be awarded to facilities that have engaged with upstream suppliers on MRSL/RSL and this engagement includes:

  • Formal process to communicate the facility’s MRSL/RSL policy and requirements to upstream suppliers.
  • Procedures to evaluate and improve MRSL/RSL management programs at upstream supplier facilities. This may include any of the following:
    • Assessment or audit of MRSL/RSL management programs at the upstream supplier. 
    • Requirements to complete and share Higg FEM.
    • Requirements to develop/provide positive lists (for chemical suppliers).
    • Requirements to source chemicals from positive lists (for material suppliers)
    • Where applicable, documented support to help upstream suppliers improve MRSL/RSL management (e.g., training, improvement plans).   

Documentation Required: 

  • Documentation that shows the facility has engaged with upstream suppliers on MRSL/RSL. This may include.
    • Contracts/agreements that cover MRSL/RSL engagement and requirements.
    • Records of MRSL/RSL communication. 
    • Assessments/audit reports or improvement plans from contractor or subcontractor engagement.
    • Positive lists from chemical suppliers. 
    • Records of Higg FEM completion and sharing by contractors/subcontractors.
    • Records of training or capacity building with contractors/subcontractors. 

Interview Questions to Ask: 

  • Staff responsible for the MRSL/RSL engagement activities can describe how the facility engages with upstream suppliers on MRSL/RSL.

Inspection - Things to Physically Look For:

  • Where applicable, observations onsite are consistent with any reported upstream supplier use and engagement. 

Partial Points: N/A

Chemcmsteam

Does your facility have the following capabilities and authority in your Chemical Management System (CMS) team? Select all that apply. (Ref ID: chemcmsteam)

  • Knowledgeable of chemical products, production processes and applications
  • You or your team have the requisite authority from the leadership to drive the CMS.
  • Has access to In-House Testing (pH Testing, Color Fastness).

Suggested Uploads:

  • Documentation that demonstrates the chemical management system (CMS) team has demonstrable knowledge of chemical products, production processes and applications (e.g., proof of tertiary education, certification/accreditation, training records/certificates). 
  • Management system documentation (e.g., policies and procedures) that demonstrates CMS team members have the necessary authorization to manage the CMS effectively. 

What is the intent of the question?

The intent of the question is for facilities to confirm that staff responsible for chemicals management have the technical capabilities and knowledge related to chemicals used in the facility and have sufficient authorization from the facility management to allow them to effectively manage the facility’s chemical management system (CMS).

Technical Guidance:

To manage a chemical management system effectively, responsible staff must have sufficient technical knowledge on chemicals and the facility’s production processes that utilize chemicals. Ensuring staff have the right capabilities and knowledge ensures that decisions related to chemicals management are made by qualified individuals. Knowledge is typically demonstrated through one or more of the following:

  • Tertiary education specific to chemicals (e.g., a degree in chemistry, chemical engineering or another related field).
  • Professional accreditation/certification or work experience related to chemicals and/or chemicals management.
  • Training from qualified training providers on topics specific to chemicals and/or chemicals management. 

It is equally important the staff have the requisite authority from facility leadership to effectively implement and maintain the facility’s CMS. This means that staff are provided with the necessary resources (e.g., financial resources and time) and authority to carry out and/or manage all aspects of the CMS. This is typically demonstrated through job descriptions and/or documented accountabilities in management system documentation (e.g., policies and procedures), however actual implementation of effective chemical management system processes and procedures is also a good measure of this.  

Resources:

Chemcmsteam Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded if the facility’s chemical management system team has all of the following:

  • Knowledgeable of chemical products, production processes and applications
  • Requisite authority from the leadership to drive the CMS.
  • Access to In-House Testing (pH Testing, Color Fastness).  

Documentation Required: 

  • Documentation that demonstrates the chemical management system (CMS) team has demonstrable knowledge of chemical products, production processes and applications. This may include:
    • Proof of tertiary education (e.g., copy of degree).
    • Copies of professional accreditation or certifications related to chemicals and/or chemicals management.
    • Records or certificate training on chemicals and/or chemicals management. 
  • Management system documentation that demonstrates CMS team members have the necessary authorization to manage the CMS (e.g., job descriptions, policies and procedures).
  • Records of in-house testing.

Interview Questions to Ask: 

  • Staff responsible for the facility’s CMS can demonstrate an understanding of chemicals, production processes and application throughout verification and can describe how they are authorized to effectively manage the CMS.
  • Facility leadership can explain how they ensure and facilitate the required authority for the CMS team.

Inspection - Things to Physically Look For:

  • Observations onsite indicate that CMS practices and procedures are being implemented by knowledgeable and qualified staff and that the CMS team has sufficient authority to effectively manage the CMS.
  • In-house testing equipment is available onsite.

Partial Points:

  • Partial points will be awarded if the facility’s chemical management system team has one (1) or more, but not all of following:
    • Knowledgeable of chemical products, production processes and applications
    • Requisite authority from the leadership to drive the CMS.
    • Access to In-House Testing (pH Testing, Color Fastness).

Chemimproveplan

Does your facility have an implementation plan to improve your chemicals management system?  (Ref ID: chemimproveplan) 

Answer Yes if: Your facility has one of the following:

  • A documented improvement plan to achieve a Yes response for all Higg FEM Level 1 Chemicals Management questions (Note: this applies to facilities that have one or more partial yes responses in level 1); or
  • A documented plan to further improve your chemicals management system (CMS) if your facility has already achieved a Yes response for all Higg FEM Level 1 Chemicals Management questions.  

If you select Yes, you will be asked the following sub question(s):

  • Does your implementation plan include the following?
    • Goals based on your priorities and scope for the Chemical Management System
    • Continuously improve the effectiveness of the Chemical Management System
    • A hazardous chemicals use reduction plan.
  • Please upload documentation.

Suggested Uploads:

  • Documented improvement plan for achieving a Yes response for Level 1 Chemicals Management questions. This plan should include which Level 1 questions were not fully achieved, and defined actions to achieve a Yes response; or
  • If all Level 1 responses are Yes, a documented improvement plan to further improve chemicals management.

What is the intent of the question?

The intention of this question is for facilities to demonstrate that they are proactively working to continually improve chemicals management regardless of how advanced their current CMS is, and the amount or type of chemicals used onsite. 

Technical Guidance:

Like any other management system, the goal of a chemicals management system should be to drive continuous improvement. This can and should be done regardless of how advanced a facility’s current CMS is, and the amount or type of chemicals used. 

Note: For facilities that have not achieved a Yes response for all Level 1 questions in the FEM, these should be prioritized as the Level 1 questions focus on the foundational aspects of chemicals management. 

The scope of improvements may depend on the extent (e.g., type and quantity) of chemicals used onsite and the status of the facility’s current CMS.  For example, the scope of improvements for a facility that uses few chemicals or chemicals only for tooling or operation may be limited compared to a facility with more complex chemical use, however in both cases, facilities should have a structured process to review their CMS and chemical management procedures to identify and prioritize improvements. This can include, but is not limited to:

  • Review of the CMS policy, strategy, and chemicals management procedures at a specified frequency (e.g., annually) by the CMS Team or by external experts to identify areas for improvement.
    • For example, conducting regular internal or external audits to identify areas for improvement.
  • Once areas for improvement have been identified, prioritize the improvements, and create improvement plans with defined timelines, actions, and responsibilities.
    • Areas of improvement may consist of action to increase the effectiveness of the chemicals management system and/or reduction of hazardous chemical use.
  • Establish a process to monitor the improvement plan to ensure actions are implemented or updated as per the developed plan.

Resources:

Chemimproveplan Verification And Scoring

How This Will Be Verified:

Full Points:

Documentation Required:

  • An implementation plan that includes details of the specific actions the facility plans to take to improve the chemicals management system. This may include: 
    • If applicable, a list of Level 1 questions which were not fully achieved, and defined actions to achieve a Yes response for all Level 1 questions.
    • If all Level 1 responses are already Yes, a plan with defined actions to further improve chemicals management.
    • Implementation timelines (i.e., the planned start and completion dates for actions listed in the plan). 

Note: If the facility has completed all actions in the plan prior to reporting year and does not have an implementation for improving chemicals management in the reporting year and beyond, a No response should be selected (i.e., points are not awarded for historical plans that were implemented prior to the reporting year).

Interview Questions to Ask:

  • Staff responsible for the implementation plan can explain the facility’s plan to achieve a Yes response to all Level 1 questions or further improve their chemicals management systems, as applicable. 

Inspection - Things to Physically Look For: 

  • The actions listed in the implementation plan directly relate to the observed chemical management practices and chemical use at the facility.

Partial Points: N/A

Chemtracelotnumber

Does your facility have a traceability procedure in place which can track chemicals and raw materials used back from the product to the inventory?  (Ref ID: chemtracelotnumber)

Answer Yes if: Your facility has documented traceability procedures that allows you to trace all chemicals and raw materials used back from the final product to the chemical or material inventory.

Answer Partial Yes if: Your facility has documented traceability procedures that allows you to trace some, but not all chemicals and raw materials used back from the final product to the chemical or material inventory.

If you select Yes or Partial Yes, you will be asked the following sub question(s):

  • Do you include the following practices in your traceability practice?
    • A clear overview of the source of your raw materials and chemical products and their suppliers.
    • Record lot/batch number on the purchase order of every chemical.
    • Record the lot/batch number of these chemicals on each colour/product batch.
    • Record the lot/batch number of these chemicals on each article type/order.
    • Do you record the lot/batch number of your raw materials (fabric, yarn, garment etc.) on each article type/order?
  • Please upload documentation.

Suggested Uploads:

  • Chemical/material traceability procedures. 
  • Product batch cards including lot/batch number, dates, and production quantity. 
  • Recipe cards, formulation sheets, process instructions (where applicable), containing all traceability information (e.g., chemical/material name, lot/batch number, quantity, etc.) 
  • Chemical mixing/blending process records including relevant information (e.g., chemical name, lot/batch numbers and quantity used in mixtures). 
  • Chemical/material inventory and/or usage logs with chemical/material lot/batch numbers, quantity, and dates of usage, etc.

What is the intent of the question?

The intent of this question is for facilities to demonstrate that procedures are in place that allow for chemicals and materials used in a final product to be traced back to the chemical/material inventory. 

Technical Guidance:

The purpose of traceability is to understand which chemicals and materials are used to make products. Traceability refers to the ability to select a final product and trace “backwards” to know the specific chemicals and raw materials that were used to produce that product (i.e., lots and batch numbers of chemicals/raw materials).  This allows a facility to know all the components used to make each product. This also helps support investigations in case of any quality or material compliance issues or product recalls.

An effective traceability program will require facilities work with chemical and material suppliers, and any subcontractors to ensure that they provide traceable information on all chemicals/materials supplied to the facility (e.g., chemical name, ingredients, lot/batch number, production dates, etc.), and this information is recorded and tracked as part of the facility’s traceability program.

A traceability program should also maintain a traceable linkage of information throughout the entire production process including, but not limited to:

  • The product batch number. 
  • The production processes that a particular product underwent. 
  • The chemical recipe(s) in relation to each chemical process used to produce the material/product.
  • Information on chemicals used in these recipes at the chemical mixing (e.g., name, lot number, and quantity) 
  • Linkage back to the chemical/material inventory and purchase records for information on the supplier and material composition and/or chemical ingredients.

Resources:

Chemtracelotnumber Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded to facilities that have documented traceability procedures that allow the facility to trace all chemicals and raw materials used back from the final product to the chemical or material inventory and the facility’s traceability program includes all of the practices listed in the sub question.

Documentation Required:

  • Documentation that shows the facility has documented traceability procedures that allows the facility to trace all chemicals and raw materials used back from the final product to the chemical or material inventory. This may include:
    • Chemical/material traceability procedures. 
    • Product batch cards including lot/batch number, dates, and production quantity. 
    • Recipe cards, formulation sheets, process instructions (where applicable), containing all traceability information (e.g., chemical/material name, lot/batch number, quantity, etc.) 
    • Chemical mixing/blending process records including relevant information (e.g., chemical name, lot/batch numbers and quantity used in mixtures). 
    • Chemical/material inventory and/or usage logs with chemical/material lot/batch numbers, quantity, and dates of usage, etc.
    • Historical production records that show chemicals/material traceability.

Interview Questions to Ask:

  • Staff responsible for the facility’s traceability program can describe the procedures in place to track relevant information on chemicals and raw materials. 
  • Relevant staff responsible for recording and/processing chemical or material information understand the facility’s traceability program and procedures. 

Inspection – Things to Physically Look For:

  • Observations on site indicate that the facility’s traceability program is being implemented appropriately (e.g., chemical/material information such as batch/lot numbers, production recipes are appropriately documented, etc.) 

Partial Points:

  • Partial point will be awarded to facilities that have documented traceability procedures that allows you to trace some, but not all chemicals and raw materials used back from the final product to the chemical or material inventory and/or the facility’s traceability program includes some, but not all of the practices listed in the sub question.

Chemsourcelist

Does your facility source already approved or preferred chemicals from a positive list? (Ref ID: chemsourcelist)

Answer Yes if:  50% or more of the chemical formulations in your facility’s chemical inventory are sourced from a positive list (e.g., a customer’s positive list, ZDHC Gateway- Chemical Module(ZDHC MRSL Conformance Level 3), bluesign FINDER, etc.)

Answer Partial Yes if: If 49% or less of the chemical formulations in your facility’s chemical inventory are sourced from a positive list (e.g., a customer’s positive list, ZDHC Gateway (ZDHC MRSL Conformance Level 3), bluesign FINDER, etc.)

Note: The percentage is based on the number of chemicals, not the volume (e.g., 50 out of 100 chemicals equals 50%).

If you select Yes or Partial Yes, you will be asked the following sub question(s):

  • Please upload documentation.

Suggested Uploads:

  • Chemical purchasing policy.
  • Chemical inventory that indicates which chemicals are sourced from a positive list (skip if previously uploaded). 
  • Copies of positive lists, or demonstrated access to positives list (e.g., bluesign FINDER).
  • Purchasing contracts/records that indicate sourcing of chemicals from positive lists. 

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they source chemicals from established positive lists to reduce impacts to human health and the environment. 

Technical Guidance:

Positive lists are designed to provide facilities with a list of chemical products that have been screened and determined to be preferred options for use in manufacturing due to their reduced impacts on human health and the environment. Positive lists also consider the quality process in place at the facilities that manufacture these chemicals to ensure the composition of the chemical formulation is consistent over time and that the risk of unwanted impurities is limited.

Purchasing chemical formulations from reliable positive lists is an effective strategy to ensure that chemicals purchased do not contain hazardous substances. Driving demand for these substitutes, and green chemistry innovation as a whole, is an important driver for the overall improvement of the sustainability performance in the industry. Several brand-driven and third-party initiatives exist to identify positive chemistry such as the ZDHC Gateway- Chemical Module (ZDHC MRSL Conformance Level 3) or bluesign FINDER.

Note: Information on chemical composition available in Safety Data Sheets (SDS) only should not be used for the development of positive lists as the level of detail available in SDSs usually does not identify impurities or substances non intentionally added that can often be the source of the non-compliance with an RSL or an MRSL.

Resources:

Chemsourcelist Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities if 50% or more of the chemical formulations in their chemical inventory are sourced from a positive list (e.g., a customer’s positive list, ZDHC Gateway- Chemical Module (ZDHC MRSL Conformance Level 3), bluesign FINDER, etc.)

Documentation Required:

  • Documentation that demonstrates the facility sources and has purchased chemicals from positive lists. This may include:
    • Chemical purchasing policy.
    • Chemical inventory that indicates which chemicals are sourced from a positive list (skip if previously uploaded). 
    • Copies of positive lists, or demonstrated access to positives list (e.g., bluesign FINDER).
    • Purchasing contracts/records that indicate sourcing of chemicals from positive lists. 

Interview Questions to Ask:

  • Staff responsible for chemicals management and/or purchasing can explain the facility’s process to source chemicals from positive lists. 

Inspection - Things to Physically Look For:

  • Observations onsite indicate that the facility is sourcing chemicals from positive lists (e.g., chemicals in use at the facility are listed on the positives lists used by the facility for sourcing). 

Partial Points:

  • Partial points will be awarded for facilities if 49% or less of the chemical formulations in their chemical inventory are sourced from a positive list (e.g., a customer’s positive list, ZDHC Gateway Chemical Modules (ZDHC MRSL Conformance Level 3), bluesign FINDER, etc.)

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