Chemical Management

Chemical Management Addressing hazardous discharge

The global apparel industry accounts for high amounts of manufacturing chemical 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.

Our approach to chemicals management includes several key components:

  • Work with suppliers: We communicate chemical safety requirements to our suppliers in our Code of Vendor Conduct (COVC) and require them to acknowledge and comply with these requirements.
  • Compliance and monitoring: We use third-party testing of products and components of products to monitor compliance with global chemicals regulations and Gap Inc. chemical restrictions. 
  • 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 the industry as a whole. 


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.

We align to 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. In 2018, we initiated pilots of two different programs developed by and for the apparel industry to proactively identify and increase use of safer chemicals. As well as checking for MRSL conformance, these programs provide additional information about input chemicals (such as a third-party chemical-hazard assessment) to help identify “best available” formulations.

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 outlines 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. 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 and air emissions. 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 in order to ensure they meet regulatory standards established by the countries where we sell products. To address emissions, we have integrated ZDHC tools and resources for output management into Gap Inc. policies and systems for managing our supplier relationships. In 2018, we formally adopted the ZDHC Wastewater Guidelines into existing supply-chain programs, including our Water Quality Program (WQP) for all denim laundries — Tier 1 facilities that generate significant amounts of wastewater — and our Mill Sustainability Program. Our strategic mills and laundries are required to test their wastewater twice per year to ZDHC standards and publish the results through the ZDHC Gateway, a data-sharing platform that allows brands to monitor supplier wastewater data.