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. Dyeing and finishing processes are a primary driver of the apparel industry’s pollution impacts; some sources estimate that toxic wastewater discharge from clothes dyeing accounts for 20 percent.

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 also working to phase out some chemicals of particular concern, including through our commitment to eliminate PFC-based finishes. 

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


  • Work toward zero discharge of hazardous chemicals in our supply chain
  • Eliminate all PFC-based finishes from our supply chain by 2023
    • In 2020, 7 percent of water and stain repellent product was made using non-PFC-based finishes

Our Approach 

Our approach to chemicals management includes three key components: 

1. Industry partnerships and standards: We partner with industry groups, including 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. Supplier engagement: 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. We take appropriate corrective actions to address noncompliance with our requirements. 

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. 

Resources for Brands 

In 2020, we developed an internal Dyeing, Finishing and Wet Processing toolkit to empower cross-functional teams to evaluate new opportunities and make informed decisions. The toolkit supports compliance with our MRSL, RSL and wastewater testing policies, as well as additional guidance on performance finishes and dyes. We will continue to expand and evolve this resource to support our brands in identifying more sustainable options for dyeing and finishing. 

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. We require our suppliers to follow key components of the ZDHC Roadmap to Zero Programme, which includes maintaining a chemical inventory list, and using input chemicals that comply with the ZDHC MRSL. We are also working to go beyond ZDHC 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 ZDHC 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 industry-aligned tools and resources for output management, including the ZDHC Wastewater Guidelines. Our strategic mills and laundries are required to test their wastewater to ZDHC Wastewater Guidelines.  

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. 


2020 Progress Toward Zero Discharge of Hazardous Chemicals 

In 2020, we continued to actively monitor and help improve wastewater quality at denim laundries through our Water Quality Program, which has been a requirement for over 15 years. In 2020, 54 denim laundries participated, with 94.2 percent of facilities meeting all conventional parameters and 88.5 percent meeting all ZDHC MRSL parameters, in line with the ZDHC Wastewater Guidelines. 

We will continue to implement industry standards and best practices, and build capability for chemicals and wastewater management in our supply chain. 
Elimination of PFC-Based Finishes 

Expanding on our 2016 ban on long-chain PFCs, we are currently on track to eliminate all PFC-based finishes from our supply chain by 2023: 

  • Fabrics with PFC-based and potentially PFC-based finishes were used in less than 2 percent of units across our brands in 2020. 
  • To enable phase-out of PFC-based finishes, we created an internal list of acceptable non-PFC-based finishes that can deliver comparable performance. 

  • Cross-functional teams continued to work closely with our suppliers to develop water-repellent and water-resistant fabrics using these acceptable finishes. 

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