PUMA follows the precautionary principle and takes measures to prevent harm to human health and the environment from its products and operations.
All the materials used in PUMA products are subject to our Restricted Substance List (RSL) Testing Program to ensure compliance with global chemicals regulations. Rather than applying internal testing standards for our tests, we rely on the AFIRM Group’s Product RSL and on the Manufacturing RSL developed by the Zero Discharge of Hazardous Chemicals Foundation (ZDHC).
In 2021 we changed our target from less than 1% RSL failure rate to maintain the RSL compliance rate above 90%, to allow for increased new material development and innovation, where each material is tested, and hence more failures can happen. In any case, no material with a failed RSL test can be used for PUMA products until the failure has been corrected and the material has successfully passed the test. In this way, we mitigate the risk of product-level RSL failures. We will still track our RSL failure rates to identify improvement opportunities and prevent such failures from occurring in the future.
At the manufacturing level, as part of our Zero Discharge of Hazardous Chemicals commitment we continued to ban the intentional use of priority chemical groups classified as particularly hazardous under ZDHC standards. This phase-out was supported by the widespread use of bluesign® and OEKO-TEX®-certified materials. While the use of most of these chemical groups was never intentional, poly- and per-fluorinated chemicals (PFCs) were used until 2017 for water repellent finishes on apparel and footwear products. In 2021 we started using Gore-Tex bluesign®-certified membranes and finishes again, which are either completely PFC-free or free from PFCs of environmental concern. In February 2017, Gore announced the “Goal and Roadmap for Eliminating PFCs of Environmental Concern (PFCEC)” from the lifecycle of its consumer fabric products following discussions with Greenpeace. Gore Fabrics Division is still fully committed to the PFCEC-free goals for its consumer products and is now on track to transition most of its portfolio by the end of 2025.
Our phase-out of hazardous substances is also reflected in the results of wastewater tests performed by our wet-processing suppliers. The tests show compliance levels of 98% among the 14 MRSL parameters listed in the ZDHC MRSL. Most parameters show compliance rates of 100% or close to 100%. Some MRSL chemicals were still found in certain samples because we share production lines with other brands and retailers.
Please see Water and Air section for further details.
There is a total of 264 ZDHC Gateway accounts connected with PUMA. 49 are core Tier 1 and 76 core Tier 2 factories and the remaining are non-core factories. These factories are part of different ZDHC programs, depending on what applies to them: InCheck reports for MRSL conformance, ClearStream reports for wastewater conformance, and the Supplier To Zero program for chemical management.
In 2021 we conducted a risk assessment using our risk assessment methodology. We used the Higg FEM chemical management score 2020 by our core suppliers and engaged with AFIRM and the ZDHC Foundation to review our risk assessment.
We see a high risk for upcoming regulatory requirements. We will keep our engagement with AFIRM and Federation of the European Sporting Industry (FESI) as a platform to engage with policy makers in different regions and countries such as the EU and the US, so standards are achievable by the industry, while protecting consumers, workers and the environment.
PUMA has had a long-lasting program to ensure compliance with industry standards. We also updated our chemical handbook and increased supplier training in 2021. These are the reasons why we see a low risk towards factory workers and communities’ health and medium risk of product claims.
In 2022 we continued using the China IPE database to screen for any environmental violations by factories located in China producing PUMA products and materials. We also continued monitoring compliance with ZDHC wastewater guidelines, ZDHC MRSL, and Higg FEM chemical management.
We organized MRSL conformance training for PUMA Tier 1 and Tier 2 suppliers and invited chemical suppliers to strengthen their commitment to conformance.
The details of compliance with ZDHC wastewater guidelines, ZDHC MRSL, and Higg FEM chemical management are described in this report.
We achieved ‘Aspirational Level’ in the 2022 ZDHC Brands to Zero Program, the highest category of success, by accelerating the implementation of sustainable chemical management across our value chain. This is a significant jump from “Foundational Level” in 2021. PUMA is recognized as ZDHC Leader to Zero in our industry, committed to ZDHC’s goals as we continue to blaze the trail of innovation and best practices to protect consumers, workers and the environment.
The Brands to Zero Program comprises an integrated package of ZDHC guidelines, platforms and solutions that streamline and create a single common implementation approach. This eliminates duplicative efforts and supply chain complexity resulting in enhanced supplier engagement and consistent benchmarking of implementation performance.
In 2022 we made significant improvements in supply chain engagement, chemical management practices, ZDHC Gateway Chemical Module, and ZDHC Gateway Wastewater Module. The higher score came as a result of our strong commitment to enhancing the implementation performance of sustainable chemical management in our supply chain.
Based on the 2022 result of the Brand to Zero Assessment, we built up the vendor supplier scorecards along with social ratings to improve the business integration area. This vendor supplier scorecard was shared with the sourcing department at the end of 2022.
PUMA is included in the ZDHC’s Detox Fashion Radar which promotes transparency and accountability within the fashion industry.
"As one of the founding members of the Roadmap to Zero Programme, PUMA has been instrumental in driving continuous improvement and collective impact. Their commitment to reducing greenhouse gas emissions, waste, and harmful chemicals in the apparel and footwear industry is commendable. Through their active participation, PUMA has demonstrated a strong leadership role in promoting sustainability and creating a more responsible future for the industry."
Executive Director, ZDHC Foundation
PUMA has moved from individual brand chemical and environmental audits to the use of industry-wide tools, such as the Higg Index Facility Environmental Module (FEM) 3.0. PUMA requires an annual external verification of the self-assessment FEM modules (verification visits are announced). This external verification may be completed by approved verifiers from PUMA’s internal team or other brands, or third-party organizations on the approved list from SAC. The FEM Chemical Management Section measures factory performance from inventory and purchasing, to production, storage and waste. PUMA’s Chemical Performance Rating System is based on the ratings developed from the factories’ verified Higg FEM scores under the chemical management section as verified by SAC-approved verifiers: A, B+, B-, C and D. The minimum passing grade from the Chemical perspective is 40% (i.e., only A, B+ and B- ratings are a passing score) and C and D are failure ratings. This rating system was presented during meetings of suppliers and sourcing teams in 2021 and was implemented gradually from 2022. Our chemical handbook has been updated accordingly. The rating system was included in vendor supplier scorecards along with social and environmental ratings.
*FEM 2020 PUMA average: 146 factories
FEM 2021 PUMA average: 142 factories
**Industry median FEM 2021 (5,889 factories): Filter used industry sector (Apparel, Footwear, Accessories include handbags, jewelry, belts and similar products) and Facility Type (Final Product Assembly, Printing, Product Dyeing and Laundering, Material Production including textile, rubber, foam, insulation, pliable materials)
*Out of 147 core factories, 142 completed FEM verification
In 2022 PUMA continued to use the Higg Facility Environmental Module (FEM), the industry tool, to measure chemical management performance through the Higg FEM Chemical Management Module, which tracks purchasing and inventory management, production, storage and waste locations. We communicated our expectation to our core factories that they improve their verified FEM Chemical Management score to 39%. In 2022, the average verified Chemical score among our factories was 39%, which means we have achieved our target.
The table shows the aggregated verified FEM2021 chemical module scores (median) for PUMA core factories with industry benchmarking. Compared to the industry, the verified FEM score overall for our factories is higher than the industry median score.
During 2022 we continued to engage with our PUMA core Tier 1 and Tier 2 factories in capacity-building activities and projects in chemical management, which are focused on how to improve Higg FEM Chemical Management scores for the factories with low performing scores. We worked together with industry expert groups such as ZDHC, AFIRM as well as ZDHC-approved laboratories to organize training webinars and develop training videos in local languages. PUMA also joined the Chemical Management Improvement Program (CMI) and the Program for Improvement of Environmental Performance of Factories (PIE) of GIZ in countries such as Vietnam and Bangladesh to improve the factory’s Chemical Management Performance. The improvement in the MRSL conformance rate also contributed to an increase in the Chemical Management Score.
In 2023 we will continue to engage with our PUMA core Tier 1 and Tier 2 factories in capacity-building activities and projects in chemical management. We will organize customized training sessions by SAC-authorized trainers. The training sessions will continue to focus on how to improve the Higg FEM Chemical Management score for the factory with low performance to support these factories to achieve 2023 goals with average FEM score of 46 for chemical management.
A series of training sessions were conducted in 2022, covering chemical management in input, process and output phases, in collaboration with ZDHC, accredited third party laboratories and external consultants.
In 2022 PUMA helped our core factories with low chemical management scores to participate in the ZDHC Supplier to Zero program, which contains a chemical management checklist to help factories identify opportunities to improve their chemical performance. A total of 58 core Tier 1 and core Tier 2 factories have completed the ZDHC Supplier to Zero assessment. Almost all of them completed their assessment at the end of 2022, so we will monitor their performance improvement in 2023.
The training course combines self-study and class training with the trainer to develop knowledge of the factory chemicals in use. After completing the training course, the factories’ management are requested to submit an action plan to improve chemical management. The PUMA sustainability team supported our vendors by reviewing and advising on the action plans.
We nominated 32 core supplier factories in Vietnam to join this program with on-site consultancy, out of which 31 core suppliers joined this project. 110 out of 118 participants who took part obtained a Certificate of Completion and a Certificate of Attendance (93%). 100% of factories are working on an action plan. 87% of factories received a Letter of Recognition with Higg FEM 2021 – their chemical scores have improved by 10%.
The PIE program is also an initiative by GIZ. In this program, the factories have worked to improve their environmental performance through capacity building and advisory services. The factories were also trained in the chemical management system. We nominated five supplier factories in Bangladesh to join this program. 12 participants from four factories obtained a Certificate of Completion. 100% of factories received a Certificate of Participation and improved their score by more than 50%, based on baselines and final assessment score.
|Virtual training||Topics||Number of factories||Number of participants|
|Industry chemical management standards, guidelines and platforms (Jointly organized with ZDHC) Conducted 3 sessions in 2 different languages|| ZDHC WW guidelines V 2.0 - Wastewater ClearStream Report
ZDHC CMS Technical Industry Guide Supplier To Zero (Chemical Management) ZDHC MRSL
ZDHC Gateway platform
|MRSL (Jointly organized with an accredited third-party laboratory) Conducted 3 sessions in 3 different languages|| ZDHC MRSL V2.0 and ZDHC MRSL Conformance Guidance (V1.1)
How to improve ZDHC MRSL conformance rate indicated in InCheck Report.
(Jointly organized with accredited third-party laboratory)
|RSL standard and testing matrix update and implementation||Approx. 130||Approx. 203|
In 2022 chemical management training sessions covered MRSL and factory chemical management (FEM). A total of six training sessions were conducted in five different languages. More than 240 factories and 570 participants were invited. More than 80% of participants were satisfied with the training arrangement and content. These training programs helped our suppliers improve their understanding on PUMA’s and industry requirements. Training in various relevant standards, guidelines and tools helped them to improve the effectiveness of their Chemical Management System (CMS).
After the training, the core factories with low MRSL conformance rates developed an action plan to improve their performance. We received such action plans from 36 factories and set up their sessions to review their plans and facilitate their implementation.
In addition, we also encouraged the suppliers’ chemical management teams to attend in-depth training courses as part of the ZDHC Academy conducted by ZDHC-approved service providers.
Examples of the training courses that have been attended by PUMA suppliers were ZDHC Top 10 Issues & Best Practices as well as CMS and Technical Industry Guide (TIG) training.
In 2022 we received 7,851 RSL tests and material certification submissions with an overall RSL compliance rate maintained at above 98%. When materials fail an RSL test, they cannot be used for PUMA products until the failure has been corrected and they successfully pass the test. In this way, we mitigate the risk of product-level RSL failures.
|Product Division||No. of test submission||Compliance rate (%)||No. of test submission||Compliance rate (%)||No. of test submission||Compliance rate (%)||No. of test submission||Compliance rate (%)|
Every year PUMA performs random RSL tests on high-risk materials of finished products. In 2022 we tested 227 materials in 29 finished products across footwear, apparel and accessories from different suppliers in different sourcing regions. The passing rate was 95%.
While all products met all legal requirements, we took actions for the RSL failures, such as material segregation, increased test frequency on materials before product manufacturing, and improved manufacturing processes at Tier 2 factories.
Regarding MRSL conformance, we use ZDHC MRSL, an industry standard adopted by many brands/retailers at the supplier level, to verify the phase out of priority hazardous chemicals. Out of 147 core factories, 26 factories do not use chemicals during the manufacturing process and therefore are out of scope of the MRSL.
In 2022, 88 of our core factories used either BHive, CleanChain or E3 tools to account for MRSL implementation at factory level. This means that 90% of Tier 1 factories and 61% of Tier 2 factories under the scope of our MRSL program have an official InCheck Report, issued by ZDHC-approved solution providers to track MRSL compliance. These are the chemical management platforms to manage chemical inventory and generate Performance InCheck Reports, which provide a summary of the MRSL conformance of the factory’s chemical inventory.
|Number of factories|
|In MRSL scope||With Chemical Inventory List||With InCheck Report|
The BHive app uses OCR technology to allow manufacturing facilities to take smartphone photos of chemical product labels, generate a full and accurate chemical inventory and within seconds identify which chemical products meet MRSL requirements used by many brands and retailers. Facilities can then see which chemicals they should keep using and which they should phase out.
From March to August 2022, Kim Viet factory in Vietnam joined the Chemical Management Improvement (CMI) program by GIZ to improve chemical management performance. In this program they completed the training courses on the chemical management system through the guided online platform to master the chemical management system and practice in the factory, received a consultation from the Chemical Management Advisor and then made a Performance Improvement Plan. The Higg FEM 2021-verified chemical score improved by 112%, from 17 to 36, in comparison to the Higg FEM 2020-verified chemical score. PUMA's average Higg FEM 2021 score is 39, whereas the industry median is 30%.
In August 2022, Formosa Group made an action plan to improve MRSL conformance for three facilities in Taiwan, China and Vietnam. The factory analyzed the MRSL conformance rate (based on the March/April/May InCheck Report) to make a list of the top 14 non-conformance chemicals and target chemical suppliers accordingly. Formosa then worked with the suppliers of these chemicals and requested them to register a ZDHC account and submit the evidence of the chemicals conformance with ZDHC MRSL (at least level 1) on the ZDHC gateway. All three facilities achieved approximately 70% MRSL conformance.
With a baseline of 45% MRSL conformance rate in 2021, we set a goal of 60% MRSL conformance in 2022. We exceeded the 2022 goal with an average MRSL conformance rate of 68%. 58 out of 88 core factories now have an InCheck report achieving the target of 60% MRSL conformance. MRSL conformance is measured by weight.
In 2023 we will focus on the remaining core factories to receive an InCheck report. We will engage with PUMA core Tier 1 and Tier 2 factories in related capacity-building activities and implementation. We will organize customized training sessions by ZDHC, ZDHC approved third-party laboratories and focus on how to improve MRSL conformance for the factories with a low MRSL conformance rate. This will support the factories in achieving the 2023 MRSL conformance goal of 70%. In 2023 we plan to work with ZDHC-approved third-party verifiers to conduct on-site verification, which is an exercise conducted to establish the credibility of the chemical inventory list uploaded by a supplier and generate the verified Performance InCheck Reports.
Besides using a chemical inventory to control input chemistry, we also use wastewater tests conducted by accredited independent laboratories to ensure no harmful chemicals are released through the wastewater of our manufacturer’s facilities with wet processing. The results of these tests show a compliance rate of over 94% for each parameter, with most parameters scoring 99 or 100% compliance.
More details on wastewater testing are provided in the Water and Air section of this report.
With much collaborative effort, we continue to edge closer towards our 2025 target of limiting VOC emissions to 10 g per pair of footwear produced. Although we faced certain supply chain difficulties in 2022, we have again managed to reduce our volatile organic compounds (VOC) and for 2022 we are reporting 13.2 g per pair. We remain confident to achieve our 2025 goal, through the increased use of water-based adhesives, as well as further innovations within our adhesive suppliers.
*Since 2019 figure-based for core suppliers in alignment with the general reporting scope.