Material pollution-related impacts, risks, and opportunities (IRO-1)
PUMA has taken steps to evaluate and address pollution risks within its value chain. PUMA joined the Zero Discharge of Hazardous Chemicals (ZDHC) Foundation, a multi-stakeholder organisation working to eliminate hazardous chemicals from the global apparel and footwear value chain, and adopted industry standards such as the ZDHC Manufacturing Restricted Substances List (MRSL) and the Wastewater Quality Guideline. The ZDHC MRSL is an industry list of chemical substances that are restricted for use in the manufacturing process, and the Wastewater Quality Guideline implements the ZDHC MRSL on wastewater quality. These standards have been incorporated into PUMA’s sustainability strategy and targets to support ongoing adherence and implementation. In addition, PUMA addresses chemical product safety by following Restricted Substance List (RSL) industry standards on final products by the Apparel and Footwear International (AFIRM), which provide guidelines for minimising the use and impact of harmful substances.
This assessment included a screening of sites and business activities for both actual and potential emissions including GHG emissions and other pollutants. While GHG emissions are reported under E1 Climate change, this section focuses exclusively on other pollutants.
Pollution of soil and pollution of air were not identified as material topics for PUMA, as they do not represent significant environmental impacts across our value chain when compared to water pollution.
PUMA depends on ecosystem services such as clean water and healthy soils (to grow natural fibres and capture CO2) to help mitigate pollution-related impacts, as these natural systems filter pollutants, break down waste, and support overall environmental health.
T.31Material pollution-related impacts, risks and opportunities (IRO-1)
Value chain location ■□□ Upstream □■□ Own operations □□■ Downstream
Time horizon ❶⑤⑩ Short-term ①❺⑩ Medium-term ①⑤❿ Long-term
Time horizon is indicated for potential impacts. If the impact is actual, marked with ●
Material topic
Material impacts, risks and opportunities
Horizon
Location
Example (mitigation) measures
Pollution of water
POSITIVE IMPACTS
Ecosystem health: Responsible water use supports healthier ecosystems and cleaner water bodies, reducing pollution and protecting biodiversity. It also strengthens agricultural and industrial resilience, contributing to sustainable resource management and improved quality of life for communities
①⑤❿
■□□
• Wastewater treatment: Monitor that suppliers have functional wastewater treatment systems
• Supplier training: Train suppliers and workers on chemical safety and water management standards and practices
• Water conservation project: Explore and engage in projects to minimise water pollution
NEGATIVE IMPACTS
Water pollution during agriculture and production: Cotton farming and textile production often involve harmful chemicals that contaminate water sources and threaten ecosystems and community health. Lower-tier factories may face challenges in adopting cleaner technologies, leading to added costs and compliance issues. The release of untreated or poorly treated wastewater containing hazardous substances can further degrade local water supplies and disrupt aquatic life
●
■□□
Microplastics
NEGATIVE IMPACTS
Microplastic contamination: Synthetic materials such as polyester and nylon release microplastics during washing, which primarily contaminate water and, to a lesser extent, air through airborne fibres. Addressing this issue is challenging, especially in deeper supply chain tiers where awareness is low and wastewater treatment solutions are costly
●
■□■
• Installation of microfiber filters: in wastewater treatment plants or in washing systems
• Garment design: Brand designs in a way to reduce fibre shedding (e.g., tighter weaves, anti-shed finishes)
Substances of concern and very high concern
NEGATIVE IMPACTS
Chemical hazards: Substances of concern and very high concern are potentially harmful chemicals that pose risks to human health and the environment, especially when they are difficult to substitute
●
■□□
• Chemical management system: Setting mechanism to comply with legal regulations and industry standards on chemical restrictions
FINANCIAL RISKS
Stricter regulations: Stricter chemical regulations may result in higher compliance costs, potential fines for non-compliance, and limitations on market access due to restrictions on certain substances
①⑤❿
□□■
Own operations
PUMA’s owned and operated entities are comprised of offices, stores and distribution centres as well as one footwear factory in Argentina. Our offices, stores and distribution centres do not run large-scale boilers, do not use water on an industrial scale, do not use significant quantities of hazardous chemicals and do not produce significant amounts of hazardous waste. The footwear factory in Argentina on average consumes less chemicals compared to other Tier 1 footwear factories in our upstream value chain. Therefore, no material impacts, risks and opportunities have been identified for our owned and operated entities related to pollution.
Upstream value chain
Processes such as dyeing, finishing, and adhesive application in footwear production may release Volatile Organic Compounds (VOCs) and other pollutants. Leather tanning involves chemicals like chromium, which, if not managed properly, could harm workers. This may impact worker health and safety, identified as a material topic under S2 Workers in the value chain section.
Downstream value chain
Activities associated with pollution material impacts, risks and opportunities in PUMA’s downstream value chain include consumer washing of apparel, which can release chemicals and microplastics into water systems. While PUMA does not control these processes, they represent potential indirect environmental impacts.
Risk assessment
PUMA uses the EiQ platform to assess upstream value chain environmental risks. Risks monitored include air pollution, wastewater violations, waste management, environmental management, and permits. In 2025, China, Vietnam, Cambodia and Bangladesh are classified as high-risk countries, while India and Indonesia are extreme risk. We implement the same chemical standards on these high risks areas as compared to other areas. Overall, these high-risk areas have ZDHC wastewater and ZDHC MRSL conformance of 99.4% and 85.8% respectively. We engaged relevant factories throughout 2025 based on our 2024 chemical risk assessment result, with 12 factories successfully switched to safer alternatives, while two are piloting new alternatives and five are addressing the challenges of phasing out dimethylformamide (DMFa). DMFa continues to be an industry challenge and we are working with ZDHC to find collaborative solutions especially for polyurethane manufacturers.
Strategy
PUMA’s strategy to address environmental pollution focuses on eliminating hazardous chemicals from its value chain through stringent chemical management and industry collaboration.
Policies related to pollution (E2-1)
The PUMA Management Board is responsible for the approval and implementation of all pollution-related policies and handbooks. Various departments handle implementation and report progress to the Management Board and leadership team.
PUMA’s Environmental Policy includes measures to manage water pollution IROs upstream in its value chain. Our policy outlines actions to mitigate, prevent, and address risks to people and the environment, including incidents. It details our monitoring practices, such as guidelines for product testing to ensure compliance with AFIRM RSL, tracking monthly chemical concentration data for compliance with ZDHC MRSL, and conducting bi-annual wastewater testing to monitor compliance with ZDHC Wastewater Guidelines. Our Environmental Policy does not currently include a standalone substitution or phase‑out commitment. However, it does outline a targeted reduction strategy for VOCs in footwear and demonstrates our intent to pursue substitution or phase‑out through adherence to industry standards (ZDHC MRSL and AFIRM RSL). The current policy does not include procedures for managing pollution-related emergencies, which will be addressed in the future revision.
Through joint multi-stakeholder industry initiatives and stakeholder dialogue, PUMA includes key stakeholders’ perspectives in the process of developing the policy related to pollution. The policy is publicly available on our website and accessible to all affected and relevant stakeholders. Detailed information on stakeholder consultation is provided in the General information (SBM-2) section.
Actions related to pollution (E2-2)
Own operations
PUMA’s own offices, stores, and warehouses do not use any water or substances of concern for industrial purposes. Therefore, pollution of air, water and soil are considered not material for PUMA’s own operations. Instead, we are reporting our efforts in the upstream value chain, where the production of PUMA goods is performed by independent manufacturing partners. Our suppliers are independent third-party entities, unaffiliated with the PUMA Group. Therefore, PUMA has no operational control over our suppliers. Further details are in the General basis for preparation (BP-1) section.
Upstream value chain
Chemicals
PUMA has implemented the ZDHC MRSL and AFIRM RSL standards across its value chain. We track chemical products used in our core Tier 1 and Tier 2 facilities monthly until at least 2030, measuring conformance to ZDHC MRSL through ZDHC Gateway.
In 2025, 100% (106 core factories) within scope submitted data achieving an 86.6% MRSL conformance rate (77.9% considering DMFa used in polyurethane factories). Our 2025 target of 90% was met by 60 factories. A deep-dive analysis ofnon-conformantchemicalswas conductedtoidentifythetop chemical suppliers withthe highest numberof non-compliantchemicals and the largest usage volumes in our upstream value chain.In 2026, we will prioritise engagement with these suppliers to drive alignment with ZDHC MRSL requirements.
PUMA requests factories to conduct ZDHC InCheck Verification as an additional level of assurance. In 2025, 75 out of 90 PUMA core factories with ZDHC InCheck reports (83.3%) completed this verification step with a 100% passing rate. stichd has not implemented ZDHC InCheck Verification in its upstream value chain for 2025 but plans to do so in the future.
In 2025, we reached 98.2% compliance with AFIRM RSL (from January to October2025).
PUMA participates annually in the Corporate Information Transparency Index (CITI) by the Institute of Public & Environmental Affairs (IPE) and the Brands to Zero Assessment of ZDHC. Our performance is evaluated and scored, helping us benchmark against other brands and identify areas for improvement.
Pollution of water
PUMA adopted the ZDHC Wastewater Guideline for factories with industrial wastewater to test their wastewater twice a year according to the ZDHC Wastewater Guideline and publish their result on the ZDHC Detox.Live platform for public disclosure. For factories with non-compliance in wastewater testing, we supported root cause analysis and corrective actions through training by third-party labs on the ZDHC Wastewater Guidelines and individual support from our regional teams. More details and results from this action can be found in the Pollution of water (E2-4) section.
Supplier training
We provide training to factories on wastewater management and monitor chemical use. Our ongoing due diligence process is intended to support compliance with ZDHC and AFIRM standards, with the goal of reducing hazardous chemicals in our value chain.
PUMA engaged with ZDHC and GIZ for industry-aligned capacity building. PUMA conducted five chemical training sessions in 2025 with multiple sessions and languages, reaching over 484 factories and 780 participants across PUMA’s upstream value chain. We also supported factories in performing root cause analyses for non-compliances based on ZDHC frameworks and in implementing the necessary corrective actions.
PUMA partnered with ZDHC and ZDHC-approved laboratories to train factories on improving the conformance rate to ZDHC MRSL and strengthening chemical management in factories. For capacity building on ZDHC MRSL, 454 participants from 264 factories were trained and 95 participants from 91 factories completed the GIZ Resource Efficient Management of Chemicals - Chemical Management Improvement (CMI) course. Three multilingual training sessions on the newly updated ZDHC Wastewater Guidelines V2.2 and overall chemical management were held, with 231 participants from 129 factories.
Factories were also encouraged to attend ZDHC Academy courses on chemical and wastewater management. In addition to training, the 76 core factories completed the ZDHC Supplier to Zero programme, a step-by-step improvement framework that helps factories in the textile and footwear industry advance their chemical management and environmental performance.
PUMA had no major incidents or pollution deposits in the reporting year. Consequently, there were no operating or capital expenditures related to such incidents, nor were there any provisions for environmental protection or remediation costs. There were no material incidents that negatively impacted the environment or financial performance. Additionally, no related products or services were at risk, and no financial assessments or critical assumptions were necessary.
Metrics and targets (MDR-M, MDR-T, E2-3)
PUMA has not set contextual targets and therefore has an overall target to improve wastewater quality and eliminate hazardous chemicals upstream and downstream. They are part of PUMA’s broader commitment to sustainability and are aligned with the SDGs. These targets were developed through double materiality assessment and stakeholder consultations as explained in General information (SBM-2) section.
The ZDHC Wastewater Guidelines that we refer to in our target, aim to minimise the release of hazardous substances into the environment. Developed by industry experts, these guidelines take into consideration national standards in pollution control and chemical management. The target is voluntary and may exceed local standards.
We set compliance targets such as tracking ZDHC MRSL substances in wastewater and chemical usage according to the ZDHC MRSL. MRSL conformance is reported as the percentage of chemicals (by weight) used in the manufacturing process in conformance with the ZDHC MRSL. For our products, we track the presence of these substances through RSL tests of all materials used; available data shows the concentration in the final product, not the total amount.
Value chain location■□□ Upstream □■□ Own operations □□■ Downstream
10FOR25 target1
Location2
Scope
Entity specific
2020 baseline
2025 achievement
90% compliance with ZDHC Wastewater Guidelines3
■■□
PUMA, stichd5
□
Target achieved for all parameters (90% compliance with ZDHC Wastewater Guidelines on parameter level)
99.2% wastewater compliance rate6
●
Maintain RSL compliance rate above 90%
■□□
PUMA, Cobra4, stichd5
□
98.8%
98.2% RSL compliance rate7
●
Reduce VOC below 10 gr/pair
■□□
PUMA
□
VOC index of 14.7 gr/pair
11.3 gr/pair8
○
Support initiative and scientific research on microfibres8
■□□
PUMA
□
Joined the Microfiber Consortium
61 microfibre shedding tests9
●
1 All targets are absolute and voluntary. Targets are not based on conclusive scientific evidence. All targets apply from January 2020 to December 2025.
2 Targets apply to all locations of the entities listed under scope.
3 Applies to the upstream value chain.
4 Cobra products sourced by PUMA Group Sourcing (PGS). Golf club parts sourced by Cobra PUMA Golf are excluded.
5 Includes only PUMA products sourced by stichd. Products sourced by stichd for other brands are excluded, as stichd follows each brand’s specific quality requirements.
6 2025 data is from 153 Tier 1 and Tier 2 wet-processing PUMA factories measured by ZDHC-approved labs conducting tests bi-annually between November-April and May-October.
7 For final products, 2025 RSL compliance rate reflects data from January to October from 498 Tier 1 and Tier 2 PUMA, Cobra and stichd factories.
8 2025 data is from 34 PUMA Tier 1 footwear factories, supported by random annual tests from PUMA-approved labs.
9 Cumulative microfibre shedding tests until 2025 conducted on 100% polyester fabrics (56) and blended fabrics (five) using TMC method.
In our 10FOR25 targets, we achieved our goals on wastewater, RSL compliance and microfibres. Achievement of these goals was supported by collaborative industry efforts to implement a common industry standard. However, we did not meet our goal for VOCs reduction in footwear as our 2025 result was 11.3 gr/pair. This result highlighted the challenges in phasing out certain chemicals due to the lack of a common industry standard while maintaining our standards of product quality. We will continue to monitor air quality for workers’ health and minimise VOCs in our footwear production as we work with the chemical suppliers.
T.33Vision 2030 targets and baseline
Value chain location ■□□ Upstream □■□ Own operations □□■ Downstream
Vision 2030 target1
Location2
Scope
Entity specific
2025 baseline
95% MRSL compliance at core factories3
■□□
PUMA, Cobra4, stichd5
□
86.6% MRSL conformance rate
(77.9% MRSL conformance rate including PU facilities)6
90% air emission compliance at core factories
■□□
PUMA, Cobra4, stichd5
■
56.5% air emission compliance rate7
1 All targets are absolute and voluntary. Targets are not based on conclusive scientific evidence. All targets apply from January 2026 to December 2030.
2 Targets apply to all locations of the entities listed under scope.
3 Applies to core factories that follow the latest ZDHC Manufacturing Restricted Substances List v3.1, including core Tier 1 and Tier 2 factories that use chemicals in their production processes.
4 Cobra products sourced by PGS. Golf club parts sourced by Cobra PUMA Golf are excluded.
5 stichd will finalise their company-level 2030 targets in 2026.
6 2025 conformance rate is the average of August to October 2025 from 106 core Tier 1 and core Tier 2 factories at PUMA, Cobra and stichd, where three of them are Tier 2 Polyurethane (PU) suppliers.
7 2025 compliance rate reflects January to October data from 62 core Tier 1 and Tier 2 (textile and leather) PUMA factories.
Performance in 2025 serves as a baseline for all Vision 2030 targets; no specific progress was planned for 2025. Whether progress is in line with the planned target will be analysed from 2026 onwards.
Pollution of water (E2-4)
Upstream value chain
In 2025, 153 of our supplier factories conducted wastewater testing according to the ZDHC Wastewater Guidelines (99.4% completion),submitting294 test reports. Of these, 130 factories achieved a compliance rate of 100%, and all factoriesdemonstrated a compliance rate of at least 90%. The overall compliance rate was 99.2% for 2025 and for each category as follows:
Conventional wastewater parameters: 99.4%
Heavy metals: 99.4%
Restricted chemicals (MRSL): 99.0%
Conventional wastewater parameters are basic water quality indicators like pH, temperature, and total suspended solids and apply only to 66 factories that discharge the treated wastewater directly into natural water bodies.
The wastewater test result is a snapshot result detecting the presence and concentration of ZDHC MRSL substances and other pollutants in the given wastewater sample. Therefore, data on the volume of pollutants at the aggregate level is not available.
Microplastics
PUMA takes a proactive approach on microplastic pollution by addressing microfibre shedding (including both plastic-based and other fibres) through engagement with industry initiatives and contributing to The Microfibre Consortium (TMC)’s 2030 roadmap, focusing on research, mitigation strategies, and industry collaboration.
Since 2021, PUMA has conducted 61 microfibre shedding tests on 100% polyester fabrics (56 tests) and blended fabrics (five tests) using TMC method. These tests contributed to the development of TMC’s standardised shedding rating system and its 2025 Root Cause Analysis Report, the first large-scale, in-depth study examining how different fabric types influence microfibre shedding. Our test results showed that PUMA’s fabrics shed less on average than TMC’s database average. In 2025, we conducted eight microfibre shedding test which showed an average microfibre loss of 0.70 g/kg (TMC database average of 0.76 g/kg). However, we had two fabric types with higher average shedding than the others. We will conduct more testing with these fabric types in following years to further substantiate the correlation between fabric types and microfibre shedding with support from TMC to validate our evaluation.
Substances of concern and very high concern (E2-5, E2-6)
Some chemicals used in the manufacturing process of our products can be considered substances of concern or substances of very high concern (SVHC), due to their potential adverse effects on humans, animals, or the environment. Our factories are prohibited from using substances listed in the ZDHC MRSL, but impurities and contamination may result in SVHC being detected in wastewater or final products. Through our Product Compliance mechanism, we ensure that the SVHC in final products are within legal limits.
Currently, we have data on chemical substances level for77.4% of our factories (82out of106) from January to September2025. However, data completeness is not sufficiently consistent to allow for accurate reporting of the volume of substance of concern and very high concern used in our manufacturing process.
Air pollution has not been identified as a material topic for PUMA, as it does notrepresenta significant environmental impact across our value chain as compared to waterpollution.However, in line with the ZDHC’s 2024 publication of Air Emission Guidelines, we implemented the guidelines at62 factories in 2025. The current guidelines calculate the Potential to Emit (PTE) of VOCs based on the chemicals used in manufacturing, thus highlighting the connection to minimising use of substances of concern or very high concern. Only35 factories were compliant (meeting the ZDHC’s Foundational level or above), while27 factories, primarily Tier 1 footwear and Tier 2 textile, were non-compliant. VOCemissions are driven by both theVOCcontent at the chemical formulationand production scale. Based on this result, we will continue to engage with ZDHC to evaluate the feasibility of current VOC limits for large-scale footwearand textileproduction.
Volatile organic compound
Wemonitorthe use of VOCs in our Tier 1 footwear factories to minimise the use of substances of concern and very high concern as part of our 10FOR25 targets. In 2025, average VOCsin footwear manufacturing was reduced to 11.3 gr/pair from a baseline of 14.7 gr/pair in 2020.
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