Consumer Confidence Safe and responsible use of chemicals in everyday products

A Unilever commitmentSeptember 2007

Our purpose

Unilever’s mission is to add vitality to life. We meet everyday needs for nutrition, hygiene and personal care with brands that help people feel good, look good and get more out of life.

Vitality is at the heart of everything we do:

our brands, our people and our values.

Our name is on all our brands and all of

our subsidiary companies worldwide, so that

people know who we are, what we do and

what we stand for. We want our brands and

the company behind them to be understood

and trusted throughout the world.

This report is part of that commitment.

We recognise that consumers everywhere

are increasingly concerned about health and

environmental issues and are demanding

more openness and information from

companies. We welcome these expectations

and believe that consumer confidence is

essential, not only for the success of our

business, but also for the wellbeing of

society, its citizens and the economy.

We are committed to building consumer

confidence on a strong foundation of

regulation, responsible practices and

transparent communication with consumers,

customers and other stakeholders.

Unilever consistently applies the highest

safety standards around the world, regardless

of where the product is made, sold, or used.

In this report we explain our approach to

ensuring that consumers can have confidence

in our home and personal care products:

CONFIDENCE that they can use them safely.

CONFIDENCE that they will effectively deliver

the benefits they need.

CONFIDENCE that they can trust our brands,

and Unilever, as the company behind

those brands.

Contents

Foreword 1

Being safe 2

Feeling safe 5

The opportunity of GHS 8

Our position in summary 9

Our H&PC partnerships 10

Our home and personal care products are

used every day in millions of homes around

the world. Whether it’s Skip or Cif, Axe or

Dove, people trust our brands – and with

good reason.

We place great emphasis on product safety,

and have a long established track record

of ensuring that our products are safe for

people and for the environment.

Benefits

We gain satisfaction from the fact that

our products have made – and continue to

make – a huge contribution to maintaining

hygiene, health and wellbeing. From

shampoos to moisturisers, detergents to

surface cleaners, our products help people to

improve their quality of life on a daily basis.

familiar and trusted

While our products are used safely millions of

times a day, we have a duty to communicate

to consumers both the benefits and risks of

our products and give advice on their safe

and effective use. We take this responsibility

very seriously.

As a global company, we believe that the

regulations governing safety instructions

for home and personal care brands should

be consistent around the world. It is vital

that consumers are provided with clear and

effective usage advice so that product safety

is guaranteed. It’s important to me that every

one of our consumers knows that a Unilever

product means the optimal combination of

safety and efficacy.

Consumers’ right to know

We are committed to being a transparent

source of information for consumers on

the social, environmental and safety issues

relevant to our brands. This also applies to

the chemicals used in them. Everything we

touch, taste and feel – natural or man-made

– is a chemical, and chemicals enable us

to deliver many of the hygiene and other

benefits that consumers demand.

We fully support consumers’ right to know

about the ingredients in our products and

we are concerned that evidence shows

current hazard warnings and product safety

advice are not always well understood by

consumers and users, particularly in relation

to chemicals. Consumers are better informed

from risk-based labelling which clearly

indicates the safest way to use products.

Clear CommuniCation

The rapid pace of development in science

and technology brings huge potential

benefits but also poses new challenges

for society. Consumers are constantly

bombarded with a mass of information

and mis-information on product and

ingredient safety.

That’s why we believe there is an urgent

need for consumer goods companies to

review and improve communication to

the public on the benefits and safe and

effective use of all products. Clearer and

simplified labelling and greater clarity about

ingredients will ensure that consumers

are better informed. Building consumer

confidence in this way – providing the right

information, at the right time, in the right

place – has positive implications for everyone:

business, civil society, legislators and, most

importantly, our consumers themselves.

Forewordby Ralph Kugler, President, Unilever Home & Personal Care

It is vital that consumers are provided with clear and effective usage advice so that product safety is guaranteed.

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Being safe

There is no question that the starting point for building consumer confidence lies with us, in ensuring day after day, around the world, that our products are safe for people to use.

We place the highest priority on safety

and environmental protection. Of course

we comply with all laws and in several

areas we set our own globally applied

standards higher than the regulations require.

We assess, and regularly re-assess, all our

products thoroughly. We have a long and

proven track record of ensuring that our

products are safe and can be trusted.

our standards

Unilever maintains a set of mandatory

requirements for the use of ingredients

and materials in its home and personal care

products, which are owned by the Global

Senior Vice President for R&D and authorised

by the President of the Home and Personal

Care business. They set restrictions on the

type and level of ingredients we will use and

impurities that we will tolerate.

These standards cover all Unilever home

and personal care products and promotional

items (i.e. items that Unilever places on

the market, or is otherwise responsible for).

They take into account the key regulatory

requirements together with human and

environmental safety factors (including

occupational safety) and are continually

reviewed and updated in light of new

information and developments.

Our standards are an essential internal

reference for product formulators,

specification writers, supply managers

and quality control. This is one of the main

mechanisms which, together with local

technical and regulatory clearance, ensures

that we:

Always meet or exceed any regulatory

requirements.

Apply consistent standards of human

and environmental safety worldwide.

Manage the proactive substitution

of materials when robust, lower risk

alternatives are available.

our safety proCess

Our Safety and Environmental Assurance

Centre (SEAC) ensures that safety and

environmental decisions are made

independently of commercial considerations.

All Unilever products must be approved

by SEAC which plays a continuous role

in assessing product safety from the

first product idea through to a final

rigorous pre-market assessment and

post-launch monitoring.

SEAC also works closely with a network

of experts throughout the company to

make safety an integral part of the design

of new products.

safe for you

We carry out risk assessments to establish

whether products are safe for consumers.

The welfare of vulnerable groups, such

as young children, pregnant women and

old people, is always taken into account.

We keep a constant watch on scientific

developments, review our findings in the

light of new information, and pursue

a deliberate policy of substitution for

products already on the market.

Internationally recognised risk assessment

methods are used to objectively and

impartially assess the safety of our ingredients

and products. Our risk assessments take

into account both the inherent properties of

chemicals (hazard) and the way they are used

(the risk, which is the exposure to the hazard)

to determine if a product is safe.

First, we determine the hazard profiles of

the ingredients in a product and establish

the level at which the ingredients have

‘no effect’. Second, we calculate the level

of exposure to the ingredients (via skin,

breathing, swallowing). This will depend

on the type of product we are assessing

and the amount of each ingredient in the

product. For example, a person’s exposure

to ingredients in a skin cream will be higher

than those in a laundry detergent. In this part

of the scientific risk assessment we also take

into account the possibility of foreseeable

accidents or misuse of the product.

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We then compare the predicted exposure

with the ‘no effect’ level for any potential

hazard. This gives us the margin of safety,

representing the risk for the user. We use

accepted safety factors to assess the safety

of the product, including a separate

assessment for children under the age

of three. If the exposure cannot be safely

managed, we will not market the product.

We also monitor the product in the market

to confirm its safety. We do this by reviewing

feedback from our consumer Carelines and

service groups as well as information from

poison centres.

safe for the environment

We carry out environmental risk assessments

to establish if our products are safe for the

environment. We use accepted scientific

techniques to work out the amount

of ingredients that will end up in the

environment and whether this poses a risk

of toxic effects.

We also estimate the total concentration

of each chemical resulting from all the

different products we make and other

sources. For example, we work with other

companies to assess the total releases of

some chemicals into the environment.

This helps us to determine our own impact

in the context of society’s wider emissions

and the capacity of the environment to

break them down.

promoting Consumer safety

As well as complying fully with all relevant

legislation, we encourage the development

of new laws to enhance consumer safety.

We have actively supported the development

of the new EU legislation on chemicals

known as REACH (Registration, Evaluation

and Authorisation of Chemicals) and we are

reviewing the chemicals we use to ensure

they will comply.

We have also worked hard to help make the

US High Production Volume Chemicals (HPV)

programme a success by taking the lead on

key ingredients which we manufacture and

by providing safety data on other ingredients

to our suppliers.

We believe that such initiatives will not only

help to reassure the public that the chemicals

used in everyday products are safe but also,

by increasing transparency, will help establish

more consistent global requirements for

chemical safety.

Safe concentrationsThe conservative safety factors that we use are well established and accepted by regulators, industry and academic scientists.

They take into account all types of consumers: children, adults, males, females and individuals that may be more sensitive to the chemical than on average.

Safety factors are also applied to environmental toxicity test data to derive safe concentrations for long-term exposure as well as different life stages, species and physiological states.

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Child resistant closuresWe also take a precautionary approach to child resistant closures (CRCs) and sometimes use them where they are not required by legislation, especially:

When a CRC is the market norm for a specific product type

When appropriate safety risk assessment indicates a CRC could improve safety margins

Where the product could cause damage to property – for example, some bleaches

If a product has an unusual degree of child appeal

At the same time, we are aware that, to maintain their effectiveness, it is important only to use CRCs where strongly indicated. Over-use of CRCs could lead to:

Reduced ability of consumers to distinguish between higher and lower risk products

Increased risks to elderly or arthritic consumers who do not reseal the closure so that they are able to re-open it

Children being taught to open CRCs on low risk products and then being able to gain access to high risk items in the home, including medicines

preCaution and suBstitution

We recognise that the science surrounding

chemicals and their impact is sometimes

not fully understood. This is why we apply

both the Precautionary Principle and the

Substitution Principle.

In practice, there are a number of substances

we no longer use:

Well before the adoption of the detergents

regulation in the EU we stopped using

highly branched or structurally complex

surfactants because of their inferior

biodegradability. Nor have we used

alkyl phenol ethoxylates for approximately

30 years.

Preservatives are key ingredients to

ensure product safety. Without them,

products would be susceptible to bacterial

contamination which could result in

poor efficacy and/or an increased risk to

consumer health. Our use of preservatives

is restricted to formulations where self-

preservation is not feasible and there is a

risk of product contamination. Our primary

concern is the safety of consumers and as

such we carefully select our preservatives

and use the minimum level to ensure

effectiveness. Like all of our ingredients,

they are thoroughly assessed for safety

before being used.

In selecting our perfumes, we apply

stringent biodegradability and toxicity

standards which has resulted in a major

screening exercise to ensure sufficient data

is available to support the materials we use.

Our internal standards are indeed tighter

than the fragrance industry norms.

For example:

– We no longer use nitromusks in

our perfumes.

– An environmental risk assessment

of polycyclic musks (PCMs) in the

mid-1990s indicated that European

safety margins were quite small

under specific conditions (for example,

where sewage was discharged untreated

into the environment). There were

also concerns about bioaccumulation.

A voluntary reduction lowered

environmental concentrations and

improved safety margins. We are

now in the process of phasing out

PCMs in our home and personal care

products worldwide.

– When new data led the industry to

reassess the safety of geranyl nitrile,

we began an active programme of

substitution resulting in the majority

of our use being substituted well ahead

of the fragrance industry’s deadlines.

The Precautionary PrincipleFor every new product or change in product we act on the side of caution. If there are uncertainties about whether a chemical or product poses unacceptable risks to the environment or the health of people or animals, we will not put the product onto the market. We also continuously monitor scientific developments and in-field experience and we re-assess our existing products if new information is generated.

Once a product is on the market, we replace safe but hazardous substances if less hazardous substitutes are available which can deliver the necessary benefits robustly and cost-effectively. We also apply substitution to new product launches.

The Substitution Principle

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Hazard Risk management Zero risk? ...Impossible!

Feeling safe

We need to make sure that we communicate

clearly with consumers to help ensure they

understand the benefits and any risks when

they choose our products and that they use

them safely and effectively.

This is a vital part of product safety and,

at the same time, is part of our commitment

to be a trusted source of information for our

consumers. Consumers want to be able to

take our word for it – industry, retailers and

government’s – that products on the shelves

are safe for them to use.

Sometimes they may want more than the

basic information – for example, because

someone in their family has allergies.

And sometimes their confidence may be

shaken by scares, often spread through

the media. They want to be able to inform

and reassure themselves that they are

making the best choices for themselves

and their families. Because being safe is

also about feeling safe.

This is why it is critical to have labels that

tell consumers how to use products safely

and effectively and, just as importantly, tell

them where they can obtain more detailed,

comprehensive information than can be

placed on a label.

responsiBle CommuniCation

In Unilever, we are continuously working to

improve our labels and other communication

channels to ensure that consumers get the

right information at the right time in the right

place to ensure their safety. We also list the

ingredients used in our home and personal

care products typically either on the label or

on our website and we respond directly to

queries received via telephone, letter or via

our websites.

We do recognise that there is more to be

done to earn and build consumer confidence.

Consumer communication and education

is key. Unilever is working with stakeholders

around the world to help to provide

both the impetus and the opportunity to

develop a coherent, consistent framework

to ensure effective and responsible safety

communication. As part of those efforts,

both we, and some of the trade associations

to which we belong around the world, have

conducted workshops with a wide variety of

experts and stakeholders that have yielded

extremely useful findings.

risk-sensitive soCiety

Consumers are more informed and as

risk-sensitive as ever. Therefore the need to

maintain and build confidence and trust has

never been higher.

Concerns about risk do seem to be higher

among younger consumers, and people are

more able to make sensible decisions when

they feel familiar with a risk and how to deal

with it.

Our responsibility does not end with making sure that the products we place on the shelves are safe for people to use. the difference between risk and haZard (no animals were harmed in the making of this cartoon).

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trust

“The key to navigating the risk

communication process lies in paying more

attention to the social amplification of risk

and the role of trust,” according to experts

at the King’s Centre for Risk Management,

King’s College, London.1

Consumers want to trust the products on

the shelves. In other words, they want to

drive the car – they don’t want to have to

look under the hood at the engine.

More transparency may not increase public

trust. But lack of transparency increases

public distrust. This is the challenge for both

industry and authorities. Research shows

that “discussing a low-probability hazard…

may actually serve to increase its imaginability

and thus its perceived riskiness.”2 Yet not

talking to consumers about risk may increase

public distrust if an issue emerges.

perCeptions of everyday produCts

Consumers trust the combination of

benefit and safety that established brands

offer.3 They generally consider home care

products as safe4, but they have developed

a perception of risk associated with common

products, and discriminate between products

they consider low risk (like washing-up liquid)

and high risk (like oven cleaners, highly

flammable products).5

BalanCe Between stakeholders

At the same time, consumers recognise that

knowledge is constantly evolving and know

there may be no black and white answers.

They can therefore be reassured if they can

see an active debate going on over an issue

in which all the main parties are involved,

because then they can see a process taking

place in which each is helping to keep the

other in check.

“At its best, risk communication is not a

top-down communication from expert to the

lay public, but rather a constructive dialogue

between all those involved in a particular

debate about risk.”6

Clarity and relevanCe

Consumers need labels to enable them to

use products safely and effectively. What they

consistently ask for is, not more information,

but clarity: clear advice on the safe and

effective use of a product to get the

desired benefit.

Research shows, time and again, that labels

are not well-read by consumers and current

hazard labels are poorly understood.7

The sheer weight of information available

can make it opaque and confusing rather

than helpful. If there are several warnings

on a pack, the most important ones may

be overlooked.

The brand is a signal of less risk.Consumer, spain9

You lose yourself in too much information. Consumer, france

All we want is structure and simplicity

– it should not be like reading a book.

Consumer, uk

The product itself is not dangerous, it is

what you do with it. Consumer, spain

keystone, risk perception research June 2005

What is natural?There is an enthusiasm for all things natural, often coupled with a feeling that natural materials are in some way safer or preferable to those which are synthetic8.

This can be true but is not necessarily the case. Some of the world’s most toxic chemicals are natural – curare, snake venom, belladonna.

Natural molecules are made up of the same atoms, often stuck together in exactly the same way as synthetic ones. The true measure of safety is how any risks are managed. The best measure we have of sustainability is the total life cycle impact – including any deforestation, fertiliser impact, etc.

In Unilever, we are careful about how and why we will use natural and naturally derived materials and how we will communicate and the advertising claims that we might make. For example:

We aim to protect exotic and endangered species – both plants and animals. It is our objective always to ensure that our materials are derived from farmed/husbanded sources consistent with our sustainability and CSR commitments and policies.

We are objective, risk-based and use Life Cycle Assessment in our raw material and process selection, formulation thinking and as the basis for any environmental improvement claims.

We believe that greater consistency within the industry, starting with agreed definitions and approaches, would reduce consumer confusion.

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1 Rogers, Löfstedt, Coldbeck, 2005, King’s Centre for Risk Management, King’s College, London

2 Slovic et al, 1981, Perceived Risk: Psychological Factors and Social Implications, Proc. R. Soc., London

3 Keystone, 2005, Risk Perception Research – Qualitative Research4 SDA Survey 20065 Keystone, 2005, Risk Perception research6 Löfstedt, 2003, Risk Communication: Pitfalls and promises,

European Review 11(3)7 Keystone, 2005, Risk Perception research8 See also UKCPI publication “Meeting Natural Expectations”9 Keystone, June 2005, Risk Perception research

Consumers want information structured,

so that they can easily access what they

want to know, when they want to know it.

They are asking that we simplify, clarify and

prioritise, as follows:

Usage – what’s it for and how do you use it

Warnings if there are dangers (using icons

and/or text)

Clear company contact details (telephone

number or website)

Poison control centre details if it is a

dangerous product (in countries where

poison control centres exist)

Disposal information including recycling

Unilever’s research gives practical indications

on how to improve clarity in labelling:

by prioritising the information that is more

important and helpful to consumers, and

removing information that is not essential

on-pack, presenting it instead accessibly on

a website, layered for greater clarity, and to

meet the needs of various stakeholders.

Labelling do’s and don’ts

P Keep it simple and clear

P Focus on use not on problems

P Structure the content – separate sections, space

P Use images to draw attention to important points

P Warnings and advice should be fact-based

P Make it clear where to go for extra advice (telephone, internet, leaflets)

O Clutter labels

O Use technical language

O Duplicate information

O Over-communicate on low risk products

O Write on bottom of pack

O Write too small

O Let bar codes get too big

O List unimportant ingredients

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The Globally Harmonised System of

Classification and Labelling of Chemicals

aims to enhance human and environmental

safety by establishing a single, universal

standard and system around the world for

the classification and labelling of chemicals.

Unilever fully supports that goal. We believe

that GHS has the potential to build on existing

chemicals legislation to ensure safety and

build consumer confidence in chemicals,

and in products containing chemicals, by

delivering the right information to consumers

in the right way.

We are committed to help ensure that GHS

succeeds, and we are convinced that, for it to

do so, it must take into account the needs of

its target audience, in particular consumers.

We see the key issues that need to be

addressed in implementing GHS as four-fold:

1) GHS is a uniquely hazard-based system.

GHS labels tell consumers to ‘Be Careful

(this is a fire hazard)’ or ‘Be Careful (this is

corrosive)’ or ‘Be Careful (this could explode)’

etc. That is important, but it is not enough.

Consumers want and need to know, OK,

so how do I be careful? What do I do to

use this product safely? That is risk-based

information. That is, the hazard-based system that is ghs must be married to a coherent, risk-based information and labelling system to give consumers the relevant information on the safe and effective use of products.

2) We are concerned that the classifications

established under GHS are not discriminating

enough. For example, according to GHS

classification, a dishwashing liquid and a

laundry powder would have to carry the

same corrosive / eye damage symbol as

a drain cleaner and use a child-resistant

closure. Used in this way regardless of real

risk, ubiquitous hazard pictograms and / or

hazard statements in home care products

will likely create ‘warning fatigue’. We want

to avoid a situation where consumers are

desensitised to product labels to the point

that they dismiss or underestimate the risks

of high-risk products and do not follow safe

use instructions. it would take only small changes to make a big difference and so avoid the risk of consumers developing warning fatigue and ignoring important hazard warnings on certain products.

3) The use of ‘by default’ classifications

might provide the motivation for unethical

business practices such as placing on the

market non-classifiable products through

dilute formulations and/or compromising

safety testing procedures for products on the

basis of not affecting classification. we are in favour of a regulatory framework for classification and labelling that does not encourage such practices thus contributing to consumer protection.

4) Companies could be motivated to do more

animal testing as a way to ensure accurate

hazard classification under GHS. This is

a risk particularly where innovations are

concerned, including where new technology

is being developed to achieve step change

improvements in areas such as sustainability.

we want to avoid any system that would result in increased animal testing or raise artificial barriers to innovation. we support alternative approaches to animal testing, and the use of human experience data within a robust scientific approach to obtain appropriate classifications for home care products and ensure consumer protection.

The opportunity of GHS

GHS should not undermine consumer confidence built through REACH.dave duncan, Senior Vice President, R&D, Unilever Home and Personal Care

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Clear, effective, consumer-relevant communication

Unilever is strongly committed to ensuring that its products are safe, properly labelled, advertised and communicated since we believe that consumers’ trust and confidence in our brands is vital to sustainable growth and success.

We support the goals of the GHS to facilitate global trade and harmonise different legislative systems.

We believe that responsible communication providing consumers with relevant information on the safe and effective use of products is crucial.

We continue to promote partnership as a route to achieving our goals and believe that multi-stakeholder collaboration is required to establish practical guidelines for the effective provision of relevant consumer information.

We are particularly concerned that new proposals could encourage animal testing in order to avoid over-classification. We believe animal testing should be discouraged by all possible means and not be required to avoid inappropriate labelling in a marketplace where the majority of products have a long history of safe and effective use.

We support the establishment and use of expert bodies to ensure uniformity in classification and to minimise any animal testing requirements. There are models around the world that could be used for this purpose.

We also support the establishment of coherent and co-ordinated monitoring of market experience to provide feedback and trigger any necessary updating of labelling on specific products.

The opportunity of GHS Our position in summary

Designed and produced by Red Letter Design.

Printed by Scanplus on paper made from responsibly managed forests.

Unilever Home and Personal Care

PO Box 68, Unilever House, Blackfriars

London EC4P 4BQ. United Kingdom

www.unilever.com

For more information, please contact:

alan.barber@unilever.com

Unilever’s Home and Personal Care business works in close

partnership with a wide range of research organisations,

trade associations and industry partners on safety and

environmental issues all over the world. Our partnership

activities include:

hera – We are a founding partner in the Human and

Environmental Risk Assessment (HERA) project, a European

voluntary initiative undertaken jointly by the European

Soap and Detergents Industry Association (A.I.S.E.)

and the chemical manufacturers federation (CEFIC).

HERA is effectively a pilot of how targeted risk assessment

can work within REACH, and has now expanded its remit

to risk communication.

swim – In partnership with the UK sustainability

organisation, Forum for the Future and others, we have

developed the SWIM (Sustainable Water and Integrated

catchment Management) principles and guidelines which

have been used to evaluate and focus our current projects

around the world. The principles are based on an integrated

approach to water management that balances competing

demands for water with environmental protection.

produCe – Piloting REACH On Downstream Use and

Communication in Europe is a strategic partnership led by

Unilever and designed to test the workability of REACH in

a practical context involving suppliers, downstream users and

other stakeholders such as NGOs.

epaa – The European Partnership for Alternative Approaches

to Animal Testing is unique partnership between more than

35 companies from 7 different industry sectors and the

European Commission’s services. The EPAA was officially

launched in November 2005. Unilever is committed to the

elimination of animal testing for its business. We are heavily

involved in assessing new methods for health and safety

testing. To this end, we support a vigorous five-year action

programme seeking suitable non-animal alternatives.

us high production volume chemicals programme

– High Production Volume (HPV) chemicals are those which

are manufactured in, or imported into, the United States

in amounts equal to or greater than one million pounds

per year. The HPV programme is a collaborative partnership

whose goal is to ensure that the American public have access

to the information they need to allow them to participate

in environmental decision-making at all levels: federal,

state, and local. Since its inception in 1998, Unilever has

actively contributed to making the programme a success by

taking the lead on key ingredients which we manufacture

and by providing safety data on other ingredients to our

suppliers. Many of the chemicals in the US programme

are also part of the global ICCA (International Council on

Chemical Associations) and United Nations initiative on high

production volume chemicals, which provide a screening

information data set for 14 toxicological and environmental

areas for these key chemicals.

alliance for Chemical education – Unilever is a key

participant in the Alliance for Consumer Education,

a non-profit organisation whose mission is “to promote

responsible and beneficial use of products to ensure a safer,

healthier and cleaner environment in homes, businesses and

the community.” Its core programme areas are: Inhalant

Abuse Prevention, Disease Prevention, Poison Prevention,

and Product Management. Unilever is primarily focused on

preventing inhalant abuse through education and other

communication vehicles.

If you would like to know more about these initiatives or

other Unilever social and environmental activities, please visit

www.unilever.com/ourvalues/environment-society

Our H&PC partnerships