Product Quality and Safety

Significance

Importance To Berry Global and our Stakeholders

Maintaining a high standard of product quality and consumer safety is core to our business. We adhere to rigorous quality control measures to ensure our products meet customer standards, reducing the risk of a customer quality complaint and any potential associated costs. Ensuring a high level of quality, especially first-pass quality, also reduces operational inefficiencies, which improves profitability. We also adhere to rigorous product safety measures, ranging from a Restricted Substances List (RSL) for our raw materials to following good manufacturing practices in our raw material handling. This is first and foremost to protect consumers. It also reduces potential legal and financial liabilities.

Our Customers: Customers depend on us for the products we produce for them. They expect a high level of product quality and safety to protect their customers, keep their lines functioning properly, protect their reputations, and prevent costly recalls.

Our Investors: We are expected to maintain a high level of product quality and safety to prevent the costs associated with producing defective products and reputational costs that could harm the value of our stock.

Our Approach

We are dedicated to assuring that every product we market can be safely used, and we have programs and processes in place to fulfill this responsibility. Our regulatory department has a lead role in ensuring the safety and compliance of all raw materials that are selected for use in our products.

Every company making products that are put into the market has the obligation to assure that their products are safe for their intended purpose, and every person or company buying goods expects that appropriate safety work has been done behind the scenes and underlie decisions to put products into the market. Berry Global endorses this obligation; our product safety management program ensures that we develop products and product solutions that are safe, compliant, and reliable, and we document the underlying basis.

Key Metrics

The below metrics are based on Berry's Fiscal Years unless otherwise noted.

Key Strategies

Product Safety Management

We have a robust Product Safety Management Program that ensures the safety and compliance of all raw materials selected for use. The program includes guidelines for: aggressively managing chemical safety, regulations for finished goods, product testing, certifications, management of change, global regulatory monitoring, and the deselection of the restricted substances noted in our RSL.

A full outline of our Product Safety Management Program can be found in our Product Safety and Quality Management Policy.

2023 Highlights

• Fifty percent reduction in purchases of polyethylene (PE) resin containing per- and polyfluoroalkyl substances) (PFAS) in our Flexibles Division in North America.
• To promote and support increasing use of Post-Consumer Recycled Plastic (PCR), we developed a PCR Due Diligence program which standardizes Berry’s acceptance criteria for PCR suppliers.

2022 Highlights

• Expanded Substances of Interest (SOI) testing program.
• Completed full chemical disclosures for entire wipes portfolio.
• Documented all products containing substances that require a California Proposition 65 disclosure.
• New PCR supplier development role expands our ability to purchase approved PCR by partnering with our PCR suppliers to improve their understanding of our requirements and regulatory knowledge.
• Increased the number of nonwoven manufacturing sites with the OEKO-TEX 100 Certification.

Restricted Substances

We implemented our universal RSL to help guide sustainable product development activities. Materials restricted from purchase and use include raw materials containing conflict minerals, heavy metals, Substances of Very High Concern (SVHC), natural rubber latex, ozone-depleting substances (ODS), Perfluorooctanoic acid/ Perfluorooctane sulfonate (PFOA/ PFOS), and Hazardous Substance (RoHS) chemicals. Raw materials containing California Proposition 65 listed substances are subject to internal controls, including appropriate risk mitigation steps that meet desired functionality for alternate materials, finished good testing to confirm the presence or absence of the listed substance, and exposure modelling, where applicable.We also encouraged the use of Roundtable on Sustainable Palm Oil (RSPO) feedstock in products containing palm oil or palm kernel oil derivative (e.g., as a stabilizer). In addition to meeting our restriction requirements for raw materials, we also conformed to customer specific RSL conditions. This combination of internal and external requirements allows us to meet the varied needs of our customers. Our RSL Policy is publicly available.

Case Study – PFAS

Recently there has been much attention to PFAS. While PFAS is primarily used in the packaging industry to provide water and grease resistance to paper packaging, the plastic packaging industry does use PFAS in some applications. Berry’s primary use is fluorinated polymers incorporated into supplied raw materials as processing aids for PE film that could be considered under the broad umbrella of PFAS.

Fluorinated polymers have a high molecular weight, which means they are unlikely to migrate from our products and affect consumers. However, we recognize the potential upstream risk of fluoropolymer production as well as the general concerns around PFAS as “forever chemicals” that are unlikely to degrade over time and could feasibly bioaccumulate. For these reasons, we have begun phasing out our use of fluorinated processing aids ahead of potential regulation requiring us to do so.

In 2022, our Flexibles division began asking PE suppliers intentionally adding fluorinated processing aids to the resin they supply us to begin identifying and qualifying alternatives. In early 2023, we began qualifying these PFAS-free alternatives internally and with customers. By the end of 2023, we should have roughly 80% of this conversion complete in North America. We are leveraging these learnings to other regions and other applications where we hope to make similar progress, ahead of regulation requiring elimination.

Where else is PFAS used?

Outside of PE film, our next largest use of PFAS is in our Health, Hygiene & Specialties division. In medical nonwovens, we use PFAS to coat some gowns and drapes used in operating rooms to repel blood and other liquids. At this time, an acceptable alternative has not yet been identified.

A much smaller amount of PFAS has been identified in other raw materials, including a small fraction of the total colorants we use. At this time, we are prioritizing elimination in our highest volume applications, although we are engaging suppliers of smaller volume applications to eliminate PFAS ahead of regulation.

Quality Management Program

We have a customer-focused quality management program, committed to providing responsibly sourced, high-quality, innovative products to our customers. Our skilled employees work together to deliver high-quality products that meet the practical, sustainable, and regulatory needs of our customers. We set annual goals, monitor the product regulatory landscape, and respond to changing market dynamics. In addition, we maintain the highest possible standards of product stewardship to help ensure the safe and responsible use of materials and enhance product quality through design and development.

As part of our ambition to achieve continuous improvement in all aspects of product development, we encourage our facilities to participate in global quality system standards and achieve third-party certifications, such as ISO 9001, FSCC 22000, and SQF.

Disclosures

Contribution to the Sustainable Development Goals (SDGs)

SDG 3: Good Health and Well-Being

With a rigorous product quality and safety program, we safeguard consumer health to assure the safety of products and mitigate potential risks associated with substandard or unsafe products

SDG 8: Decent Work and Economic Growth

Our business relies on our ability to consistently produce reliable and safe products. This continued success helps us preserve jobs and livelihoods in our operations and across the manufacturing supply chain, enabling continued economic growth.

SDG 9: Industry, Innovation, and Infrastructure

Our commitment to producing high-quality, safe products amplifies responsible industry practices, driving further innovation and infrastructure development across the supply chain.

SDG 12: Responsible Consumption and Production

Our high-quality products are designed with the circular economy and responsible growth at the core. Durable, reliable, and safe products last longer, meeting customer specifications and eliminating potential waste. 

GRI and SASB Alignment

GRI 2-27 Compliance With Laws and Regulations
GRI 416(3-3) Customer Health and Safety
GRI 416-1 Assessment of the Health and Safety Impacts of Products and Service Categories
GRI 416-2 Incidents of non-compliance concerning the health and safety impacts of products and services
SASB RT-CP-250a.1 Number of Recalls Issued, Total Units Recalled
SASB RT-CP-250a.2 Discussion of Process to Identify and Manage Emerging Materials and Chemicals of Concern

Last updated: December 14th 2023