REI, BURTON, AND NEMO EQUIPMENT ACCELERATE TRANSITION TO CLEAN ENERGY

Brands collaborate ​in a challenging market ​to ​advance ​solar energy ​investments ​with suppliers

Clean energy is best achieved by collective action. And that’s exactly what REI, Burton, and NEMO Equipment set out to do through OIA’s Vietnam Renewable Energy Impact CoLab. In collaboration with Allotrope Partners, these brands ideated sustainable solutions and accelerated their transition to cleaner energy. Vietnam is a key manufacturing hub for many OIA members, but its carbon-intensive electricity grid means it is a large source of greenhouse gas emissions. Vietnam’s growing clean energy market has opened the door for financially attractive on-site rooftop solar projects and off-site renewable energy procurement. However, COVID-related supply chain disruptions and evolving regulations have posed significant challenges in the Vietnam renewable energy market. These challenges inspired OIA to launch the Vietnam Renewable Energy CoLab to support members in navigating the challenging renewable energy landscape together. By bringing members together through the CoLab, members and their suppliers could collaborate on shared solutions to more effectively transition to renewable energy.  

“NEMO was excited to partner with Burton, REI, OIA, and Allotrope on the Vietnam Renewable Energy CoLab. NEMO has set a target to reduce our greenhouse gas emissions intensity by 50% by 2030. So far, we’ve achieved a 36% reduction in emissions intensity per product, but to reach our goals, we need to partner with our supply chain. This CoLab is an example of collective action helping to accelerate emissions reductions,” Theresa McKenney, Director of Sustainability and Government Affairs, NEMO Equipment. 

OIA’s Impact CoLabs are collaborative, pre-competitive, emissions reduction initiatives led by OIA and service providers to help members meet their sustainability goals in less time and with less cost by working together. The Vietnam Renewable Energy CoLab focused on accelerating the transition to a sustainable energy future by supporting suppliers with rooftop solar evaluations. The Impact CoLab enabled REI, Burton and NEMO to work collaboratively with suppliers to install 3.5 MW of power across five supplier facilities in Vietnam. 

“In order to achieve REI’s goal of more than halving emissions by 2030, we have to do a great deal of work with partners—from our manufacturing facilities to retailed brands. The CoLab presented an opportunity to engage deeply in that shared work. Our suppliers were able to gain a clear understanding of the “what”, “how” and “why” of procuring rooftop solar electricity in Vietnam”, said Evan Scandling, Supply Chain Decarbonization Lead, REI.

CoLab Results + Impact

The Vietnam Renewable Energy CoLab included five industry suppliers that joined together in an RFP that produced bids for five on-site rooftop systems totaling 3.5 MW, with power purchase agreement (PPA) prices ranging from 8-20% below the buyers’ current electricity rates and covering between 25-35% of the facilities’ electricity needs. Over the life of this project, market conditions have continued to evolve, with government approvals of operating and construction permits emerging as a challenge, along with buyer concerns over their ability to prioritize clean energy procurement during tough financial times. As the supplier facilities continue to work toward clean energy solutions, these proposals serve as a starting point and guidepost for what’s possible. 

Michelle Murphy Rogers, Senior Director of Allotrope’s Clean Energy Advisory Practice notes, “The OIA CoLab process offers an amazing opportunity to explore innovations on renewable energy procurement in a low-risk environment. This project incorporated time and cost-saving approaches to engage project developers and evaluate proposals that can be used in future procurements. Current market challenges in Vietnam underscore the need to work together to pursue new innovations like engaging buyers and developers to pair on-site solar with battery energy storage solutions to maximize system sizes and enhance reliability.” 

“Allotrope was a great partner throughout the project. They worked directly with our supplier to review the process, clearly laid out the evaluation of proposals, and worked hard to overcome challenges in a highly complex regulatory environment. We gleaned valuable learnings from the process”, said Emily Foster, Director of People & Planet Impact at Burton. 

Pre-Competitive Collaboration: OIA’s Impact CoLabs  

Climate change is one of, if not the most, crucial issues the outdoor industry faces today. If there is not a thriving environment to recreate in, outdoor businesses do not have a future. Collaboration is necessary to significantly reduce climate impacts in the outdoor industry; the problem is too large for individual companies to solve on their own. Companies must work together to decarbonize the global supply chain, and OIA provides an avenue with a clear path to do just that. OIA’s Impact CoLabs are collaborative, pre-competitive, emissions reduction initiatives led by OIA and service providers to help members meet their sustainability goals in less time and with less cost by working together.  Through OIA’s six Impact CoLabs, 19 OIA members have invested in collaborative emissions reduction projects across their supply chains – working collectively to maximize impact and protect our planet.  
 

“OIA recognizes that tackling climate action goals and reducing emissions can be a daunting journey for individual member companies. However, we also recognize the power of collective action. If we collaborate, we can move faster and realize significant emissions reductions. Through collaborations such as the Vietnam Renewable Energy CoLab, OIA supports members in making lasting impacts across their supply chains”, said Breana Nehls, OIA Sustainable Business Innovation Manager. “Together, we can be a force for sustainable growth.”

MiiR, Stanley, and YETI’s Bold Collaboration to Reduce Supply Chain Emissions

Three drinkware brands, one mission: protect the planet

Making a significant move to create a more sustainable future, three drinkware brands came together in a first-of-its-kind effort to reduce carbon emissions across the drinkware supply chain. Deemed the Drinkware CoLab, ​ MiiR, Stanley, and YETI, facilitated by the Outdoor Industry Association (OIA), spearheaded this collaboration to reduce the environmental impact of manufacturing. The brands invited four shared third-party suppliers to participate in the project and all parties provided financial and human resources to support the project. The scoped work of the CoLab launched in 2022 and was completed in early 2024.   

The primary goals of the project were to move industry suppliers to 100% renewable electricity and develop facility emissions reduction plans. The project supports OIA’s goal to take bold, collective action against climate change by reducing and removing greenhouse gas emissions across the outdoor industry, carving a new, bold path for others to follow.​ MiiR, Stanley, and YETI participated in the Drinkware CoLab through OIA’s Climate Action Corps, the outdoor industry’s collaborative model to lead on climate action.    

“It was a remarkable experience to work with YETI and Stanley to identify key strategies in reducing our collective footprints. The OIA team did a phenomenal job leading us through this process and we’re excited to get to work on the things we learned. Our hope is that this collaboration inspires other groups in the outdoor space to set aside competition for the sake of sustainability,” said Josh Stinger, Vice President of Supply Chain & Sustainability at MiiR. 

Reduction Roadmaps: Drinkware CoLab Impact

MiiR, Stanley, and YETI collectively nominated four factories and each of the facilities received management training, detailed greenhouse gas measurements of their facility, assistance in setting science-aligned emissions reduction targets, and a customized plan outlining steps to reduce their emissions.  The group identified a global service provider, Environmental Resources Management (ERM), to lead the assessment with each supplier.   

The emissions reduction action plans, or “roadmaps,” provide detailed information on sustainable actions that will improve energy management and reduce emissions. All opportunities were assessed and prioritized based on environmental impact and cost implications for each facility.   

“We know that deep engagement with our suppliers and other stakeholders is critical to ensure that our collective emissions reduction goals are in reach, said Emily Cichy, Senior Director, Corporate Responsibility at Stanley. By collaborating with Outdoor Industry Association, our suppliers, and these esteemed brands, we can help create a more sustainable world.” 

The Trail Ahead

MiiR, Stanley, and YETI are partnering with all four suppliers to ensure these roadmaps are implemented, and are planning to touch base with each other quarterly through OIA to share progress. They are also considering replicating the CoLab process with other strategic suppliers in their networks.  Interested in participating or learning more about CoLabs? Contact OIA at sustainability@outdoorindustry.org 

“The Drinkware CoLab gave YETI the chance to join an industry-wide initiative that aligns with our ongoing sustainability priorities to help keep the wild, wild,” Said Marty Duff, SVP, Supply Chain and Operations at YETI. “We are honored to help drive meaningful progress and help impact broad-based change.” 

Pre-Competitive Collaboration: OIA’s Impact CoLabs

Collaboration is necessary to significantly reduce climate impacts in the outdoor industry; the problem is too large for individual companies to solve on their own. Companies must work together to decarbonize the global supply chain. OIA’s Impact CoLabs are collaborative, pre-competitive, emissions reduction initiatives led by OIA and service providers to help members meet their sustainability goals in less time and with less cost by working together. Learn more about OIA’s Impact CoLabs here.  

 “The Drinkware CoLab provides members the opportunity to take bold, collective climate action. We know that individual companies cannot solve the climate crisis alone, they must come together to create shared solutions to reduce emissions across the supply chain”, said Breana Nehls, OIA Sustainable Business Innovation Manager. “OIA provides this invaluable collaboration space for members to make lasting impacts across their supply chains.” 

OIA Expands Sustainable Business Innovation Programs

OIA Advocates for Sustainability

Sustainability has been central to OIA’s mission since 2007, when the first sustainability working group launched. Since then, our sustainability programming has continued to grow, fostering a culture of collaboration where members take the reins, determine the agenda, invest personally, and encourage partnership without succumbing to competitive barriers. 

Last week at our OIA Sustainability All-Member Webinar, we unveiled several exciting new opportunities for all members to connect and collaborate with peers grappling with similar challenges. Through these collaboration opportunities, we can join hands and address the complexities of chemicals and climate together.  

New Goals: OIA is leading the charge for a sustainable future

CAC Goal 

Take bold, collective action against climate change by reducing and removing greenhouse gas emissions across the outdoor industry, carving a bold new path for others to follow.  

Why the change? CAC’s old goal was to “Become the world’s first climate positive industry by 2030, setting a bold example for others around the world to follow.” While we still stand by this goal in spirit, the sustainability landscape is rapidly evolving. The term “climate positive” is no longer widely used and, in some cases, is even prohibited under certain rules and regulations concerning sustainability claims. Our updated goal reflects the evolving sustainability landscape, the need to align with science, and the focus on greenhouse gas reduction in order to prevent catastrophic climate change.  

CCMC Goal

Blaze the trail in the innovation and adoption of safer chemicals that deliver functional, durable, and trustworthy materials and products to our customers.  

CCMC is approaching its one-year birthday. Chemical regulations continue to progress at a rapid and disjointed rate. However, our members are now more prepared than ever to comply thanks to CCMC’s community and expertise. This goal represents all of the progress that CCMC has made in the past year, and the coalition’s future aspirations for safer chemistry in the industry.  

New Program Requirements 

  • Commit to Program Goals  
  • Share Annual Progress  

New Resources: Our Evolved Offerings for OIA Members

For both CAC and CCMC, we aspire to offer our members:  

  • Guidance – Approachable guidance with the basics of what you need to know in order to make progress towards the program goal.  
  • Trainings – Virtual events to engage and instruct members on addressing chemical and climate impacts.  
  • Tools – Recommended and discounted tools to help you measure your impacts and keep track of important legislative timelines.  
  • Community – Online communities, in-person events, and other opportunities to connect with your industry peers.  
  • Collaboration – CoLabs aimed at specific impact reduction initiatives and Task Forces where members roll up their sleeves to discuss innovative solutions to shared challenges.  

We hope that through these two programs, our members will:  

  • Comply with upcoming regulations  
  • Reduce industry emissions  50% by 2030 and achieve net-zero by 2050 (UNFCCC)  
  • Replace harmful substances with clean chemistry and materials  

New Collaboration Opportunities: Let’s Work Together

As we move towards our sustainability goals, we must move together, as an industry. It’s in this spirit that OIA is launching more collaboration opportunities for our members to investigate challenges, implement solutions, and progress the industry.   

OIA Impact CoLabs: Pre-Competitive 

Existing CoLabs (not recruiting):  

  • Tent Flammability (CCMC) – Change outdated laws in 7 states to no longer require flame retardants in tents   
  • Drinkware (CAC) – Carbon auditing, target setting, and decarbonization action planning for suppliers   
  • Clean Heat (CAC) – Creation of a decision support tool for the electrification of heating in textile plants    
  • Vietnam Renewable Energy (CAC) – Aggregated solar procurement for suppliers in Vietnam    
  • Virtual Power Purchase Agreement (CAC) – Aggregated solar procurement for owned and operated facilities (Scope 2)     
  • Carbon Leadership Project (CAC) – Carbon auditing, target setting, and decarbonization action planning for suppliers  

New CoLab (recruiting):  

  • Developing: Philippines RE (CAC) – OIA is collaborating with Allotrope Partners once again to give members the opportunity to explore clean energy at the Dong In Entech facility in the Philippines  

 

OIA Task Forces 

Task Forces are member-led and member-driven teams dedicated to addressing specific challenges and producing specific deliverables within a set period of time. Here are the task forces OIA is currently offering members: 

  • Aluminum Task Force 
  • Hardgoods Task Force 
  • PFAS Testing Task Force 
  • Supplier Climate Principles Task Force 
  • TSCA Task Force 
  • Sustainability Policy Task Force  
  • Recycled Inputs Task Force  

 

To learn more about OIA Sustainability, visit our OIA webpage, or reach out to sustainability@outdoorindustry.org.  

New EPA Reporting Rule to Require 12 Years of PFAS Data from Manufacturers and Importers

Snowy ascent

By James Pollack, OIA Clean Chemistry and Materials Coalition Legislative Advisor, Attorney at Marten Law

In October 2023, EPA finalized a rule that will require reporting on PFAS in all articles manufactured or imported into the United States from January 1, 2011 to December 31, 2022. You can view the rule here.

The final rule, adopted under the Toxic Substances Control Act, establishes this one-time reporting requirement. Manufacturers and importers of any articles containing PFAS must investigate and certify to EPA the amount of PFAS that they have manufactured or imported into the United States during the reporting period. The specific content of the report for each year will include the following information:

1). Chemical information such as:

a). Chemical identity of the PFAS in the article (the specific chemical name, if known, or otherwise a generic name or description of the PFAS if the specific chemical name is confidential business information or unknown)

b). Chemical identification number

c). Trade name or common name, if applicable, of the chemical

d). Representative molecular structure for any PFAS not in Class 1 of the Toxics Release Inventory

2). Import production volume of the imported article (in units or weight)

3). Industrial processing and use of the article, if any

4). Consumer and commercial use of the article, if any (e.g., product category, functional use of category, maximum PFAS concentration in product, whether children are intended users)

The above information reflects a more streamlined form available to article importers. Domestic manufacturers have a more detailed reporting obligation.

Who is covered under the new PFAS Reporting Rule?

The PFAS Reporting Rule covers nearly all importers and manufacturers. It only offers a narrow set of exemptions for products like pesticides, food, drugs, cosmetics, medical devices, as well as municipal waste importers. Otherwise, reporting is required.

How hard do you have to work to collect this information?

The due diligence standard for collecting information is “to the extent it is known or reasonable ascertainable.” That includes “all information in a person’s possession or control, plus all information that a reasonable person similarly situated might be expected to possess, control, or know.” Manufacturers and importers may also make reasonable estimates based on other information in their possession.  EPA has issued several guidance documents further elaborating the standard.

What can I do about it?

Build a team with the knowledge and skills necessary to engage in this search. Appoint a team leader who can coordinate the search. Include a cross-section of business functions that may have knowledge of where to find relevant information—that may include product designers, supply chain relationship managers, marketers, and IT department members. Bring in outside expertise, including legal support, to help engage in this record search as well as to support in the documentation of the search. Make a comprehensive search plan, and document the search and conclusions in case that information is needed in the future.

What if my suppliers have the information?

It may be the case that your brand does not know the chemical content of your product, even if you know (or suspect) that the product contains PFAS. This can particularly be true for article importers, or those who work with specialized chemical suppliers that use proprietary chemistries. The PFAS Reporting Rule provides an entirely new process for joint reporting where a reporter can identify a relevant supplier that would be better positioned to provide EPA with information on the chemical content of the relevant product. Depending on the results of your due diligence efforts, joint submission may be the best path forward to provide responsive information to the agency.

Will my reported information be made public?

EPA plans to make portions of the information public so that state and federal agencies may set priorities for regulation and to help consumers avoid specific products. Whether or not EPA makes records public on its own, submissions may become subject to public records requests. EPA expects that the PFAS data it collects could potentially be used by the public, including consumers wishing to know more about the products they purchase, communities with environmental justice concerns, and government agencies to take appropriate steps to reduce potential risk. As a result, your brand may consider whether to submit a confidential business information (CBI) claim to protect submitted information.

What is the timeline for complying with this rule?

Overall, about 18 months. The submission period opens on November 12, 2024, with the general submission deadline on May 8,2025. Certain small manufacturers and importers will receive an additional six months to comply.

How can OIA support me?

We at OIA are committed to supporting members as they engage in this reporting process. OIA will keep its membership up to date on any developments and is looking to develop a guide to help brands understand their reporting obligations. Look out for that guide in the coming months.

Need support keeping up with chemical reporting rules and evolving sustainability legislation? Join OIA’s Clean Chemistry and Materials Coalition to access advice from legislative and chemicals experts along with a community of other outdoor brands, manufacturers, suppliers, and retailers working to eliminate and replace harmful chemicals from their supply chains.

About James Pollack

James Pollack is an attorney at Marten Law based in Seattle, WA, whose practice focuses on consumer product regulatory compliance, emerging contaminants, and environmental review. James leads the firm’s consumer products regulatory practice and helps consumer product manufacturers in a wide array of industries that are working to understand the complicated and shifting regulatory and litigation environments surrounding emerging contaminants. He has extensive knowledge on PFAS regulatory compliance at the federal and state level. James’s clients include textile and apparel manufacturers, outdoor recreational product manufacturers, food product manufacturers, and retailers. He also works with industry associations to update membership on regulatory developments.

 

 

 

Read more from James on PFAS:

About James

PFAS PHASE-OUT: 5 KEY STEPS FOR YOUR OUTDOOR BRAND

Can Orange Juice Claim to be Green?

PFAS in Consumer Products are Targeted by State Regulators and Class Action Plaintiffs

What Is in EPA’s Billion Dollar PFAS Reporting Rule?

California Bans PFAS in Apparel, Textiles, Cosmetics

Washington is Latest State to Ban PFAS in Consumer Products 

Regulation of PFAS in Consumer Products 

 

PFAS Phase-Out: 5 Key Steps for Your Outdoor Brand

By James Pollack, OIA Clean Chemistry and Materials Coalition Legislative Advisor, Attorney at Marten Law

Start your brand’s journey to eliminating per- and polyfluoroalkyl substances (PFAS), also known as Forever Chemicals.

You have probably started hearing a lot about PFAS, a large, complex group of synthetic chemicals found in various everyday consumer products like water-resistant clothing and cookware. A combination of regulatory requirements and consumer demand has created growing pressure on sectors worldwide to achieve PFAS elimination. States have proposed hundreds of potential laws and regulations targeting PFAS in a variety of consumer products. Many of these laws will impact outdoor brands that have used PFAS for durability as well as water and stain resistance. Intimidated? Don’t be. Together, we can replace existing products with more sustainable alternatives to provide customers with products that are just as reliable and durable.

1). Assemble your PFAS team

First and foremost, you have to build a dedicated team to effectively tackle PFAS phase-out. For the most comprehensive and holistic approach, I recommend bringing together a diverse group with a multiplicity of perspectives and expertise. While a chemicals expert may understand what needs to change about your product’s material composition, a designer will have insight into how materials fit into the product, marketing will help articulate why and how your outdoor brand is evolving its product, and sales will have to communicate the transition to buyers and consumers alike. Once you have a team assembled, appoint a champion who will take ownership of the initiative and lead it to fruition.

2). Understand the timeline for PFAS legislation

As PFAS chemicals are generally a state legislative issue for the time being, your brand will have to navigate different states with different deadlines for phase-out and elimination. For example, California’s ban on PFAS in textile articles goes into effect January 1, 2025, Vermont’s ban on all PFAS in food packaging, ski wax, and after-market fabric treatments goes into effect on July 1, 2024, and Minnesota’s ban on the sale of cookware, fabric treatments, juvenile products, ski wax, and food packaging with intentionally added PFAS goes into effect on January 25, 2025.

Once you have a grasp on the state regulations that apply to your product categories, it is important to align your product development cycle with upcoming regulatory deadlines.

Pro Tip: CCMC members have access to a constantly updated Regulatory Tracker to ensure members are aware of new and evolving deadlines around PFAS and other harmful chemicals.

3). Work with your suppliers on a PFAS phase-out plan

After aligning your product development cycle with your state’s regulatory timeline, you should work to communicate key deadlines with your suppliers. There’s a good chance that your suppliers are addressing similar requests from other brands and distributors, so leverage their expertise. Ask them about the alternatives to PFAS they’ve been using and the options that exist for sustainable material evolution.

4). Draw on expertise within the outdoor industry

The outdoor industry has a long history of working together to catalyze broader change and drive innovation. As catalysts, we know that we go farther, and faster, when we work together. In addition to your suppliers, you can leverage the expertise of lawyers, labs, consultants, and other outdoor brands to crystalize your PFAS phase-out strategy.

OIA’s Clean Chemistry and Materials Coalition is designed to support retailers, brands, manufacturers, and distributors in a way that is unique to their PFAS phase-out stage. We provide our members with scalable action plans for eliminating and replacing harmful chemicals and materials, delivering supply chain transparency, addressing recycling and emissions disclosures, and more. CCMC members also gain access to a community network of other brands working on the same challenges, and technical and legislative advisors (like myself) who are here to offer support. For more insight into how CCMC can support your brand, watch our introductory webinar.

5). Design and implement your ongoing PFAS and chemical compliance efforts

The last step, of course, is execution. Now that you have a team, a timeline, and a supportive community of peers and experts, it is time to begin the process of altering your products and supply chain to ensure they are compliant with a variety of state sustainability regulations. This may include steps like testing your product’s material composition, obtaining appropriate certifications, and implementing a restricted substance list. It is important to ensure that all your outdoor brand’s products meet regulatory requirements, so I recommend establishing inventory management practices to track different products’ PFAS phase-out life stages.

The path towards PFAS elimination is not linear–nor easy–but if we take one step at a time and work together, we can be catalysts for sustainable growth. If you’re looking for more robust support and a community to lean on, join me and the Clean Chemistry and Materials Coalition.

About James Pollack

James Pollack is an attorney at Marten Law based in Seattle, WA, whose practice focuses on consumer product regulatory compliance, emerging contaminants, and environmental review. James leads the firm’s consumer products regulatory practice and helps consumer product manufacturers in a wide array of industries that are working to understand the complicated and shifting regulatory and litigation environments surrounding emerging contaminants. He has extensive knowledge on PFAS regulatory compliance at the federal and state level. James’s clients include textile and apparel manufacturers, outdoor recreational product manufacturers, food product manufacturers, and retailers. He also works with industry associations to update membership on regulatory developments.

Read more from James on PFAS:

About James

Can Orange Juice Claim to be Green?

PFAS in Consumer Products are Targeted by State Regulators and Class Action Plaintiffs

What Is in EPA’s Billion Dollar PFAS Reporting Rule?

California Bans PFAS in Apparel, Textiles, Cosmetics

Washington is Latest State to Ban PFAS in Consumer Products 

Regulation of PFAS in Consumer Products