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Supplier Responsibility Expectations

  • 3M values supplier partnerships where our core values align with empowering ethical growth, inspiring integrity through collaboration and compliance, as well as stewardship of our people, planet and practices. We encourage all suppliers to have a proactive approach in aligning with 3M's policies and programs to strengthen our supply chains and ensure conformance to regulations. By working together, we can achieve business success and uphold our strong, positive reputations.

    It is the responsibility of 3M Suppliers to stay current on applicable laws.

  • Supplier Responsibility Code

    Background: The 3M “Supply Chain Policies” were first established in 2006 to document our expectations for suppliers’ environmental, health, safety, labor and transportation performance. The Supplier Responsibility Code is the “next generation” of our expectations for supplier responsible practices.

    Why this, why now? Over the past decade, expectations for corporations to apply responsible sourcing practices to their supplier network have been expanding in scope and detail. Our foundational requirements for our suppliers must mature to meet these expectations. In addition, 3M became a signatory to the UN Global Compact in early 2014, and this updated set of expectations for our suppliers aligns with the UN Global Compact 10 principles.

    How was this new version developed?  A cross-functional team benchmarked the supplier requirements from many peer companies (multi-national manufacturers of diverse products).   We also consulted guidance from organizations like the OECD and the UN, and recent case studies from consulting firms and not-for-profit sustainability organizations.  Most significantly, we used as a basis for this draft the Electronics Industry Citizenship Coalition (EICC) Code of Conduct, tailoring it to include important aspects of 3M’s existing Supply Chain Policies.  The EICC Code is a well-established, comprehensive Code that is pervasive in the electronics industry, and is increasingly being emulated in other industries.

    What does it cover?  This 3M Supplier Responsibility Code consists of 5 main sections, with some of the more significant updates to our original Policies noted below:

    • Labor – includes more specific requirements and controls for the elimination of forced labor, and more details on appropriate working hours and time off.
    • Health & Safety – includes specific requirements for emergency exits, fire protection, and worker housing (when provided).
    • Environment – includes expectations on reducing environmental impacts, and protecting air, water, and land resources.
    • Ethics – this is a new section, mirroring 3M’s Code of Conduct positions on anti-bribery, conflicts of interest, protection of intellectual property, and related Business Conduct issues.
    • Management Systems – another new section, requiring strong policies and systems to control the aspects in the previous sections, and propagate the requirements up the supply chain.

    How will we implement?  New and renegotiated supply contracts and PO terms will reference the new code.  Existing contracts will not be re-negotiated solely for this change.  Our supplier assessment program is being updated to match the Code expectations.

    The 3M Supplier Responsibility Code is available in 8 languages (English, French Canadian, German, Japanese, Mandarin Chinese, Portuguese, Spanish, Taiwanese Chinese).

    Access the 3M Supplier Responsibility Code.


  • Heavy Metals in Packaging

    3M is committed to compliance with all laws, including those relating to “Heavy Metals” in packaging. “Heavy Metals” are lead, mercury, cadmium and hexavalent chromium.

    Packaging suppliers are required to minimize heavy metals in packages and packaging materials under both the European Parliament and Council Directive 94/62/EC on Packaging and Packaging Waste (“Directive 94/62/EC”) and the United States laws enacted by various states under the Coalition of Northeastern Governor (“CONEG”) Model Toxics in Packaging legislation, including the California Toxics in Packaging Prevention Act, which requires suppliers to provide to their purchasers Certificates of Compliance with that law.

    Suppliers to 3M that deliver finished packaged products are also required to follow the Essential Requirements outlined in Annex II of Directive 94/62/EC.

    Please see 3M Corporate General Specification 180 on heavy metals in packaging, found on 3M.Com Partners and Suppliers / Packaging which includes additional background and 3M's requirements for its suppliers regarding the heavy metals content of packaging and packaging components.

    We are sure that your company, like 3M, is committed to compliance with all applicable laws.

    PDF Document Heavy Metals Certificate (75KB) (form 35664)

    For additional information regarding Packaging Legislation, see links below:

    Toxics in Packaging Clearinghouse

    Summaries of the European Union Regulations

  • Conflict Minerals

    Background. Armed groups operating in the eastern Democratic Republic of the Congo (DRC) have controlled many of the region’s mines or transit routes and have engaged in armed conflict, as well as some of the world's worst human rights violations. Concern that proceeds from the mining of minerals have been used to fund extreme violence in that region led to a requirement in the U.S. Dodd-Frank Financial Reform Law of 2010, that U.S. publicly-traded companies must disclose any "conflict minerals" necessary to the functionality or production of products they manufacture or contract to manufacture. The conflict minerals are tin, tungsten, tantalum and gold (called the 3TG's). Companies using conflict minerals must also disclose their supply chain inquiries to verify whether these minerals originated in the DRC or adjoining countries.

    On August 22, 2012, the SEC approved the final rule on conflict minerals. All public companies must evaluate their product lines to determine whether they contain necessary conflict minerals and if so, file a Form SD by May 31 annually beginning in 2014, for products they manufacture or contract to manufacture in the year 2013. While the burden of compliance is on the public companies who manufacture those products, members of their supply chains for those products are also impacted.

    PDF Document Text of the U.S. Conflict Minerals Law (50KB)
    Conflict Minerals - SEC Small Entity Compliance Guide
    PDF Document Text of the final Conflict Minerals Rule - Fed Register (1.19MB)

    3M's Conflict Minerals Policy. 3M deplores the violence in the DRC and adjoining countries and is committed to supporting responsible sourcing of conflict minerals from the region. Accordingly, 3M has adopted a conflict minerals policy, as part of 3M's Supply Chain Policies: EHS, Transportation, Labor/Human Resources and Supplied Materials. 3M expects its suppliers to adopt a similar policy and to meet the expectations set out below.
    PDF Document 3M Supply Chain Policies, including on Conflict Minerals (201KB)

    3M's Form SD and Conflict Minerals Report
    Form SD
    Conflict Minerals Report (EX-1.01)

    3M's Expectations for Suppliers.

    • Supply "DRC Conflict Free" materials. Under 3M's conflict mineral’s policy, suppliers are expected to supply materials to 3M that are "DRC conflict free," which means either: 1) any 3TGs necessary to the functionality or production of supplied materials must not directly or indirectly fund armed conflict in the DRC or adjoining countries, or 2) any 3TGs must be from recycled or scrap sources.
    • Adopt conflict minerals policies. Suppliers to 3M must adopt a policy regarding conflict minerals consistent with 3M's policy, implement management systems to support compliance with their policy and require their suppliers to take the same steps.
    • Send surveys to their suppliers, and complete 3M's survey. 3M suppliers are expected to pass the CFSI public Conflict Minerals Reporting Template (link below) to their suppliers and successively upstream until the smelter/refiner is identified. The survey information must then be passed back down through the levels of the supply chain to 3M's direct supplier, who then can complete 3M's internet-enabled version of the Conflict Minerals Reporting Template linked from this Supplier Regulatory eEnablement (SREE) website.
      Important Note: Contacted suppliers are asked to complete both Parts 1 and 2 of 3M's survey as instructed in the covering e-mails.

    CFSI public Conflict Minerals Reporting Template for use by 3M's suppliers with their supply chain

    Conflict Free Smelter program, smelter lists

    Extending Support. 3M is a member of the Conflict Free Sourcing Initiative (CFSI), an industry-wide initiative to develop practices and control systems regarding smelters and refiners through independently validated audits under CFSI’s Conflict Free Smelter (CFS) program. 3M encourages its suppliers not already members to join the CFSI. Increased participation throughout supply chains will strengthen collaborative efforts to increase leverage on smelters and refiners to join the CFS program and thereby become validated as DRC Conflict Free.

    3M encourages its suppliers to responsibly source 3TGs from the DRC and adjoining countries through smelters or refiners validated as DRC Conflict Free through the CFS or similar programs.
    Link to CFSI website:

    For more information on 3M Sustainability and Conflict Minerals, including a link to 3M's Form SD and Conflict Minerals Report, see Working With Suppliers.

    * Conflict minerals are from "recycled or scrap sources" if they are from recycled metals, which are reclaimed end-user or post-consumer products, or scrap processed metals created during product manufacturing. Recycled metal includes excess, obsolete, defective and scrap metal materials that contain refined or processed metals that are appropriate to recycle in the production of tin, tantalum, tungsten, and/or gold. Minerals partially processed, unprocessed, or a "bi-product" from another ore are not included in the definition of recycled metal. Item 1.01(d)(6) for Form SD, 77 Fed. Reg. 56274, 56364 (Sept. 12, 2012).

  • Counterfeit Goods

    3M is a worldwide leader in innovation and quality. To deliver best value, cutting edge products, 3M maintains a dynamic, worldwide supply chain. As with any global supply chain, there is risk that counterfeit materials, parts, components and assemblies may be introduced. The presence of counterfeit material could adversely impact 3M’s ability to meet customer expectations and expose 3M to penalties, fines, damages and other serious adverse consequences. Accordingly, 3M has established a Counterfeit Material Control Plan to ensure compliance with customer anti-counterfeit requirements, the evolving laws in this area and to ensure the overall quality, compliance and reputation of 3M’s diverse, innovative product lines.

    3M Expectations of Suppliers
    As part of 3M’s Counterfeit Material Control Plan, 3M has implemented a minimum set of risk-based counterfeit mitigation measures for all product lines, including measures relating to products and materials provided to 3M by suppliers. These measures are reflected in the Counterfeit Goods Provisions referenced below and are in addition to any other counterfeit goods requirements specified in a written agreement with 3M or provided to a supplier by 3M.

    Counterfeit Goods Provisions
    The following provisions apply to any purchase order for goods issued by 3M Company or its affiliates and to products provided to 3M or its affiliates pursuant to a written agreement:

    PDF Document Counterfeit Goods (146KB)

  • Pulp and Paper Sourcing

    Why Forests and Responsible Supply Chains are Important

    Forests are used by people around the world for recreation, cultural significance, health and livelihood. They are home to many species of plants and animals, their trees capture and store atmospheric carbon, and they support vital services like clean water. These complex ecosystems are valuable resources that should be responsibly managed and preserved for future generations. 3M does not support natural forest degradation or conversion to non-forest use. We support the protection of indigenous peoples’ rights to offer Free and Prior Informed Consent (FPIC) to harvesting operations on their land, and of workers’ safety and other basic rights.

    At 3M, we are guided by our values; they are woven into the very fabric of our company culture. We act with uncompromising integrity. We respect our social and physical environments around the world. We share our sustainability values with our customers and stakeholders. 3M wants to work with the best suppliers who share these commitments to sustainable forests and responsibility in all stages of the forest products supply chain.

    The 3M Pulp and Paper Sourcing Policy

    The PDF Document 3M Pulp and Paper Sourcing Policy (254KB) formalizes our and our supply chain’s responsibilities to comply with global regulations, and further the causes of sustainable forestry and transparent, responsible supply chains.

    We expect our pulp and paper suppliers to read, understand and implement the expectations in our Policy. The companion PDF Document Policy Conformance Guidance Document (206.57KB) contains definitions and additional explanation of many of the important concepts in the Policy. 3M will also provide our suppliers additional information and opportunities for education and engagement.





    3M’s Expectations for Suppliers

    Legality: 3M expects that all pulp, paper and packaging supplied to us contains wood or plant-based fiber that is legally harvested, sourced, transported and exported from its country of origin. Please see the Legal Harvesting Laws on this page for more information on these expectations.

    Traceable to Forest Source: 3M expects suppliers to know their own supply chains, and respond to our requests for material traceability information in a complete and timely manner. Understanding our forest products supply chain, including paper and pulp mills and forest sources, is fundamental to ensuring Policy conformance. We depend on our direct suppliers to understand and disclose their supply chains to us, so that together we can ensure Policy conformance and drive responsible sourcing and sustainable forestry.

    Due Diligence Management System: 3M expects our suppliers to adopt company policies and a due diligence management system approach to address responsible forest products sourcing and sustainable forestry. We also expect our suppliers to work with their suppliers to adopt similar policies and management systems. 3M has created a Word Document due diligence management system template outline (59.5KB) for our suppliers' use if they choose, and which can be shared with their suppliers.

    Certification: 3M expects our suppliers to know the forest certification status of the material they purchase and of the entities in their supply chain, and to disclose certification information to us upon request. 3M’s policy expectations and guidelines are consistent with many forest certification standards, but our Policy does not require certification. Certification in and of itself is not the objective of our Policy, but it is one useful tool to help verify what is happening on the ground. Please refer to this PDF Document forestry certification overview (513.30KB) for more on how we believe our Policy compares to the major global forestry certification schemes.

    Collaboration: 3M expects our suppliers to work together with us and their suppliers to ensure Policy conformance and promote responsible and transparent supply chains. We recognize the integral role that our suppliers play to source and produce the materials required for 3M products, and we know that collaboration and transparency depend on a foundation of mutual trust. Through our Pulp & Paper Sourcing Policy, we wish to harness the power of our supply chain to achieve real, positive change for the world's forests.

    Conformance: 3M expects our suppliers to be forthcoming in their opportunities for performance improvements for themselves or their suppliers, and in cases where conformance cannot immediately be demonstrated, we will support suppliers that are working on timely and reasonable progress towards conformance. If a supplier won’t work with us or change their practices to conform, 3M will seek alternative sources of supply.

    Refer to this PDF Document presentation (PDF, 2.3M) for additional information on the 3M Pulp and Paper Sourcing Policy.

    How Policy Conformance Benefits 3M Suppliers

    The business climate is continually changing and evolving. Not only are more customers interested in understanding where their products come from, but governments around the world, through laws and regulations, are requiring product producers to know more about the sources of their raw materials. Products that can be traced to responsible sources will help your business comply with regulations and protect your reputation, and can be a differentiation factor in retaining existing business and earning opportunities for new business.

    Together, we can support sustainable forestry and responsible, transparent supply chains.

    Additional Guidance

    United Nations Supply Chain Sustainability
    A Guide to Traceability: A Practical Approach to Advance Sustainability in Global Supply Chains

  • Rigid Plastic Packaging Container (RPPC)

    California's Rigid Plastic Packaging Container (RPPC) law was enacted in 1991 as part of an effort to reduce the amount of plastic waste disposed in California landfills and to increase the use of recycled postconsumer plastic. The law mandates that product manufacturers that sell products held in RPPCs meet one of the compliance options identified in the regulation.

    3M is committed to compliance with all laws, including those relating to Rigid Plastic Packaging Container (RPPC). RPPC generally means a packaging container that:

    • is made entirely of plastic (except for incidental portions of the packaging),
    • has a relatively inflexible shape or form,
    • has a minimum capacity or volume of eight (8) ounces up to a maximum capacity or volume of five (5) gallons,
    • is capable of at least one closure (including closure during the manufacturing process).

    RPPCs can range in shape, color, size, and form. RPPCs can include, but are not limited to:

    • Buckets
    • Tubs
    • Pails
    • Tubes
    • Cartridges
    • Jugs
    • Bottles (wide mouth and/or narrow neck)
    • Clamshells (heat-sealed and/or reclosable)
    • Plastic Folding Cartons

    RPPC legislation requires Packaging component suppliers to provide Certificates of Compliance with California law as required by Title 14 of the California Code of Regulations. We are requesting that as a supplier to 3M you provide all Container Manufacturer Certification Information as required under Section 17945.4 of Title 14, California Code of Regulations (CCR) for the package component numbers provided.

    We are sure that your company, like 3M, is committed to compliance with all applicable laws.

    For additional information regarding RPPC Packaging Legislation, see links below:

    California's Department of Resources Recycling and Recovery (CalRecycle)

    Regulations: Title 14, California Code of Regulations (CCR) Chapter 4, Article 3,

    Section 17942-17946

    Statutes: California Public Resources Code (PRC)

    Section 42300-42301

    Section 42320-42327

    Section 42330

    Section 42340-42345

  • RoHS Specification

    3M Company has developed a corporate EU RoHS Specification which sets forth 3M's expectations for suppliers providing materials to 3M that may be subject to the requirements of the European Union's Directive 2002/95/EC, Restriction of the use of certain Hazardous Substances in Electrical and Electronic Equipment, as amended, and/or the substance restrictions of the recast RoHS Directive 2011/65/EU, Annex II, jointly known as "EU RoHS."

    Directive 2002/95/EC as amended is repealed on January 3, 2013. Directive 2011/65/EU is in effect as of that date.

    Under EU RoHS, electrical and electronic equipment placed on the European Union market may not contain more than certain levels of:

    • Lead
    • Mercury
    • Cadmium
    • Hexavalent Chromium
    • Polybrominated biphenyls (PBBs) (flame retardant)
    • Polybrominated diphenyl ethers (PBDEs) (flame retardant)

    Other countries around the world are considering and/or have implemented regulations that are similar to EU RoHS.

    The 3M EU RoHS Specification applies to all materials, parts, components and/or products (whether finished or semi-finished) that include restrictions on the EU RoHS substances listed above or that have this specification cited on or in their 3M part number drawing, part or product specifications, sourcing agreements, purchase contracts, purchase orders or other purchasing documentation.

    Here is the PDF Document3M Corporate EU RoHS Specification (32KB)

    For more information on the EU RoHS Directive, please see the following link:

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