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.
ALERT for 3M China Suppliers:
ALERT for All Suppliers: U.S. Customs and Border Protection Legislation; North Korean Labor:
3M, as an importer into the United States, is required to comply with U.S. Customs and Border Protection (CBP) laws and regulations. CBP published the Countering America’s Adversaries Through Sanctions Act (CAATSA) in August 2017. CAATSA prohibits importation under 19 U.S.C. 1307 into the U.S. of goods produced wholly or in part with North Korean labor.
More information can be found on the CBP Website.
3M expects its suppliers to ensure no North Korean laborers are present in their supply chains. If North Korean laborers are present, 3M must be notified immediately.
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.
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:
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 a number of different languages as provided on the 3M Supplier Responsibility Code page. This Supplier Responsibility Code Assessment introductory presentation (PDF, 1.2 MB) can be accessed and/or shared with suppliers to help them better understand 3M’s environmental and social compliance expectations.
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 (75 KB) (form 35664)
For additional information regarding Packaging Legislation, see links below:
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.
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 (146 KB)
3M is committed to respect for human rights in our own operations, in any business that works on our behalf, and in our supply chain. Our global Human Rights Policy applies to all 3M employees, contingent workers, anyone doing business with or on behalf of 3M, and candidates for hire at 3M. In addition, 3M expects its suppliers to be in full compliance with all applicable labor and human resource laws, committed to upholding the human rights of workers, and treating them with dignity and respect as understood by the international community and as stated in our Supplier Responsibility Code.
In 2014, 3M became a signatory member of the United Nations Global Compact (UNGC), thereby committing to align our operations and strategies with the UNGC principles on human rights. Our global Human Rights Policy contains our prohibition on human trafficking. We are committed to using effective systems and controls to prevent human trafficking from taking place anywhere within our business or supply chains. The prohibitions apply to 3M and its subsidiaries, our federal contracts and subcontracts for either commercial or non-commercial items, and all of 3M’s global suppliers.
The California Transparency in Supply Chains Act of 2010 (SB 657) and the UK Modern Slavery Act 2015 require certain businesses to produce a statement setting out the steps they have taken to ensure there is no modern slavery in their own business and their supply chains. Recent disclosure statements 3M has issued can be found below.
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 (254 KB) 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 (206.57 KB) 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.
Please refer to 3M's web page on Sustainable Forestry for more information, including links to our semi-annual Policy Progress Reports.
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 (60 KB) 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 KB) 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 (2.3 MB) 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.
United Nations Supply Chain Sustainability
A Guide to Traceability: A Practical Approach to Advance Sustainability in Global Supply Chains
Legal Harvesting Laws
Products and product packaging supplied to 3M Company must comply with laws related to product content, including laws that prohibit use of illegally harvested timber or plant materials. Laws regarding timber and timber products, such as the United States Lacey Act, the European Union Timber Regulation, and the Australia Illegal Logging Prohibition Act, restrict the sales and imports of illegally harvested timber or products derived from such timber (including paper or paper pulp). These laws also may include "due care" or "due diligence" requirements.
Additional Details on U.S. Lacey Act Requirements
The U.S. Lacey Act was amended in 2008 to prohibit the purchase or sale of products or product packaging in the United States made from wood, paper, wood fiber or other plant materials, with certain limited exceptions, if the plant material was illegally harvested in its country of origin. The Lacey Act has import declaration requirements that are currently in effect for a limited number of wood products. However, the prohibition on purchase or sale of products containing illegally harvested plant materials applies to all products containing plant material.
3M has developed a corporate U.S. Lacey Act Specification. The Specification has additional background on this law, and sets out 3M's expectations for suppliers providing materials to 3M that contain plant material subject to the Lacey Act. See U.S. Lacey Act Specification.
3M's Sourcing Contract Provisions and Supply Chain Policies on Legal Harvesting
3M includes prohibitions on illegally harvested plant materials in new and renewed sourcing contracts. Under 3M's Supplier Responsibility Code and previously 3M's Supply Chain Policies: EHS, Transportation, Labor/Human Resources and Supplied Materials, suppliers are expected to supply 3M materials containing plant materials or their derivatives that are legally sourced, harvested and exported from their country of origin. Suppliers are also expected to adopt policies and management systems with respect to the United States Lacey Act, the European Union Timber Regulation and similar laws (such as the Australia Illegal Logging Prohibition Act), and to require their suppliers to adopt similar policies and systems.
As a supplier to 3M, please become aware of these requirements and take the following steps:
Click here for more information on the U.S. Lacey Act: USDA Animal and Plant Health Inspection Service.
Click here for more information on the EU Timber Regulation.
Click here for more information on the Australia Illegal Logging Prohibition Act.
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:
RPPCs can range in shape, color, size, and form. RPPCs can include, but are not limited to:
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:
Regulations: Title 14, California Code of Regulations (CCR) Chapter 4, Article 3,
Statutes: California Public Resources Code (PRC)
Under EU RoHS, electrical and electronic equipment placed on the European Union market may not contain more than certain levels of:
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 (32 KB)
(*) – Restriction of final products placed on the EU market containing these substances does not enter into force for EEE Category 1-7, 10 & 11 until July 22, 2019 and until July 22, 2021 for Category 8 & 9 products. However, to allow time for parts/products to permeate through the supply chain which must meet these timelines when they are to be placed on the EU market, 3M still expects suppliers to meet this specification.
For more information on the EU RoHS Directive, please see the following link: http://ec.europa.eu/environment/waste/rohs_eee/index_en.htm