Chemours Supplier Code, Responsible Procurement and TfS PCF Framework: Establish Scope 3, fluorochemical, titanium and chemical stewardship controls across speciality chemistry supply chains

What’s Required

Chemours’ supplier framework is a speciality chemicals private regulatory system. It is not only a purchasing code. It is a procurement-controlled governance model designed to align suppliers with environmental stewardship, safety, ethics, human rights, product carbon transparency and responsible chemistry.

The framework is built around:

• Chemours Supplier Code of Conduct.

• Responsible Procurement Programme.

• supplier sustainability resources.

• supplier selection criteria covering risk, sustainability and innovation.

• product carbon footprint data collection using the Together for Sustainability PCF Exchange.

• Scope 3 emissions reduction through supplier and customer collaboration.

• responsible minerals principles and CMRT supplier surveys.

• chemical stewardship and environmental compliance.

• EHS controls for contractors and industrial suppliers.

• fluorochemical and titanium technologies supply-chain management.

• Responsible Supplier Awards and supplier performance recognition.

Chemours states that suppliers are required and expected to adhere to its Supplier Code of Conduct. Its Responsible Procurement page frames procurement as a sustainability lever, with Chemours seeking a sustainable supplier base aligned with environmental stewardship, human rights, ethical behaviour, safe working conditions and zero tolerance for discrimination, fraud and unsafe practices.

1. Supplier Code of Conduct as baseline supplier regulation

Chemours’ Supplier Code of Conduct is the baseline compliance instrument. It is based on the ten principles of the UN Global Compact and sets expectations for suppliers across labour, human rights, environment, anti-corruption and responsible business conduct.

Supplier obligations include:

• compliance with applicable laws and regulations.

• ethical business conduct.

• anti-corruption and integrity controls.

• labour and human rights protections.

• health and safety controls.

• environmental responsibility.

• responsible resource use.

• emissions and waste management.

• accurate documentation.

• cooperation with Chemours procurement and compliance expectations.

This operates as a private regulatory mechanism because Chemours does not treat supplier sustainability as separate from supplier eligibility. Its supplier onboarding materials state that supplier selection considers total cost, quality, risk, sustainability and innovation.

For suppliers, this means cost competitiveness is not sufficient. A supplier can be technically capable but still become commercially weaker if it cannot demonstrate credible sustainability, EHS, responsible sourcing or product-carbon data capability.

2. Responsible Procurement as procurement enforcement

Chemours’ Responsible Procurement programme is the operational layer of the framework. Chemours states that responsible procurement requires more than setting expectations for suppliers. It requires embedding responsible sourcing into the supply chain in ways that reduce environmental impact, uphold labour and human rights, ensure ethical practices and help communities thrive.

Supplier requirements may include:

• Supplier Code acknowledgement.

• EHS documentation.

• sustainability performance information.

• emissions and energy data.

• responsible minerals declarations where applicable.

• environmental compliance evidence.

• labour and human rights controls.

• corrective action plans.

• data supporting product carbon footprint calculations.

• participation in procurement-led supplier improvement initiatives.

Chemours also provides sustainability resources for suppliers, stating that its procurement organisation is committed to building a sustainable supplier base and provides resources to help suppliers improve sustainability performance.

This creates a supplier development and enforcement model. Suppliers are expected to improve performance, not merely sign a code once.

3. Scope 3 emissions and supplier decarbonization

Scope 3 is one of the most important climate implications of Chemours’ supplier framework. Chemours states that reducing Scope 3 emissions requires partnership with suppliers and customers and that value-chain emissions include emissions generated to produce goods Chemours purchases and emissions connected to customer use of products.

Suppliers may need to provide:

• Scope 1 emissions from their own operations.

• Scope 2 emissions from purchased energy.

• raw-material carbon intensity.

• process emissions information.

• product carbon footprint inputs.

• renewable energy evidence.

• transport and logistics emissions data.

• waste treatment data.

• emissions reduction plans.

• data quality and methodology information.

• site-specific or product-specific data where available.

Chemours’ 2024 annual reporting states that reducing Scope 3 emissions will allow the company to partner with suppliers to improve product carbon footprints by reducing upstream emissions, while also reducing downstream emissions through low-carbon solutions such as the Opteon™ portfolio of lower-global-warming-potential refrigerants.

This makes supplier emissions data strategically material. Chemours’ climate strategy depends on upstream raw materials and downstream use-phase impacts, especially in refrigerants, advanced materials and titanium technologies.

4. Product carbon footprint data and TfS PCF Exchange

Chemours’ responsible procurement approach includes product carbon footprint data collection using the Together for Sustainability PCF Exchange solution. Chemours states that the secure platform is intended to improve transparency and accuracy in emissions reporting and help track and manage upstream supply-chain emissions more effectively.

Suppliers may need to provide:

• product-level carbon footprint data.

• cradle-to-gate emissions calculations.

• primary production data where available.

• allocation methodology.

• emissions factor sources.

• energy and fuel consumption data.

• raw-material input data.

• logistics assumptions.

• data-quality indicators.

• methodology alignment with TfS PCF requirements.

This is a major supplier governance shift. Chemours is moving from general emissions estimates toward supplier-specific product carbon data. For speciality chemicals, this is technically demanding because emissions must often be allocated across multi-output chemical processes, shared utilities, co-products and complex raw-material chains.

5. Fluorochemicals, refrigerants and downstream climate impacts

Chemours’ Thermal & Specialized Solutions business includes refrigerants and fluorochemical products. These products create distinctive climate governance issues because downstream use-phase emissions, global warming potential, leakage, product substitution and regulatory transition are material.

Suppliers supporting these value chains may need to provide:

• fluorochemical raw-material data.

• process emissions data.

• containment and safety documentation.

• chemical handling records.

• quality and purity documentation.

• regulatory compliance evidence.

• logistics and hazardous materials information.

• emissions data supporting product carbon footprints.

• data supporting lower-GWP product claims.

The supplier relevance is direct. Chemours’ ability to offer lower-carbon or lower-GWP solutions depends partly on raw-material carbon intensity, process efficiency, regulatory-compliant production and reliable supply of speciality inputs.

6. Titanium technologies, minerals and upstream feedstocks

Chemours is also a major producer of titanium dioxide through its Titanium Technologies segment. Titanium supply chains can involve mineral extraction, mineral sands, chlorination or sulfate route chemistry, energy-intensive processing, logistics and waste streams.

Suppliers may need to provide:

• mineral origin data.

• energy and emissions data.

• mining or processing environmental controls.

• tailings and waste management evidence.

• transport emissions data.

• responsible sourcing documentation.

• occupational safety records.

• chemical input data.

• product quality and traceability records.

Titanium and mineral-linked supply chains create Scope 3 and responsible sourcing exposure. Supplier data is important both for product carbon footprints and for broader environmental risk management.

7. Responsible minerals and CMRT-based supplier surveys

Chemours maintains conflict minerals principles. Its conflict minerals statement says Chemours completes supplier surveys using letters and the Responsible Minerals Initiative Conflict Minerals Reporting Template, and intends to further develop its due diligence programme as tools become available.

Its SEC conflict minerals filing states that Chemours does not directly purchase covered minerals from smelters or mines and works with suppliers to ensure the responsible sourcing of conflict minerals necessary to the production or functionality of its products. The filing identifies tin in relevant products and states that supplier representations were obtained for raw materials containing that mineral.

Supplier obligations may include:

• CMRT completion.

• identification of covered minerals.

• smelter and refiner information.

• country-of-origin data.

• written supplier representations.

• responsible sourcing documentation.

• corrective action for unresolved sourcing risks.

• ongoing updates as due diligence tools evolve.

This is a targeted due diligence framework. It may not apply to every supplier, but mineral-linked suppliers are expected to provide traceability and origin information.

8. Chemical stewardship, EHS and environmental compliance

Chemours’ supplier framework is also shaped by high EHS expectations. The company’s sustainability positioning emphasises responsible chemistry, health and safety, environmental stewardship and manufacturing responsibility.

High-risk supplier categories include:

• raw-material suppliers.

• chemical intermediate suppliers.

• site contractors.

• maintenance and engineering contractors.

• hazardous materials logistics providers.

• waste handlers.

• environmental service providers.

• packaging suppliers.

• industrial equipment suppliers.

• energy suppliers.

Suppliers may need to maintain:

• EHS management systems.

• environmental permits.

• hazardous material handling procedures.

• safety data sheets.

• waste and wastewater controls.

• air emissions documentation.

• worker safety training.

• incident reporting processes.

• emergency response plans.

• contractor safety record

• corrective action systems...

In speciality chemicals, EHS is a procurement gate. A supplier with weak EHS systems can create operational, legal, environmental and reputational risk even if its pricing is attractive.

9. Supplier recognition and performance incentives

Chemours recognises suppliers through the Responsible Supplier Awards. In 2026, Chemours described the awards as recognising partners who move beyond compliance, strengthen sustainability performance, reduce risk and build resilience across the supply chain.

This creates a performance incentive layer.

Recognition can signal supplier strength in areas such as:

• sustainability performance.

• risk reduction.

• supply-chain resilience.

• innovation.

• EHS maturity.

• emissions reduction.

• product carbon data support.

• responsible sourcing.

Supplier recognition does not replace enforcement, but it changes procurement dynamics. High-performing suppliers gain reputational and relationship advantages, while suppliers with weak sustainability performance become less strategically attractive.

10. Data systems and governance architecture

Chemours’ supplier framework requires suppliers to build data systems capable of supporting procurement, PCF exchange, EHS, responsible minerals, Scope 3 accounting and sustainability performance management.

Suppliers need systems covering:

• Supplier Code compliance.

• emissions and energy accounting.

• product carbon footprint calculations.

• TfS PCF Exchange data submission.

• raw-material traceability.

• responsible minerals reporting.

• EHS documentation.

• chemical safety records.

• logistics emissions data.

• waste and wastewater records.

• corrective action tracking.

• audit-ready evidence.

The main compliance risk is data quality. Chemours needs supplier data to support product carbon footprints, Scope 3 accounting, responsible sourcing, customer disclosures and regulatory claims. Weak data systems can reduce supplier competitiveness.

Important Deadlines

Key timelines include:

• 2015: Chemours launched as an independent company following separation from DuPont.

• 2023: Chemours’ 2023 Sustainability Report stated that its global procurement policy and Supplier Code of Conduct underpin supplier expectations.

• 2024: Chemours 2024 Sustainability Report was published in August 2025 and reflected progress against 2030 Corporate Responsibility Commitments.

• 2024: Chemours completed its first Double Materiality Assessment, according to its 2024 Sustainability Report-related materials.

• 2025: Chemours public responsible procurement materials referenced supplier PCF data collection through the TfS PCF Exchange.

• 2026: Chemours recognised Responsible Supplier Awards winners, reinforcing supplier performance incentives.

• 2030: Chemours’ corporate responsibility commitments use 2030 as a key sustainability target year.

• Ongoing: Supplier Code compliance.

• Ongoing: responsible procurement and supplier sustainability resource engagement.

• Ongoing: Scope 3 reduction through supplier and customer collaboration.

• Ongoing: responsible minerals due diligence using supplier surveys and CMRT where applicable.

Current Status

The framework is active and expanding. Chemours has a public Supplier Code of Conduct, Responsible Procurement programme, supplier sustainability resources, responsible minerals principles, Scope 3 supplier collaboration and product carbon footprint data collection through the TfS PCF Exchange.

The framework is strongest in:

• Supplier Code compliance.

• responsible procurement.

• product carbon footprint data collection.

• Scope 3 supplier collaboration.

• responsible minerals due diligence.

• EHS and chemical stewardship.

• supplier performance recognition.

• sustainability-linked supplier resources.

It is especially relevant because Chemours operates in fluorochemicals, refrigerants, titanium technologies and advanced performance materials, where supplier data can affect climate claims, regulatory compliance, product stewardship and customer Scope 3 reporting.

Penalties for Non-Compliance

Enforcement is procurement-driven.

Potential consequences include:

• failed supplier onboarding.

• reduced supplier preference.

• increased documentation requests.

• corrective action requirements.

• exclusion from strategic supplier status.

• reduced sourcing opportunities.

• inability to participate in PCF-enabled product chains.

• loss of recognition or supplier performance advantage.

• contract escalation.

• non-renewal or replacement.

• reputational exposure.

• customer disclosure risk where supplier data is unreliable.

The strongest enforcement mechanism is procurement access. Suppliers that cannot comply with Chemours’ Code, EHS expectations, PCF data requests or responsible minerals requirements become less competitive.

Examples of Known Violations

This analysis does not identify specific public violations by named Chemours suppliers. Realistic failure modes include:

• failure to comply with the Supplier Code.

• incomplete emissions or energy data.

• refusal or inability to provide product carbon footprint data.

• PCF data not compatible with TfS expectations.

• unsupported low-carbon material claims.

• weak EHS systems.

• hazardous material handling failures.

• missing environmental permits.

• incomplete CMRT responses.

• failure to identify smelters or refiners where relevant.

• inaccurate raw-material carbon intensity data.

• poor logistics emissions documentation.

• weak corrective action implementation.

• chemical safety documentation gaps.

These failures can affect supplier eligibility, product carbon accounting, responsible minerals compliance and participation in strategic supplier programmes.

Resources

• https://www.chemours.com/en/supplier-center/responsible-procurement

• https://www.chemours.com/en/supplier-center/becoming-a-supplier

• https://www.chemours.com/en/supplier-center/existing-suppliers

• https://www.chemours.com/en/-/media/files/corporate/supplier-code-of-conduct.pdf

• https://www.chemours.com/en/-/media/files/corporate/sustainability/2024/cc_2024-sust-report_ada_final.pdf

• https://www.chemours.com/en/sustainability/policy-position-statements

• https://www.chemours.com/Chemours_Home/en_US/assets/downloads/PDF/chemours-conflict-minerals-statement.pdf