Authors: Dr. Tricia Underwood & Kenny Unice | February 23, 2026

TRC’s tested practitioners provide the answers organizations need to go from reactive compliance to proactive leadership

As regulatory expectations, customer scrutiny and supply chain complexity continue to rise, product stewardship has emerged as a critical business capability. Once viewed primarily as a regulatory concern, product stewardship today sits at the intersection of sustainability, risk management, innovation and brand strategy.

In this Q&A, TRC’s Tricia Underwood and Kenny Unice explore what product stewardship really means, why it matters now more than ever and how organizations can move from reactive compliance to proactive leadership across the product life cycle.

Q: What is product stewardship?

A: Product stewardship is a cross-functional business leadership process that transforms regulatory and environmental requirements into competitive advantages. It is a management strategy in which producers, sellers, consumers and disposers share responsibility for a product’s entire life cycle.

This approach encompasses ethical sourcing, traceability of eco-friendly materials, compliance with regulatory standards and assessment of environmental and human health impacts from raw material extraction through end-of-life. When implemented effectively, product stewardship aligns environmental responsibility with core business objectives.

Q: Why is product stewardship becoming more important?

A: Societal expectations for corporate responsibility have accelerated dramatically from basic pollution control in the 1970s to today’s extended producer responsibility (EPR) mandates. EPR policies increasingly require manufacturers to manage products through end-of-life, including collection, recycling and disposal costs.

Leading companies now recognize product stewardship as a competitive differentiator. By reducing environmental and human health impacts across the product life cycle, stewardship strategies also reduce waste, improve efficiency and strengthen resilience. With executive sponsorship, proactive product stewardship helps companies mitigate supply chain disruptions, avoid unexpected compliance costs, protect brand reputation, and convert regulatory requirements into market advantages. 

Q: How does product stewardship differ from traditional compliance or EHS programs?

A: Traditional compliance and EHS programs define what companies must do to meet regulatory and safety requirements. Product stewardship explains how companies proactively achieve environmental and human health outcomes.

While facility-level EHS compliance remains a baseline requirement covering workplace safety, permits and emissions, product stewardship is externally oriented. It manages reputation risk across the value chain, responds to customer inquiries about product ingredients and sourcing and ensures products meet evolving regulatory and market expectations. In short, companies establish goals through compliance and environmental programs, but product stewardship is the action required to reach them.

Q: What are the key challenges companies face when implementing a product stewardship strategy?

A: One of the biggest challenges is navigating complex, global supply chains alongside constantly evolving regulations that vary by jurisdiction. Staying current requires ongoing vigilance and technical expertise.

Another critical but often overlooked barrier is cross-functional communication. Marketing, sales, legal, operations, customers and regulators all operate with different priorities and vocabularies with a focus on different risks. Effective product stewards act as connectors and translators, aligning technical requirements with business strategy, integrating customer expectations into operational decisions and driving proactive responses to regulatory change rather than reactive scrambles.

Q: What pitfalls do manufacturers face when considering product stewardship?

A: Product stewardship applies to all parties involved, including manufacturers. The most critical pitfall for manufacturers is treating product stewardship solely as a compliance cost rather than a value-creating investment. Without clear business metrics demonstrating avoided risks and captured opportunities, stewardship programs can struggle to secure resources and executive support.

Manufacturers must also manage varying customer compliance requirements across jurisdictions and maintain transparency about chemicals used in production. Successful product stewards leverage cross-functional expertise to define measures of success across input metrics (resources and scope); performance metrics (quality and quantity of work) and business value metrics (protected revenue, avoided costs, brand value and competitive positioning).

Q: What role does supplier engagement play in a successful product stewardship program?

A: By fostering transparency and accountability, supplier engagement is foundational to effective product stewardship. Accurate information on materials, sourcing and production enables better risk assessment and supports sustainability goals. Strong partnerships also encourage innovation, waste reduction and continuous improvement in upholding environmental and ethical standards.

An effective product stewardship program strengthens trust across the supply chain by balancing technical requirements with the commercial realities that shape how information is shared. One of the most common hurdles in supplier engagement is managing confidential business information. Suppliers may be reluctant to disclose detailed formulation data, process specifications, or sourcing relationships because of competitive sensitivities, while manufacturers require sufficient transparency to anticipate emerging regulatory obligations and assess risk.

Product stewards play a critical intermediary role. They design frameworks that safeguard proprietary information while ensuring access to the data necessary for safety evaluations and compliance. This often includes tools such as aggregated data reporting, carefully structured confidentiality agreements, and third-party verification mechanisms that enable transparency without compromising competitive advantage.

Q: What is the best advice for companies just starting their product stewardship journey?

A: The most successful companies frame product stewardship as a competitive advantage. Rather than viewing chemicals as compliance challenges, they treat them as opportunities to differentiate their brand, strengthen supply chain communication and design sustainable, cost-effective products.

Communicating the criticality of performance requirements balanced with sustainable design is an often overlooked but important component of effective product stewardship. Product stewards must be able to explain why substitutes deliver equivalent or superior performance, how they integrate into existing manufacturing processes and how they create for customers. Technical competence alone is not enough; translating data into compelling business narratives accelerates adoption, builds durable competitive moats and helps to avoid regrettable substitutions.

Q: How can responsible AI adoption and data analytics enhance product stewardship programs?

A: Companies are increasingly using generative AI, machine learning and advanced analytics to improve traceability and transparency across the product life cycle. These tools help identify raw material origins, monitor supply chain risks, support ethical sourcing and enable faster, evidence-based decision-making.

Machine learning models can process vast volumes of supplier data, regulatory updates and material composition information to detect patterns and emerging risks across global supply chains. However, effective implementation requires strong governance that addresses data quality, algorithmic transparency, human oversight and auditability. AI itself also requires stewardship, including data privacy protections, mitigation of algorithmic bias and management of computational environmental impacts.

Q: What does the future of product stewardship hold?

A: As the circular economy grows, life cycle considerations will be integrated into business strategy and product design from the outset rather than addressed reactively. AI-enabled tracking systems will increasingly support sustainable design, material recovery and waste reduction.

At the same time, while greater computational power will raise standards for societal accountability, proactive stewardship can create a strategic advantage. Advanced analytics will deliver more precise toxicological endpoints, detailed exposure pathways and quantitative impact assessments. Successful product stewards will be those who can interpret complex hazard models while articulating robust benefit cases that justify product decisions in increasingly data-driven regulatory and market environments. Companies investing in these capabilities now will differentiate themselves as regulatory and market expectations increasingly demand quantitative justification for product decisions. 

Q: How can companies move from reactive compliance to proactive leadership?

A: The transition from reactive compliance to proactive leadership begins with an honest assessment of current capabilities including identifying knowledge gaps, supply chain vulnerabilities and emerging regulatory pressures. From this baseline, companies can strengthen technical expertise, improve cross-functional coordination and enhance stakeholder communication.

Market leaders actively engage their supply chains, monitor regulatory developments across jurisdictions and invest early in evaluating alternatives or substantiating the safe use and benefits of existing chemistries before mandates require action. By clearly communicating the science and rationale behind their decisions, companies build trust and credibility across the value chain.

Turning Stewardship into Strategic Advantage: TRC Can Help

Product stewardship is no longer just a compliance function. It is a business-critical capability that connects science, strategy and market trust. As regulations tighten, customer expectations rise and supply chains become more complex, companies that treat product stewardship as a leadership discipline will be better positioned to proactively manage risk, innovate responsibly and differentiate their brands.

The organizations that succeed are those that move beyond reactive compliance. They embed lifecycle thinking into organizational objectives, product design requirements and rely on data-driven decision-making. They engage suppliers as partners and communicate the value of their choices with clarity and credibility. In doing so, product stewardship becomes a driver of resilience, growth, long-term value and strategic advantage.

TRC has developed strategies and a framework to assist retailers, importers and manufacturers with product stewardship compliance requirements and risk evaluation, including reduction/elimination approaches for targeted chemicals or compounds in products and packaging within the supply chain.

With a proven experience establishing and implementing product stewardship programs in highly complex organization, coupled with extensive chemistry, product safety, and regulatory knowledge, we help organizations identify and establish goals and objectives that lead to successful implementation of robust and regulatory savvy product stewardship program.

Learn more about our solutions and how they can support your product stewardship journey or contact us today.

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TriciaUnderwood_Headshot
Dr. Tricia Underwood

Dr. Tricia Underwood, DABT, MBA, has over 27 years of experience in toxicology, human health risk assessment, regulatory science, and environmental management, including executive leadership roles at the U.S. Departments of Defense and Homeland Security. She has directed enterprise-wide programs addressing product stewardship, chemical supply chain risk, regulatory review and strategic engagement, and environmental health policy. She oversaw all strategic aspects of chemical risk management and regulatory policy for the Department of Defense as Chief Toxicologist and Principal Director. Dr. Underwood currently serves as Vice President of Strategic Health Sciences at TRC and can be reached at punderwood@trccompanies.com.

KennyUnice_Headshot
Kenny Unice

Kenny Unice, MS, AIGP, has over 25 years of experience in computational health risk assessment, environmental modeling, and product stewardship, including leadership roles in multi-stakeholder industry initiatives and regulatory science. He has led applied research programs that bridge technical science and stakeholder needs, managing long-term collaborations with the World Business Council for Sustainable Development Tire Industry Project and serving as co-chair of California's Ocean Science Trust microplastics risk assessment framework. He has authored ISO technical specifications for tire and road wear particle analysis and published over 85 peer-reviewed articles on environmental fate modeling, toxicokinetics, PFAS assessment, and emerging contaminants. Kenny currently serves as Principal Health Scientist at TRC Companies and can be reached at kunice@trccompanies.com .