Code of Practice. Product Design & Claim Validation. Consumer Goods Supplier Requirements

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1 Code of Practice Product Design & Claim Consumer Goods Supplier Requirements

2 Table of Contents Contents Section 1 - Claim Section 2 - Claim Development Section 3 - Claim Integrity Section 4 - Testing Section 5 - Product Inputs Section 6 - Products Stability Page 2 of 5

3 Code of Practice - Product Design and Claim for Formulated Non Food Products To help identify how the requirements must be met for each clause a P, R or O will be indicated under the columns headed PRO. These columns indicate whether the requirement is met through: P = Procedure - A documented procedure that has been fully implemented. R = Record - Documented and accurately completed records. O = Observation - Compliance will be checked through observation. Product Design and Claim P R O Section No. Checkpoint/Requirement Section 1- Claim x x x 1.1 Where product claims are intended to be used on the product label, the following supporting documentation must be maintained to ensure validity of the claim: Where Certification is relevant, certificates must be held and reviewed on a minimum annual basis to validate the claim (or as per relevant certificate expiry date). Certification standards and reference material to support the validity of the claims. eg Therapeutic Goods Administration Hospital Grade Disinfection. Any supporting literature to demonstrate appropriateness of claims. Full traceability and/or chain of custody must be demonstrated and monitored as part of the Approved Supplier Program Claims based on theoretical data must be approved by the Woolworths Quality Specialist and documented in the specification. Test reports to show compliance to the claim. Page 3 of 5

4 Section 2 - Claim Development x x x 2.1 Section 3 - Claim Integrity x x x 3.1 Section 4 - Testing During the product development process, all product claims must be validated in full with formal approval from the Woolworths Quality Specialist before artwork dispatch or product launch. Claims include, but are not limited to the following: Sustainability Claims e.g FSC or PEFC Performance claims e.g. Fast knockdown, instant action, unbeatable shine Antibacterial claims Disinfection claims Therapeutic Goods Administration Registered or Listed claims e.g Hospital Grade Disinfection Environmental claims e.g. Environmentally friendly, recycled or recyclability claims, biodegradable, compostable Active ingredient claims e.g contains ingredient x Ingredient sustainability claims e.g. RSPO Palm oil derivatives Ingredient Claims e.g. Natural ingredients, fragrance descriptors, active ingredients The integrity of all products supplied to Woolworths Group must be guaranteed. Suppliers supplying products to Woolworths must ensure the claim status of products is maintained from raw material procurement to end of finished product shelf life. All products must be handled in a manner which prevents contamination or substitution with products which are not compatible with the certified/ verified claim/ standard. The process flow for the production of products where claims are made must be documented and potential areas for contamination or loss of identity identified. Appropriate controls must be established to ensure the integrity of the product claims. Claims must be re- validated for any changes that may impact the product claims, these could include, but are not limited to, changes in raw materials, process, or to the supplier of the raw material. x x x 4.1 x x x 4.2 Chemical analysis testing is required to validate the performance level of an active ingredient to demonstrate a claim, or to meet the minimum specification required to deliver the product performance or maintain the claim status of the product. Where product testing to verify accuracy of claims is conducted by third party independent laboratories, ideally NATA accredited or NATA recognized (i.e accredited by an ILAC MRA such as CNAS) facilities are preferred. Page 4 of 5

5 P R O Section No. Checkpoint/Requirement x x x 4.3 Approved claims based on theoretical data are exempt from analytical testing, however a sound technical argument supporting the claim must be documented and approved by the Woolworths Quality Specialist x x x 4.4 Testing protocols must be documented with clearly defined test procedures and acceptance criteria for validating the claim x x x 4.5 x x x 4.6 Testing protocols or methods must be of a sound scientific nature and where appropriate must include statistically significant replication of data points and statistical analysis of test results to validate the proposed claims. Where claims are regulated or legislated to meet predefined acceptance criteria, it must be demonstrated that the testing adheres to and meets the minimum requirements (e.g Therapeutic Goods Administration, Disinfection claims, Antibacterial claims). Section 5 - Product Inputs x x x 5.1 Where products make claims which are dependent on a status of a raw material including: Section 6 - Product Stability assured status (e.g. RSPO, FSC, PFSC) material inputs (e.g RSPCO certified sustainable Palm Oil derivatives) named specific trademarked ingredients Then, the status of each batch of the raw material must be verified. The manufacturing facility must maintain purchasing records, copies of certificates, traceability of raw material usage, and final product packing records to substantiate these claims. x x x 6.1 Product and packaging compatibility, and leakage testing of all packaging components in direct contact with the product must be demonstrated for the product s entire shelf life. Evaluations will include as applicable: x x 6.2 corrosion paneling stress cracking component swelling weight loss leakage The product must be shelf stable and remain so for its entire expected shelf life. Stability studies should include testing of those attributes of the product that are susceptible to change during storage and are likely to influence quality, safety and/or efficacy. The testing should cover, where appropriate, the physical, chemical and microbiological attributes and functionality as appropriate. Page 5 of 5

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