PRODUCT COMPLIANCE PROCEDURES

Transcription

1 PRODUCT COMPLIANCE PROCEDURES Updated: January, 2016

2 1. PRODUCT TESTING AND COMPLIANCE BUSINESS PROCESSES ESTABLISHMENT PRODUCT REVIEW AND RISK ASSESSMENT PROGRAM LABORATORY TESTING PROGRAM TEST REPORT REVIEW PROCESS GENERAL CONFORMITY CERTIFICATE AND MANUFACTURER S DECLARATION LETTER COMPLIANCE RECORD PRODUCT COMPLIANCE PROCESS FLOW

3 Product Compliance Procedures To ensure the completion of compliance for our Kate Spade & Company products, the following steps are followed strictly: 1. Product Testing and Compliance 1.1 Supplier, Agency and Laboratory are responsible to download and understand the Product Testing & Compliance documents (named Product Testing and Compliance Manual ) from Kate Spade & Company website ( Supplier is requested to understand clearly and follow strictly product testing & compliance requirements with business processes established. 1.2 If supplier is not able to comply to the Product Safety & Restricted Substances List (RSL), Kate Spade & Company will inform the supplier about the consequences which would possibly include the termination of the supplier code. 2. Business Processes Establishment 2.1 When the supplier agrees following Kate Spade & Company Product Compliance standards, the supplier is required establishing the business processes as committed. Kate Spade & Company has the right to validate the business processes of the supplier if necessary. 3. Product Review and Risk Assessment Program 3.1 At Salesmen Sample(SRS) stage, supplier is responsible to determine the appropriate tests for safety, quality/performance and labeling requirements per style based on Kate Spade & Company Product Safety and Compliance Manual and relevant country of destinations in order to prepare Product Review Report accordingly. 3

4 3.2 To cope with the Product Review and Risk Assessment Program, the supplier or agency will initiate a product review meeting per season with relevant technical teams such as laboratory and/or Kate Spade & Company product compliance team in order to finalize the product compliance per style in the Product Review Report. 3.3 For any requirement which is proposed to be exempted by supplier/vendor, relevant compliance document must be submitted to Kate Spade & Company Product Compliance Team for approval. The supplier is required to fill Exemption in the Product Review Report for future reference. 3.4 If Kate Spade & Company Product Compliance Team rejects the exemption request, the supplier is required to follow the Laboratory Testing Program based on the established Product Review Report. 3.5 The Product Review Report must be completed by filling compliance test report number or pre-approved exemption. 3.6 Apart from the test reports, if Suppliers and/or Agency have other supporting documents, it is required to be reviewed and confirmed the acceptance by Kate Spade & Company Product Compliance Team. All documents must be maintained and accessible to Kate Spade & Company. 4. Laboratory Testing Program 4.1 Before shipment, the supplier is responsible to submit each bulk test sample (bulk sample means sample that is dyed and finished same as finished goods) per shipment to the Kate Spade & Company approved laboratories which are listed in this manual for conducting the confirmed tests based on the Product Review Report. Test report issued other than those approved laboratories by Kate Spade & Company will not be accepted. For all shipments, there must be pass test reports or accepted reports on record prior to shipping and provided to Kate Spade & Company upon request. The supplier is responsible to follow below sample submission guideline in order to minimize the testing costs; otherwise KS&C will not pay the extra testing cost: For the same material (same color, same finishing and manufactured by same supplier) used for different finished products in the same season, it is required to apply testing once by providing all the necessary finished goods style numbers on the Test Request Form. For the same material with more than one color, it is required to follow below: 4

5 o Fabric: minimum one color is required to apply Full Fabric Package Test and for balance of colors apply Additional Color Package Test. Both Full Fabric Package and Additional Color Package for all relevant colors are required to apply under the same application. o Garment: minimum one color is required to apply for Garment Package Test o Trims: if same materials are used for different parts, it is required to declare them on Test Request Form 4.2 Each testing application must be submitted with complete and correctly filled in Test Request Form which is provided in this manual. Other test request forms will not be accepted. Incomplete test request form can delay the test application. Complete information includes below (but not limited to): - Finished goods style numbers - Trim codes/ names if any - Fabric codes/ names if any - Age grading for finished goods - Color names - Market destination - Composition/ Fiber Content - Appropriate Lab Tests selection - Season - Previous relevant report number as below: Applied Package Previous relevant Test Report Number should be provided Fabric Full Package N/A Additional Colorway Fabric Full Package Report Package Number Garment Package Fabric Full Package Report Number and Additional Colorway Package Retest Previous Report Number 4.3 The laboratory is responsible to ensure the accuracy of lab test result(s) and send the official each test report to Kate Spade & Company and the related parties who are stated in the Test Request Form. 5

6 5. Test Report Review Process 5.1 Any failure has been reported from the laboratory, agency will provide recommendation according to the failure with consultation to Kate Spade & Company product compliance team if needed. All recommendation must be maintained and accessible to Kate Spade & Company 5.2 For the test failure(s), the supplier is requested to rectify the failure(s) and validate the improvement before release shipment. 5.3 When all the required laboratory tests are complied, the supplier is requested to complete the Product Review Report by filling in the corresponding test report number or relevant document number for future tracking purpose. 6. General Conformity Certificate and Manufacturer s Declaration Letter 6.1 The supplier is responsible to prepare the completed Product Review Report and General Conformity Certificate (GCC) or Manufacturer s Declaration Letter subjecting to the relevant products. 6.2 Kate Spade & Company has the right to validate the accuracy of completed Product Review Report including the testing report(s) and relevant documentation per shipment if necessary in prior to release shipment. 6.3 If all related documents are validated by agency without failure, shipment will be released. 6.4 If any related document is validated with discrepancy found, shipment will be on-hold for further clarification or possibly rejected. 7. Compliance Record Supplier and/or Agency are required to keep the compliance record for a period of minimum 3 years to maximum up to 10 years as directed by individual country legislation from the date of product shipment to the consumer. 7.1 Compliance Record Validity Based on the different materials, the compliance record is accepted in varied timeframe and is stated in this section. 6

7 The validity period of Kate Spade & Company test reports is also subjected to the requirement of the latest global laws and regulation (e.g. Consumer Product Safety Improving Act (CPSIA)) Newly Used/Developed Materials Newly used/developed materials refer to the materials have never been used on Kate Spade & Company products. They are required to have relevant Kate Spade & Company report(s) per style per season for ensuring the compliance status Replenishment/ Carry-On Materials Replenishment/ Carry-On Materials refer to the repeated used materials and/or components having the same materials, same color and same manufacturing processes with Pass compliance proven records. The related Kate Spade & Company Pass test reports can be carried over for certain periods shown as below table, except the requirement ruled by the latest global laws and regulation (e.g. CPSIA): Apparel Accessories Pet Items/ Packaging Test Parameters Main Materials/ Finished Product Trims* Main Materials/ Finished Product Trims* Main Materials/ Finished Product/ Trims Fiber Content Per Season Per Year Per Season Per Year Per Year Care Label Per Season Per Year Per Season Per Year Per Year Colorfastness Per Season Per Year Per Season Per Year Per Year Physical Per Season Per Year Per Season Per Year Per Year Children Safety Per Season Per Year Per Season Per Season Per Season Flammability Per Season Per Year Per Season Per Year Per Year Restricted Substances Per Season Per Year # Per Season Per Year # Per Year 7

8 Remarks: *refer to Trims Testing Protocol for the Trims classification # exclude legislation and/or regulatory requirement, e.g. CPSIA is required per shipment Same Materials used on different finished products If the same materials with same colors provided by same supplier are used on different finished products with different style numbers, the related Kate Spade & Company reports can be used within the same season provided that the relevant style numbers and/or article number are marked in the Kate Spade & Company reports for appropriate compliance traceability Same Material with more than one color If the same material has more than one color, the Kate Spade & Company reports should cover the colors as below table: Apparel/Accessories/Pet Items/Packaging Test Parameters Main Materials/ Finished Product/ Trims Fiber Content Test minimum one color is accepted Test minimum 3 major colors are accepted Care Label (Darkest Shade, Middle Shade & Light Shade) Colorfastness Test all colors is required Physical Test minimum one color is accepted Children Safety Flammability Restricted Substances Test minimum one color is accepted Test minimum one color is accepted Test all colors is required, except exemption mentioned in Restricted Substance List 8

9 8. Product Compliance Process Flow The Product Compliance Process Flow is summarized as below: 9