Guide to Labeling Organic Textile Products

Transcription

1 20 Version 1.2 Guide to Labeling Organic Textile Products Written by Anne Gillespie with the advice and input of: Akiria Hibi Japan Organic Cotton Association Fred Elhert Ehlert Organics Graham Burden Marks & Spencer Lee Holdstock Soil Association Marcus Brugel IMO Mark Prose Control Union Marty Mesh Quality Certification Services Paul Schnepf Hermann Buhler Yarns Tom Hutcheson Organic Trade Association

2 Exchange Guide to Labeling Organic Textile Products Version 1.2, December, 2007 The Exchange Guide to Labeling Organic Textile Products has been developed to provide increased clarity for brands and retailers trying to understand how to most accurately and effectively label their products containing organic fiber. A working group consisting of certification experts from around the world has contributed to the development and review of this document. However, note that this is not a legal document, and we strongly recommend that you review with your own legal counsel before making final decisions. Copyright 20 Exchange. All rights reserved. This report is distributed solely to members of Exchange ( E). It can be copied and shared with all direct employees of OE member companies. If individuals of companies or organizations outside of Exchange would like to purchase a copy of this document, they may contact Exchange directly at info@ xchange.org. The guide sells for US$250.

3 Table of Contents Table of Contents Frequently Asked Questions page 1 Guide to Labeling Organic Textile Products page 4 Summary of 3rd Party Marks page 9 Decision Tree page 11 Resources page 14 Exchange thanks Article.1, Control Union Certifications, H&M, Parkdale Mills, Thai Textile Industry PCL, and Texas Organic Cotton Marketing Cooperative for their sponsorship of this guide Texas Organic Cotton Marketing Cooperative

4 Page 1 Guide to Labeling Organic Textile Products Frequently Asked Questions 1. If I want to label my product as made with organic fiber, to what level do I need to certify to? Your first priority is to meet the legal requirements of the countries you are selling into. To date, these all apply to truth in labeling or advertising claims. In order to do this, you will need to be able to prove that the fiber in the product is certified organic: it has been grown to the accepted organic standard for the country of sale, and it has been segregated from conventional and other fibers along the production chain. For the U.S., the fiber must be certified to the NOP standards. If you are using a third party standard then you will have to certify according to the rules set out in that particular standard. A summary is included in the labeling guide. Note that you will still have to ensure that the fiber has been certified to NOP for the U.S., as this is not always set out in these standards. The best way to protect your company is to be assured that your production partners can track the certified organic fiber they buy and sell, and can back up all their claims with proper documentation. The Organic Exchange Online Tracking System does this through a web-based system and is one of the best ways to assure your claims are accurate. 2. Can I say made with organic fiber if there is less than 100% organic fiber in my product? Although there are no legal requirements that give specific direction on how to label finished textile products, we advise that if the fiber content is between 95% and 100%, you can claim that the project is made with organic cotton. (a small allowance is typically made for non-organic content in trims). For any amounts less than that, you should identify the actual percentage of organic fiber (eg: made with 50% organic cotton: the remaining fiber may be conventional cotton, hemp, silk or other fibers such as nylon). Note that third party standards will have their own specification, and keep in mind the laws on ensuring that your claims are not false or misleading. 3. What do I need to know about the farming certification? If you are selling textile fiber products into the United States, the fiber must be certified to the National Organic Program (NOP) standard, even if the farming and production is being done elsewhere. If you are selling product into any other country, there are no legal requirements for the standard to which the fiber has to be certified. However, we advise you to check that the certification is one that is recognized; the most globally recognized standards are NOP, EU 2092, IFOAM and Codex Alimentares. 4. What is the minimum certification that I need to legally label my products with organic? The minimum certification that is needed is the farm certification (be sure that it is valid for the country where the products are being sold). However, note that you will also have to ensure that the organic fiber can be tracked from the certified farms, through all steps of processing, and into your final products. Most companies at this time are choosing to certify to the spinning level as a minimum. 5. Do I need to certify the processing? Within Europe, North America and Japan there are no legal requirements to certify the processing of organic fibers; there are no government standards that have been developed beyond farming.

5 Page 2 6. Why would I use a processing standard? By having certified your product against a voluntary third party processing standard, you will have the assurance that your supply chain has taken all the steps to track the organic cotton as it moves through processing and that it has not been contaminated by other fibers. Third party certifiers also have a great deal of experience and credibility to allow you to stand behind your claims. 7. Why would I not certify the processing? You may choose not to certify against a standard if you feel that you already have the steps in place to trace the organic cotton and ensure its purity. These steps may include use of the Organic Exchange Online tracking system, as well as affidavits on proper handling from your supply chain partners. 8. Is there a certification to prove that my product contains only organic fiber but does not make any other claims? Yes, the Organic Exchange 100 Standard is being specifically developed to certify that products made with 100% organic fiber have been tracked through the production chain and segregated to prevent commingling with other fibers. The OE 100 does not consider other claims such as processing, social or quality issues. You may already be addressing these with other standards or choose to ignore them for now. 9. What standard would I use if my product uses a blend of organic and conventional fiber? The OE Blended Standard covers products made with a blend of organic and conventional fiber. 10. If I do not want to use a private standard can I simply call my product organic? You should not label products as organic independently of a private standard, as it will be misleading to customers; it is hard to justify a claim of organic when chemicals are used to create the final product. You must keep in mind that national labeling laws requiring truth in all claims. However, the Global Organic Textile Standard does allow you to call your product organic as long as it has been certified to meet all of their guidelines. 11. If I get Global Organic Textile Standard certification for my products does that mean it can be sold under their label in all countries around the world? Unfortunately, GOTS has slightly different requirements depending on whether the final product is being sold in the U.S. or elsewhere. The exception for the U.S. makes certain allowances for optical brighteners and synthetic content. These exceptions will be reviewed in the future, but for now you will have to take extra care when using GOTS for products sold both into the U.S. and other countries. 12. Which product labels do all of these rules apply to? All of the rules relating to organic claims apply to all labels related to your products. These include care/content labels, labels on the outside of garments, on packaging, or hang tags, and even signage and advertising. 13. There is a discrepancy now between what is said in the OE Blended Standard and how GOTS say claim and performance should match. "Made with organic cotton": in the OE Blended it should be 95% organic cotton at least, in GOTS it says 70% at least. Which one can I use? If you are using GOTS for your overall certification (which includes not just organic fiber content but also processing, quality and social standards), then you will have to label according to their standard. This means that there must be a minimum of 70% organic content to say made with organic fiber or over 95% organic content to say organic. Note that your label will have to say that the product is certified to the GOTS. This will apply in both the U.S. and else-

6 Page 3 Guide to Labeling Organic Textile Products where, but do note that for the U.S. there are some differences in the GOTS requirements and that the fiber must be certified to the NOP Standard. If, however, you choose to use the OE Blended Standard, then you can make the claim 'made with X% organic cotton', and X can be any number from 1 to 99. NOTE: We are also developing the OE 100 Standard, which can be used to back up claims of 'made with 100% organic cotton'. Both OE standards focus only on the organic fiber content in the final product, ensuring that the cotton can be tracked all the way through the production chain, and that is it protected from contamination by other fibers as appropriate. The bottom line is that the claim you make depends on the standard you are using, but both are valid. 14. Why would I use a private mark? To establish your own organic branding can be complex, time consuming and resource intensive. There are many established and credible private labels available which consumers already recognize. These labels are backed up by voluntary processing standards that have been developed by independent, private organizations. These organizations derive their influence and credibility from the individuals and businesses that use their labels and their marketing and history in the marketplace. A summary is included at the end of this labeling guide. Note that for a label to have maximum credibility, it must be certified by an independent, third party certifier. This agency will offer greater credibility, no bias, and a high level of expertise in certification. 15. What are the different voluntary processing standards that I can certify against? There is a wide range of standards available that will suit different goals. A full listing and description of each of the current standards are summarized in the OE Labeling Guide. 16. I m a brand - how do I get my products certified to the standards I choose? As a brand or retailer, you need to signal to your suppliers that the products they are selling to you must be certified to the standard you have chosen. You will need to be very clear about your expectations, and the suppliers will have the responsibility for delivering to your requirements. They can contact Organic Exchange or the specified certifying agencies for further support. 17. I m a mill how do I get my products certified? As a mill, you need to contact your chosen certifying agencies and ask to start the certification process. 18. What is a private standard? This is a standard that is established by an independent organization that can cover anything from the source of the fiber to all aspects of production, including environmental impacts, social conditions, packaging and quality. This standard will often be backed up by a mark or logo that indicates it has been certified to the given standard. As a company, you can choose to use a third party standard, set your own, or simply meet legal requirements. 19. Is the organic cotton logo that the OE has on their website attached to any certification? This logo in not attached to any standards or certification it has been developed as an icon to bring attention to the use of organic fiber. The OE logo may be used by OE members to indicate their support for the organization. For the specific use of direct employees of OE Member Companies.

7 Page 4 1. Introduction Farming organically means growing crops in harmony with ecological principles, and without the use of toxic and persistent pesticides or fertilizers, sewage sludge, irradiation or genetic engineering, and being certified by an accredited independent organization. Although the term organic is commonly used to describe products or fiber, in its pure sense it describes the way that a fiber has been grown at the farm level; it must be grown on land that has been certified as organic. Handling and processing of the fiber may conform to a number of voluntary standards that serve to protect the organic integrity of the original fiber. Organic is a term that has gained strong recognition in many markets around the world and has a high level of trust with consumers. In order to maintain this credibility, it is important that companies selling products labeled as organic take all the necessary steps to ensure the term is being used correctly. The purpose of this document is to give increased clarity for brands and retailers working to accurately and effectively label their products containing organic fiber. This document will be developed into a more detailed guide on how to go forward with certification and labeling by the end of Please note that rules and regulations change often, and that this is not meant to be a comprehensive document - be sure to check for the most current updates. It is also recommended to talk with your legal counsel before making final decisions about your labeling. 2. What is a label? A label is any identifying or descriptive marker that is used to describe a product. Labels are used for disclosure (eg: a care/content label) or for representation to convey an idea or meaning (eg: a company name, or an organic logo). The term organic can be found in both types of labels, and its use may be governed by federal laws or by the requirements of the organizations that issue their own logos. Generally, national labeling laws address the use of permanent labels and govern the use of fiber names and declaration of content percentages. Permanent and semi-permanent labels (eg. hang tags) are used by retailers or brands to further communicate with consumers these too cannot mislead, and labeling laws will set limits on the terminology that can be used. There are further distinctions that need to be made: A standard lays out a set of conditions for the farming and/or processing of a product. A certifying agency confirms compliance with the standard. The certifying agency and/or the organization that developed the standard may have a mark that confirms that a product has been certified to the specific standard. 3. Using the term organic All of the marks discussed in this document require the use of organic fiber to meet legal requirements or to meet the standards of third party organizations. To be considered organic, the fiber must be certified to a valid standard by a qualified certifier. The most globally recognized standards are: United States Department of Agriculture National Organic Program (USDA NOP) European Economic Community regulation 2092/91 (EEC 2092/91) International Federation of Organic Agricultural Movements (IFOAM) Note that in the US, organic fiber can only be certified to the NOP standard. As a brand or retailer, your responsibility is to ensure that the fiber used in your products has been certified to the appropriate organic standards for the country of sale.

8 Page 5 Guide to Labeling Organic Textile Products 4. Ensuring the validity of organic claims In addition to verifying that the fiber has been certified as grown to an organic standard, it is also very important to ensure that the fiber that has been certified as organic is actually the fiber that ends up in your products, and to the percentage you are claiming. This means that for all steps of processing and manufacturing, documents are kept so that there is full traceability from the farm to the finished product, with no room for accidental or deliberate confusion. For claims of 100% organic fiber, all production partners must take additional steps to protect the organic fibers from commingling with any other fibers. Certification by a third party certification agency ensures that all of the proper documentation and procedures are in place and that the claims are valid. The certification agency will have to be accredited or licensed to certify to given standards. This authority can be given by the organization that has issued the standard, or by a broader accreditation organization, such as IFOAM. Currently, the only standards that specifically address the integrity of the fiber claims are the OE Blended (for fiber blends that contain over 5% organic cotton) and OE 100 (for claims of 100% organic cotton content), developed by Organic Exchange. If a company decides to make independent organic claims on the processing of its products, then it will need to ensure that all of its production partners are taking the needed steps to guarantee that the claims are valid. To do this independently is a complex and time-consuming process, as the movement of all organic fiber must be tracked through each stage of production, and the processing units should be inspected to ensure that they are taking the necessary steps to identify the organic fiber and protect its integrity as needed. Note that the organic farming can only be certified by an accredited third party certification agency. The Organic Exchange Online Tracking Service (see offers an excellent solution to cover the tracking of organic fiber content and processing through the complete supply chain. It can be used with certifications and affidavits on handling practices from production partners. The Tracking Service gives additional credibility to the claims being made, offers transparency from the consumer to the farm, and is highly efficient. The other alternative is personal visits and maintaining documentation yourself a cumbersome and costly process. 5. Why use organic marks? For many consumers, organic is a trusted term that signifies purity, health, and integrity. While a company may choose not to identify their use of organic fiber, most want to take advantage of the positive association with the term organic and the added credibility of 3 rd party marks that incorporate organic, sustainable and social principles. The use of 3 rd party organic marks offers a range of benefits: Consumer recognition Proven product integrity Accountability of environmental management Point of differentiation Sales people have an easy reference for discussing the product with customers Positive association with organic food and the organic lifestyle Increased awareness and credibility of organic for the industry The 3 rd party marks we refer to in this document each represent a standard, which gives the consumer the guarantee that the product has been produced to a set of guidelines which include organic certification of the fiber. 6. Choosing how to label your products There are a few things to consider when choosing how to label your organic cotton products. Ask the following questions to determine what your labeling options are, and which, if any, third party mark you will use:

9 Page 6 What countries are we selling in? Countries or regions differ in terms of the laws on textile product labeling, the standards behind the term organic, and the market recognition of different marks. It is important to understand all of these aspects for the markets where you are selling your products, to ensure that your labeling choice is legal and effective. What is your company s strategy with organic cotton? Are you using 100% or a blend? Are you paying attention to the environmental impacts of processing and/or the treatment of workers? What message do you want to communicate to your market? These are a few of the questions you will want to answer before you make a choice about the way you will label your products. The answers will help define your choice to simply comply with legal regulations, use a third party mark, create your own label or mark, or even choose not to say anything at all. There are also numerous marks that deal specifically with the social aspects of production, but they are not covered in this document. 7. Legal Labeling Requirements by Region When deciding on how to label a product containing organic fiber, the first thing a company must do is to comply with the legal requirements regarding the use of the term organic for each market being sold to. The following is an overview of the laws relating to the use of the term organic in various regions, but it is best to research the full requirements for each country you are selling into. Canada All textile products must conform to the Textile Labeling and Advertising Regulations issued by the Competition Bureau of Canada. A label is considered to be any mark, sign, device, implant, brand or ticket. The regulations allow for the use of organic to describe the fiber content on any label, as long as the claim is not misleading or false. In December, 2006 Canada released their new Organic Products Regulations. This regulation will affect all Canadian businesses engaged in international or interprovincial trade and all businesses that import to Canada or buy Canadian organic products. The regulations is expected to be fully implemented in two years. At this point the Canadian Regulation will not allow for the term organic to be used on products that are not processed to the standard, and because it is a food standard, it is unlikely that many textile products would comply. However the Organic Trade Association, with the support of Organic Exchange, is working to have textile products exempted before the implementation occurs. Europe In Europe, there are no legal restrictions on the use of the term organic to describe textile products, although all labeling must conform to the European Communities Names and Labeling of Textile Products, 1998 and relevant additional legal requirements of the EEC member states. The law that deals with the use of the term organic is EU 2092/91, which applies to processed products for human consumption or unprocessed agricultural and livestock products, but does not apply to finished textiles. However, note that many countries enforce truth in labeling regulations and these will need to be respected; be sure that all claims are accurate and can be backed up with documentations. Each country may also have specific rules for textile labeling: in Germany for instance, the term organic is not allowed on care/content labels. Japan The Japanese Agricultural Standard (JAS) for Organic Certification Program does not have any regulation for organic cotton production, because cotton is currently not planted commercially in Japan, so there are no require-

10 Page 7 Guide to Labeling Organic Textile Products ments for the standard to which the cotton is certified; JAS only regulates food and feed products. However, false labeling is regulated by the Act Against Unjustifiable Premium and Misleading Presentation and companies are therefore responsible for ensuring any claims they make about the use of organic fiber can be proven. United States There are two governing bodies to consider when labeling organic textiles: the Federal Trade Commission (FTC) and the National Organic Program (NOP) of the USDA. The FTC requires that the type and percentage of the fiber used are correctly represented: false or misleading claims may not be made.. For example, 100% organic cotton is fine if the garment is made of only organic cotton, or 5% organic cotton/95% cotton for a blend. On any label or tag the font and size for the word organic must be the same as for cotton. Note that you will need to be able to back up your organic claims in the case of a dispute or challenge, therefore it is advisable to have a strong tracking system in place, such as the Organic Exchange Online Tracking System. The NOP further requires that for all products labeled with the term organic, the agricultural input (ie: the textile fiber) has been certified to the NOP organic farming standard. If a processed fiber product meets all of the processing standards set out by the NOP, that were developed primarily to deal with food production, the product can be called organic and use the USDA organic logo. ** note-need to confirm this with QCS/OTA 8. Company labels Companies may already have their own mark or label, or choose to develop one. This could be a brand label for a company s organic program, or one that supports their entire code of conduct, dealing with issues such as organic, fairly traded, environmental processing, protection of animal welfare and more. It is important for all labels that any claims made can be verified, and that they comply with the laws of the country in which the products are being sold. 9. Third Party Marks Establishing your own organic mark or production standard is complex, time consuming and resource-intensive. There are many established and credible private marks available which consumers already recognize. These are marks that have been created by independent, private organizations to identify products that conform to the standards they have set. These organizations derive their influence and credibility from the individuals and businesses that use their labels, and their marketing and history in the marketplace. Note that for a mark to have maximum credibility, it must be certified by an independent, third party certifier. This agency will have no bias, greater credibility, and will have a higher level of expertise in certification as that is their core focus. The standards behind the marks described in Section B: Summary of Third Party Marks all have organic fiber as part of their criteria, but also address additional issues such as the social and/or environmental impacts of production. Each company will have to look at its strategy for organic textile products, and choose the mark or marks that best support it. How are marks backed up? In order for the marks to have good credibility in the market, they need to be backed up with strong standards, and some form of auditing or certification system (like the Organic Exchange Tracking System). Standards can deal with raw material sources (ie: organic fiber), the chemicals used in processing, treatment of workers and more. Verification is done by by accredited third party certification agencies.

11 Page 8 Accredited certification agencies are those that have been audited to verify their practices and conduct. Accreditations for certifiers include IFOAM-IOAS, ISO65, EN45011 (used in the EU) and the USDA NOP. Where can I use third party marks? There is generally no restriction on where marks can be used, as long as the organic and labeling standards of the country are met, but most have greater recognition in certain markets. For example, JOCA, a Japanese label, will have little or no recognition in North America or Europe. However, recognition may not be why a business chooses a particular mark they may like the values and rigor which a particular mark represents, and use it as a way to ensure the integrity of their products. What are the requirements to use third party marks? Typically companies will have to sign a contract with the organization that is issuing the mark, and may also have to pay a fee. The contract will ensure that the company understands and will meet the requirements of the label: from how to certify to the standards, to use of the logo on their finished products and advertising. In some cases certification will be conducted by an arm of the organization that is issuing the mark and in others they will refer to separate, approved agencies to certify to their standards. 10. Important Information Please note that this Guide has been created as a tool to help companies determine their best labeling strategies. Organic Exchange has worked with an Advisory Committee and experts from around the world, who have generously donated their time and expertise, to make this guide as complete and accurate as possible. However, given the fast-changing pace of the industry, and the complexity of issues relating to labeling, we strongly recommend that you do your own due diligence before making decisions, and consider referring to your own legal council. Also be sure to watch for updates on this Guide from Organic Exchange. Conclusion The correct use of labels and marks on organic products is important to both the industry and individual companies. The customers who choose organic fiber products rely on the companies and organizations that are making claims to be honest and accurate. The industry needs the trust of the consumer market to continue to grow, and it is the responsibility of everyone to do all that they can to support this trust. Thanks Organic Exchange would like to thank the following people for donating their valuable time and expertise in putting this guide together: Akiria Hibi Japan Organic Cotton Association Fred Elhert Elhert Organics Graham Burden Marks & Spencer Lee Holdstock Soil Association Marcus Brugel IMO Mark Prose Control Union Marty Mesh Quality Certification Services Paul Schepf Buhler Yarn Tom Hutcheson Organic Trade Association Hong Lee Control Union

12 Page 9 Guide to Labeling Organic Textile Products Summary of 3rd Party Marks 3rd Party Labels Requirements Demeter Demeter International is composed of 20 members from Europe, the U.S., Afri ca and New Zealand representing 3,000 producers in almost 40 countries. Demeter focuses on Biodynamic farming, which is a holistic approach that goes beyond organic to address spiritual and philosophical aspects or agriculture, and to treat the farm as a living system. The Demeter textile standards address the full supply chain, from farming to processing through to the final packaging of the products. EKO The EKO Sustainable Textile logo is issued by Control Union, a Holland-based certification agency. It is backed up by the GOTS. ECOCERT ECOCERT is a French standard that allows for organic and organic-in-conversion. It addresses the environmental aspects of processing, sets quality standards, and supports organic (over 95%) and made-with-organic (70-95%) claims. Logo pending Global Organic Textile Standard (GOTS) The Global Organic Textile Standard is the result of a technical harmonization procedure between leading standard-setting organizations from around the world. To date the standard has been adopted by the International Association Natural Textile Industry, Soil Association, Organic Trade Association and Japan Organic Cotton Association and is being used by Control Union and IMO. The development is supported by IFOAM. The aim of the standard is to define requirements to ensure organic status of textiles, from harvesting of the raw materials, through environmentally and socially responsible manufacturing up to labeling in order to provide a credible assurance to the end consumer. The goal is to enable textile manufacturers to qualify their organic fabrics and garments with one certificate accepted in all major world markets. Note that there are some temporary exceptions in the standards for products sold in the U.S., and these are under discussion. GOTS allows for two levels of labeling: "organic" or "organic in- conversion" 95% or more of the fibres - excluding accessories - must be of certified organic origin or from 'in conversion' period. The remaining balance, up to 5%, may be made of non-organic fibres including regenerated and synthetic fibres. The remaining balance may not contain any conventional fibre of the same raw material that is used in organic quality in the same product (ie: no blending). "made with x % organic materials" or "made with x % organic in-conversion materials" 70% - 95% of the fibres - excluding accessories - must be of certified organic origin or from the 'organic-in-conversion' period. The remaining balance may not contain conventional fibres of the same raw material as the organic fiber, ie: no blending.

13 Page 10 3rd Party Labels Requirements Naturtextil The Naturtextil label is issued by the International Association Natural Textile Industry (IVN) and is widely used in the German speaking countries. IVN has adopted the GOTS standards, and certification is carried out by IMO. Naturland Naturland is a German-based standard that requires organically farmed fibers, full traceability, ecofriendly processing, social standards (following the standards of the International Labour Organization: ILO) and neutral health effects of the final products. JOCA Japan Organic Cotton Association (JOCA) has adopted the GOTS standard. No label Some companies may choose not to put any labels related to organic fiber on their finished products. This can be for a number of reasons; they do not consistently use organic fiber, they are not able to back up claims about organic content, they do not wish to draw attention to the fact they are using organic fiber, or they simply don t see it as a priority. OE Blended 2007 Organic Exchange has developed the OE Blended standard to support companies that choose to use a blend of organic and conventional cotton in their products. OE Blended tracks and documents the purchase, handling and use of certified organic cotton fiber in blended yarns, fabrics and finished goods. It ensures that the products contain certified organic ingredients to the level stated on the product label. The standard does not address any processing. OE 100 Organic Exchange is the in the process of developing the OE 100 standard to support companies that wish to make a claim about the 100% organic fiber content of their products, without addressing any of the processing. The standard tracks and documents the purchase, handling and use of 100% certified organic cotton fiber in yarns, fabrics and finished goods. Soil Association Soil Association has adopted the GOTS standard. Certification is carried out by Soil Association Certification Ltd: the certification arm of the Soil Association.

14 Page 11 Guide to Labeling Organic Textile Products DECISION TREE Labeling Options Summary When deciding on how to label your garments made with organic fibers, you need to answer a number of questions: 1. What countries are you selling your products into? 2. Do you want to make a fiber claim or a full product claim? 3. What percentage of organic fiber are you using in your products? 4. Do you want third-party verification, or will you do your own (and create a company label)? WHERE ARE WE SELLING OUR PRODUCT? US CANADA EUROPE JAPAN Miniumum legal requirements All labeling must conform to the textile labeling laws enforced by the US Federal Trade Commission, and all fiber must be certified to NOP standard at the farm level All labeling must conform to the Textile Labeling and Advertising Regulations enforced by the Competition Bureau of Canada. Canada now has Organic Product Regulations, but they will not be implemented until Dec All labeling must conform to the European Communities Names and Labeling of Textile Products, 1998 All labeling must meet the requirements of the Act Against Unjustifiable Premium and Misleading Presentation. WHAT CLAIMS DO WE WANT TO MAKE? If your goal in using organic fiber is simply to have an impact at the farm level, and you are not wanting to use a standard that addresses processing (eg: environmental or social impacts) then you will be making a fiber claim. If you want to address both the farming and processing impacts, then you will be making a product claim. 1) 100% organic fiber, processed to a standard Product Claim Global Organic Textile Standard (logo pending - can use logo of certifying agency) Naturtextil (IVN) - using GOTS Ecocert Soil Association - using GOTS Demeter Naturland JOCA Pure, JOCA dyed/printed - using GOTS 2) 100% organic fiber content, no processing claims being made Fiber Claim OE 100 Standard (pending) identify organic fiber content in accordance to legal requirement

15 Page 12 3) Less than 100% organic fiber, processed to a standard Product Claim Global Organic Textile Standard (minimum 70% organic fiber) Ecocert Soil Association Using GOTS 4) Less then 100% organic fiber, not processed to a standard Fiber Claim LABELS SUMMARY JOCA Pure, JOCA dyed/printed - using GOTS Naturtextil (IVN) - using GOTS OE Blended Standard Logo Organization Main office Issues addressed* Website Naturland Germany Organic farming, traceability, processing, quality, social standards Demeter Germany, Belgium, Singapore, USA Biodynamic farming, processing, packaging Control Union Netherlands Organic fiber, processing, residues, packaging, social issues IVN Germany Uses GOTS JOCA Japan Uses GOTS OE Blended USA Farming, traceability OE 100 USA Farming, traceability Soil Association United Kingdom Uses GOTS logo pending GOTS International Farming, processing, traceability, social, quality, residues

16 Page 13 Guide to Labeling Organic Textile Products Terms: Farming ILO Processing Quality Residues Social Traceability unless otherwise stated, all standards require organic farming many of the social standards require adherence to the Internation Labour Organization (I LO) conventions ( addresses ginning, spinning, knitting or weaving, dyeing and finishing includes prohibition of certain chemicals, standards for use of chemicals, treatment of effluent some labels set quality standards, as they consider that quality is an environmental issue other labels leave it up to the brand or retailer to take responsibility for the quality of their goods sets limits on the types of amount of residual chemicals allowed on finished products he purpose is to protect the health of the consumer addresses the treatment of workers at some or all stages of textile production note that all standards with proper documentation that will prove the claims being made but some standards address traceability specifically

17 Page 14 Resource List Websites Competition Bureau Canadian labeling laws Demeter EcoCert EU textile labeling GOTS IFOAM IMO Japan Fair Trade Commission JOCA Naturland US Federal Trade Commission textile labeling KRAV NOP Organic Agricultural Centre of Canada Skal Soil Association For the specific use of direct employees of TE Member Companies. Guide to Labeling Organic Textile Products Copyright 2011 Textile Exchange. All rights reserved.