Textile Exchange CCS Implementation Manual Version 1.0-2012 CCS Implementation Manual 2012 CS CONTENTCLAIM CSTANDARD 1
Table of Contents Introduction... 3 SECTION A: CCS Standard Interpretations... 4 A1 Scope... 4 A1.2 Application of the Standard... 4 A1.3d What is outside the scope of the Standard?... 4 SECTION B: General Principles for Certification... 5 B1 General Requirements for Certification... 5 B1.2 Records... 5 B1.3 Staff and Management... 5 B2 Auditing Requirements... 5 B2.1 Inspection Requirements... 5 B2.2 Frequency of Inspections... 5 B2.3 Inspection Coverage... 6 SECTION C: Certification Requirements... 7 C1 Documenting the purchase and sale of CCS inputs and outputs... 7 C1.1 Inputs... 7 C1.3 Mass balance test... 8 C2 Managing CCS goods during production... 9 C2.3 Segregation... 9 C2.4 Identification... 9 C3 Packaging and Transporting CCS Products... 9 SECTION D: Appendix... 11 D1 Frequently Asked Questions... 11 2
Introduction The CCS Implementation Manual provides interpretations and clarifications for the Content Claim Standard and its supporting documents. All guidance given in the manual is to be considered binding to Certification Bodies working with, and Organizations certified to, the Content Claim Standard. This manual will be updated regularly to address areas of uncertainty or to give further detail in the application of the standard. It is up to all users of the standard to regularly check for the most current version of the manual found at www.textileexchange.org/content/content-claim-standard. The manual does not change or alter any of the criteria of the standard, but rather is intended to support correct and consistent application of the standard. Note that the Manual is divided into two sections; the first gives guidance on specific requirements of the standard, and the second addresses frequently asked questions that generally refer to the way that the standard is applied. 3
Section A - General Information A1 - Scope A1.2 Application The CCS applies to organizations that wish to demonstrate the validity and legality of the material content claim of the products they buy, sell and/or produce. It provides third party verification of the amount of a given material being claimed in a final product. It addresses the flow of goods within and between companies, and covers manufacturing, storage, handling, and shipping. Guidance: CCS certification applies to the full supply chain, from the source of the input material; typically to the last point of production or sale to the brand or retailer that is selling to end-consumers. Note that if a brand or retailer is receiving CCS goods and selling them on to other brands or retailers, they will need to be certified. A1.3 What is outside the scope of the Standard? A1.3d The Standard does not address any processing inputs. Guidance: Processing inputs are those materials or substances that are used in the processing of products, and that do not become a significant part of the product being produced. Examples would be chemicals used in dyeing and finishing, or detergents used in scouring. 4
Section B - General Principles B1 - General requirements for Certification B1.2 Records The organization shall maintain complete and up-to-date records to demonstrate conformity with all requirements of the CCS. Guidance: These should include results from regular internal mass balance tests, as well as a material flow diagram for all CCS products. The organization shall keep complete and up-to-date records of the description, quantities, origins and/ or destinations of all CCS products received and delivered. Guidance: Note that these records must be matched up with supporting CCS transaction certificates. B1.3 Staff and Management The organization shall maintain and communicate clearly defined roles and responsibilities for all staff and management that may have an impact on the implementation of the Standard. The organization shall appoint a management representative to be responsible for the overall compliance to the CCS standard. The staff responsible for each procedure impacted by CCS will be identified and given proper and regular training with regards to the implementation of the Standard. Auditable records are to be kept of staff training related to the CCS. Guidance: Training should be updated at least once a year. See the CCS Training Guide for further guidance B2 - Auditing Requirements B2.1 Inspection Requirements Organizations involved in the manufacturing and handling of CCS products, from the initial processing of the received Claimed Material to final packing, as well as traders of CCS products, must be inspected by a certification body licensed by Textile Exchange, and must hold a valid scope certificate. Guidance: Licensing by TE will involve accreditation by a professional third-party accreditation body. B2.2 Frequency of Inspections Inspections are to be carried out on an annual basis. The certification body has the right to carry out unannounced inspection visits. The visits shall cover in particular those units or situations where there may be specific risk of confusion or exchange of CCS 5
products with other products. Guidance: Inspections must be carried out no less than 10 months after, and no more than 12 months after the last day of the previous inspection. Certification decisions must be made within 2 months of the inspection. Non-conformities must be corrected within 2 months of the certification decision. Certification bodies that are certifying more than 50 sites to the CCS must perform a minimum of 2% unannounced inspections. No more than 48 hours notice can be given in advance on an unannounced inspection. B2.3 Inspection Coverage The certification body shall make a full physical inspection of the records, production processes and storage units at each site. Note that external storage units being used for CCS products must be declared and will be subject to inspection. Further details on inspection requirements are found in the CCS Implementation Manual. Guidance: In advance of each inspection, the organization must prepare and submit to the CB a document that contains: a full description of the production units including: name of each unit name and location of the site activity being performed a list of all the practical measures taken at the level of the unit to ensure compliance with the CCS standard a declaration that the organization is performing its operations in accordance with the CCS standard The description, practical measures list, and statement of compliance with the Standard must be signed by a representative of the organization. This document will be verified by the certification body during the certification process. If deficiencies and non-compliances with the requirements of this Standard are found, the certification body will issue an inspection report to the organization. The organization must countersign this report and take necessary corrective measures. Certification will be given only after deficiencies or non-compliance issues have been corrected by the applying organization and confirmed by certification agency. 6
Section C - Certification Requirements C1 - Documenting the purchase and sale of CCS inputs and outputs C1.1 Inputs: Records must be maintained to enable the organization and the certification body to track the Claimed Material as it moves through and between the different processing operations. Records must be current, complete, accurate, easily auditable and understood, and must be held for at least five years. Transaction certificates (Appendix D2.3) must be used to capture the transfer of goods from one organization to another. Transaction Certificates may only be issued by the certification body that has issued the Scope Certificate for the organization. The information that certifiers will look for and verify includes: the identity of the Claimed Materials or CCS inputs being supplied, the quantities, and the supplier of the inputs the identity of the CCS products being produced, the quantities, and the consignees or buyers of the outputs the relationship between the amounts of CCS inputs and outputs Guidance: Note that the CB must review the documents and amounts before issuing a TC, with all inputs accounted for through valid TC s. At a minimum the CB will check against the written requirements of the standard (C.1.) as well as: copies of invoices/shipping documents and TC s for inputs that will be used to produce CCS goods amounts of stock on hand for inputs that will be used to produce CCS goods expected gain or loss during the production process(es) amount of CCS product being shipped and amount being put into stock copies of invoices/shipping documents and TC s for CCS goods that are being sold If the organization has issued 12 or less TC s, then all TC s must be inspected. For amounts over 144 TC s, the CB must inspect the square root of the total number of TC s issued over the year. If one TC is missing or is wrong, then there is cause for a non-conformity, and a root cause analysis must be done, including investigation into the extent of the problem, to see what the corrective action should be. If only a statistically minor number of mistakes are found, then a simple correction can be made, but if there is evidence of regular errors, then a full corrective action with follow up will be required. It will be up to the discretion of the certifier to review a greater number of TC s, and to determine what correction actions should be taken. C1.1a For Claimed Materials entering the supply chain from an outside source: For materials entering the supply chain, there must be a document giving the name and address of the supplier, the quantity and description of the goods, reference to claims being made about the material along with any corresponding verification or certification. 7
Guidance: Shipping documents and invoices can be used to supply this information, or if a separate document is created, they must contain the same information about the identity and quantity of the claimed material. Note that any claims being made about the attributes of the claimed material (eg: social, environmental, quality, performance) that may be carried through to final product claims should also be included. C1.1b For products already certified to CCS: A transaction certificate confirming that CCS inputs have been produced by a supplier that has been certified to the CCS or an accepted equivalent standard. The organization shall check the supplier invoice and supporting documents to confirm that the date, quantity, blend percentage and material description all conform to the TC. Guidance: Note that TC s from any standard that uses the CCS for its chain-of-custody verification (eg: Organic Content Standard, Global Recycle Standard) or that has been approved as having equivalent requirements (eg: Global Organic Textile Standard) will be accepted. All non-ccs standards must be submitted to Textile Exchange for approval (with the input of the MTWG). C1.1c CCS products received from an internal source: For goods that are flowing from one production unit to another within the same organization there must be corresponding documentation that references the initial Claimed Materials, the quantity, blend percentage, and description of the CCS products being received. Guidance: Example: a factory purchases fiber and receives a transaction certificate for this, then manufactures yarn and fabric internally. The factory will document the transactions from business unit to business unit, connecting the material with the original transaction certificate. C1.3 Mass balance test For each production step, the records must demonstrate the balance between the CCS inputs and the outputs containing the declared final amount of Claimed Material. All calculations are done based on the weight of the materials. In its simplest form, the equation is: (A+B)*(1-C) = D containing A/(A+B) % of material A A = Amount of claimed material by weight B = Amount of non-claimed material by weight C = Percentage of loss during production D = Amount of final product by weight The calculation must also take into account stock levels and rejected goods. When the properties of the claimed material vary significantly from the other materials, and the variance could lead to significant differences in gain or loss in production between the different materials, the organization must show that they are taking this into consideration in their own calculations, and the CB will check these. 8
The final percentage of gain or loss will be compared to the expected percentage and any differences will be investigated. Deviations of over 5% of the expected amounts will be investigated and may result in a non-conformity assessment. Guidance: Companies will be required to submit their formulas and sample mass balance calculations to their certification bodies in advance of an inspection. C2 - Managing CCS goods during production C2.3 Segregation Claimed Materials must be kept separately from non-claimed Materials and CCS products must be separated from other products of the same type. Extra precautions must be taken where Claimed Materials or CCS products are being shipped, stored or produced alongside non-claimed Materials or products of the same type to ensure that no confusion or substitution occurs. Sufficient steps must be taken to ensure that no significant amount of non-claimed material is mixed in with the claimed materials during production, handling, shipping or storage. Guidance: The organization shall have clear procedures for segregating and clearly identifying the Claimed Materials or products during production, handling, shipping, and storage. Steps must be taken to ensure that the claimed material amount is not compromised by any other materials (for example, if organic cotton is being processed through a gin, the machinery must first be cleaned out, or the first bale of organic fiber that is processed shall be sold as conventional). C2.4 Identification Claimed Materials or CCS products must be clearly identified and tracked as they move through production. This may include, but is not limited to, direct labelling of Claimed Materials or CCS products, machines, storage vessels, or storage areas. Guidance: Note that in some cases it may be necessary for the Claimed Materials or CCS products to be labelled directly, while in others, it will be sufficient for the machines, carrying vessels and storage containers or areas to be clearly signed. It may also be possible that no identification is needed, as in the example of a spinning mill that only processes 100% organic cotton. Labels and signage must be visible and understandable by all workers operating in the area. Final products that are to be sold to consumers may not have the CCS logo or name on them. C3 - Packing and Transporting CCS Products The organization shall ensure that the products containing Claimed Material must be transported to other units, including wholesalers and retailers, only in appropriate packaging, containers or vehicles that are closed in such a manner that substitution of the content cannot be achieved without manipulation or damage of the seal. All shipments of CCS products must have a label stating: 9
the name and address (city and country) of the producer or, where different, of the owner or seller of the product the name and address (city and country) of the consignee the name of the product, including a reference to the Claimed Material content (expressed as a percentage) of the product being shipped the name of the transporter reference to the Content Claim Standard, the name of the certification body and the identification number (project number) of the certification body the lot identification number quantity of products date of shipment Alternatively, this information can be presented on an accompanying document, as long as such document can be undeniably linked with the packaging, container or vehicle of the product. Guidance: Note that it is possible to mix CCS and non-ccs products; however within that container/ box/shipment the CCS products must be have clear identification. In the case that CCS is being used in a standard with a consumer-facing logo, the logo will be sufficient, but if there is not a consumerfacing logo, another means of identification will be required and must be attached to the CCS products in a way that they cannot be easily moved to other products. 10
Section D - Appendix D1 - Frequently Asked Questions List of Questions 1. How can the CCS name and logo be used? 2. Do retailers that import goods (certified products) need to be certified? What about brands/retailers? 3. Do importers dealing with certified products need to be certified and pay a fee? 4. Can a core operation that is sub-contracted be inspected as part of the contracting unit s certification? 5. Can sewing be a subcontracted operation, and therefore exempt from inspection? 6. Can dyeing be a subcontracted operation, and therefore exempt from inspection? 1. How can the CCS name and logo be used? The CCS cannot be used for any communication to consumers; it is solely intended for businessto-business communications. Organizations may use the CCS name and/or logo in their written or electronice marketing or transaction documents to other organizations, as well as internally. For the purpose of maintaining the clear identity of CCS products, the CCS logo may also be used to identify certified products or their containers as they move through the supply chain. 2. Do retailers that import goods (certified products) need to be certified? What about brands/ retailers? No: if the retailer is only selling directly to end consumers, and not to other shops, certification is not required. However, if there is a brand/retailer that sells to other retailers, or if they are re-packaging or relabeling the goods, they would need to be certified to the standard in order to claim certification. 3. Do importers dealing with certified products need to be certified and pay a fee? As an importer you are not required to pay a fee unless you get certified yourself. You are required to be certified if you will be re-packaging the goods in any way, applying the standards logo yourself, or selling the products to companies other than your own. 4. Can a core operation that is sub-contracted be inspected as part of the contracting unit s certification? Examples of sub-contracted core processing operations for textiles include ginning, spinning, knitting or weaving and all must be inspected and certified. The sub-contracted unit can be inspected and certified independently from the contracting unit, or it can be inspected and certified as a part of the contracting operation s certification. If the sub-contractor is certified as part of the contracting operation s certification, the subcontractor cannot advertise itself as certified, and they would be certified for only 11
those products which are for that contracting unit and not work done for other clients. 5. Can sewing be a subcontracted operation, and therefore exempt from inspection? As long as the sewing factory does not take ownership of the goods, and the goods can be tracked through the mandatory documentation, then it is not a requirement to have the sub-contracted sewing factory certified. However, the certification body will check that the cutting records are available through the owner of the goods and that the product flow is fully traceable there. The certification body still has the right to require an inspection if they feel it is needed to fully verify all parts of the chain. 6. Can dyeing be a subcontracted operation, and therefore exempt from inspection? For chain of custody standards, although a product sent to a dye house under a sub-contracting arrangement falls under the same guidelines as all other sub-contracted processes, it is strongly recommended that certification bodies do at least one initial inspection of a sub-contracted dye house to fully understand the processes being used, and the way that the documentation of product flow is being handled. This is especially relevant for organic cotton certification. The reasoning behind this is that there is the potential for issues down the line: if any contaminates were to be found in the final product, it would be very difficult to determine the source of any cheating or inadvertent contamination. It would be much easier to rule out the dye house up front, just as the spinners, knitters and weavers (all core operations) should prevent fiber flying. 12