PROPER EXECUTION OF APPAREL TESTING PROGRAM

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1 SCOPE PROPER EXECUTION OF APPAREL TESTING PROGRAM 1.1. This document establishes the proper procedure for executing the apparel testing program. 2 ISSUE/REASON 2.1 Clarify apparel testing procedure for relevant parties and allow vendors/suppliers to prepare for testing requirement. 3 PROCEDURE 3.1 Test submissions 3.1.1 For every test submission, a Testing Request Form (TRF) must be filled out completely and properly. 3.1.2 Fabric TRF test submissions 3.1.2.1 All colorways must be submitted and one style should be referenced per TRF submissions, however: 3.1.2.1.1 If the exact same fabric in the same bulk production run is used across multiple styles, those multiple styles may be referenced together in a fabric TRF submission. 3.1.3 Garment TRF test submissions 3.1.3.1 Only one style may be referenced in the garment TRF submission. 3.1.4 Fill in all fields on the TRF to prevent delays. Labs will contact the factory if there is missing information on the TRF which may extend turn-around time. 3.1.5 Contact your local lab representative for any questions regarding the TRF. 3.2 Fabric Testing 3.2.1 Review the testing protocols and ensure that the fabrics can meet the specified standards/requirements. 3.2.2 Kroger GM testing protocols are available on: https://docushare.cps.bereauveritas.com/docushare /dsweb/view/collection-14490 Page 1 of 5

3.3 Garment Testing Contact your buyer or developer to gain access. 3.2.3 Fabric testing must be done on approved fabrics by Kroger developers and only on the production material. 3.2.4 All colorways must be submitted for testing. 3.2.4.1 Darkest colorway will be tested to full fabric protocol and additional colorways will be tested to the additional colorway protocol. 3.2.5 If the fabric fails testing, contact the Regulatory Compliance Manager immediately at michaele.logronio@kroger.com and copy the Kroger 3.2.5.1 Vendor must submit root cause analysis and corrective action plan (CAP) on the failure. 3.2.5.2 After CAP is approved by Kroger Regulatory Compliance Manager, vendor must retest corrected fabrics. 3.2.5.3 Retest must pass requirements. 3.2.6 Once fabric passes testing, proceed to garment production. 3.3.1 Submit garment for testing only after fit and style have been approved by Kroger Developer. 3.3.2 Garment testing must be from Top of Production (TOP) line and from the producing factory. 3.3.3 For adult garments, submit the darkest colorway, medium colorway, and lightest (non-white) colorway. 3.3.3.1 Darkest colorway will be tested to full garment protocol; medium colorway and lightest (non-white) colorway will be tested to Appearance After Care test line. 3.3.4 For children s garments, submit all colorways for evaluation to the lab. 3.3.4.1 Darkest colorway will be tested to full garment protocol; medium colorway and lightest (non-white) colorway will be tested to Appearance After Care test line. 3.3.4.2 Testing laboratory will also evaluate all colorway and test accordingly for Lead, Cadmium, Phthalate as well as any other applicable regulatory requirement. 3.3.4.3 Ensure that all coloways for children s garments are evaluated by the lab. Failure to do so may result in non-compliance and may hold shipment and/or result in an order cancellation. Page 2 of 5

3.3.5 If the garment fails testing, contact the Regulatory Compliance Manager immediately at michaele.logronio@kroger.com and copy the Kroger 3.3.5.1 Vendor must submit root cause analysis and corrective action plan (CAP) on the failure. 3.3.5.2 After CAP is approved by Kroger Regulatory Compliance Manager, vendor must retest corrected garments. 3.3.5.3 Retest must pass requirements. 3.4 GCC 3.4.1 Once garment passes testing, generate a General Certificate of Conformity (GCC) document with all necessary information filled out. 3.4.1.1 All children s product GCC must be generated by the testing laboratory. 3.4.1.2 A GCC can only be generated with the support of a passing garment test report. 3.4.1.3 If there are any inquiries on the GCC, contact your lab rep. 3.5 Periodical test 3.5.1 Test is required to be performed on each production. 3.5.2 Changes on raw materials, material suppliers, process, production, design and factory will require retest. 3.6 Test Report and GCC Submission 3.6.1 Once garment passes testing, generate a General Certificate of Conformity (GCC) document with all necessary information filled out. 3.6.1.1 All children s product GCC must be generated by the testing laboratory. 3.6.1.2 A GCC can only be generated with the support of a passing garment test report. 3.6.2 Test report completion and GCC creation must be done 4 weeks prior to shipment to allow for time to resolve issues and prevent delays. 3.6.3 Submit final garment test reports and GCC s to bank along with Letter of Credit.. Page 3 of 5

Revision History Rev. No. Revision Date Effective Date Revision Summary Revised by Approved by 01 March 15, March 15, - New Issue - Original Author: 02 March 17, March 17, - Accounts for fabrics that are used across multiple styles. 03 May 15, May 17, - Separation of requirement between adult and children s garments. - Clarifications of different sections. Page 4 of 5

Step #1 Submit Fabric testing after bulk fabric has been approved by Kroger developer. Fabric testing must be on production material. All colorways must be submitted for testing. Fabric testing occurs before garments go into production. Passing tests are required before production can begin. Step #2 Complete Test Request Form (TRF) and submit to lab with fabrics to be tested. Fill in all fields of the TRF to prevent delays. If the exact same fabric is used across multiple styles, within the same bulk production run, those multiple styles may be referenced together in the fabric TRF submission. Any questions regarding the TRF should be directed to laboratory contact. Testing Turn Around Time is 5 working days unless expedited service is requested on the TRF. STOP!!! Failed Testing: If the fabric fails testing, contact the Regulatory Compliance Manager immediately at michaele.logronio@kroger.com and copy the Kroger Vendor must submit root cause analysis and corrective action plan (CAP). Vendor must retest fabrics once CAP is approved by Kroger. Proceed to Step #1 once CAP is approved and as per direction from Compliance team. Step #3 Fabric Passes Testing: Proceed to production. Step #4 Submit Garment testing after fit and style has been approved by Kroger Garment testing must be on Top of Production Samples (TOPs) TOPs are first produced garments off the production line. Test garments must include all trims, findings, fabrics, labels, components, etc. used in production and must be from the producing factory. For adult garments, submit the darkest colorway, medium colorway, and lightest (non-white) colorway. For children s garments, submit all colorways for evaluation to the lab. Passing garment tests are required before the purchase order can ship. Step #5 Complete Test Request Form (TRF) and submit to lab with garments to be tested. Fill in all fields of the TRF to prevent delays. One TRF per style. Do not submit multiple styles on one TRF. A GCC is REQUIRED for all Kroger Imports. Make sure GCC section of TRF is checked. Any questions regarding TRF should be directed to lab contact. Testing Turn Around Time is 5 working days unless expedited service is requested on the TRF. STOP!!! Failed Testing: If the garment fails testing, contact the Regulatory Compliance Manager immediately at michaele.logronio@kroger.com and copy the Kroger Vendor must submit root cause analysis and corrective action plan (CAP). Vendor must retest Garments once CAP is approved by Kroger gmcompliance@kroger.com Proceed to step #4 once CAP is approved and as per direction from gmcompliance@kroger.com. Goods are not approved to ship with Failed Test Reports. Step #6 Garment Passes Testing: Once garment testing report is accepted, General Certificate of Conformity (GCC) will be generated by the lab. Reminder: Purchase Order (PO)is only approved to ship once Passing Fabric and Garment testing is complete and a GCC is issued from the laboratory. Submit final garment test reports and GCCs to bank along with Letter of Credit <END OF DOCUMENT> Page 5 of 5