Sustainability and Compliances in Textile Industry

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Global Organic Textile Standard Sustainability and Compliances in Textile Industry Green Business Options -for Textile, Chemicals & Pharmaceutical Sectors Ambernath, India 20 th March, 2016 Sumit Gupta Deputy Technical Director Global Organic Textile Standard (GOTS) gupta@global-standard.org

Man as a Part of Nature Image Source: www.quotelotus.com

Types of Compliances in Textiles Social Compliance (Child, bonded labour, living wages) Environmental Compliance (PCB, GOTS) Testing for Harmful Substances (Brand RSL, GOTS, Oeko-Tex 100)

Social Compliance

Social Compliance Ginning: Seasonal Labour Issues Spinning: Sumangali Practice Garmenting: Child Labour (The Hidden Workforce Report) Image: From the report: The Hidden Workforce by Save the Children

Social Criteria- I Social minimum criteria based on the ILO key conventions is compulsory for all processing and manufacturing stages. The requirements include e.g.: No child labor Payment of living wages Working hours must not be excessive Safe and hygienic working conditions No discrimination, no harsh or inhumane treatment Operators must establish social compliance management tools that support the implementation and monitoring of the social minimum criteria

Social Criteria- II Relevant Chapters in GOTS Version 4.0 Standard: Chapter 3 3.1. Scope 3.2. Employment is freely chosen 3.3. Freedom of association and the right to collective bargaining are respected 3.4. Working conditions are safe and hygienic 3.5. Child labour must not be used 3.6. Living wages 3.7. Working hours are not excessive 3.8. No discrimination is practised 3.9. Regular employment is provided 3.10. Harsh or inhumane treatment is prohibited

Social Compliance Management -I 3.11. Social Compliance Management Companies must have a policy for social accountability to ensure that the social criteria can be met. They must support the implementation and monitoring of the social criteria by: - nominating a person responsible for social accountability - monitoring compliance with the social criteria and implementing necessary improvements at its facilities - informing its workers about the content of the minimum social criteria in the applicable local language(s)

Social Compliance Management -II - maintaining records of the name, age, working hours and the wages paid for each worker - allowing the workers to nominate a representative for social accountability that is able to provide feedback to the management regarding implementation status of and compliance with social criteria - recording and investigating complaints from workers or third parties related to the adherence to the social criteria and maintaining records about any necessary corrective measures arising from them - refraining from disciplinary measures, dismissals or other forms of discrimination against workers for providing information concerning observance of the social criteria

Environment Compliance

Env. Compliances- 1 REACH Primary objective registration of known chemicals and knowledge sharing EU implemented REACH since 2006 South Korea launched its own REACH regulation, Aug 2013 The SVHC under EU REACH was expanded on 17 th Dec, 2015 to include a total of 168 Substances of Very High Concern. (SVHC) RAPEX, European Union Issues notifications to products being sold in EU for various reasons, including chemical risks. 18% of total notifications due to CHEMICAL RISK (410) in year 2012

Env. Compliances- 2 Prop 65, California, USA Prop 65 is enforced through litigations by Citizen Enforcers. Avg settlement in 2010 75,000 USD Number of Fashion Related 60 Day Notices- Prop-65 Reason 2011 2012 Lead or Lead Compounds 66 64 Phthalates 133 343 Other 9 14

Env. Compliances- 3 CPSIA, USA Test & Certify: Federal law requires manufacturers and importers to test many consumer products for compliance with consumer product safety requirements. Based on passing test results, the manufacturer or importer must certify the consumer product as compliant with the applicable consumer product safety requirements in a written certificate that it must provide to retailers, distributors and, upon request, to the government. Civil penalties - for failure to report possible product hazards to the CPSC in a timely manner from $5,000 to $100,000 per violation

Testing for Hazardous Substances (RSL/ MRSL)

Body Parts Susceptibility to Hazardous Chemicals

RSL/ MRSL- 1 Manufacturing Restricted Substance List (MRSL): It normally refers to restricting harmful substances at inputs chemicals stage (dyes, pigments, inks, auxiliaries, chemicals). Restricted Substance List (RSL): It normally refers to testing of textile products to asertain presence of any of the restricted chemicals (residue testing). Brands and Brands Associations have their respective lists, which are supposed to be followed by their suppliers. These lists are stricter than legal requirements.

RSL/ MRSL- 2 Aromatic solvents Chlorophenols (including their salts and esters) APEOs EDTA, DTPA, NTA LAS (Linear alkyl benzene sulphonate), Fluorocarbons (eg- PFOS, PFOA etc.) GMO's and their derivatives (including enzymes) Halogenated solvents Functional nanoparticles Halogen containing compounds a-mes (methyl ester sulphonate (C16/18)) Prohibited Prohibited Prohibited Prohibited Prohibited Prohibited Prohibited Prohibited Prohibited Prohibited Prohibited

RSL/ MRSL- 3 Plasticizers Prohibited Quaternary ammonium compounds Prohibited Substance that are legally restricted internationally Prohibited Inputs assigned risk phrases (health) 67/548EEC Prohibited Risk phrases (environment) 999/45EC, 2006/8/EC Prohibited Ammonia Treatment Prohibited Chlorine based Bleaches Prohibited Chlorination of wool Prohibited Dyes with heavy metal (Except Fe) in basic structure Prohibited

Feasibility

Traceability

Traceability

Traceability Traceability is the ability to track forward/ backward the movement through specified stage(s) of the extended supply chain. Sustainable and transparent supply chain is vital for a brand s future. Helps to ensure security of long term supply as well as has a positive impact on the social and environmental conditions.

Levels of Traceability Lot Traceability: (Level 1 traceability) Component Traceability: (Level 2 traceability) Source Traceability: (Level 3 traceability and beyond)

Benefits of Traceability- Manufacturers Authenticity Guarantee : Particularly for luxury, high-end and safety critical products Quality Control: Monitoring quality of raw materials/ manufacturing process Reputation: Traceability serves to ascertain the origins of raw materials (e.g. for reasons of environmental damage, child labour, animal abuse etc.) Standard Audits: Traceability is ultimately a built in procedural and compulsory aspect Savings/ Efficiencies: It reduces the person hours required to track an order in case of complaints/ investigations post shipment.

Benefits of Traceability- Brands Sensational opportunity to masscustomise marketing efforts and consumer engagement It fosters the customer s trust towards a brand and its products suggesting safety Answers customers questions about sourcing and manufacturing of the products they are going to buy Reputation

Practicing Traceability in your Factory Internal Colour Codes: An individual label mentioning details of the lot, shade, buyer, variety, organic, etc for trolleys/containers used. ERP Solutions: Unique tracing program ensures/captures lot numbers and consignment numbers at each stage to trace origins of a product for concrete traceability. Internal Compliance: Minimizes any incidence of contamination. Peer to Peer Internal Inspections: Ensures unbiased monitoring and helps to conduct an exhaustive review of the compliance. Worker Education: Extended awareness about risk of mixing and contamination can be highly useful.

Certificates along the supply chain (slide courtesy of Textile Exchange)

Certification Systems along Supply Chain Cotton Farm/Collector Government regulated standards Processing Units Industry voluntary standards Retailer Industry voluntary standards Scope & Transaction Certificate Scope & Transaction Certificate Scope & Transaction Certificate

Mass Calculations and Traceability Farmer / Ginning Mill / Collector Spinning Knitting / Weaving/Dyeing Finishing End Product Yield Production 1000 tons 500 tons : Factory A 500 tons : Factory B 200 ton: Factory A1 300 ton: Factory A2 100 tons : Factory C 100 tons : Factory D 200 tons : Factory E 100 tons : Factory F 50 tons : End Buyer 1 50 tons : End Buyer 2 Note: There is a production loss due to wastage at every processing step. The above figures are for representation purpose only.

Labelling

Correct and complete labelling contains the GOTS logo (or the wording Global Organic Textile Standard or GOTS) the GOTS label grade ( organic (95-100% organic fibre) or made with (x%) organic materials (70-94% organic fibre) the reference to the certifier - this can be the full name, short form or certifier s logo the license number of the certified entity Organic certified by Certifier XY 12345

Samples for correct and complete labelling A B C Organic T-Shirt Certified by Certifier XY 12345 Organic XY 12345 Made with 90% organic cotton XY 12345 Product name can be added to label grade organic Shortest labelling option possible; ref. to certifier can be part of the license number Black/white version; Label grade made with organic correct (70-94% organic fibre)

Samples for incorrect and incomplete labelling D E F 100% Organic 12345 Organic certified by Certifier XY 70% Organic cotton certified by Certifier XY 12345 100% organic not possible as label grade; Reference to certifier missing Garment must be white; License number missing Old GOTS logo!; Label grade is made with (70%) organic

Off product logo use by companies for advertising purpose (chapter 8, GOTS Licensing & Labelling Guide) Principle: Use allowed in appropriate and unambiguous context only Certified entities may advertise their certified products and the fact that their company is certified Retailers may advertise their GOTS Goods that are marked with the GOTS logo If the products are finally not labelled in the retail trade, they must not be advertised with GOTS logo / as GOTS certified

Unauthorised Referencing to GOTS Samples of unauthorised self-claims for non-certified products: This t-shirt is made from (x%) GOTS certified fabric (or yarn or cotton) The textile fibres used in this mattress are GOTS certified => No reference to GOTS is permitted for (final) textile products, if certification is valid for previous stages or for specific components of the product only

Labelling Visible commitment to the end consumer 12345

Labelling Release & Design Approval Design Approval: The design must be approved by the manufacturer s certification body for GOTS, using form- Labelling Release for GOTS Goods. Buyer s Label: Labels / handtags provided by buyer also need to be approved by manufacturer s certification body, prior to application.

EcoLabels

EcoLabels- Key Features Voluntary in general Third party and independent Based on scientific evidence Distinctive on environmental performance

EU Eco-labelling Scheme (EU Flower) Established in 1992 Type I voluntary label Criteria developed considering the life cycle Important product categories are tourist accommodation services, textiles products, paints and varnishes, and cleaners Majority of applying companies come from Italy, France, and Denmark Few Asian companies also awarded EU Ecolabel so far Most of the licenses given to Textile products.

Global Organic Textile Standard (GOTS) Latest version 4.0, launched in March 2014. ISO Type I Standard More than 3,800 certified textile operators in more than 50 countries Worldwide leading standard for textile goods using organic fibres + environmental + social criteria + traceability Residue testing included Min 70% of the fibre material must be certified organic Widely supported by leading brands Also known as Gold Standard for Sustainability

Organic Content Standard (OCS) Developed and Controlled by Textile Exchange, USA Latest version 2.0 launched in Jan 2016 Requirement for Organic fibre use and traceability, but not environment/ social OCS: Min 95% - certified organic fibre content OCS Blended: Min 5% - certified organic fibre content Residue testing excluded Supported by brands

Global Recycled Standard (GRS) Developed and Controlled by Textile Exchange, USA Latest version 3.0 launched in Aug 2014 Tracking and verifying the content of recycled materials in a final product Min 20% recycled content Defines Production Requirementsincluding social & environment criteria Accepts GOTS Positive List for processing inputs chemicals Residue testing excluded

Brands Perspective

What does a Brand/ Factory looks for improvement because of standards Technical: All raw materials screened; Fibres, social & environment are well addressed Time, space, people management with traceability Workers Confidence Good work environme nt Consumer Assurance Vendors Credibilit y Economically viable

Benefits from standards Nutzen von Nachhaltigkeitsstandards für die Unternehmen (vgl. ISEAL 2010, 12)

Brands Supporting Organic Cotton & GOTS_1 Source: http://cottonedon.org/whoscottonedon

Brands Supporting Organic Cotton & GOTS_2 Source: http://cottonedon.org/whoscottonedon

Brands Supporting Organic Cotton & GOTS_3 Source: http://cottonedon.org/whoscottonedon

Background of GOTS Standard

Global Organic Textile Standard (GOTS) GOTS is recognized as the leading processing standard for textiles made from organic fibres worldwide. It defines high level environmental criteria along the entire supply chain of organic textiles and requires compliance with social criteria as well.

Global Organic Textile Standard (GOTS) Processing Standard for textiles made from organic fibres. Environmental Criteria Social Criteria Entire Supply Chain Covered ISO Type I Standard

Basic Features of GOTS 70 % Organic Fibers Environmental and Social Criteria All Processing and B2B Trading Stages Independent Certification

Dual System for Quality Assurance On-Site inspection On-site inspection of the entire processing chain up to the import level Annual inspection cycle Organic product flow, environmental and social criteria subject to inspection & Residue Testing Limit values for residues Risk assessment of contamination Analysis in ISO 17025 accredited labs

Criteria: Material Composition I Criteria Fibres Allowed Fibres Not Allowed Item Cotton, Bast, Silk, Wool, Other Animal Fibres (Certified Organic)- EC/NOP/IFOAM Conventional Cotton, Conventional Angora Wool, Virgin Polyester, GMO, Asbestos, carbon, steel, Acrylic Fibres Restricted Synthetic & Regenerated (Max 10%) Special Conditions (in Restricted Fibres) Special Conditions (Regenerated fibres) Special Conditions (Synthetic fibres) For socks & Sportswear, including Yogawear (Max 25%) Regenerated fibres from organic raw materials, from certified sustainable forestry management are permitted now up to 30% Recycled synthetic fibres are permitted now up to 30%

Criteria: Material Composition II The use of conventional cotton, conventional angora wool, virgin polyester, acrylic, carbon and silver fibres is NOT possible Regenerated and synthetic fibres made from environmentally improved raw materials are permitted up to 30% Regenerated fibres that are from certified organic raw materials, sustainable forestry management or recycled are permitted now up to 30% for label grade made with organic Certified recycled synthetic fibres are permitted now up to 30% for label grade made with organic Adequate verification proofs added to the manual For conventional natural, regenerated and virgin synthetic fibres, which are not banned in GOTS, the previous rule (use up to 10% resp. up to 25% in socks, leggings and sportswear) is still in place

Key criteria for all Facilities Along the Supply Chain Environmental management requirements (e.g. monitoring water and energy use, target goals and procedures to reduce consumption, monitoring waste and disposal) Waste water requirements for wet processing stages (e.g. functional treatment plant in place, limits for specific parameters) Internal quality assurance (identification and separation system, product flow documentation) Social minimum criteria based on ILO key conventions (e.g. no child labour, no excessive working hours, health & safety criteria)

Product Specific Key Criteria for a GOTS Certified Textile Product Use of certified organic fibres (min. 95% for organic label grade, min 70% for made with organic ) Requirements for additional fibres, accessories, packaging (e.g. all polyester used in fabric must be recycled; no PVC, nickel or chromium) All chemical inputs must be approved prior to usage (e.g. strict criteria related to environmental and health hazards; no use of any Greenpeace detox chemicals ; worldwide no use of any substances banned in any legislation; no formaldehyde, GM or nano particles -> processors receive positive lists containing trade names of approved inputs) Strict RSL requirements on the final product

Restricted Criteria for Additives in GOTS Section 2.3.1: Azo dyes and pigments releasing carcinogenic arylamine compounds (MAK III, category 1,2,3,4) Section 2.3.2: Certain preparations which contain at least one substance which is classified with any of hazard statements Section 2.4.6: Dispersed dyes known to be allergenic Red List of the IUCN: The use of natural dyes and auxiliaries that are derived from a threatened species are prohibited

Hazards Data Your Certification Body will do an evaluations and Risk Assessment of your products based on documents submitted and suggest on testing requirements. Toxicity Oral Toxicity LD50 > 2000 mg/kg 2) Aquatic Toxicity LC50, EC50, IC50 > 1 mg/l Relation of biodegradability / eliminability to aquatic toxicity Only allowed, if: < 70% and > 100 mg/l > 70% and > 10 mg/l > 95% and > 1 mg/l

Image: www.deviantart.net Assessment of Chemical Inputs/ Inks/ Auxiliaries All Chemical Inputs need to get GOTS Approval Preparations evaluated and their Trade Names have to be registered on approved lists prior to their usage Alternative Trade Names of same products also need to be separately listed in Positive List MSDS to be prepared according to a norm or directive recognised by GOTS Processors (like printing units) can request for a copy of Positive List from their Certification Body

Low Impact Dyes and Chemicals Prohibited and restricted inputs Requirements related to hazards and toxicity Assessment of chemical inputs Limit values for restricted substances Details to be submitted: MSDS Test Reports Calculated toxicity values Non-GMO Declaration (s) Any other documents asked by CB

MSDS Applicable recognised norms or directives for preparing MSDS - ANSI Z400.1-2004 - ISO 11014-1 - 1907/2006EEC (Reach) - 2001/58/EEC - GHS (Global Harmonised System) - JIS Z 7250:2005, Part 1

Environment Criteria- Textile Companies Energy & Water Consumption Data must be available Waste & Discharges Chemical & Sludge Disposal Staff Training Max COD content of discharged water: 20 g/kg of textile output ph of discharged water 6 to 9 Max Temperature of discharged water 35 C GOTS Monitor (Water/Energy) is really helpful here

Positive lists Statistics Positive lists according to GOTS Version 4.0 are prepared for: 479 suppliers of colourants (dyestuffs and prints) and auxiliaries They contain (status 31.12.2015) 5042 trade names of colourants and 7110 trade names of auxiliary agents --------- Figures for 2014 : 409 suppliers, 3238 colourants, 5823 auxiliary agents

GOTS 4.0 Minimum Social Criteria Social criteria based on the International Labor Organization key norms is required for all processing and manufacturing stages. This includes no child labor. Also under current Version 4.0: Health and safety training must include fire prevention training and evacuation drills Protective equipment given to the workers is used whenever necessary MSDS s for all chemicals used must be maintained, and applicable health and safety measures for handling and storing must be met.

GOTS: International Recognition U.S. Department of Agriculture: policy memorandum (May 20, 2011) explicitly recognizes GOTS and its label grade organic : Textile products that are produced in accordance with the Global Organic Textile Standard (GOTS) may be sold as organic in the U.S. Note that this does not entitle use of the USDA seal. IFOAM endorses GOTS as the minimum reference for organic textile processing. The endorsement letter (April 23, 2014) includes the recommendation to governments not to start development of redundant standards and regulations but to make references to GOTS as processing standard for textiles labelled organic. Greenpeace International Textile Procurement Policy (October, 2012) states that all cotton-based textiles used by volunteers, activists, or staff must be certified to GOTS or the equivalent.

Label Grades Using 95 100% organic fibers: Using 70 94% organic fibers: Organic Certified by [certifier s ref.] License no. [12345] Made with (x%) organic materials Certified by [certifier s ref] License no. [12345]

The Gold Standard for Sustainability

GOTS- an Ideal Sustainability Tool Covers all natural textile fibres Covers all processes in manufacture Covers Chemical Restrictions Covers Product Performance Covers Waste Management to check environment pollution Covers Social Aspects (ILO) Covers Work Environment Covers Water and Energy Management GOTS is legally registered as a Non-Profit Organisation in Germany. Hence GOTS has no commercial interest and is working for upliftment and safety of people and stakeholders involved

A post-toxic world is not only desirable, it s possible. Together we can create it.

Global Organic Textile Standard Thank You! Sumit Gupta Deputy Technical Director Global Organic Textile Standard (GOTS) gupta@global-standard.org +91 9892270594