Industry Problem Solutions

LEAF Labeling Ecologically Approved Fabrics™

Proposed U.S. Apparel Labeling Program Public Review Document

Disclaimer Statement: All information provided in this public review document is provided for the public review process only. Every effort was made to present whole, complete and accurate information.

Table of Contents 1.0 Label Program Overview......................................................................................................3 1.1 Introduction ............................................................................................................................................ 3 1.2 Purpose .................................................................................................................................................... 3 1.3 Goals......................................................................................................................................................... 3 1.4 Program Scope ....................................................................................................................................... 4

2.0 LEAF and SEED Labeling Programs..................................................................................4 2.1 Program Structure and Functions ...................................................................................................... 4 2.2 Public Awareness ................................................................................................................................... 5

3.0 LEAF Label and SEED Label Requirements.......................................................................5 3.1 LEAF Label Requirements .................................................................................................................. 5 3.1.1 Organic/Sustainably Sourced Fiber Criteria: ................................................................................ 5 3.1.2 Environmental Manufacturing/Processing Criteria:.................................................................... 6 3.1.3 Fair Labor Criteria (Manufacturing Facilities): ........................................................................... 6 3.2 SEED Label Requirements................................................................................................................... 6 3.3 Additional Categories ............................................................................................................................ 7

4.0 Apparel Industry Standards..................................................................................................7 5.0 Standards and Certification Agency Criteria .......................................................................8 6.0 Organizational Structure......................................................................................................9 6.1 Board of Directors.................................................................................................................................. 9 6.2 Industry Stakeholder Board................................................................................................................. 9 6.3 Public Awareness Board ..................................................................................................................... 10

7.0 Cost Structure.....................................................................................................................10 8.0 Labeling and Marketing Guidelines...................................................................................10 8.1 FTC Green Guidelines ........................................................................................................................ 10 8.2 Label Licensing Guidelines ................................................................................................................ 10 8.3 Labeling Guidelines ............................................................................................................................. 11 8.4 Marketing Guidelines .......................................................................................................................... 11

9.0 Resources ...........................................................................................................................11 10.0 Appendix ..........................................................................................................................12 10.1 Definitions ........................................................................................................................................... 12 10.2 Proposed LEAF Hangtag.................................................................................................................. 12 10.3 Proposed SEED Hangtag .................................................................................................................. 14

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1.0 Label Program Overview 1.1 Introduction In this Public Review, a new environmental/social responsibility labeling program is being presented to the following:

• Apparel Supply Chain • U.S. Consumer (End User) Marketplace • Standards-Setting Bodies and Third-Party Certification Organizations of the Textile Industry The purpose of the public review process is to introduce a collaborative, unifying eco-labeling concept intended for, and applicable to, garments and potentially other textile products sold in the United States. This review process will allow relevant stakeholders the opportunity to review and provide comments on this proposed program. Please note: Every four weeks during the review, LEAF will post comments received and submit proposed solutions from feedback received that will include a written response to the comment, or group of comments, on a particular issue. All users will be able to view comments, the name of the commenter, and any/all solutions presented both by the commenter and LEAF. Stakeholder feedback should be noted in the comment boxes above.

1.2 Purpose The purpose of the LEAF labeling program is to provide producers and consumers alike with one unifying, comprehensive environmental/social responsibility (SR) labeling program for apparel and other textile related products that are sold in the United States. LEAF will administer and promote an apparel label licensing program that communicates where products have received third-party certifications for environmental and SR claims. Roles and Responsibilities: • Ensure that participating companies hold valid accreditation to a textile standard(s) participating in this program • Verification and review of participating companies and certifiers • Create public awareness for LEAF labeled products, companies, certification groups and standards affiliated with this program • Revise program in accordance with the eco-labeling requirements outlined in the Global Eco-labeling Network (GEN) Standards and Protocol 1.3 Goals LEAF proposes to work in concert with apparel industry stakeholders, U.S. consumers, and participating standards-setting organizations and certification agencies to encourage the following outcomes: 3

• • • • • • • •

Increased demand for and use of organic and sustainable apparel Increased demand for and use of organic and sustainable raw materials Environmentally sound manufacturing and processing techniques Fair Labor practices in manufacturing facilities Fair Trade standards for small-scale subsistence farmers Sustainable packaging practices Humane animal treatment standards Decreased environmental impacts throughout the supply chain

1.4 Program Scope The program is intended for apparel that is sold in the United States. The program may also include other textile categories, e.g. home textiles and fabrics used on accessories (including shoes, bags, purses, etc.). The label is not intended for automotive, industrial or carpet furnishings. Please note: to comment on section 1, please press on the

comment box above.

2.0 LEAF and SEED Labeling Programs LEAF proposes two entry levels to this program: 1.) The LEAF Label represents products certified to at least three categories of environmental and/or social achievement. 2.) The SEED Label represents products certified to at least one category of achievement. Please see section 2.1 for a description of the Standards proposed for this program and the Appendix for proposed LEAF and SEED hangtag formats. 2.1 Program Structure and Functions The LEAF and SEED Logos will be licensed to producers, designers, brands and manufacturers. The LEAF and SEED logos are not considered an endorsement of a company as an entity. Licensing will include use of the LEAF or SEED labels and logos, as well marketing support from Public Awareness Campaigns (see section 2.1.1 for further information on End User and Industry Awareness). The LEAF Label will initially convey certification for the following categories: • • •

Organic/Sustainably Sourced Fibers Environmental Manufacturing /Processing Fair Labor Practices 4

It is proposed that other categories will be added to this program, at a later date. Proposed future categories may include (but are not limited to): • • •

Fair Trade Standards Packaging Requirements Humane Animal Treatment Standards

2.2 Public Awareness A key component to the LEAF program is implementing and administering a public awareness platform. The goal is to deliver clear, concise and easy to understand information to the U.S. marketplace. This will be accomplished through easy to read and understand product labeling, the accompanying LEAF website and other PR related and media-rich awareness activities. Overall public awareness efforts may include: coverage in print/online publications, media-rich awareness strategies, endorsements, TV and radio presence, representation on social networking sites, sustained relationships with the online blogging community, and presence at industry and green/mainstream trade shows and events. It is proposed to work in conjunction with all stakeholders in the supply chain including, participating standards-setting bodies to accomplish these goals. It is also proposed the overall public awareness strategy will be governed by the Public Awareness Board (please see section 6.3). Please note: to comment on this section, please press on the

comment box above.

3.0 LEAF Label and SEED Label Requirements Please note: At this time there are no contractual agreements nor affiliations between LEAF and the standards outlined in this section of the document. 3.1 LEAF Label Requirements To be approved to utilize the LEAF Label, all of the following three standards certification criteria/categories of achievement must be met: 3.1.1 Organic/Sustainably Sourced Fiber Criteria: The Organic/Sustainable Fiber Criteria is a fiber level qualification and enables an end user to know a garment was produced with a fiber that was either ‘organically produced’ or ‘sustainably produced’. A minimum of 70% organic and/or sustainably sourced fibers is required to be present in the overall product to be represented by this category.

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The 70% qualification for this category is based upon the National Organic Program’s (NOP) ruling that any reference to organic content of product is prohibited for less than 70 % organic ingredients1.

3.1.2 Environmental Manufacturing/Processing Criteria: The Environmental Manufacturing/Processing Criteria delineates certification of textile production facilities. This category could include testing for: prohibited and restricted inputs in production stages, risk phrases and toxicity requirements, requirements for separation and identification, spinning, sizing and weaving/knitting, non-woven manufacture, pre-treatment stages, wet processing, dyeing, printing, finishing, accessory requirements, environmental management, waste water treatment, storage, internal quality assurance, technical quality parameters, orientation values for residues, and orientation values for residues in additional materials and accessories. The outlined qualifications for this category are in accordance with the Global Organic Textile Standard’s general and specific requirements for chemicals and processing2.

3.1.3 Fair Labor Criteria (Manufacturing Facilities): Fair Labor is a qualification in which companies must demonstrate compliance with international labor standards. The standards addressed could include the following: No child labor practices, no forced labor, safe and healthy work environment, freedom of association and right to collective bargaining, respect the right to form and join trade unions and bargain collectively, no discriminatory practices, no mental or physical coercion or verbal abuse, working hours comply with the applicable laws but, in any event, voluntary overtime paid at a premium rate, wages paid for a standard work week must meet the legal and industry standards and be sufficient to meet the basic need of workers and their families, and adequate management systems. The outlined qualification for this category are in accordance with Social Accountability International’s (SAI) SA8000 voluntary requirements to be met by employers in the workplace, where the normative elements of the standard are based on national law, international human rights norms and the conventions of the International Labor Organization (ILO) 3.

3.2 SEED Label Requirements To be approved to utilize the SEED Label, one of the following standards certification criteria categories of achievement must be met: 1

Qualifications referenced from the National Organic Program’s (NOP) USDA National Organic Program Requirements for Food Retailers and Distribution Centers, <www.fmi.org/gr/USDA_OrganicProgram.pdf>

2 Qualifications referenced from the Global Organic Textile Standard’s requirements for processing and chemicals, <www.Global-Standard.org> 3 Qualifications referenced from Social Accountability International’s (SAI) requirements for Fair Labor Standards, <www.SA-intl.org>

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• • •

Organic/Sustainably Sourced Fiber Environmental Manufacturing/Processing Fair Labor Practices

3.3 Additional Categories In the future or at the launch of the programs as determined by the Stakeholder Board, the LEAF and SEED Label programs may include additional criteria, such as: Fair Trade Criteria: Applicants must have TransFair USA certification with respect to fair labor conditions, direct trade, democratic and transparent organizations, community development, and environmental sustainability for farmers involved with the production of fibers used in the apparel supply chain. Packaging and Distribution Criteria: Applicants must adhere to packaging and distribution standards as outlined by the Sustainable Packaging Coalition (SPC). Humane Animal Treatment Criteria: Applicants must comply with existing and emerging standards concerning animal well-being issues associated with animal products used in the supply chain. Please note: to comment on this section, please press on the

comment box above.

4.0 Industry Standards The following list outlines industry standards that could potentially correspond to the proposed categories of achievement (see section 2.1) of this program. Please note: At this time there are no contractual agreements nor affiliations between LEAF and the standards outlined in this section of the document. It is proposed the Stakeholder Board will determine which standards are applicable for the LEAF and SEED programs (part of this decision process will also include feedback received during the public review process). Organic/Sustainable Fiber Standards Global Organic Textile Standard (GOTS) Organic Exchange 100 (OE) Global Recycling Standard (GRS) Forest Stewardship Council (FSC) Potentially other standards as recognized by the Stakeholder Board Manufacturing/Processing Standards GOTS BlueSign EU Flower Oekotex 1000 7

Cradle to Cradle (C2C) Fair Labor Standards Social Accountability 8000 (SA8000) Fair Labor Association 3.0 (FLA) GOTS Proposed Standards for inclusion in Future Categories Fair Trade Standards TransFair USA Packaging and Distribution Standards Sustainable Metrics Project (under development by the Sustainable Packaging Coalition) Animal Welfare Standards Certified Humane It has been suggested that some and or all of the following programs be considered for collaboration in addition to the standards outlined above:

Track and Trace Systems Historic Futures Made-By Sustainability Initiatives Sustainable Cotton Project Greenhouse Emissions Carbon Disclosure Project PAS 2050 End Product Standards Oekotex 100 Please note: to comment on this section, please press on the

comment box above.

5.0 Standards and Certification Agency Criteria Standards and Certifying organizations affiliated with the LEAF Program must follow internationally recognized protocol that address the standards development process, as created by ISO 14020 (International Organization for Standardization) or ANSI (American National Standards Institute). Participation in any standards program by a company should be voluntary and accessible to all interested parties – no barriers to trade or organization size. All fees shall be transparent, fair, 8

and equitable. LEAF proposes to work with certification groups approved by affiliate standards. Affiliated certification agencies should comply with the requirements of ISO /IEC Guide 65: 1996 General Requirements for bodies offering certification programs. Please note: to comment on this section, please press on the

comment box above.

6.0 Organizational Structure LEAF currently receives its 501 [c] (3) non-profit status through the umbrella non-profit sponsor organization; the International Humanities Center (IHC) (www.ihcenter.org). All contractual and financial obligations, as well as any intellectual property assets and operational procedures will be managed by the IHC D.B.A. LEAF. LEAF will be comprised of a Board of Directors, a Stakeholder Advisory Board, a Public Awareness Board and a Management Team.

6.1 Board of Directors The Board of Directors will provide leadership concerning the organization’s missions, longterm vision and planning. The Board will review and approve the annual budget and oversee major program policies. 6.2 Stakeholder Board The Stakeholder Board will be led by textile subject matter experts, industry stakeholders, participating standards-setting bodies and representatives from relevant overseeing organizations. This Board will vote on which national and international standards are appropriate for this program and represent the perspectives of industry stakeholders. 9

6.3 Public Awareness Board The Public Awareness Board will be comprised of societal leaders who are interested in increasing public awareness of sustainability issues facing the fashion/clothing/fabrics industries and beyond. This board will advise on the strategy to successfully implement a nationally-scaled consumer awareness and education campaign. This board will represent the perspectives of US society and non-industry stakeholders. Please note: to comment on this section, please press on the

comment box above.

7.0 Cost Structure The cost model goals are to create a program that is: cost effective for participating clients (with special attention to enable affordability of program costs for smaller-scaled companies), implements quality consumer education/awareness campaigns and supports LEAF overhead costs. Multiple pricing options are being evaluated. The final cost model will be determined during the beta trials that follow the public review. Stakeholder input is encouraged concerning the development of a fair and balanced pricing model. Please note: to comment on this section, please press on the

comment box above.

8.0 Labeling and Marketing Guidelines 8.1 FTC Green Guidelines LEAF labeling and marketing guidelines are being developed in accordance with the Federal Trade Commission’s (FTC) Green Guidelines, which require that labels and communications making environmental and social claims: • • • • • • •

Tell the truth Have substantiation Are based on consumer perceptions and require claims controls so they are not misleading Have clear qualifications & disclosures Specify whether claims apply to the product, the package, or both Do not overstate the product attributes General Environmental Claims qualify and identify specific "green" attributes

8.2 Label Licensing Guidelines

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Once a company’s product(s) has been certified to a standard affiliated with the LEAF and SEED Labeling Programs, they then apply for a license which entitles use of the LEAF or SEED logo/labeling options. The goals of the label licensing guidelines are to deliver a labeling system that will work in concert with the inventory, production and distribution systems used by brands/designers/manufacturers, participating standards and certifiers, and retailers. 8.3 Labeling Guidelines Each Client licensing (utilizing) the Label agrees to the following: Use of the LEAF and/or SEED logo is utilized in compliance with the guidelines for mark usage. 8.4 Marketing Guidelines Marketing Guidelines (e.g. the requirements for utilizing the LEAF and/or SEED logos as displayed in the public sphere) are being developed to ensure the integrity of the LEAF brand. This will serve to protect the interests of all companies, standards groups and third-party certification programs associated with this program. Final marketing guidelines will be finalized during the beta trials that follow the public review. In general, however, use of the LEAF and/or SEED hangtag will be the preferred method of LEAF, as these hangtags provide a visual platform to convey categories of achievement to the US consumer in a retail setting. It is also understood this method may not be appropriate or feasible in some cases. Therefore, use of the hangtag will not be required, and other labeling options will be provided, which may include:    

Display on packaging Adhesive labels Corporate website Sewn in or imprinted labels

Please note: a recent and additional format possibility for transmitting information to the U.S. end user may also include an application for mobile devices such as the IPhone, blackberry and amoeba based phones. Please note: to comment on this section, please press on the

comment box above.

9.0 Resources • BlueSign (www.bluesign.com) • British Standards Institution (BSI) (http://www.bsi-global.com) 11

• • • • • • • • • •

• • • • • • •

Certified Humane (www.CertifiedHumane.org) Carbon Disclosure Project (http://www.cdproject.net) Eco-Textile Labeling Guide (http://www.ecotextile.com) Fair Labor Association (www.FairLabor.org) Federal Trade Commission (FTC) Green Guidelines (http://www.ftc.gov) Global Ecolabeling Network (GEN) (www. http://www.gen.gr.jp/) Global Organic Textile Standard (www.Global-Standard.org) Historic Futures (www.HistoricFutures.com) McDonough Braungart Design Chemistry (www.C2Ccertified.com) National Organic Program (NOP) (www. http://www.ams.usda.gov/AMSv1.0/nop) Organic Exchange (www.OrganicExchange.org) Oeko-Tex (www.Oeko-Tex.com) PAS 2050 (carbon footprint)(www.BSI-Global.com) Social Accountability International (SA8000) (www.SA-Int.org) Sustainable Cotton Project (http://www.SustainableCotton.org) Sustainable Packaging Coalition (www.SustainablePackaging.org) Transfair USA (www.TransFair.org)

Please note: to comment on this section, please press on the

comment box above.

10.0 Appendix 10.1 Definitions Certification (Third-party): A scientific process by which a product, process or service is reviewed by a reputable and unbiased third party to verify that a set of criteria, claims or standards are being met. Certification Agency/Certifier: A business, organization or individual that inspects and verifies environmental and/or SR (Social Responsibility) compliance of farms, handling facilities, factories and/or processing plants. Chain of custody: The pathway that a product takes from its point of production to the end consumer, consisting of each entity that takes legal and/or physical possession along this pathway. Claim: Oral, written, implied, symbolic representation, statement, advertising or other forms of communication presented to the public that relate to a product’s status. Consumer: A person who uses goods or services. Used interchangeably with the term ‘end user’. Industry Stakeholder: a person or group involved within the apparel/fabric supply chain of custody practices having a stake, or interest, in the workings of an enterprise, program, service, movement, etc. 12

Inspector: A person employed to conduct inspections of applicants, factories or of production or handling operations. Also known as an auditor. Inspection: The act of examining and evaluating the production or handling operations of an applicant to determine conformance to a standard. Label/labeling: A display of written, printed, or graphic material on the primary container of a product, or any such material affixed to a product or its container. Labeling can also include representations used to communicate environmental and/or social accountability practices. Labeling Ecologically Approved Fabrics (LEAF): A proposed apparel labeling program that presents a unifying, public awareness-based label to the U.S. marketplace. Achievement Criteria Categories: The LEAF and SEED licensing labeling Programs communicate distinct aspects of an apparel products environmental and social life achievement. The proposed categories will be introduced to the end user and industry in a phased process. The proposed categories are as follows (but are not limited to): • Fiber Level Organic/Sustainable Criteria • Environmental Manufacturing and Processing • Fair Labor Future categories may, but are not limited to: • Fair Trade • Packaging and Distribution • Humane Animal Treatment Organic fibers: Fibers derived from agricultural products that are produced in accordance with the National Organic Program (NOP), 7 CFR Part 205. Stakeholders: Individuals or groups who are, or who might be, affected by actions taken by an operation. Example stakeholders for the purposes of this review are: apparel end users, company owners, employees, retailers, certification agencies, standards groups, contractors, manufacturers, suppliers etc. Sustainable fibers: A fiber that can be produced without a significant negative impact on the environment or its inhabitants. Standards-Setting Organization: An entity whose primary activities are developing, coordinating, promulgating, revising, amending, reissuing, interpreting, or otherwise maintaining standards that address the interests of a wide base of users outside the standards development organization. Most voluntary standards are offered for use by people, regulators, and/or industry. 10.2 Proposed LEAF Hangtag (representing environmental and/or social achievements in 3 categories of achievement) The following images are examples of potential LEAF labels and are subject to change 13

dependent upon stakeholder review and feedback.

10.3 Proposed SEED Hangtag (representing achievement in 1 Life Cycle Category) The following images are examples of potential LEAF labels and are subject to change dependent upon stakeholder review and feedback.

(Please see next page)

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