Public Review Document

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.

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: .............................................................. 6 3.1.2 Environmental Manufacturing/Processing Criteria: ................................................... 6 3.1.3 Fair Labor Criteria (Manufacturing Facilities):.......................................................... 6 3.2 SEED Label Requirements .............................................................................................. 7 3.3 Additional Categories....................................................................................................... 7 4.0 Organizational Structure............................................................................................................. 8 4.1 Board of Directors............................................................................................................ 8 4.2 Industry Stakeholder Board ............................................................................................ 8 4.3 Consumer Education Board............................................................................................. 8 5.0 Licensing, Labeling and Marketing Guidelines.......................................................................... 8 5.1 FTC Green Guidelines ..................................................................................................... 8 5.2 Label Licensing Guidelines .............................................................................................. 9 6.0 Resources...................................................................................................................................... 9 7.0 Appendix ...................................................................................................................................... 9 7.1 Definitions......................................................................................................................... 9 7.2 Proposed LEAF Hangtag............................................................................................... 11 7.3 Proposed SEED Hangtag ............................................................................................... 12

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Please note: This review document is a shortened version of the LEAF public review document. The version presented to the industry is a more detailed version that contains industry-relevant sections that do not necessarily pertain to the needs of end user. If you are interested by this more industry-relevant subject matter, however, it is encouraged to review the industry version of this review.

1.0 Label Program Overview 1.1 Introduction In this version of Public Review, a new environmental/social responsibility labeling program is being presented to the U.S. Consumer (End User) Marketplace. The purpose of the 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 the proposed program. Please note: Every four weeks during the review, LEAF will post comments received and submit the conversation online. All users will be able to view comments, the name of the commenter, and any/all solutions presented both by the commenter and LEAF. All feedback should be noted in the comment boxes above.

1.2 Purpose The purpose of the LEAF labeling program is to provide consumers and producers alike with one, unifying environmental and social label for apparel and other textile related products that are sold in the United States. LEAF will administer and promote an apparel licensing and labeling program that communicates to the end user where products have received third-party certifications for environmental and social responsibility (SR) declarations. 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 Ecolabeling Network (GEN) Standards and Protocol 1.3 Goals LEAF proposes to work in concert with U.S. consumers, apparel industry stakeholders and participating standards-setting organizations and certification agencies to encourage the following 3

outcomes:

• • • • • • • •

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

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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 environmental and/or social achievement. 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 three 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. 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 4.3). Please note: to comment on this section, please press on the

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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

Please see appendix for large-scaled version of proposed hangtag format

To be approved to utilize the LEAF Label, all of the following three standards certification criteria/categories of achievement must be met: 5

3.1.1 Organic/Sustainably Sourced Fiber Criteria: The Organic/Sustainable Fiber Category 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 present in the overall product for a product to be represented by this category. 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 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>

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Organization (ILO) 3. 3.2 SEED Label Requirements

Please see appendix for large-scaled version of this proposed hangtag format

To be approved to utilize the SEED Label, one of the following achievement categories must be met: • • •

Organic/Sustainable Fiber (ie. if the cotton is organic or not) 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 3

Qualifications referenced from Social Accountability International’s (SAI) requirements for Fair Labor Standards, <www.SA-intl.org>

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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

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4.0 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 and administrative support staff. 4.1 Board of Directors The Board of Directors will provide leadership concerning the organization’s missions, long-term vision and planning. The Board will review and approve the annual budget and oversee major program policies. 4.2 Industry Stakeholder Board The Industry Stakeholder Board will be led by textile subject matter experts, industry stakeholders and representatives from participating standards-setting bodies and third-party certification agencies. This Board will vote on which standards are appropriate for this program. 4.3 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 nonindustry stakeholders. Please note: to comment on this section, please press on the

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5.0 Licensing, Labeling and Marketing Guidelines 5.1 FTC Green Guidelines

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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

5.2 Label Licensing Guidelines 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 communicate truthful information to the U.S. end user and work in concert with the inventory, production and distribution systems used by brands/designers/manufacturers, participating standards and certifiers, and retailers. Please note: to comment on this section, please press on the

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6.0 Resources • • • • • •

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) Social Accountability International (SA8000) (www.SA-Int.org) Sustainable Packaging Coalition (www.SustainablePackaging.org) Transfair USA (www.TransFair.org)

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7.0 Appendix 7.1 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. 9

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. 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 Categories: The LEAF and SEED licensing labeling programs communicate distinct aspects of an apparel product’s environmental and social responsibility (SR) achievements. 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, 10

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. 7.2 Proposed LEAF Hangtag—large-scaled version The following images are examples of potential LEAF labels and are subject to change dependent upon stakeholder review and feedback.

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7.3 Proposed SEED Hangtag (representing one Achievement Category) The following images are examples of potential LEAF labels and are subject to change dependent upon stakeholder review and feedback.

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