Ready To Manufacture VERSION 2.0 INDEX Index Introduction 1 Scope 1 Objective 1 RTM Description 1 Key Definitions 3 A. Good Manufacturing Practices and Best Practices for INDITEX Direct Suppliers and Sub-Suppliers 6 1. INDITEX Direct Supplier and Sub-Supplier Staff 7 1.1. INDITEX Product Health and Safety Standard Compliance Manager 7 1. 2. Training of the INDITEX Product Health and Safety Standard Compliance Manager 8 2. Traceability Documents 9 2.1. Purchase Orders to Suppliers 9 2.2. Documentation and Records 9 B. Good Manufacturing Practices and Best Practices for Mills 11 1. Mill Staff 12 1.1. INDITEX Product Health and Safety Standard Compliance Manager 12 1. 2. Training of the INDITEX Product Health and Safety Standard Compliance Manager 13 2. General Warehouse Conditions 2.1. Stock Management and Traceability 3. Raw Materials Warehouse 13 13 15 3.1. Raw Material Traceability 15 3.2. Fiber Composition Analysis 15 4. Auxiliaries and Dyestuffs/Pigments Warehouse 16 4.1. CTW, RTM and MRSL Hard Copies Availability 16 4.2. Auxiliaries and Dyestuffs/Pigments Information 16 4.3. Auxiliaries and Dyestuffs/Pigments Repackaging and Relabeling 18 4.4. Auxiliaries and Dyestuffs/Pigments Weighing 19 4.5. Dyestuffs/Pigments Specific Storage Conditions 21 4.6. Auxiliaries Specific Storage Conditions 22 5. Finished Goods Warehouse 23 5.1. Finished Goods Identification 23 5.2. Management of CTW Non Compliance Finished Goods 24 6. Work in Progress 6.1. Internal Orders Management 7. Dyeing and Washing 7.1. Dyeing and Washing Recipe 25 25 25 25 INDEX 8. Printing 26 8.1. Printing Conditions Criteria 26 8.2. Printing Recipe 28 8.3. Printing Paste Conservation 28 9. Water Discharge Effluents 9.1. Water Discharge Effluents Control 10. Production and Chemical Products Control 29 29 29 10.1. Analysis Requirements for Production Control 29 10.2. Chemical Products Selection 30 10.3. Chemical Products Suppliers Evaluation 31 10.4. Analysis Requirements for Chemical Products Control 32 10.5. Required Instrumentation for In-House Analysis 33 10.6. Outsourced Laboratories 35 10.7. Control Records 36 11. CTW Management 36 11.1. Purchase Orders to Suppliers 36 11.2. Documentation and Records 37 12. Annexes 39 Annex I. Template for Raw Materials and Greige Garments Traceability 40 Annex II. Template for Auxiliary Products and Dyestuffs/Pigments Stock Traceability 41 Annex III. Internal Order Template 42 Annex IV. Main Corrective Actions to Manage CTW/MRSL Non-Compliances 43 Annex V.a. Analysis to be Performed in Outsourced Laboratories for Arylamine Control of the Production 44 Annex V.b. Workflow of the Analysis to be Performed in Outsourced Laboratories for Arylamine Control of the Production 48 Annex VI.a. Analysis to be Performed in Outsourced Laboratories for Formaldehyde Control of the Production 49 Annex VI.b. Workflow of the Analysis to be Performed in Outsourced Laboratories for Formaldehyde Control of the Production 52 Annex VII. Dyeing/Printing/Washing Recipe Template 53 Annex VIII. Summary of In-House Analysis According to the Manufacturing Processes Carried Out 55 Annex IX. Analysis to be Performed In-House for Color Fasteness Control of the Production 56 Annex X. Analysis to be Performed In-House for pH Control of the Production 58 Annex XI. Analysis to be Performed in Outsourced Laboratories for Fiber Composition Control of the Production 59 Annex XII. Summary of the Chemical Products Subjected to Analysis 60 Annex XIII. Analysis to be Performed in Outsourced Laboratories for APEOs Control of Chemicals 61 Annex XIV. Analysis to be Performed in Outsourced Laboratories for PFCs Control of Chemicals 62 Annex XV. Summary of In-House Instrumentation According to the Manufacturing Processes Carried Out 63 Annex XVI. In-House Color Fastness Analysis Template for Production Control 64 Annex XVII. In-House pH Analysis Template for Production Control 66 Annex XVIII. Example of a Chemical Supplier Process Evaluation 68 INTRODUCTION Introduction INDITEX has developed the manufacturing code “Ready To Manufacture” (hereinafter, RTM) with the aim of helping its suppliers to comply with the requirements of its product health standard “Clear To Wear” (hereinafter, CTW) and the “Manufacturing Restricted Substances List” (hereinafter, MRSL). This document will help you to implement the criteria and requirements to be applied in the facilities of 1 INDITEX direct suppliers as well as in the manufacturing processes, management of warehouses and chemical products and productions control of the dyeing and printing mills, laundries, tanneries and yarn, fabric or leather suppliers included in their supply chains. In case you need further information related to RTM, please do not hesitate to contact INDITEX through the Corporate Social Responsibility Department (hereinafter, CSR). To this end, send an e-mail to rtm@inditex.com including in the subject the name of the INDITEX brand you are currently working for and/or you have received a purchase order from. Scope 2 RTM covers INDITEX direct suppliers or sub-suppliers as well as the dyeing and printing mills, laundries and tanneries included in their supply chain. Objective The main objective of RTM is to ensure that all INDITEX suppliers comply with CTW requirements and the 3 MRSL resulted from the “Zero Discharge of Hazardous Chemicals” (hereinafter, ZDHC). INDITEX direct suppliers and the mills included in their supply chain into the scope of RTM will find in this document: • Textile and leather good manufacturing practices in order to deliver quality products. • Indications to improve technological skills of their facilities. • Procedures to ensure proper transmission of CTW and its implications to the entire INDITEX supply chain. Thus, once these objectives will be achieved, both INDITEX and its suppliers will benefit of a reduction in manufacturing times and costs associated to article reprocessing due to CTW non compliances. RTM Description RTM describes good manufacturing practices and best practices related to the different stages of the textile and leather manufacturing processes in order to ensure production traceability and CTW compliance. Yarn, fabric, leather or garment suppliers who have a direct commercial relationship with INDITEX. Suppliers who provide goods to INDITEX direct suppliers and may have their own supply chain. They can be traders or vertically integrated suppliers. 3 https://www.inditex.com/en/sustainability/environment/manufacturing 1 2 1 INTRODUCTION RTM is structured in two chapters clearly separated “Good Manufacturing Practices and Best Practices for INDITEX Direct Suppliers and Sub-Suppliers” and “Good Manufacturing Practices and Best Practices for Mills” included into the supply chain of INDITEX direct suppliers and sub-suppliers. 4 Important: In case an INDITEX direct supplier is vertically integrated, they should comply with the good manufacturing practices described in “Good Manufacturing Practices and Best Practices for INDITEX Direct Suppliers and Sub-Suppliers” as well as in “Good Manufacturing Practices and Best Practices for Mills”. Additionally, compliance with best practices described in both chapters is highly recommended. Good Manufacturing Practices Good manufacturing practices are basic requisites that should be implemented in order to achieve RTM objective. They are summarized and highlighted in red colour at the beginning of every section and their compliance is mandatory. Best Practices Additionally, RTM includes best practices or recommendations to be implemented and which compliance is not mandatory but highly recommended. In the same way that the good manufacturing practices, best practices are summarized and highlighted in green colour and with a dotted line at the beginning of every section. Note: Best practices are focused in those facilities with a commitment and engagement beyond merely complying with RTM good manufacturing practices. RTM Implementation, Performance and Evaluation As previously mentioned, every INDITEX direct supplier or the dyeing and printing mills, laundries and tanneries included into their supply chain should comply, at least, with RTM good manufacturing practices. In order to verify RTM implementation and compliance, a self-audit questionnaire (hereinafter, SAQ) will be provided. This questionnaire includes questions about all good manufacturing practices included in RTM and only two answers are possible: “Yes” or “No”. Thus, RTM compliance is only ensured if all questions are positively answered. On the other hand, a negative answer means that there is a good manufacturing practice that is not being complied with what could lead to a potential CTW non compliance. Note: SAQ is only a tool to help mills included in the supply chain of INDITEX direct suppliers or sub-suppliers to check RTM implementation. Thus, to send it back to INDITEX or any other third party is not needed. Note: SAQ should be filled in for the mill responsible together with a representative of the INDITEX direct supplier they are working for. Supplier which participates in all or major stages of production of an article, from the acquisition of raw materials to its production and commercialization. 4 2 INTRODUCTION Finally, INDITEX will conduct technical audits by means of its internal teams or outsourced and nominated service providers in order to evaluate RTM implementation. Technical audit results will be communicated to 5 INDITEX direct suppliers by means of INDITEX extranet. According to the results obtained in the technical audits, two different situations could happened: • Positive technical audit result (green color): The mill will be periodically audited by means of “Follow-Up Audits” in order to check that they continue to comply with RTM good manufacturing practices over time. • Negative technical audit result (red color): The auditor will provide a corrective action plan to the mill that should be implemented over an agreed time period to ensure that the mill has the opportunity to meet RTM good manufacturing practices. Afterwards, a second technical audit will happen that in case of a positive technical audit result (green color) will be followed by the previously described procedure of regular visits or “Follow-Up Audits”. Conversely, if the result of the technical audit is negative (red color), the commercial department of the INDITEX brand working with this mill will be informed what may result in temporary or permanent blocking of purchase orders (hereinafter, PO’s) to this mill. Important: Remember that RTM good manufacturing practices compliance does not exclude full CTW compliance. Key Definitions In order to help in RTM comprehension there are different concepts that should be previously defined: • Auxiliary products or auxiliaries: RTM considers auxiliaries to the chemicals used during the manufacturing processes of textile and leather articles without comprising dyestuffs/pigments and chemical commodities (acids, sodium chloride, sodium sulphate, sodium carbonate, chromium sulphate, caustic soda, hydrogen peroxide, sodium hydrosulphite, among others). • Batch: RTM considers a batch to each yarn, fabric, leather or garment delivery from the same supplier, produced at the same mill, using the same recipe and by means of the same manufacturing process, regardless the number of shipments and their date. As an example, see the following situations: o 1 PO supplied by two different suppliers will be considered as two batches. o 1 PO supplied by the same supplier but in two different dates will be considered as one single batch only if it was manufactured in the same mill, with the same recipe and by means of the same manufacturing process. • Dyeing lot: RTM considers a dyeing lot to the quantity of yarn, fabric, leather or garments that have been dyed simultaneously, using the same machinery and the same recipe. Note: Mixing of different dyeing lots should be avoided during storage and the manufacturing process. 5 https://extranet.inditex.com/extranet 3 INTRODUCTION • Dyeing lot number: traceability purposes. • Internal order number: RTM considers internal order number to the code assigned to each processing subset of yarn, fabric, leather or garments from one initial PO. • Lot number: supplier assigns to their chemical products for traceability purposes. 6 • Manufacturing Restricted Substances List (MRSL): Register of chemical substances that are subject to a usage ban/restriction during the manufacturing process of an article in order to comply with the “Zero 7 Discharge of Hazardous Chemicals” (ZDHC). • Printing lot: RTM considers a printing lot to the quantity of fabric, leather or garments that have been printed simultaneously, using the same machinery and the same recipe or until the printing panels or rotary screens are cleaned. Note: Mixing of different printing lots should be avoided during storage and the manufacturing process. • Printing lot number: RTM considers a printing lot number to the identification code assign to a printing lot for traceability purposes. • Product to carry out special effects: RTM considers products to carry out special effects all chemicals comprised in the following categories: o Transparent printing base pastes. o White and lac pastes. o Foam pastes. o Foil/transfer adhesive. o Glitter paste. o High density pastes and puff pastes. o Pigment gloss and metal effect pastes. o 3D products. o Cationic/mordanting agents. o Wool protectors. o UV curing agents and additives. 6 7 https://www.wateractionplan.com/ https://www.inditex.com/en/sustainability/environment/manufacturing 4 INTRODUCTION • Raw materials: RTM considers raw materials to flat knitted yarn, fabric and leather. • Recipe: Dyestuffs/pigments and auxillaries formulation use to dye, print or wash yarn, fabrics, leather or garments. Note: In case lot number and/or concentration of any of the chemicals used changes, it will be considered as a different recipe. • Small part or accessory: RTM considers a small part or accessory to an independent element of the finished article characterized by: o Low manufacturing control. o Low stock traceability. o Independent manufacturing process to the rest of the article. o Incorporated to the article at the final stage of its manufacturing process. • Washing lot: RTM considers a washing lot to the quantity of fabric, leather or garments that have been washed simultaneously, using the same machinery and the same recipe. Note: Mixing of different washing lots should be avoided during storage and the manufacturing process. • Washing lot number: RTM considers a washing lot number to the identification code assign to a washing lot for traceability purposes. 5 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR INDITEX DIRECT SUPPLIERS AND SUB-SUPPLIERS GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR INDITEX DIRECT SUPPLIERS AND SUB-SUPPLIERS A. Good Manufacturing Practices and Best Practices for INDITEX Direct Suppliers and Sub-Suppliers 1. INDITEX Direct Supplier and Sub-Suppliers Staff 1.1. INDITEX Product Health and Safety Standard Compliance Manager. INDITEX Product Health and Safety Standard Compliance Manager Knowledge Profile. INDITEX Product Health and Safety Standard Compliance Manager in the Different Mills of a Vertically Integrated INDITEX Direct Supplier. 1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager. Attendance to INDITEX Meetings for Direct Suppliers. Workshop for Supply Chain CTW Training. 1.1. INDITEX Product Health and Safety Standard Compliance Manager Every INDITEX direct supplier or sub-supplier should have a designated person for all health and safety issues related to INDITEX Product Health Standard, “Clear To Wear” (hereinafter, CTW). This person should have a deep knowledge of this standard and attend all INDITEX training programs described in the following section “1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager”. 8 In case that an INDITEX direct supplier is vertically integrated, the INDITEX product health and safety standard compliance manager should ensure that purchasing, production line and technical area managers are deeply aware of CTW requirements. 9 Note: In case that a sub-supplier is included into the supply chain of an INDITEX direct supplier, both this sub-supplier and their corresponding dyeing and printing mills, laundries and tanneries should also have their corresponding INDITEX product health and safety standard compliance manager. In the same way, all facilities 10 into the supply chain of a sub-supplier should be registered in INDITEX extranet by the corresponding INDITEX direct supplier. Important: INDITEX product health and safety compliance manager role can be played by one of the workers already hired and does not imply to hire one more person since only a deep knowledge of CTW is needed. Supplier which participates in all or major stages of the production of an article, from the acquisition of raw materials to its production and commercialization. 9 Suppliers who provide goods to INDITEX direct suppliers and may have their own supply chain. They can be traders or vertically integrated suppliers. 10 https://extranet.inditex.com/extranet 8 7 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR INDITEX DIRECT SUPPLIERS AND SUB-SUPPLIERS Best Practice: Recommended INDITEX product health and safety standard compliance manager knowledge profile should include the following issues: • A minimum of 2 years of experience in the textile and/or leather wet processing. • Knowledge of auxiliaries, dyestuffs/pigments and industrial processes related to the textile and/or leather processing industry. • Basic knowledge of legislation related to the textile or leather processing industry as well as the chemical tests for their control. • Basic knowledge of environmental legislation and parameters related to the discharge of water effluents. Best Practice: In case that an INDITEX direct supplier is vertically integrated and has several mills in different geographical locations, it is highly recommended to have an INDITEX product health and safety standard compliance manager in all of them. 1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager The INDITEX product health and safety standard compliance manager should become the in-site internal trainer for the rest of the workers. In order to be continuously updated about INDITEX policies, this person should attend to all INDITEX training programs which include: • e-CTW&STW program: An educational program developed in order to inform, train and support all suppliers about CTW requirements and, help them to reach its requirements. This program is carried out by means of webinars (web conferencing meetings) which allow internet conferencing events in real time with remote locations. • Technical Audits (TA´s): Visits performed to INDITEX direct suppliers or sub-suppliers by the most skilled team of experts in textile and leather industry globally nominated by INDITEX to assure CTW and MRSL requirements compliance. Best Practice: The INDITEX product health and safety standard compliance manager should also attend: • INDITEX supplier´s meetings: periodically organized by INDITEX in order to inform, train and aware suppliers in the compliance of CTW and MRSL requirements. Best Practice: INDITEX direct suppliers should organize workshops about CTW and MRSL requirements for both their internal staff and the mills included in their supply chain. Workshops records should be maintained for at least 2 seasons (12 months approximately). 8 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR INDITEX DIRECT SUPPLIERS AND SUB-SUPPLIERS 2. Traceability Documents 2.1. Purchase Orders to Suppliers. 2.2. Documentation and Records. 2.1. Purchase Orders to Suppliers All purchase orders (PO’s) to suppliers should be in written form and including INDITEX PO number and brand the PO belongs to. Additionally, PO’s should also mention the following remark: • All goods related to this PO should comply with the latest version of CTW and MRSL. Important: In case PO includes goods for babies (0-3 years old) it should be also mentioned and highlighted. Important: Oral communications should be always avoided. 2.2. Documentation and Records All INDITEX direct suppliers should have a documentation management system in order to ensure production control traceability and their appropriate implementation. According to this, following is a summary of all documents that should be stored and maintained: • CTW and MRSL compliance commitment from all suppliers (excluding chemicals suppliers) and mills into their supply chain of the INDITEX direct supplier or sub-supplier. o INDITEX direct suppliers or sub-suppliers should get from every mill included into their supply chain and also from every supplier (excluding chemical suppliers), a written and dully signed commitment stating that they know and understand both CTW and MRSL and that all the goods provided by them will comply with their requirements. Important: Please, note that every time an INDITEX direct supplier decides to include a new mill into their 11 supply chain, it should be registered on INDITEX extranet. In order to have the supply chain information always updated, it is mandatory to register all facilities used in the last 12 months and that may be used in the near future. Additionally, any change on it should be also registered as soon as possible and without waiting for an INDITEX PO. • Hard copies of all documentation related to CTW, RTM and documents related to the technical audits conducted to your facilities and the mills included into their supply chain. • INDITEX PO´s. 11 https://extranet.inditex.com/extranet 9 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR INDITEX DIRECT SUPPLIERS AND SUB-SUPPLIERS • PO´s sent to the mills included into their supply chain. • Shipment delivery notes to the mills included into their supply chain. • Shipment delivery notes from the mills included into the supply chain of an INDITEX direct supplier or sub-supplier to the INDITEX direct supplier of sub-supplier. • Fiber composition analysis test report for every raw material (except leather) batch purchased: o Fiber composition analysis test report should be provided by the raw material supplier and performed in accordance with section “10.1. Analysis Requirements for Production Control”. Additionally, INDITEX direct supplier or sub-supplier should provide this information to the dyeing and/or printing mills included in their supply chain before starting the production of the article. Note: In case of textile processes which could change composition (i.e. carding yarn articles, napping, brushing, enzymatic washings, “devore”/burnout printing, among others), composition analysis should be performed at the end of these processes and it will be exclusive responsibility of the INDITEX direct supplier. Important: Initially, INDITEX direct supplier or sub-supplier should have the required information available for the current season. Eventually, it should be updated until covering the last 2 seasons (approximately 12 months). Important: In case an INDITEX direct supplier or sub-supplier is vertically integrated, they should also comply with good manufacturing practices shown in the following chapter of this document “Good Manufacturing Practices and Best Practices for Mills”. Important: RTM compliance does not exclude full CTW compliance. According to this, all INDITEX direct suppliers should ensure that finished goods comply with CTW requirements previously to their shipment to INDITEX. 10 TÍTOL GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS 11 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS B. Good Manufacturing Practices and Best Practices for Mills 1. Mill Staff 1.1. INDITEX Product Health and Safety Standard Compliance Manager. INDITEX Product Health and Safety Standard Compliance Manager Knowledge Profile. 1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager. Attendance to INDITEX Meetings for Direct Suppliers and the Mills Included in their Supply Chain. Workshop for Internal CTW Training. 1.1. INDITEX Product Health and Safety Standard Compliance Manager Every yarn, fabric or leather supplier, dyeing and printing mill, laundry or tannery into the supply chain of an INDITEX direct supplier or sub-supplier should have a designated person for all health and safety issues related to INDITEX Product Health Standard, “Clear To Wear” (hereinafter, CTW). This person should have a deep knowledge of this standard and attend all INDITEX training programs described in the following section “1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager”. Additionally, this person should also ensure that purchasing, production line and technical area managers are deeply aware of CTW requirements. Important: INDITEX product health and safety compliance manager role can be played by one of the workers already hired and does not imply to hire one more person since only a deep knowledge of CTW is needed. Best Practice: Recommended INDITEX product health and safety standard compliance manager knowledge profile should include the following issues: • A minimum of 2 years of experience in the textile and/or leather wet processing. • Knowledge of auxiliaries, dyestuffs/pigments and industrial processes related to the textile and/or leather processing industry. • Basic knowledge of legislation related to the textile or leather processing industry as well as the chemical tests for their control. • Basic knowledge of environmental legislation and parameters related to the discharge of water effluents. 12 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS 1.2. Training of the INDITEX Product Health and Safety Standard Compliance Manager The INDITEX product health and safety standard compliance manager should become the in-site internal trainer for the rest of the workers. In order to be continuously updated, this person should attend to all technical audits carried out in the mill: • Technical Audits (TA´s): Visits performed to the mills included in the supply chain of INDITEX direct suppliers by the most skilled team of experts in textile and leather industry globally nominated by INDITEX to assure CTW and MRSL requirements compliance. Best Practice: The INDITEX product health and safety standard compliance manager should also participate in the following training programs: • INDITEX supplier´s meetings: periodically organized by INDITEX in order to inform, train and aware suppliers and the mills included in their supply chains in the compliance of CTW and MRSL requirements. • e-CTW&STW program: An educational program developed in order to inform, train and support all INDITEX direct suppliers and the mills included in their supply chains about CTW requirements and, help them to reach its requirements. This program is carried out by means of webinars (web conferencing meetings) which allow internet conferencing events in real time with remote locations. Best Practice: Mills should organize workshops about CTW and MRSL requirements for internal staff. Workshops records should be maintained for at least 2 seasons (12 months approximately). 2. General Warehouse Conditions This section comprises all good manufacturing practices and best practices common to all warehouses involved in the textile and leather manufacturing processes. However, in later sections, specific good manufacturing practices and best practices for raw materials, auxiliaries, dyestuffs/pigments and finished goods warehouses will be also covered. 2.1. Stock Management and Traceability. Printed Traceability Documents. Use of Location Markers. 2.1. Stock Management and Traceability All stored goods should be always identified by at least, their lot number in the case of dyestuffs/pigments and auxiliaries or, their batch number for raw materials. 13 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS Incoming raw materials (yarn, fabrics or leather) and greige garments should be always registered including all information shown in Annex I. Stock of auxiliaries and dyestuffs/pigments should be always updated. For this reason, their stock should be monthly registered including all information shown in Annex II. Note: In case stock management is automated, the register of chemicals should be printed once a month in order to have it always available. Important: Annex I and Annex II templates are for guidance only. Alternatively, any other format which includes, at least, all the information required in these templates can be used. Note: Traceability of products which could be stored outdoor (raw materials and auxiliaries) should be always ensured, even under extreme weather conditions. Best Practice: In order to avoid confusions, all traceability documents of stored aticles should be always typed. To ensure the identification of hides, skins and leather in tanneries, traceability codes should also be stamped on their surface. Goods properly identified Goods without proper identification Best Practice: Location markers should be used for proper location and identification of goods. 14 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS Goods properly identified with location markers 3. Raw Materials Warehouse 3.1. Raw Material Traceability. 3.2. Fiber Composition Analysis. 3.1. Raw Material Traceability Incoming raw materials should be identified by their batch number which should be incorporated to an internal order template including all information shown in Annex III. To ensure an appropriate traceability, internal order number should accompany the goods along their manufacturing process and storage. Important: Annex III template is for guidance only. Alternatively, any other format which includes, at least, all the information required in this template can be used. 3.2. Fiber Composition Analysis Along with every batch of flat knitted yarn or fabric provided to a dyeing or printing mill, a composition analysis should be provided. The analysis should be performed by the raw material supplier according to section “10.1. Analysis Requirements for Production Control” and provided to the mill by the INDITEX direct supplier or subsupplier before the production starts. However, in case composition analysis is not provided by the INDITEX direct supplier or sub-supplier, composition analysis should be performed directly by the dyeing or printing mill. Important: In case batch number information is not available, a composition analysis should be performed after every reception of a new raw material shipment. Note: In case of textile processes which could change composition (i.e. carding yarn articles, napping, brushing, enzymatic washings, “devore”/burnout printing, among others), composition analysis should be performed at the end of these processes and it will be the exclusive responsibility of the INDITEX direct supplier. 15 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS 4. Auxiliaries and Dyestuffs/Pigments Warehouse 4.1. CTW, RTM and MRSL Hard Copies Availability. CTW, RTM and MRSL Hard Copies Availability in Close Proximity to Chemicals. 4.2. Auxiliaries and Dyestuffs/Pigments Information. SDS and TDS Availability in Close Proximity to Chemicals. Translation of SDS and TDS Key Information into Local Language. 4.3. Auxiliaries and Dyestuffs/Pigments Repackaging and Relabeling. 4.4. Auxiliaries and Dyestuffs/Pigments Weighing. Auxiliaries and Dyestuffs/Pigments Auto Dosing System. Auxiliaries and Dyestuffs/Pigments Weighing Responsible Person. Balance Proximity to Auxiliaries and Dyestuffs/Pigments. Auxiliaries and Dyestuffs/Pigments Balance Calibration. 4.5. Dyestuffs/Pigments Specific Storage Conditions. Dyestuffs/Pigments Warehouse Door or Polymer Curtain. Proper Opening of the Dyestuff/Pigment Containers. 4.6. Auxiliaries Specific Storage Conditions. 4.1. CTW, RTM and MRSL Hard Copies Availability CTW, RTM and MRSL hard copies should be always available on-site. Best Practice: CTW, RTM and MRSL hard copies should be stored close to auxiliaries and dyestuffs/pigments for ease of reference if necessary. 4.2. Auxiliaries and Dyestuffs/Pigments Information All incoming auxiliaries and dyestuffs/pigments should be properly identified by means of their original labeling which should always include lot number, chemical product and manufacturer/distributor names. In case, a chemical product does not include all this information or it does not comply with CTW and/or MRSL requirements, it should be considered as a CTW and/or MRSL non compliant product, highlighted and store segregated. 16 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS Dyestuff which does not comply with CTW requirements perfectly identified and segregated Auxiliaries which does not comply with CTW requirements perfectly identified and segregated Note: Auxiliaries or dyestuffs/pigments which labels have been totally or partially removed or include hand written information will not be allowed. In the same way, to remove or hide total or partially their original label information will be also not accepted. Dyestuff containers with hand written labels and which labels from their original manufacturer/distributor have been removed Additionally, along with the reception of an auxiliary product, dyestuff or pigment for the first time, its Safety 12 13 Data Sheet (SDS) and Technical Data Sheet (TDS), completed and updated, should be included. Additionally, in case of any update in the SDS or TDS, it should be sent again by the chemical supplier. Note: Every SDS should be checked to ensure the chemical product does not contain any restricted substance included in the MRSL or the content of this substance is not above CTW requirements. Best Practice: SDS and TDS should be stored close to auxiliaries and dyestuffs/pigments for ease of access if necessary. Document which describes the hazards associated with a chemical product. They list hazardous ingredients (i.e. formaldehyde), types of hazards present and ways that workers should handle the materials and protect themselves. 13 Document which summarizes the application mode and other technical characteristics of a chemical product. 12 17 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS Best Practice: Auxiliary products, dyestuffs or pigments instructions for use as well as their main potential CTW non compliance issues from SDS should be translated into local language to ensure all workers understanding. Appropriate signs and pictures can be included to highlight key points and reinforce the information. SDS key issues translated into local language 4.3. Auxiliaries and Dyestuffs/Pigments Repackaging and Relabeling Auxiliaries and dyestuffs/pigments repackaging and relabeling should be always avoided and carried out only in case it is strictly necessary. If this happens, new containers should include a label that ensures traceability to the original one. Additionally, every time the relabeled container is refilled with a different lot number product, its label should be updated. Repackaging of dyestuffs with the original labeling attached at their upper lid Repackaging of dyestuffs without proper identification 18 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS Important: Do not mix auxiliaries or dyestuffs/pigments with different lot numbers in the same container. In the case of auto dosing systems minimize the mix of different lot numbers as far as possible. 4.4. Auxiliaries and Dyestuffs/Pigments Weighing In order to avoid cross contamination during auxiliaries and dyestuffs/pigments weighing, next indications should be followed: • Dyestuffs/pigments and auxillaries should be always weighed carefully. In the specific case of solid dyestuffs (powder, grains and flakes), they should be always weighed independently and then, put together in one single container. Correct practice Incorrect practice • Every auxiliary product, dyestuff or pigment should have its own weighing accesory (jar, bucket, spoon, among others) which should be properly identified and traceable to the product they are used for. Dyestuff container with its weighing spoon properly identified Auxiliaries without their own weighing accessories • Containers re-use or modification to ease auxiliaries or dyestuffs/pigments dispense is not allowed. 19 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS Use of original auxiliaries containers Use of no original auxiliaries containers modified by including a tap in their bottom • Auxiliaries and dyestuffs/pigments weighing balance should be always placed in a clean, dry and, flat surface for proper weighing and to avoid any risk of contamination. Balance in a clean, dry and flat surface Balance under inappropriate conditions Note: In case the balance is equipped with a level indicator, make sure that it is in the position which implies that this instrument is well-balanced. Best Practice: Auto dosing systems are highly recommended since they can reduce the risk of exposure, spillage and wastage of auxiliaries, dyestuffs and pigments. Best Practice: Auxiliaries and dyestuffs/pigments handling and weighing should be always carried out by one trained and designated person and if possible, in a segregated area from the chemical warehouse. Best Practice: Auxiliaries and dyestuffs/pigments weighing should be carried out once they are placed close to the balance as carrying small product amounts over large distances can lead to inaccuracy and potential cross contamination. 20 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS Best Practice: Balance needs to be periodically calibrated according to manufacturer recommendations. Once calibrated, records should be properly maintained. 4.5. Dyestuffs/Pigments Specific Storage Conditions All dyestuff/pigment containers should be stored indoor, avoiding direct contact with the floor and walls and according to what was previously described in section “2. General Warehouse Conditions”. Additionally, dyestuff and pigment containers should be always stored closed and will be opened only for weighing. Proper dyestuff storage Improper dyestuff storage Best Practice: Since most particles of powdered dyestuffs are low specific gravity, dyestuff warehouse should be equipped with a door or at least, a plastic polymer curtain in order to avoid the contamination of other areas of the mill. Dyestuff warehouse equipped with a door Dyestuff warehouse equipped with a polymer curtain 21 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS Best Practice: Dyestuff containers should be opened following chemical supplier indications to ensure that the upper side of the container can be used as its lid. Dyestuff containers properly opened Dyestuff containers improperly opened Best Practice: To keep and maintain a sample of every dyestuff/pigment lot number used for all INDITEX PO’s received during the last season (approximately 6 months) is highly recommended. In the case of printing mills, it is also highly recommended to keep and maintained samples of all lot numbers of thickeners, binders, resins or any other aromatic polyurethane (PU) based products used during the period previously mentioned. 4.6. Auxiliaries Specific Storage Conditions To avoid potential cross contamination, auxiliaries in solid and liquid form should be stored in segregated areas. Liquid and solid auxiliaries stored segregated Liquid and solid auxiliaries improperly stored 22 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS 5. Finished Goods Warehouse 5.1. Finished Goods Identification. 5.2. Management of CTW Non Compliance Finished Goods. Register of Detections/CTW Non Compilances. 5.1. Finished Goods Identification Finished goods should be stored indoor, avoiding direct contact with the floor and walls and according to what was previously described in section “2. General Warehouse Conditions”. Additionally, finished goods should be identified with at least, their internal order number which should be traceable to the corresponding internal order template which should include all the information shown in Annex III. Important: Annex III template is for guidance only. Alternatively, any other format which includes, at least, all the information required in this template can be used. Finished goods storage with an appropriate traceability and avoiding direct contact with the floor Finished goods storage without proper traceability and in direct contact with the floor 23 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS 5.2. Management of CTW Non Compliance Finished Goods In the case that despite all efforts made during the manufacturing process finished goods do not comply with CTW requirements, they should be highlighted and stored in segregated areas. CTW non compliance finished goods highlighted in red colour and store segregated Additionally, the next procedure should be followed: • Identify the source of the incidence. • Halt the manufacturing process until the issue is properly identified and solved. • Inform the customer, the INDITEX direct supplier, who should contact the Corporate Social Responsibility (here in after, CSR) Department product health and safety area responsible and/or the commercial agent of the INDITEX brand which placed the order to know the corrective actions to be implemented. • Put in place the corrective actions to manage CTW non-compliances and to prevent their recurrence in future productions (see Annex IV). Best Practice: All incidences related to detections or CTW non compilances should be registered and maintained. Finally, you may be required by the INDITEX CSR Department product health and safety area to be enrolled in a Root Cause Analysis (RCA) audit in order to evaluate and identify the source of an incidence found in an article produced in your facilities and delivered to INDITEX and to prevent it in the future. 24 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS 6. Work In Progress 6.1. Internal Orders Management. 6.1. Internal Orders Management In order to have proper traceability throughout the entire manufacturing process, work in progress should be always identified by their corresponding internal order number which should be traceable to the internal order template (see an example in Annex III). This template should include all the information related to the goods that are being manufactured and the different processes they are being subjected to. Important: Annex III template is for guidance only. Alternatively, any other format which includes, at least, all the information required in this template can be used. 7. Dyeing and Washing 7.1. Dyeing and Washing Recipe. Liquor Ratio Control. Dyeing and Washing Parameters Automated Control Machinery. Indirect Steam Dyestuff/Pigments Dissolution. 7.1. Dyeing and Washing Recipe An independent dyeing or washing recipe should be filled in for every dyeing or washing lot. This recipe should include all the information shown in Annex VII. Important: In case dyeing or washing recipe includes any codification of a chemical product, its traceability to the commercially available chemical product name should be ensured. Important: Annex VII template is for guidance only. Alternatively, any other format which includes, at least, all the information required in this template can be used. 14 Best Practice: In order to obtain an appropriate reproducibility and colour fastness results, liquor ratio should be controlled during dyeing. Best Practice: All dyeing and washing machinery should be microprocessor based controlled in order to control all key parameters of the process, especially temperature and time, to ensure appropriate reproducibility and colour fastness results. 14 Weight of yarn, fabric or garment to bath proportion. 25 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS Best Practice: To prevent metals transportation from the piping system to the articles that are being manufactured, direct hot steam dyestuff dissolution should be avoided and replaced by indirect steam along with a stirring facility to provide heat uniformity. 8. Printing 8.1. Printing Conditions Selection. Resin Curing Maximum Temperature in Accordance with TDS of the Resin with the Highest Curing Temperature. 8.2. Printing Recipe. Printing Parameters Automated Control Machinery. Indirect Steam Dyestuff Dissolution. 8.3. Printing Paste Conservation. Printing Pastes Proper Storage. 8.1. Printing Conditions Selection Printing conditions, especially temperature and resin curing time, are critical since inappropriate settings can lead to arylamines and formaldehyde promotion and colour fastness decrease. For this reason, every printing mill should pay special attention to different issues throughout the manufacturing process and follow the next steps: • Documents related to the chemical products used (SDS and TDS): o To check by means of their SDS that content of formaldehyde or any other substance complies with CTW requirements for the application in use. Note: Remember that formaldehyde or any other substance contents shown in a SDS are referred to that specific chemical product and global contributions of all the products included in a printing recipe could lead to a CTW non compliance. o To check that application conditions of the chemical products carefully follow TDS instructions. 26 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS • Machinery for printing: o To check that machinery used for printing is able to reach, maintain and control all parameters defined in the TDS of the chemical products in use, especially resin curing temperature and time. o To check that the curing machine has an appropriate steam extraction system which avoids potential formaldehyde condensation from the chemical products in use and the corresponding contamination of the articles manufactured. Appropriate printing resin curing with temperature and time control and adequate steam extraction Inappropriate printing resin curing without temperature and time control and no steam extraction • Curing process: o To check by means of temperature stripes, thermocouples or any other thermosensor device and always previously to start every printing lot that, both final resin curing and intermediate drying steps (if any) temperatures are in accordance with conditions shown in the TDS of the chemical products in use. Note: In case this information is not available in the TDS, the original manufacturer/distributor of the chemical product should be contacted in order to know maximum temperature and time for every step. Additionally, any reduction of time and/or temperature not covered by TDS information should be also checked with the curing resin supplier. Important: Temperature of intermediate drying steps higher than resin curing temperature will not be allowed. Important: Whenever possible, chemical products based on aromatic polyurethane (PU) materials should be avoided since subjected to low or high temperatures or by side reactions between diisocyanate with water may promote the formation of forbidden arylamines. o To avoid, whenever possible, printing processes where different resins with different curing temperatures are used. 27 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS Best Practice: Whenever different resins with different curing temperatures are used, highest temperature for curing should be always equal or below the maximum curing temperature of the resin with the highest curing temperature. Important: The use of heat guns or any other device without a proper control of both time and temperature the print is subjected to should be always avoided. 8.2. Printing Recipe An independent printing recipe should be filled in for every printing lot. This recipe should include all the information shown in Annex VII. Important: In case printing recipe includes any codification of a chemical product, its traceability to the commercially available chemical product name should be ensured. Important: Annex VII template is for guidance only. Alternatively, any other format which includes, at least, all the information required in this template can be used. Best Practice: All printing machinery should be microprocessor based controlled in order to control all key parameters of the process, especially temperature and time, to ensure appropriate reproducibility and colour fastness results. Best Practice: To prevent metals transportation from the piping system to the articles that are being manufactured, direct hot steam dyestuff dissolution should be avoided and replaced by indirect steam along with a stirring facility to provide heat uniformity. 8.3. Printing Paste Conservation All additives used to preserve printing pastes should comply with CTW and MRSL requirements. For this reason, make sure you strictly follow section “10.2. Chemical Products Selection”. Best Practice: To prevent cross contamination and to achieve better traceability, printing paste containers should be stored closed, properly identified and in a systematic manner. Printing pastes with good traceability Printing pastes without proper traceability 28 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS 9. Water Discharge Effluents 9.1. Water Discharge Effluents Control. 9.1. Water Discharge Effluents Control Both INDITEX direct suppliers and the mills included into their supply chains should have a constant commitment with the protection of the environment and comply with all requirements established by local and international legislation as well as the use of substances not included in the MRSL. Additionally, they should be committed to comply with all environmental standards established by INDITEX including actions to reduce and compensate their own impact on the environment. 10. Production and Chemical Products Control 10.1. Analysis Requirements for Production Control. 10.2. Chemical Products Selection. 10.3. Chemical Products Suppliers Evaluation. Internal and Written Procedure to Evaluate Chemical Suppliers. 10.4. Analysis Requirements for Chemical Products Control. 10.5. Required Instrumentation for In-House Analysis. 10.6. Outsourced Laboratories. 10.7. Control Records. 10.1. Analysis Requirements for Production Control RTM considers that in order to comply with CTW requirements, all mills included into its scope should implement an internal procedure to monitor and control their productions. In this regard, RTM aims to become a reference in the development and implementation of control procedures by means of a set of good practices of analysis that every mill working for an INDITEX direct supplier should comply with. Depending on the complexity of the analysis, it should be performed in-house or outsourced: • Analysis to be performed in-house: o pH. o Colour fastness: - To perspiration. - To water. - To rubbing (dry and wet). - To saliva (only for baby articles). Important: To know specific exceptions to pH and colour fastness in-house analysis check Annex VIII. 29 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS Important: Once a month, regardless a new INDITEX PO is received and in order to check pH and colour fastness results obtained in-house are correct, mills should send one of the samples internally analyzed to one external lab for correlation. In the specific case of colour fastness, only medium and dark shades should be sent for correlation. Note: See section “10.6. Outsourced Laboratories” to know the requirements that an external laboratory should comply for acceptance of the results provided. Note: For more information about the main issues related to in-house colour fastness and pH analysis for production control, see Annex IX and Annex X, respectively. • Analysis to be outsourced: o Arylamines. o Formaldehyde. o Fiber Composition. Note: For more information about the main issues related to outsourced analysis for production control see Annex V.a., Annex V.b., Annex VI.a., Annex VI.b. and Annex XI. Additionally, you may be required by the INDITEX CSR Department product health and safety area to be enrolled in different mandatory programs for production control such as: • Small Pieces Collection & Testing Program (SCOLT Program). • Composition Guideline. • Arylamines Guideline. • Formaldehyde Guideline. • Colour Fastness Guideline. • pH Guideline. 10.2. Chemical Products Selection Auxiliaries, dyestuffs and pigments selection is an important issue to comply with CTW and MRSL requirements. For this reason, every mill should take into account both documents before purchasing chemicals. In order to facilitate an appropriate selection of these chemicals, INDITEX provides its suppliers with “The 15 List by INDITEX”, a register of chemicals used in the textile and leather manufacturing processes, produced by reputed suppliers with high technical skills and classified by their degree of compliance with different parameters of CTW. Important: One chemical product will be considered as included in “The List by INDITEX” only if its commercial name exactly matches with the description shown in this document. “The List by INDITEX” will be periodically updated and may incorporate new chemical products, parameters and participants. You can download the latest version of this document directly from INDITEX web page (www.inditex.com). 15 30 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS Note: Please, note that “The List by INDITEX” chemical product classification only considers a reduced number of parameters. For this reason, any other potential CTW non compliances related to other substances registered in CTW should be checked. Since the use of chemical products included in “The List by INDITEX” is not mandatory, any other chemical product not included in this document could be used for any INDITEX production as long as their chemical supplier complies with the requirements included in section “10.3. Chemical Products Supplier Evaluation” and the chemical products have been tested according to the requirements shown in Annex V.a., Annex V.b., Annex VI.a. and Annex VI.b.. Important: In the specific case of fur and leather industry, special attention should be paid to chromium (Cr) and particularly to Cr(VI) which should not be present in any of the salts or solutions used during the tanning process. Additionally, taking into account that Cr(III) can be oxidized to Cr(VI), high oxidizing power products, unsaturated fats or pH over 6.5 should be avoided. 10.3. Chemical Products Suppliers Evaluation Auxiliaries, dyestuffs and pigments used in an INDITEX production should be acquired from chemical suppliers which belong to one of the following 2 options: • To be a chemical supplier not included in “The List by INDITEX” which complies with the following requirements: o To provide the mill 1 test report according to Annex XII along with the first delivery of a new lot number of a chemical product. Important: In the case of chemical products subjected to APEOs and/or PFCs analysis, test reports should not be provided along with the first delivery of every new lot number but for 2 of them per year. Note: Test reports should belong to one of the laboratories shown in “INDITEX Proposed Laboratories 16 and Sample Collection Centres” or any other lab ISO 17025 accredited in the test they are hired for. Important: Auxiliaries that should not be tested directly but after their application on a fabric, printed panel or leather should be applied at the highest concentration defined in its TDS and tested. o To provide the mill both completed and updated SDS and TDS together with the first delivery of a chemical product. Additionally, in case of any update, SDS and/or TDS should be sent again to the mill by the chemical supplier. Since this document will be periodically updated, you can download the latest version directly from INDITEX web page (www. inditex.com). 16 31 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS o To provide all chemical products in their original container and properly identified by means of their original typed labeling and including product and manufacturer/distributor names and, chemical product lot number. o To provide the mill shipment delivery notes where chemical product lot number is included. • To be a chemical supplier included in “The List by INDITEX”. Important: Since APEOs are not considered in “The List by INDITEX”, chemical suppliers included in this document should provide 2 test reports per year of the first delivery of 2 lot numbers of every chemical subjected to APEOs analysis. Best Practice: To have an internal and written procedure to evaluate chemical products suppliers is highly recommended. Annex XVIII shows as an example, some criteria that could be taken into account for chemical suppliers´ evaluation. 10.4. Analysis Requirements for Chemical Products Control In the same way that productions should be controlled, dyestuffs, pigments and some auxiliary chemicals should be also checked. For this reason, every mill should test, at least once per year, one lot number of every chemical product included in the different categories and according to the different parameters shown in Annex XII. Important: Chemical products included in “The List by INDITEX” are excluded from this requirement except for APEOs testing. In this case, chemicals should be always free of APEOs what implies a global content below 100 ppm. Important: Auxiliaries that should not be tested directly but after their application on a fabric, printed panel or leather should be applied at the highest concentration defined in its TDS and tested. Due to the complexity of all analysis related to APEOs and PFCs, tests should be performed in external laboratories according to Annex XIII and Annex XIV, respectively. 32 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS 10.5. Required Instrumentation for In-House Analysis Since pH and colour fastness analysis should be carried out in-house, mills into RTM scope should have well trained and qualified staff as well as the following instrumentation: pH Analysis pH meter with temperature probe Mechanical shaker Important: pH measurements cannot be performed with pH indicator papers or indicator solutions due to their inaccuracy and that they do not take into account potential pH changes due to temperature variations. 33 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS Colour Fastness Analysis Crockmeter for textiles Perspirometer Balance Oven Colour fastness grey scales Light box Mono or Multifiber species 34 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS Note: Please note that in the case of leather, both crockmeter and the cloth for colour fastness to rubbing are different from textiles. Crockmeter for leather Wool felt cloth for colour fastness to rubbing Important: A summary of in-house instrumentation that should be available in a mill according to the different manufacturing processes carried out are shown in Annex XV. 10.6. Outsourced Laboratories In order to obtain correct and reliable analytical results, the selection of an external laboratory is critical. According to this, all outsourced laboratory should comply with one of the following requirement: • To have an ISO 17025 accreditation in the test they are hired for or, 17 • To be included in the document “ INDITEX Proposed Laboratories and Sample Collection Centres”. Important: To use laboratories shown in “INDITEX Proposed Laboratories and Sample Collection Centres” is not mandatory. Finally, in order to facilitate the shipment of samples to the laboratories, INDITEX provides you a set of sample collection centres worldwide where you can send the samples to be analyzed. Afterwards, the sample collection centre will assign the laboratory where the analysis will be carried out. Note: Please, note that samples sent to a collection centre will be sent to laboratories belonging to the same analytical service provider. For this reason, please check before sending the samples to a collection centre that the chosen analytical service provider the collection centre belongs to has at least one laboratory capable to carry out the tests requested. Since this document will be periodically updated, you can download the latest version directly from INDITEX web page (www.inditex.com). 17 35 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS Important: Shipment of dangerous chemical products cannot be performed by means of the sample collection centres and should be sent directly to the outsourced laboratories. In order to know if a chemical product is considered as dangerous, air transportation restrictions in SDS section 14 of the chemical product “Transport information”. Additionally, find below a summary of some recommendations to be followed for an appropriate shipment of chemical products: • Use double cap plastic containers. • Do not use containers with a capacity higher than 30 mL / 30 g. • Use insulating tape around each container to avoid leaks. • Pack every container individually in a polyethylene bag. 10.7. Control Records Test reports from outsourced laboratories should be maintained for at least 2 seasons (approximately 12 months). In the same way, in-house colour fastness and pH analysis results should be registered including all information shown in Annex XVI and Annex XVII, respectively, and maintained for the same period of time. Note: In the case of colour fastness analysis, along with the in-house colour fastness analysis template for production control (see Annex XVI), tested sample and specimen should be also maintained. Important: Annex XVI and Annex XVII are for guidance only. Alternatively, any other format which includes, at least, all the information required in these templates can be used. 11. CTW Management 11.1. Purchase Orders to Suppliers. 11.2. Documentation and Records. 11.1. Purchase Orders to Suppliers All PO´s sent to suppliers should be in written form and including the following remark: • All goods related to this PO should comply with the latest version of CTW and MRSL. Additionally, in the specific case of PO’s sent to chemical suppliers, the following disclaimer should be also included: • All goods included in this PO should be delivered in their original container, with their original labeling including product name, manufacturer/distributor name and chemical product lot number. Important: Oral communications should be always avoided. 36 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS 11.2. Documentation and Records Every mill included into the supply chain of an INDITEX direct supplier should have a documentation management system in order to ensure productions and chemicals control traceability. For this reason, find below the information that should be available on-site: • PO´s received from the INDITEX direct supplier. • Shipment delivery notes from the INDITEX direct supplier to the mill. • Shipment delivery notes from the mill to the INDITEX direct supplier. • Templates for raw materials and greige garments traceability (see an example in Annex I). • Templates for auxiliaries and dyestuffs stock traceability (see an example in Annex II). • Internal order templates (see an example in Annex III). • Dyeing/printing/washing recipe templates (see an example in Annex VII). • In-house colour fastness and pH analysis templates (see examples in Annex XVI and Annex XVII, respectively). • CTW, RTM, MRSL and technical audits corrective actions plan (if any) hard copies. • PO´s sent to chemical suppliers. • Shipment delivery notes from the chemical suppliers to the mill. • ISO 17025 accreditation certificate for external labs in use and not registered in “INDITEX Proposed Laboratories and Sample Collection Centres”. • Reports of all tests carried out in external laboratories for fiber composition, formaldehyde, arylamine, APEOs and PFCs control as well as for pH and colour fastness correlation studies. • Test reports provided by chemical suppliers along with the first delivery of a new lot number of a chemical product not included in “The List by INDITEX” and subjected to analysis according to Annex XII. • SDS and TDS of all dyestuffs/pigments and auxiliary products. 37 GOOD MANUFACTURING PRACTICES AND BEST PRACTICES FOR MILLS Important: Initially, mills into the supply chain of an INDITEX direct supplier should provide the required information for the current season. Eventually, it should be updated until covering the last 2 seasons (approximately 12 months). Important: In order to ensure full CTW compliance, in-house pH and colour fastness analysis templates and test reports from external laboratories, should be provided to the INDITEX direct suppliers. 38 12. ANNEXES Annex I. Template for Raw Materials and Greige Garments Traceability MONTH Date Delivery Note Nº Supplier/Customer Name Quantity Batch Nº Fiber Composition Analysis (Y/N) Name and Signature Month when the raw materials or greige garments were received at the raw materials warehouse. Number of units in which goods sent by the customer are received at the raw materials warehouse. manufacturing process, regardless the date and the number of deliveries. INDITEX Proposed Laboratories and Sample Collection Centres” (applicable only for Name and signature of the person in charge of controlling the incoming and outgoing raw materials and greige garments at the raw materials warehouse. 40 Annex II. Template for Auxiliary Products and Dyestuffs/Pigments Stock Traceability MONTH Chemical Product Name Chemical Product Lot Nº Manufacturer Name Distributor Name Initial Stock (kg or L) Quantity Purchased (kg or L) Final Stock (kg or L) 8 Monthly Consumption (kg or L) Month considered to calculate the consumption of auxiliary products and dyestuffs/pigments. Commercial name of the auxiliary product or dyestuff/pigment. Lot number(s) of the auxiliary product or dyestuff/pigment. Name of the manufacturer of the auxiliary product or dyestuff/pigment. Name of the distributor that is commercializing the auxiliary product or dyestuff/pigment. Amount of auxiliary product or dyestuff/pigment available at the warehouse at the beginning of the current month. Amount of auxiliary product or dyestuff/pigment purchased during the current month. Amount of auxiliary product or dyestuff/pigment available at the warehouse at the end of the current month when the stock is checked. Consumption of auxiliary product or dyestuff/pigment during the current month. This calculation should be performed as follows: Initial Stock + Quantity Purchased – Final Stock Comments 41 Annex III. Internal Order Template GENERAL INFORMATION Delivery Note Nº Batch Nº Internal Order Nº Composition/Leather Type Date Quantity (Units/Weight/Length/Area) Customer Name Article Description PROCESSES Description Date Process 1 Process 2 Process 3 Process 4 Identification code assigned to the goods sent by the customer once they are received at the facility warehouse. Code assigned to each processing subset of yarn, fabric, leather or garments from one initial purchase order while they are being processed. Date when the internal order is processed. Identification code of each one of the yarn, fabric, leather or garment deliveries from the same supplier, produced at the same mill, using the same recipe and by means of the same manufacturing process. Description of the fibers and percentages (for textiles) or the type of leather that the article processed is made of. Amount of yarn, fabric, leather or garments that are being processed in the internal order. Description of the article that is being processed (yarn, fabric, trousers, t-shirt, etc.). Description of the different processes that the articles included in the internal order are or will be subjected to. Date when the mentioned process is carried out. 42 Annex IV. Main Corrective Actions to Manage CTW/MRSL Non-Compliances CTW / MRSL NON COMPLIANCE INCIDENCE INCIDENCE MANAGEMENT AND FOLLOW-UP To remove from the recipe the chemical product responsible of the incidence. Arylamines Detection of arylamines values over 5 ppm in the first dyeing or printing lot. To store the chemical product segregated and highlighted as “CTW non compliant”. To replace the chemical product in the recipe for another one previously analyzed or classified as “A” or “B” in “The List”. To continue controlling production as per RTM indications (see Annex V.a. and Annex V.b.). To ensure a proper washing off the affected lots. To check formaldehyde values in all reprocessed lots. To remove from the recipe the chemical product responsible of the incidence. Formaldehyde Detection of formaldehyde values over 16 ppm (5 ppm for baby articles) in the first dyeing or printing lot. To store the chemical product segregated and highlighted as “CTW non compliant”. To replace the chemical product in the recipe for another one previously analyzed or classified as “A” or “B” in “The List”. To continue controlling production as per RTM indications (see Annex VI.a. and Annex VI.b.) To reprocess the article if possible. Colour Fastness Test results out of CTW requirements during the approval/regularity stage of colour fastness production control. To check colour fastness by means of colour fastness analysis type which provided the CTW non compliance result in all reprocessed lots. To adapt the manufacturing process in accordance with previous article reprocessing. To continue controlling production as per RTM indications (see Annex IX). To reprocess the article to ensure pH values in accordance with CTW requirements. pH Test results out of CTW requirements during pH control in a dyeing/printing/ washing lot. To adapt the manufacturing process in accordance with previous article reprocessing. To continue controlling production as per RTM indications (see Annex X). In the case of baby articles (0-3 years old), make sure that external laboratory is able to provide a suitable detection limit to quantify values equal or above 5 ppm. 43 Annex V.a. Analysis to be Performed in Outsourced Laboratories for Arylamine Control of the Production ARYLAMINE ANALYSIS HOW MUCH? WHAT? “A” in “The List” as “B(4)” in “The List” as “C(4)” in “The List” Use is prohibited in INDITEX productions printing mills, tanneries and laundries Chemical products not included in “The List” with a result 1 analysis of the chemical product per year < 20 ppm Chemical products not included in “The List” with a result > 20 ppm HOW? After reception of the BS EN No analysis is needed for the current recipe Dyeing and · Pigments WHEN? No analysis is needed for the current recipe · Dyestuffs · Inks WHO? 1 analysis of the chemical product per year chemical product at the 14362-1:2012 mill warehouse Annex F 44 Annex V.a. Analysis to be Performed in Outsourced Laboratories for Arylamine Control of the Production (continuation) ARYLAMINE ANALYSIS HOW MUCH? WHAT? as “A” in “The List” WHO? WHEN? HOW? No analysis is needed for the current recipe Textile BS EN 14362-1:2003 · Chemical products as “B(4)” in “The List” No analysis is needed for the current recipe BS EN 14362-2:2003 based on aromatic PU BS EN 14362-1:2012 · Cross-linkers/ catalyst based on Dyeing and aromatic aziridines · Cross-linkers/catalyst as “C(4)” in “The List” Use is prohibited in INDITEX productions printing mills, based on blocked tanneries and aromatic isocyanates laundries · Glues · Adhesives Chemical products not included in “The List” with a result 1 analysis of the chemical product per year Chemical products not included > 5 ppm (application analysis) Leather ISO 17234:2015 In case of aniline or 1,4-phenylenediamine detection LFBG B82.02-9 or ISO/TS 17234-2:2011 < 5 ppm (application analysis) in “The List” with a result In case of aniline or After reception of the 1,4-phenylenediamine detection chemical product at LFBG B82.02-9 or the mill warehouse BS EN 14362-3:2012 1 analysis of the chemical product per year 45 Annex V.a. Analysis to be Performed in Outsourced Laboratories for Arylamine Control of the Production (continuation) ARYLAMINE ANALYSIS HOW MUCH? WHAT? WHO? WHEN? Dyed/printed articles with Textile No analysis is needed for the current recipe BS EN 143621:2003 as “A” in “The List” First dyeing/printing lot result < 5 ppm Dyed/printed articles with chemical products B ” in “The List” (4) dyeing/printing lot of the current recipe First dyeing/printing lot result > 5 ppm Finished Articles No more analysis current recipe Any type BS EN 143621:2012 See section 5.2 Dyed/printed articles with printing mills, chemical products not tanneries and included in “The List” which No analysis is needed for the current recipe < 20 ppm (chemical analysis) < 5 ppm (application analysis) Dyed/printed articles with chemical products not First dyeing/printing included in “The List” which lot result < 5 ppm provided a result dyeing/printing lot > 20 ppm (chemical analysis) of the current recipe or > 5 ppm (application analysis) laundries Just after the end of the process In case of aniline or 1,4phenylenediamine detection LFBG B82.02-9 or BS EN 143623:2012 Leather ISO 17234:2015 or Note: BS EN 143622:2003 are needed for the Dyeing and provided a result HOW? First dyeing/printing lot result > 5 ppm No more analysis are needed for the current recipe See section 5.2 In case of aniline or 1,4phenylenediamine detection LFBG B82.02-9 or ISO/TS 172342:2011 46 Annex V.a. Analysis to be Performed in Outsourced Laboratories for Arylamine Control of the Production (continuation) ARYLAMINE ANALYSIS HOW MUCH? WHAT? First printing lot result ≤ 5 ppm Printed articles using resins with different curing temperatures First printing lot result > 5 ppm Finished Articles printing lot First printing lot result ≤ 5 ppm Transfer printed articles with elastane First printing lot result > 5 ppm WHO? WHEN? No more analysis are needed for the Textile current recipe BS EN 143621:2003 See section 5.2 Dyeing and Just after printing mills, the end of the No more analysis are tanneries and dyeing/printing needed for the laundries process current recipe See section 5.2 Small parts´ supplier criteria or 9 small parts randomly collected from the whole purchase order Note: BS EN 143622:2003 Any type BS EN 143621:2012 In case of aniline or 1,4phenylenediamine detection LFBG B82.02-9 or BS EN 143623:2012 Leather ISO 17234:2015 Small Small Parts HOW? parts´ supplier Before small or parts are INDITEX attached to the direct supplier article In case of aniline or 1,4phenylenediamine detection LFBG B82.02-9 or ISO/TS 172342:2011 47 Annex V.b. Workflow of the Analysis to be Performed in Outsourced Laboratories for Arylamine Control of the Production Does the chemical product belong to any of the categories subjected to arylamine analysis shown in Annex XII? No analysis is needed NO YES Is it included in “The List”? NO YES Check test report of the specific lot number in use provided by chemical supplier Check classification (A, B(4) or C(4)) Result ≤ 20 ppm (chemical analysis) ≤ 5 ppm (application analysis) Result > 20 ppm (chemical analysis) > 5 ppm (application analysis) No more tests are needed for the current recipe Test 1st dyeing/printing lot of the current recipe Result ≤ 5 ppm No more tests are needed for the current recipe A C(4) B(4) Use is prohibited in INDITEX productions. Highlight and segregate No analysis is needed Test 1st dyeing/printing lot of the current recipe Result > 5 ppm Inform customer Customer informs INDITEX Follow INDITEX instructions Additionally, all chemical products not included in “The List by INDITEX” and subjected to analysis (see Annex XII) should be tested by the mill once per year. 48 Annex VI.a. Analysis to be Performed in Outsourced Laboratories for Formaldehyde Control of the Production FORMALDEHYDE ANALYSIS WHAT? Chemical · Fixers for dyeing · Fixers for printing* · Resins · Cross-linkers/catalyst based on melamineformaldehyde as “A” in “The List” Chemical as “B(1)” in “The List” · Adhesives · Products for coating · Thickeners · Binders · Retanning agents produced by WHEN? HOW? No analysis is needed for the current recipe No analysis is needed for the current recipe Textile Chemical ISO/EN 14184:2011 Use is prohibited in INDITEX productions · Fluorescent pigments · Glues WHO? HOW MUCH? or as “C(1)” in “The List” Chemical products not included in “The List” with a result < 16 ppm application analysis 1 analysis of the chemical product Dyeing and printing After reception of the mills, tanneries and chemical product at the laundries mill warehouse per year GB/T 2912.1:2009 Leather ISO/TS 17226:2008 GB/T 19941:2005 (< 5 ppm for baby articles) condensation reactions with formaldehyde Chemical products · Products to carry out not included in “The special effects List” with a result > 16 ppm application analysis 1 analysis of the chemical product per year (> 5 ppm for baby articles) “Key Definitions” section. In the case of baby garments, make sure that external laboratory is able to provide a suitable detection limit to quantify the above mentioned concentrations. 49 Note: Extreme precautions to avoid CTW non compliances when performing processes which homogeneity may not be achieved, such as spraying, garment tinting, among others. Note: or Annex VI.a. Analysis to be Performed in Outsourced Laboratories for Formaldehyde Control of the Production (continuation) FORMALDEHYDE ANALYSIS WHAT? WHO? HOW MUCH? WHEN? HOW? Dyed/printed articles with chemical No analysis is needed for the current recipe “A” in “The List” Dyed/printed articles with chemical dyeing/printing lot of the current “B ” in “The List” (1) Finished Articles Dyed/printed articles with chemical products not included in “The List” which provided a result < 16 ppm (< 5 ppm for baby articles) Dyed/printed articles with chemical products not included in “The List” which provided a result > 16 ppm (> 5 ppm for baby articles) recipe First dyeing/printing lot result < 16 ppm (< 5 ppm for baby articles) First dyeing/printing lot result > 16 ppm (> 5 ppm for baby articles) No more analysis are needed for the current recipe Textile ISO/EN 14184:2011 See RTM section 5.2 or Dyeing and printing mills, tanneries and No analysis is needed for the current recipe laundries Just after the end of the process Leather ISO/TS 17226:2008 or GB/T 19941:2005 dyeing/printing lot of the current recipe First dyeing/printing lot result < 16 ppm (< 5 ppm for baby articles) No more analysis are needed for the current recipe First dyeing/printing lot result > 16 ppm (> 5 ppm for baby articles) See RTM section 5.2 In the case of baby garments, make sure that external laboratory is able to provide a suitable detection limit to quantify the above mentioned concentrations. Note: Extreme precautions to avoid CTW non compliance when performing processes which homogeneity may not be achieved, such as spraying, garment tinting, among others. 50 Note: GB/T 2912.1:2009 Annex VI.a. Analysis to be Performed in Outsourced Laboratories for Formaldehyde Control of the Production (continuation) FORMALDEHYDE ANALYSIS WHAT? HOW MUCH? WHO? WHEN? HOW? Textile ISO/EN 14184:2011 or Small Parts Small parts´ supplier criteria Small parts´ supplier or or 9 small parts randomly collected from the whole purchase order INDITEX direct supplier Before small parts are attached to the article GB/T 2912.1:2009 Leather ISO/TS 17226:2008 or GB/T 19941:2005 51 Annex VI.b. Workflow of the Analysis to be Performed in Outsourced Laboratories for Formaldehyde Control of the Production Does the chemical product belong to any of the categories subjected to formaldehyde analysis shown in Annex XII? No analysis is needed NO YES Is it included in “The List”? NO YES Check test report of the specific lot number in use provided by the chemical supplier Check classification (A, B(1) or C(1)) A Result ≤ 16 ppm (≤ 5 ppm for baby articles) Result > 16 ppm (> 5 ppm for baby articles) No more tests are needed for the current recipe Test 1st dyeing/ printing lot of the current recipe Result ≤ 16 ppm (≤ 5 ppm for baby articles) No more tests are needed for the current recipe B(1) C(1) Use is prohibited in INDITEX productions. Highlight and segregate No analysis is needed Test 1st dyeing/ printing lot of the current recipe Result > 16 ppm (> 5 ppm for baby articles) Inform customer Customer informs INDITEX Follow INDITEX instructions Additionally, all chemical products not included in “The List by INDITEX” and subjected to analysis (see Annex XII) should be tested by the mill once per year. In the case of baby garments (0-3 years old), make sure that external laboratory is able to provide a suitable detection limit to quantify the above mentioned concentrations. 52 Annex VII. Dyeing/Printing/Washing Recipe Template GENERAL INFORMATION Recipe Nº Composition/Leather Type Date Colour Customer Name Internal Order Nº Quantity (Units/Weight/Length/Area) Machine ID. DYEING/PRINTING/WASHING PROCESS Dyestuff/Pigment or Auxiliary Product Lot Nº %, cc/L or g/L Chemical Product Name Quantity Pick Up (only for continuous dyeing) TDS Maximum Temperature for Resin Curing (only for printing) Applied Resin Curing Temperature (only for printing) Applied Maximum Temperature for Intermediate Drying (only for printing) TDS Time for Resin Curing (only for printing) Resin Curing Time Applied (only for printing) 17 Comments SAMPLE (optional) 18 53 Identification code of a recipe used in the dyeing, printing or washing processes of a specific internal order. Date when the recipe is used for a dyeing, printing or washing process of a specific internal order. Amount of yarn, fabric, leather or garments that are being dyed, printed or washed using the recipe. Description of the fibers and percentages (for textiles) or the type of leather that the article processed is made of. Description of the expected colour after the process described in the recipe. Code assigned to each processing subset of yarn, fabric, leather or garments from one initial purchase order while they are being processed. Identification code of the machine where the dyeing, printing or washing process has been carried out. Identification code a dyestuff/pigment or auxillary product supplier assigns to their chemical products for traceability purposes. Commercial name of the dyestuff/pigment or auxiliary product that is being used in the recipe and which lot number has been previously provided. Concentration of dyestuff/pigment or auxiliary used in the recipe. Amount of dyestuff/pigment or auxiliary used in the recipe. In case the amount of dyestuff/pigment or auxiliary product is expressed as a percentage, the amount is calculated multiplying this percentage by the amount of yarn, fabric, garment or leather that is being dyed, printed or washed. In case the concentration is expressed in g/L, this amount will be multiplied by the number of dyeing, printing or washing bath litres. Amount of water absorbed by a fabric in a continuous dyeing process after leaving the bath of dyestuff. Maximum temperature that can be used for final resin curing according to resin manufacturer TDS. In case an article is printed using different resins with different curing temperature, highest temperature for curing should be always equal or below the maximum curing temperature of the resin with the highest curing temperature. Maximum temperature that has been applied for final resin curing. Maximum temperature that has been applied during intermediate drying steps (if any) and before final resin curing. Time or time range that should be used for resin curing according to resin manufacturer TDS. 17 18 Time used for final resin curing. Area reserved for those cases in which a sample of the dyeing, printing or washing process is stored. 54 Annex VIII. Summary of In-House Analysis According to the Manufacturing Processes Carried Out SUMMARY OF IN-HOUSE ANALYSIS IN-HOUSE ANALYSIS Process pH COLOUR FASTNESS To perspiration To water To dry rubbing To wet rubbing To saliva Continuous dyeing Yes Yes Yes Yes Yes Yes Flat knitted yarn dyeing or Fabric exhaust dyeing Yes Yes Yes Yes Yes Yes No Yes Yes Yes Yes Yes Garment dyeing Yes Yes Yes Yes Yes Yes Denim fabrics dyeing Yes No No No No No Positional printing No No No Yes Yes No Soluble dyestuffs and VAT/Disperse continuous printing Yes Yes Yes Yes Yes Yes Pigment continuous printing Yes No No Yes Yes No Transfer printing of polyester articles No No No Yes Yes No No Yes Yes Yes Yes Yes Tannery No No No Yes Yes No Laundry (without dyeing processes) Yes No No No No No Yarn dyeing Transfer printing of cellulosic - 55 Only for baby articles (between 0 and 3 years old). Annex IX. Analysis to be Performed In-House for Colour Fastness Control of the Production COLOUR FASTNESS ANALYSIS HOW MUCH? WHAT? PROCESS Fabric Continuous Dyeing APPROVAL STAGE Garment Dyeing 1 analysis of the colour fastness analysis type which provided the worst result during the approval stage every 6 dyeing lots 1 analysis of the colour fastness analysis type which provided the worst result during the approval stage every 10 dyeing lots 1 analysis of the colour fastness analysis type which provided the worst result during the approval stage every 4 dyeing lots 1 analysis of 1 analysis of 1 analysis of colour fastness colour fastness colour fastness to rubbing in to rubbing every to rubbing every 10,000 meters 20,000 meters meters 1 analysis of colour fastness to rubbing every 5,000 meters 1 analysis of the colour fastness 1 analysis of analysis type each type of colour fastness which provided the worst result during the approval dyeing lot stage every 40 dyeing lots 1 analysis of each type of colour fastness Soluble Dyestuffs and VAT/Disperse Continuous Printing 56 Pigment Positional Printing 1 analysis of the colour fastness analysis type which provided the worst result during the approval stage every 20 dyeing lots WHO? WHEN? HOW? DARK SHADE 1 analysis of the colour fastness analysis type which provided the worst result during the approval stage every 20 dyeing lots 1 analysis of each type of colour fastness dyeing lot Pigment Continuous Printing MEDIUM SHADE 1 analysis of the colour fastness analysis type which provided the worst result during the approval stage every 10,000 meters Finished Articles PALE SHADE 1 analysis of the 1 analysis of the colour fastness colour fastness analysis type analysis type which provided which provided the worst result the worst result during the during the approval stage approval stage every 40,000 every 20,000 meters meters meters Fabric or Yarn Exhaust Dyeing REGULARITY CONTROL STAGE 1 analysis of the 1 analysis of the colour fastness colour fastness 1 analysis of the colour fastness 1 analysis of analysis type analysis type analysis type each type of which provided which provided which provided colour fastness the worst result the worst result the worst result during the during the during the approapproval stage approval stage meters val stage every every 20,000 every 10,000 5,000 meters meters meters 1 analysis of 1 analysis of 1 analysis of 1 analysis of colour fastness colour fastness colour fastness to colour fastness to rubbing per to rubbing of the to rubbing every rubbing every 3 5 printing lots printing lots printing lot To Water GB/T 5713-2013 or ISO 105E01:2013 Just after the end Dyeing and of the dyeing/ printing mills process 3 To Rubbing GB/T 3920-2008 or ISO 105X12:2001 To Perspiration GB/T 3922-2013 or ISO 105E04:2013 To Saliva (only for baby articles) GB/T 18886:2002 Annex IX. Analysis to be Performed In-House for Colour Fastness Control of the Production (continuation) COLOUR FASTNESS ANALYSIS HOW MUCH? WHAT? PROCESS APPROVAL STAGE 1 analysis of colour fastness Transfer printed to rubbing in Polyester Articles 2,500 meters Transfer printed articles Small Parts Leather 1 analysis of Transfer printed each type of articles with colour fastness CellulosicPolyester Fiber printing lot or Blends meters REGULARITY CONTROL STAGE PALE SHADE MEDIUM SHADE 1 analysis of 1 analysis of colour fastness colour fastness to rubbing every to rubbing every 5 printing lots or 3 printing lots or 20,000 meters 10,000 meters WHEN? HOW? DARK SHADE 1 analysis of colour fastness to rubbing every printing lot or 5,000 meters 1 analysis of the 1 analysis of the colour fastness colour fastness 1 analysis of the colour fastness analysis type analysis type analysis type which provided which provided the worst result the worst result which provided the worst result during during the during the approval stage approval stage the approval stage every 5 printing every 3 printing every printing lot or 5,000 meters lots or 20,000 lots or 10,000 meters meters Small parts supplier criteria or 9 small parts randomly collected from the whole purchase order 1 analysis of 1 analysis of 1 analysis of colour fastness colour fastness colour fastness Dyeing/Finishing to rubbing of the to rubbing every to rubbing every 5 dyeing lots 3 dyeing lots first dyeing lot WHO? 1 analysis of colour fastness to rubbing per dyeing lot To Water GB/T 5713-2013 or ISO 105-E01:2013 Dyeing and printing mills Just after the end of the dyeing/ printing process To Rubbing GB/T 3920-2008 or ISO 105-X12:2001 To Perspiration GB/T 3922-2013 or ISO 105-E04:2013 To Saliva (only for baby Small parts´ articles) supplier Before small parts GB/T 18886:2002 or are attached the INDITEX direct to the article supplier Tanneries At the end of the process To Rubbing ISO 11640:2012 (For leather) or EN ISO 17700:2005 (For footwear) Regularity control should be carried out by means of the colour fastness analysis test which provided the worst result during the approval stage. In case all types of colour fastness analysis provided the same result, the type of colour fastness to be used will be selected randomly. To perform color fastness analysis according to legislation does not imply to invest in laboratory infrastructures but, follow analytical methodologies and make sure analytical 57 Note: Annex X. Analysis to be Performed In-House for pH Control of the Production pH ANALYSIS WHAT? HOW MUCH? PROCESS Continuous Dyeing or Washing Finished Articles Soluble Dyestuffs and VAT/Disperse Continuous Printing Exhaust Dyeing or Washing Garment Dyeing or Washing ANALYSIS WHEN? HOW? 1 analysis every 10,000 meters per dyeing/ printing/washing lot Just after the end of Last mill in the dyeing/printing/ the dyeing/printing washing process process but always after washing GB/T 7573-2009 or ISO 3071-2005 1 analysis every 3 dyeing/washing lot Small parts´ supplier criteria Small Parts WHO? or 9 small parts randomly collected from the whole purchase order Small parts´ supplier or the INDITEX direct supplier Before small parts are attached to the article Remember that according to legislation, every analysis should be performed in triplicate. To perform analysis according to legislation does not imply to invest money in laboratory infrastructures but, follow analytical methodologies and make sure analytical instrumentation comply 58 Note: Annex XI. Analysis to be Performed in Outsourced Laboratories for Composition Control of the Production COMPOSITION ANALYSIS WHAT? HOW MUCH? TYPE OF FABRIC ANALYSIS PER BATCH Cellulosic Fiber Blend 3 3 (from 9.000 meter onwards, 1 analysis every 3.000 meters until a maximum of 9 analysis) Regenerated (mainly carding yarn) · Flat knitted yarn · Fabrics WHO? WHEN? HOW? For Binary Fiber Blends Directive 1007/2011/ CE, Standard EN ISO Raw material 1833-1:2010 supplier or Fiber Blends with Elastane 3 or Fiber Blends for Linings 3 dyeing/printing Animal Fibers Blends 3 Before raw material´s GB/T 2910.1:2009 shipment or mill GB/T 29862:2013 For Tertiary Fiber Blends Others Directive 1007/2011/ 1 blends, among others) CE, Standard EN ISO 1833-2:2010 or Secondary components’ supplier criteria Secondary or Components 9 secondary components randomly collected from the whole purchase order Secondary components supplier or the INDITEX direct supplier Before secondary components are attached GB/T 2910.2:2009 or GB/T 29862:2013 to the article RTM considers secondary component to a textile element of an article, different to the main and secondary fabrics, the percentage of which exceeds 5 % or 15 % on weight or surface, respectively. Elbow patches, edgings and embroideries, among others, are examples of secondary components. Note: In case of textile processes which could change composition (i.e. carding yarn articles, napping, brushing, enzymatic washings, “devore should be performed at the end of these processes and it will be the exclusive responsability of the INDITEX direct supplier. 59 Annex XII. Summary of the Chemical Products Subjected to Analysis Chemical Product Formaldehyde Arylamines APEOs PFCs Fixers for dyeing X --- --- --- Fixers for printing X --- --- --- Resins X --- --- --- Cross-linkers/catalyst based on aromatic aziridines --- X --- --- Cross-linkers/catalyst based on melamine-formaldehyde X --- --- --- Cross-linkers/catalyst based on blocked aromatic isocyanates --- X --- --- Glues X X --- --- Adhesives X X --- --- Products to carry out special effects X --- --- --- Products for coating X --- --- --- Thickeners X --- --- --- Binders X --- --- --- Dyestuffs --- X --- --- Pigments (except fluorescent ones) --- X --- --- Fluorescent Pigments X X --- --- --- X --- --- Inks --- X --- --- Water repellents --- --- --- X Oil repellents --- --- --- X Soil release --- --- --- X Lubricants for dyeing processes --- --- X --- Antistatics --- --- X --- Dispersing agents --- --- X --- Emulsifiers --- --- X --- Silicon based softeners --- --- X --- Levelling agents --- --- X --- Detergents --- --- X --- Fatliquors --- --- X --- Retanning agents --- --- X --- X --- X --- --- --- X --- Chemical products based on aromatic PU Retanning agents produced by condensation reactions with formaldehyde Auxiliaries with high content of emulsifiers or dispersing agents Chemical products included in this category should not be tested directly but after their application on a fabric, printed panel or leather should be applied at the highest concentration defined in its TDS and tested. To know which chemical products are comprised in this category, see its definition in “Key Definitions” section. Important: All tests should be conducted in external laboratories in accordance with section “10.6 Outsourced Laboratories”. 60 Annex XIII. Analysis to be Performed in Outsourced Laboratories for APEOs Control of Chemicals APEOs ANALYSIS WHAT? For Textile · Lubricants for dyeing processes · Antistatics · Dispersing agents · Detergents · Silicon based softeners · Levelling agents · Auxillary products with a high HOW MUCH? WHO? WHEN? HOW? Dyeing and After reception printing mills, of the chemical External lab tanneries and product at the methodology laundries mill warehouse Chemical products which provided a result 1 analysis of the chemical product per year < 100 ppm or dispersing agents For Leather · Detergents · Fatliquors · Retanning agents Chemical products which provided Use is prohibited in INDITEX productions a result > 100 ppm RTM considers the following CAS numbers as substances to be analyzed: NP (25154-52-3, 84852-15-3; 104-40-5); OP (140-66-9; 1806-26-4; 27193-28-8); NPE (68412-54-4; 26027-38-3; 9016-45-9); OPE (26636-32-8; 9036-19-5; 9002-93-1). 61 Annex XIV. Analysis to be Performed in Outsourced Laboratories for PFCs Control of Chemicals PFCs ANALYSIS WHAT? HOW MUCH? WHO? WHEN? Dyeing and After reception printing mills, of the chemical External lab methodology HOW? Chemical products “A” No analysis is needed for the current recipe in “The List” Chemical products “C” · Water Repellents Use is prohibited in INDITEX productions in “The List” · Oil Repellents · Soil Release No detection of C4-C8 1 analysis of the chemical tanneries and product at the compounds product per year laundries mill warehouse Detection of C4-C8 Use is prohibited compounds in INDITEX productions Chemical products not included in “The List” RTM considers the following CAS numbers as substances to be analyzed: PFOA (335-67-1); PFOS (1763-23-1); Potassium salt PFOS (2795-39-3); Amide PFOS (754-91-6); PFHxA (307-24-4); PFHxS (355-46-4); 8:2 FTOH (678-39-7); 6:2 FTOH (647-42-7). Please, note that “The List by INDITEX” 62 Annex XV. Summary of In-House Instrumentation According to the Manufacturing Processes Carried Out SUMMARY OF IN-HOUSE INSTRUMENTATION Process pHmeter Shaker Crockmeter Perspirometer Balance Mono or Multifiber Species Continuous dyeing Yes Yes Yes Yes Yes Yes Yes Yes Yes Flat knitted yarn dyeing or Fabric exhaust dyeing Yes Yes Yes Yes Yes Yes Yes Yes Yes No No Yes Yes Yes Yes Yes Yes Yes Garment dyeing Yes Yes Yes Yes Yes Yes Yes Yes Yes Denim fabrics dyeing Yes Yes No No Yes No No No No Positional printing No No Yes No No Yes No Yes No Soluble dyestuffs and VAT/Disperse continuous printing Yes Yes Yes Yes Yes Yes Yes Yes Yes Pigment continuous printing Yes Yes Yes No Yes Yes No Yes Yes Transfer printing of polyester articles No No Yes No No Yes No Yes Yes No No Yes Yes Yes Yes Yes Yes Yes Tannery No No Yes No No Yes No Yes Yes Laundry (without dyeing processes) Yes Yes No No Yes No No No No Yarn dyeing Transfer printing of cellulosic- 63 Light box will not be considered as mandatory but highly recommended. Please, note that in case of leather, both crockmeter and the cloth for colour fastness to rubbing are different from textiles. Oven Grey Scale Light Box Annex XVI. In-House Colour Fastness Analysis Template for Production Control GENERAL INFORMATION Delivery Note Nº Composition/Leather Type Article Description Quantity (Units/Weight/Length/Area) Customer Name COLOUR FASTNESS ANALYSIS Colour Fastness Analysis Results Internal Order Nº Recipe Nº Date Nº Dyeing/ Printing Lot or Meters Perspiration Water Saliva Colour Colour Colour Colour Colour Colour Change Staining Change Staining Change Staining Dry Rubbing Wet Rubbing Colour Staining Colour Staining Responsible Signature Sample sent for correlation (Yes/No) Responsible Signature Sample sent for correlation (Yes/No) TESTED SAMPLE AND SPECIMEN COLOUR FASTNESS ANALYSIS Colour Fastness Analysis Results Internal Order Nº Recipe Nº Date Nº Dyeing/ Printing Lot or Meters Perspiration Water Saliva Colour Colour Colour Colour Colour Colour Change Staining Change Staining Change Staining Dry Rubbing Wet Rubbing Colour Staining Colour Staining TESTED SAMPLE AND SPECIMEN 64 Identification code assigned to the goods sent by the customer once they are received at the facility warehouse. Description of the article that is being processed (yarn, fabric, trousers, t-shirt, among others). Description of the fibers and percentages (for textiles) or the type of leather that the article processed is made of. Total amount of yarn, fabric, leather or garments initially received at the mill warehouse and that posteriorly will be processed in different internal orders. Code assigned to each processing subset of yarn, fabric, leather or garments from one initial purchase order while they are being processed. Identification code of the recipe used in the dyeing, printing or washing process of a specific internal order. Date when the colour fastness analysis of a specific internal order was performed. Identification code assigned to a dyeing or printing lot for traceability purposes or number of meters dyed or printed before the colour fastness analysis was conducted. Test to be carried out only for baby articles (0-3 years old). Name of the person who performed the colour fastness analysis. Signature of the person in charge of performing the colour fastness analysis. Field reserved for indicating if the sample tested in-house was also sent to an external lab for a correlation study. In case the sample was sent for correlation, test report number should be also included. Field reserved for the storage of the sample tested and the specimen used in the analysis. 65 Annex XVII. In-House pH Analysis Template for Production Control GENERAL INFORMATION Delivery Note Nº Composition Article Description Quantity (Units/Weight/Length/Area) Customer Name pH ANALYSIS RESULTS Internal Order Nº Recipe Nº Date Nº Dyeing/ Printing Lot or Meters pH Analysis Result 1 Result 2 Result 3 Final Result Responsible Signature Sample Sent for Correlation (Y/N) 66 Identification code assigned to the goods sent by the customer once they are received at the facility warehouse. Description of the article that is being processed (yarn, fabric, trousers, t-shirt, among others). Description of the fibers and percentages (for textiles) the article processed is made of. Total amount of yarn, fabric, leather or garments initially received at the mill warehouse and that will be processed afterwards in different internal orders. Code assigned to each processing subset of yarn, fabric, leather or garments from one initial purchase order while they are being processed. Identification code of the recipe used in the dyeing, printing or washing process of a specific internal order. Date when the pH analysis of a specific internal order is performed. Identification code assigned to a dyeing or printing lot for traceability purposes or number of meters dyed or printed before the analysis was conducted. Final pH result expressed as the mean of Result 2 and Result 3. Person in charge of performing the pH analysis. Signature of the person in charge of performing the pH analysis. Field reserved for indicating if the sample tested in-house was also sent to an external lab for a correlation study. In case the sample was sent for correlation, test report number should be also included. 67 Annex XVIII. Example of a Chemical Supplier Process Evaluation CTW requirements non compliance risk: • CTW requirements non compliance related to chemical products provided by the chemical supplier under study in the last 2 seasons (12 months approximately). • Matching between the results of the test reports provided by the chemical supplier and the results obtained directly by the mill. Information availability in chemical product delivery notes: • Shipment delivery note number. • Chemical product manufacturer/distributor name. • Customer name. • Chemical product name. • Delivery date. • Lot number. Chemical product identification what implies: • Chemical product name. • Chemical manufacturer/distributor name. • Chemical product lot number. Chemical products delivery time: • Reasonable delivery times. • Delivery times compliance. • Number of incidences during last 2 seasons (12 months approximately) such as stock breakage, etc. Technical service: • Technical service availability. • Time period between the technical service request and the problem is solved. • Quality of the technical service received. • Availability of a laboratory to develop applications, recipes or colour matching. • Availability of chemical product samples in order to carry out pre-production samples. 68
