Code of Practice for Restricted Substances in Textiles

Author: David Bolton Tara Luckman Date Issued: Feb 2009 Date Revised: Applicable to: All Categories Product: Textiles Country: UK Revision Due: Feb 2010

Legal and Technical Document Matrix No: 391

Tesco Stores Ltd. All Rights Reserved. This document is supplied by Tesco for use of the immediate recipient

INDEX
Page 1 2 3 4 5 Aim Objective Scope Introduction Procedure 5.1 5.2 5.3 Introduction & Description Important Notes on Analytical Methods REACH Requirements 5.3.1 5.3.2 5.3.3 5.3.4 6 6.1 6.1.1 6.1.2 6.1.3 6.1.4 6.1.5 6.1.6 6.1.7 6.1.8 6.1.9 Azo Dyestuffs Disperse Dyes & Other Colorants Dye Carriers Organotin Compounds / Alkyl Tin Compounds Solvent Based Pigment Printing Fluorocarbons Moth Proofing Agents Pentachlorophenol (PCP) & Derivatives Mercury Suppliers of Articles from within the EU Suppliers of Articles from outside the EU Suppliers of Articles from outside the EU Regarding Substances of very high Concern Suppliers of Preparations from outside the EU 3 3 3 3 4 4 4 4 4 5 5 6 7 7 7 7 9 9 10 12 12 13 14 14 15

Prohibited Substances

6.1.10 Biocide Treatments 6.1.11 Hexavalent Chromium (Chrome VI)

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INDEX
Page 6.2 Substances Restricted by End Use 6.2.1 6.2.2 6.2.3 Phthalates Polyvinyl Chloride (PVC) Alkylphenol Ethoxylates (APEs APEOs) 16 16 17 17 18 20 20 20 21 23 23 23 24 25 26 27 27 28 29 30 31 31 32 33 35 35 36 37 40 41 44 45

6.2.4 Flame Retardant Finishes including Polychlorinated Biphenyls (PCBs) & Teraphenyls (PCTs) 6.2.5 6.3 6.3.1 6.3.2 7 Appendices 7.1 7.2 7.3 7.4 7.5 7.6 Residual pH & Skin Irritation Environmental Considerations Storage & Handling of Chemicals Use of Supplier Data Sheets (MSDS) Approved Testing Houses Dyestuff Suppliers Prohibited Azo Colourants & Pre-metallised Dye 7.6.1 7.6.2 7.7 7.8 7.9 7.10 7.11 7.12 7.13 7.14 8. 8.1 8.2 8.3 8.4 8.5 AZO Dyes Prohibited Aromatic Amines AZO Dyes Prohibited AZO Dyes Pesticides Formaldehyde Certain Heavy Metals Substances Restricted by Quantity

Prohibited Flame Retardants Prohibited Disperse Dyes Prohibited Other Colorants Prohibited Organotin Compounds Prohibited Solvents (Montreal Protocol) Restricted Pesticides Restricted Phthalates Prohibited & Restricted APEOs Site Audit Document for Tesco Suppliers Site Audit Result Grades Management, Environment & Ethics Document for Tesco Suppliers Management, Environment & Ethical Audit Results Grades Supplier: Corrective Actions & Improvement Plan

Suppliers Site Audit & Management, Environment & Ethics Audit

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1.

Aim

The aim of this Code of Practice is ensure that our suppliers are aware of all legislative and additional Tesco requirements prohibiting or controlling the use of certain materials, chemicals and processes in the production of textile products for Tesco. 2. Objective

To ensure all products launched meet all safety, legal, quality and policy requirements in accordance with the Tesco Rule 7 New Product Development Process New Product Development Testing. 3. Scope

This protocol applies to all Tesco own brand products. The protocol also covers products not branded as Tesco but for which we have the legal responsibility. 4. Introduction

Tesco Stores Ltd has a reputation for quality, value, good supplier relationships and customer service. As part of this commitment we take our customers safety and environmental issues very seriously. Whilst we do not expect the scope of this booklet to cover every environmental aspect it is our aim to be as environmentally pro active as is reasonably possible. The purpose of this Code of Practice therefore, is to ensure that our suppliers are aware of legislative and other requirements prohibiting or controlling the use of certain materials, chemicals and processes in the production of textile products for Tesco. As a supplier to Tesco Stores Ltd your knowledge of the content of this Code of Practice (CoP) is mandatory and you are obliged to ensure any factories supplying Tesco Stores Ltd via your production chain are equally aware of the content. This is to ensure the following:a) Prohibited substances & chemicals are not used in the supply chain. b) Restricted Substances & chemicals are only used within defined limits. c) The environmental protection of your own workforce d) Protection of the Tesco brand and customer confidence in the brand This booklet must also be used in conjunction with and compliments the TESCO TEXTILE PERFORMANCE STANDARDS which are available from the online Tesco Technical Library and from International Sourcing directories. Whilst our suppliers are obliged to ensure they conform to the requirements of this CoP we are keen to encourage any feedback on problems they have concerning the content and as part of our partnership with you will always endeavour to resolve any matters to the satisfaction of all parties. We welcome any suggestions or improvement we can make in this respect.

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The Code of Practice is based on the best available information at the time of issue and will be subject to updates as technological advances continue in the areas of materials, chemicals and processes, legislation, media/NGO issues, and customer requirements. It is however equally your responsibility as a supplier to be fully aware of any such changes which could affect your production chain. Tesco require that you nominate a person within your organisation to manage compliance with the requirements defined in this booklet and be responsible for keeping abreast of new requirements in this area. Please refer to appendix 7.2 ENVIRONMENTAL CONSIDERATIONS - for more information about this matter. 5. Procedure

Suppliers are expected to read and understand the following contents relating to their specific products. 5.1 Introduction & Code of Practice Description

The Code of Practice consists of five separate sections as follows:Section 6.1) Prohibited Substances Section 6.2) Substances Restricted by End Use Section 6.3) Substances Restricted By Quantity (Upper Limit Test Results) Section 7) Section 8) Appendices pages Supplier Site & Audit Management

An up-to-date version of this document will be retained on the Tesco Technical Library (TTL). Please take time to understand the whole content of this Code of Practice and refer to a Tesco Technical Manager in the event of any queries. 5.2 Important notes on Analytical Methods

In the case of prohibited or restricted substances where test Methods of Analysis are given the permitted levels are the maximum levels tolerated. Ideally these substances should be controlled well below the permitted level. The Methods of Analysis are given as:a) A means of identifying the presence of the prohibited or restricted substance. b) Where a quoted permitted limit is given this refers to the maximum allowed limit arising as a result of background contamination from non deliberate use of the substance in question. Under no circumstances must substances be used where they are clearly prohibited. Chemicals must not exceed permitted levels 5.3 REACH Requirements

5.3.1 Suppliers of articles from within the EU: The REACH Regulation entered into force in the EU on 1 June 2007 and imposes
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new obligations on companies. Among these new requirements is the obligation for retailers to provide information to consumers (professional and private ones) on the chemical composition of the products referred to as articles in REACH they sell. Articles are objects which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition. Examples of articles include furniture, textiles, toys, electrical devices, etc. To comply with REACH, retailers need to be informed of products containing Substances of Very High Concern (SVHC) which are present in concentrations above 0.1% weight by weight. Besides providing the name of the SVHC present in the article, suppliers will have to make available the necessary information to allow the safe use of the article in a format understandable to the final user, assuming this is not already provided. The list of these SVHC known as the candidate list can be found on the website of the European Chemicals Agency (ECHA) http://echa.europa.eu/chem_data/candidate_list_tabel_en.asp 5.3.2 Suppliers of articles from outside the EU: New legislation - known as REACH - entered into force in the EU on 1 June 2007 which imposes new obligations on companies. Among these new requirements is the obligation for importers to prove the safety of the products in regard to chemicals they import. To comply with this new legislation importers have to register all the substances contained in the articles they import that are intended to be released and that fulfil some specific criteria. Examples of articles containing substances which are intended to be released are scented candles, scented eraser, textile containing anti-perspiration agents etc. Articles are objects which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition. Examples of articles include furniture, textiles, toys, electrical devices, etc. Registration of substances in articles consists in importers providing information on all substances intended to be released and their use to a central agency. Therefore to comply with REACH, importers need to obtain as of now from their suppliers the composition of the products they import i.e. the name (CAS-Number) and the quantities of all the substances which are intended to be released which the article contains. 5.3.3 Suppliers of articles from outside the EU regarding Substances of Very High Concern (SVHC): New legislation - known as REACH - entered into force in the EU on 1 June 2007 which imposes new obligations on companies. Among these new requirements is the obligation for importers to prove the safety of the products in regard to chemicals they import.
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To comply with REACH, retailers need to be informed of Substances of Very High Concern (SVHC) which are present in articles in concentrations above 0.1% weight by weight. SVHC are chemicals that will be included in a list known as the Candidate List of substances of very high concern for Authorisation. This list will be regularly updated. A first version should be available by the end of 2008 and should be available on the website of the European Chemicals Agency (ECHA) http://echa.europa.eu/chem-data/candidate_list_table_en.asp SVHCs will be identified according to a complex procedure. They should be of the sort: CMR category 1 and 2 (carcinogenic, mutagenic and toxic for reproduction) e.g. asbestos, benzene, vinyl chloride, acrylamide, cadmium chromate, trichloroethylene, lead compounds etc. PBT (persistent, bioaccumulative and toxic) vPvBvT (very persistent, very bioaccumulative and very toxic) Endocrine disruptors Any substance which does not fulfil the above criteria but where there is evidence of probable serious effect human health

Therefore to comply with REACH, importers need to obtain from their suppliers as of the publication of the candidate list, information on the presence of SVHC in concentrations above 0.1% weight by weight in the articles it imports. Besides providing the name of the SVHC present in the article, suppliers will have to make available the necessary information to allow the safe use of the article in a format understandable to the final user, assuming this is not already provided. 5.3.4 Suppliers of preparations from outside the EU: New legislation - known as REACH - entered into force in the EU on 1 June 2007 which imposes new obligations on companies. Among these new requirements is the obligation for importers to prove the safety of the products in regard to chemicals they import. To comply with this new legislation importers have to register all the substances contained in the preparations they import that meet some specific criteria. Preparations are all mixtures or solutions composed of two or more substances. Examples include varnishes, cosmetics, paints, detergents etc. Registration consists in importers providing information on substances and their use to a central agency. Therefore to comply with REACH, importers need to obtain as of now from their suppliers the composition of the products they import i.e. the name (CAS-Number) and the quantities of all the substances the preparation contains.

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6. 6.1.1

PROHIBITED SUBSTANCES AZO DYESTUFFS

Restrictions on the use of Azo Dyes apply as per EU Directive 2004/21/EC of 24th February 2004 being an amendment to EU Council Directive 76/769/EEC. This restriction applies as certain Azo dyes can be reductive cleaved to form carcinogenic aromatic amines. Additionally a pre metallised blue colourant is restricted due to toxicity concerns. DYESTUFFS FALLING UNDER THE ABOVE RESTRICTION ARE PROHIBITED. PLEASE OBTAIN WRITTEN CONFIRMATION FROM YOUR SUPPLIER THAT NO PRODUCTS WHICH ARE BEING SUPPLIED TO YOU FALL INTO THIS CATEGORY. Refer appendix 7.6.1 for a full list of the concerned aromatic amines covered by this ban. Refer appendix 7.6.2 for details of the pre-metallised blue dyestuff Method of Analysis for Textiles:EN 14362 Part 1 & Part 2 The maximum permitted limit in all cases is less than 30mg/kg (0.003% m/m) in finished articles Alternatives:There is no reason for the prohibited products to restrict colour palettes as adequate alternatives exist. Use only permitted dyestuffs.

6.1.2

CERTAIN DISPERSE DYES AND OTHER COLOURANTS

Disperse dyes

Restrictions apply as to the use of certain disperse dyes in textiles as per Section 30 of the German Foods & Commodities Law. Disperse dyes are used in the coloration of polyesters, polyamide and acetate. This restriction applies as certain disperse dyes have been found to be allergenic & carcinogenic
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DISPERSE DYESTUFFS FALLING UNDER THE ABOVE RESTRICTION ARE PROHIBITED. PLEASE OBTAIN WRITTEN CONFIRMATION FROM YOUR SUPPLIER THAT NO PRODUCT YOU ARE BEING SUPPLIED WITH FALLS IN THIS CATEGORY. Refer appendix 7.8 for a full list of concerned disperse dyes covered by this ban Method of Analysis for Textiles:DIN 54231: 2005 The maximum permitted limit in all cases is not detected (i.e. less than 5mg/kg 0.0005% m/m) in finished articles. Other Colourants:-

Restrictions apply as to the use of certain acid, basic & direct dyes in textiles as per Section 30 of the German Food & Commodities Law This restriction applies as certain dyestuffs falling into this category have been found to have allergenic and carcinogenic properties. ACID, BASIC & DIRECT DYES FALLING IN THIS CATEGORY ARE PROHIBITED. PLEASE OBTAIN WRITTEN CONFIRMATION FROM YOUR SUPPLIER THAT NO PRODUCT YOU ARE BEING SUPPLIED WITH FALLS IN THIS CATEGORY Refer appendix 7.9 for a full list of concerned colorants covered by this ban. Method of Analysis for Textiles:DIN 54231: 2005 The maximum permitted limit in all cases is not detected (i.e. less than 5mg/kg 0.0005% m/m) in finished articles. Alternatives:There is no reason to restrict colour palettes as adequate alternatives of both the Disperse Dyes & other colorants exist. Use only permitted dyestuffs.

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6.1.3

DYE CARRIERS

GENERAL TEXTILE INDUSTRY BAN SUPPORTED BY TESCO The chemicals listed are prohibited or restricted in National Legislation in various European Countries including but not restricted to Section 30 of the German Foods & Commodities Law The restriction applies as certain dye carriers have been found to be carcinogenic and environmentally detrimental. DYE CARRIERS BASED ON TRICHLORO BENZENE, BIPHENYL PHENOL. ORTHOPHENYL PHENOL & HALOGENATED AROMATIC HYDROCARBONS ARE PROHIBITED. It is Tesco policy in this respect that dyeing of polyester should not take place at low temperature thereby eliminating the need for the use of carriers. It is the suppliers responsibility to ensure any dyeing of polyester takes place at high temperature and in the event this is not possible refer the matter to Tesco at once. Method of Analysis for Textiles:USEPA 625 The maximum permitted level in all cases is less than 1mg/kg (0.0001% m/m) in finished articles. Alternatives:High temperature dyeing of polyester by aqueous or continuous dyeing techniques only should be used. Use only permitted dyestuffs. Substitute chlorinated carriers with toxicologically acceptable carriers such as Carboxylic Acid Esters.

6.1.4

ORGANOTIN COMPOUNDS / ALKYL TIN COMPOUNDS

GENERAL TEXTILE INDUSTRY BAN SUPPORTED BY TESCO The Chemicals appear on the primary list of restricted substances published by Business for Social Responsibility 2004 Organotin Compounds are highly toxic and can affect landfill, water supplies and aquatic life. Such chemicals are mainly used as preservatives for fabrics and chemical formulations, or stabilisers in the processing of PVC. Also used as a catalyst in polyurethane and polyester foam.

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THE USE OF TRI BUTYL TIN (TBT) OR ANY OF ITS DERIVATIVES IN ANY STAGE OF MANUFACTURE IS PROHIBITED. PLEASE OBTAIN WRITTEN CONFIRMATION FROM YOUR SUPPLIER THAT NO PRODUCT YOU ARE BEING SUPPLIED WITH FALLS WITHIN THIS CATAGORY Please refer to appendix 7.10 for a full list of concerned Organotin compounds covered by this ban Method of Analysis for Textiles:DIN 38407 - 13 (1999) The maximum permitted limits in finished articles are as follows:Childrens products (0 -14 years) :- Less than 0.5mg/kg (0.00005% m/m) Adults products Alternatives Seek advice from chemical supplier. : - Less than 1.0mg/kg (0.0001% m/m)

6.1.5

SOLVENT BASED PIGMENT PRINTING SYSTEMS & OZONE DEPLETING SOLVENTS

A) Solvent based pigment printing systems:-

GENERAL TEXTILE INDUSTRY BAN SUPPORTED BY TESCO The chemical appear on the primary list of restricted substances published by Business for Social Responsibility 2004 Solvent based printing systems are highly toxic and have ozone depleting properties THE USE OF SOLVENT BASED PIGMENT BINDER SYSTEMS IS PROHIBITED. All pigment print binder systems must follow the aqueous route Method of Analysis:Textiles: - USEPA 624 & 8260B The limit required is the limit of detection. Alternatives: - Aqueous based binder systems to be used

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B) Ozone Depleting Solvents:-

The use of ozone depleting solvents as defined in the Montreal Protocol is prohibited Refer :- www.unep.ch/ozone/pdfs/Montreal-Protocol2000.pdf

Solvents are principally used as cleaning agents although are also found in other products such as adhesives and dye carriers. All processes where solvents are used must comply with the following criteria. a) Authentic data & safety sheets must be available to all operatives. Due regard must be paid to the health and safety of the operative when operating with solvents with adequate ventilation and a proper records kept of operative exposures. b) The solvent must be recoverable. c) In the case of adhesives an aqueous based alternative should used where possible. d) Spot stain removal should be done where possible using aqueous based agent. Solvent operations should be minimised with no residual solvent left on the final product. Extreme caution should be exercised when handling solvents with proper risk assessment as to their usage undertaken. IN ANY EVENT THE USE OF OZONE DEPLETING SOLVENTS AS DEFINED IN THE MONTREAL PROTOCOL IS PROHIBITED. www.unep.ch/ozone/pdfs/Montreal-Protocol2000.pdf Refer to appendix 7.11 for a list of solvents covered by this ban Method of Analysis for Textiles:USEPA 624 & 8260B The limit required is the limit of detection. Alternatives:Use aqueous cleaning systems wherever possible

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6.1.6

FLUOROCARBONS

Restrictions have been proposed in an amendment to EU Directive 76/769/EEC Certain fluorocarbons have been determined as having possible carcinogenic properties and are environmentally toxic. Fluorocarbons applied to textiles are used in water, stain and oil repellent finishes. THE USE OF FLUOROCARBONS CONTAINING PERFLUORO OCTANOIC ACID (PFOA) OR PERFLUORO OCTANYL SULFONATE (PFOS) IS PROHIBITED. PLEASE OBTAIN WRITTEN CONFIRMATION FROM YOUR SUPPLIER THAT NO PRODUCT YOU ARE BEING SUPPLIED UTILISES THE ABOVE CHEMICALS. SHOULD TRACE ELEMENTS OF THE ABOVE CHEMICALS BE UNAVOIDABLY PRESENT IN ANY PROCESS TESCO MUST BE INFORMED IMMEDIATELY Method of Analysis for Textiles:Appropriate method of test at a suitably accredited laboratory to show absence of fluorocarbons. The maximum permitted limit in all cases is less than 1.0mg/kg (0.0001% m/m). Alternatives:Chemical suppliers are now able to offer adequate alternatives

6.1.7

MOTHPROOFING AGENTS

Mothproofing agents and certain other pesticides are prohibited or restricted in EU and National Legislation including but not restricted to Section 30 of the German Foods & Commodities Law. The chemicals also appear on the primary list of restricted substances published by Business for Social Responsibility 2004 In this context your attention is also drawn to item 6.2.5 concerning Pesticides. Mothproofing agents have been found to be detrimental to other forms of wild life THE USE OF MOTHPROOFING AGENTS IN THE PRODUCTION OF TEXTILE GOODS IS PROHIBITED. PLEASE OBTAIN WRITTEN CONFIRMATION FROM YOUR SUPPLIER THAT MOTHPROOFING AGENTS ARE NOT USED IN ANY PRODUCTS YOU ARE BEING SUPPLIED WITH

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Method of Analysis for Textiles:Appropriate method of test at a suitably accredited laboratory to show absence of mothproofing agents. The limit required is the limit of detection (currently 20 ppb parts per billion). Alternatives:There is no alternative to moth proofing agents. Use of agents giving similar properties is not necessary in a properly controlled production environment

6.1.8

PENTACHLOROPHENOL (PCP) & DERIVATIVES

Restrictions apply according to :Switzerland :- Ordinance Relating to Environmentally Hazardous Substances (Ordinance on Substances , Osubst) ( 06/06/93) Germany :- Chemicals Act (Chemikalien Verbotsverordnung) of 14/10/93, Bundesgesetzblatt III 8053-6-20) Czech Republic :- Decree 356 of 2003 Orthochlorophenol, Pentachlorophenol & Penatachlorophenol are highly toxic, carcinogenic and detrimental to general health as well as releasing toxic dioxins on combustion. Pentachlorophenols are used as anti fungal preservatives principally in cotton growing, various greige cloths and some print pastes. THE USE OF PENTACHLOROPHENOL AND ANY OF ITS DERIVATIVES IS PROHIBITED. However it is understood by Tesco that traces of PCPs may exist in production and in this event they must not be above the practical limits of detection. Method of Analysis in Textiles:35 LMBG B 82.02 8 (June 2001) The maximum permitted limit in all cases is less than 0.5mg/kg (0.00005% m/m) in finished articles. Alternatives:Seek supplier advice. Use should not be required if long term storage is not needed.

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6.1.9

MERCURY Hg

Mercury is prohibited in National Legislation in various European Countries. Mercury has been found to have detrimental effects on the central nervous system and is an anticipated carcinogen. Certain caustic soda processes used in fabric / textile product manufacture may use mercury containing products. MERCURY CONTAINING PRODUCTS IN TEXTILE PROCESSING ARE PROHIBITED. ALL CAUSTIC SODA (SODIUM HYDROXIDE) TREATMENTS MUST BE MERCURY FREE. PLEASE OBTAIN WRITTEN CONFIRMATION FROM YOUR SUPPLIER THAT NONE OF THEIR PRODUCTS OR PROCESSES UTILISE MERCURY CONTAINING PRODUCTS. Method of Analysis for Textiles:Extract using ISO 105 E04 (solution ii) with analysis according to BS 6810-2:2005 The maximum permitted limit according to the above extraction technique is less than 60mg/kg (0.006% m/m) in textile articles. Alternatives:Use of non Mercury containing products required.

6.1.10

BIOCIDE TREATMENTS

Some Biocide treatments are prohibited or restricted in EU & National Legislation including but not restricted to section 30 of the German Foods & Commodities Law. The chemicals appear on the primary list of restricted substances published by Business for Social Responsibility 2004 Biocide treatments are used as a bacterial control. Any such biocide treatments must be permanent and non-leaching and must not be implicated in anti biotic resistance. THE USE OF APPLIED BIOCIDE TREATMENTS IN CHILDRENS PRODUCTS* IS PROHIBITED. Biocide treatments may only be used elsewhere within Tesco by specific agreement of the buying department.
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Triclosan notified under CAS No 3380-54-35 is prohibited. Dimethylfumarate notified under 624-49-7 is prohibited. Method of Analysis:Textiles: Appropriate method at a suitably accredited laboratory to show the absence of biocide treatments. The maximum permitted limit in all case is less than 5mg/kg (0.0005% m/m) Alternatives:Seek advice from chemical supplier.

*= Childrens products are defined as age group 0-14 years

6.1.11

HEXAVALENT CHROMIUM (CHROME VI)

GENERAL TEXTILE INDUSTRY BAN SUPPORTED BY TESCO The chemical is prohibited or restricted in EU & National Legislation including but not restricted to section 30 of the German Foods & Commodities Law Hexavalent chromium (VI) compounds have been found to possess carcinogenic & allergenic properties, as well as being environmentally persistent. It is used in the application of certain dyestuffs in both the textile and leather industries (after chroming of textiles improves colour fastness). In leather tanning harmless Chromium III will normally be present, but Chromium VI arises from subsequent processes and treatments. Lead Chromate is often added to pigments for plastics. THE USE OF ANY SUBSTANCES CONTAINING HEXAVALENT CHROMIUM, ITS DERIVATIVES OR PROCESSES THAT GENERATE IT ARE PROHIBITED BY TESCO. Method of Analysis for Textiles:Extract using ISO 105 EN 04 (solution ii) with analysis according to BS 6810 -1: 1987. The maximum permitted limit is 3.0mg/kg (0.0003% m/m) in any finished article. Alternatives:Avoid 2 bath chrome tanning as it uses Chrome VI directly. Carefully control 1 bath tanning to avoid the conversion from Chrome III to Chrome VI. Avoid strong alkaline conditions (e.g. treatment with Ammonia before tanning and strong alkaline glues).
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Careful selection of neutralizing agents (replace with reducing agents) and fat liquoring agents.

6.2

SUBSTANCES RESTRICTED BY END USE 6.2.1 PHTHALATES

Restrictions apply as to the use of Phthalates as per EU Directive 199/815/EC and EU Directive 2005/84/EC Restrictions on the use of certain Phthalates in toys and Childcare articles The principal use of phthalates is a Plasticiser in the production of PVC and other polymers. There is evidence to show that certain plasticisers can act as endocrine disruptors. Tesco are adopting the following policy with regard to phthalates; THE USE OF PHTHALATES IN AREAS OF CHILDRENS* PRODUCTS, TOYS & CHILDCARE ITEMS PRODUCTION IS PROHIBITED BY TESCO. THIS APPLIES TO THE PRINCIPAL PRODUCT/BODY FABRIC, COMPONENTS, EMBELISHMENTS, PRINTS, BADGES, MOTIFS, BELTS, BUTTONS, SEQUINS, BAGS ETC. It is recognised that phthalates can be evident as a background contamination and Tescos policy in this respect is as follows; WHERE CONTAMINATION IS A RISK, E.G. WET FINISHING, PRINTING, PLASTIC MOLDING, ALL CHILDRENS* IT IS BEST PRACTISE FOR PRODUCT PROCESSING & STORAGE TO BE CARRIED OUT IN A MANAGED SEGREGATED PHTHALATE FREE AREA. Restricted phthalates are shown in appendix 7.13 Method of Analysis for Textiles:BS EN 14372: 2004 The maximum permitted level is 500mg/kg (0.05% m/m) for each phthalate with no combined phthalate level exceeding 1000mg/kg (0.1% m/m) Alternatives: Alternatives are: Di- (isononyl) - cyclohexan -1,2-dicarboxylate (DINCH) Adipates (DEHA) Citrates (ATBC) *= Childrens products are defined as intended for age group 0-14 years

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6.2.2

POLYVINYL CHLORIDE (PVC)

ASSOCIATED WITH PROHIBITED PHTHALATES & ORGANOTIN PVC is a thermoplastic which can be used in many end uses being soft, hard, transparent or coloured. In the textile industry PVC is often found in accessories such as zip pullers, coatings, prints and accessories such as badges etc. Prohibited phthalates are regularly used to soften PVC and prohibited Organotin is often used as a stabilizer in PVC, therefore the three substances are closely associated with one another. See 7.13 Phthalates & 7.10 Organotin The following restrictions apply to the use of PVC: THE USE OF PVC IN TESCO PRODUCTS IS DISOURAGED WHERE POSSIBLE AND ONLY USED WHERE NO SUITABLE ALTERNATIVE EXISTS. THE USE OF PVC IN TESCO PRODUCTS IS FOR GRADUAL PHASE OUT & AS SUCH MAY ONLY BE USED WITH ADVANCE PERMISSION FROM THE TESCO TECHNICAL MANAGER. Method of Analysis for Textiles:Beilstein Test or FTIR (Fourier transform infrared spectroscopy) The maximum permitted level (where PVC has been restricted by the Technical Manager), is none detected. Alternatives:Non polyvinylchloride, Polyurethane or Acrylic containing products are readily available 6.2.3 ALKYLPHENOL ETHOXYLATES APEOs

Restrictions apply as to the use of APEOs as per EU Directive 2003/53/EC APEOs are a group of non ionic surfactants which are principally used as wetting agents in textile and other related industries. There is concern that APEOs may act as endocrine disruptors and their biodegradation to Nonylphenols (NP) and Octylphenols (OP) may give rise to fish toxic metabolites and long term environmental impact. However it is recognised that NPs and OPs may be evident as a background contamination in water suppliers and therefore the Tesco policy in this respect is as follows:THE USE OF APEOs SPECIFICALLY CONTAINING OCTYL PHENOLS (OP) & NONYL PHENOLS IS RESTRICTED IN ALL AREAS OF TESCO PRODUCTION, PENDING COMPLETE PHASE OUT.
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Prohibited and restricted APEOs and derivatives are shown in appendix 7.14. Method of Analysis for Textiles:Appropriate method of test at a suitably accredited laboratory to show the extent of alkylphenol ethoxylates. Defined test methods are GCMS, HPLC & LCMS. The maximum permitted limit as a background contamination for prohibited APEOs (NPs & Ops) is 30mg/kg (0.003% m/m) in finished textiles. For restricted APEOs (NPE & OPE) used as a processing additive the permitted limit is 250mg/kg (0.025% m/m) in finished textiles, pending phase out. Alternatives:Alcohol ethoxylates are an acceptable alternative. On volume production this should not reflect on the processing cost.

6.2.4

FLAME RETARDANT FINISHES

Restrictions apply as to the use of Flame Retardants as per EU Council Directive 83/264/EC & 2003/11/EC being amendments to EU Council Directive 76/769/EEC Flame retardants which utilise organophosphates are toxic and persistent in the environment. Certain products have to meet legislative requirements regarding consumer safety. Application of flame retardant finishes is only permitted where there is a specific need and with the written consent of Tesco. FLAME RETARDANT FINISHES APPLIED AS PART OF A PROCESSING TREATMENT ARE PROHIBITED IN ALL CHILDRENS* CLOTHING AND RESTRICTED ON ALL OTHER CLOTHING PRODUCTS. FLAME RETARDANT FINISHES APPLIED AS PART OF A PROCESSING TREATMENT ON NON CLOTHING PRODUCTS MUST BE AUTHORISED BY THE TESCO TECHNICAL MANAGER. Inherent flame retardant finishes (inherent in fibres and yarns) must be checked to ensure no leaching out during wash/care & use. Refer to appendix 7.7 for a full list of prohibited flame retardant agents Method of Analysis for Textiles:Appropriate method of test at a suitably accredited laboratory to show the absence of flame retardant finishes. The maximum permitted limit in all restricted cases is not detected
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Alternatives:Suppliers should be aware of continued progressing technology in this area and should update themselves with their own suppliers in this respect *= Childrenswear is defined as age group 0-14 years.

POLYCHLORINATED BIPHENYLS (PCBs) & TERPHENYLS (PCTs)

The use of Polychlorinated Biphenyls & Polychlorinated Terphenyl products is banned in the production of Textile materials according to EU Council Directive 85/467/EEC. Polychlorinated Biphenyls (PCBs) have in the past been used as stabilizing agents during the application of flame retardant finishes. They are highly toxic persistent organic pollutants evident as background contamination in the environment due to use and disposal. THE USE OF ANY PRODUCT CONTAINING PCBs ACCORDING TO CAS NUMBER 1336-36-3 AND CONGENERS OR MIXTURES IS BANNED. RERSTRICTIONS AS TO THE LEVEL OF BACKGROUND CONTAMINATION APPLY. Polychlorinated Teraphenyls (PCTs) are persistent organic pollutants evident as background contamination in the environment. THE PRESENCE OF PCTs ACCORDING TO CAS NUMBER 61788-33-8 AND CONGENERS OR MIXTURES IS RESTRICTED TO BACKGROUND CONTAMINATION ONLY. RESTRICTIONS AS TO THE LEVEL OF BACKGROUND CONTAMINATION APPLY. Method of Analysis for Textiles:USEPA 8082 with solvent extraction by GCMS. The permitted limit as a background contamination is restricted to a combined total of PCP / PCB presence of less than 0.5mg/kg (0.00005%). Alternatives:Modern processing techniques do not require use of PCBs.

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6.2.5

PESTICIDES

GENERAL TEXTILE INDUSTRY BAN SUPPORTED BY TESCO. Pesticides are prohibited or restricted in EU and National Legislation including but not restricted to Section 30 of the German Food & Commodities Law Pesticides are used to treat textiles, leather, feathers and down to prevent attack from pests prior to manufacture or transportation. Restrictions apply as some pesticides are not biodegradable and are therefore harmful to the environment, affecting animal plant and aquatic life. Method of Analysis:Textiles: - Appropriate method of test at a suitably accredited laboratory to show absence of pesticide residue. The use of pesticides in textiles is restricted and the sum of all listed pesticides noted in appendix 7.12 must not exceed the following limits. Wool & other Keratin (hair/fur/feathers) based fabrics: - 0.5mg/kg (0.00005% m/m). Cotton, natural cellulose & cotton blends: - Individual levels must not exceed 0.05 mg/kg (0.000005% m/m). Alternatives:Checks to be made with supplier as regulations are regularly changing Note: Accepted levels of residual pesticides will be reduced to 20 ppb (parts per billion) by the end of 2008. Please consider this for forward planning.

6.3

SUBSTANCES RESTRICTED BY QUANTITY FORMALDEHYDE

6.3.1

VARIOUS EUROPEAN REGULATIONS APPLY WHICH ARE SUPPORTED BY TESCO Formaldehyde has been found to be a skin and mucous membrane (airway) irritant. It has also been classified as a carcinogen by the World Health Organisation. Formaldehyde is usually associated with easy care (pre-shrink / pre-crease) finishes applied to cellulosic fabrics and derivatives, but is also used in dye fixation, tanning and certain specialised finish applications such as flocking. Tescos policy as regards the use of formaldehyde containing finishes is that they should be avoided where a reasonable pure finish or other alternative is available
Page 20 of 45

without compromising the fabric performance. However the use of formaldehyde containing finishes is permitted by agreement with Tesco providing the following threshold limits noted below are not exceeded. Method of Analysis for Textiles:EN ISO 14184-1: 1999 (Free Formaldehyde) & EN ISO 14184- 2: 1998 (Released Formaldehyde) Free Formaldehyde: - Values must not exceed:I):- 20mg/kg (0.002% m/m) for all Baby & Toddler items (0-3 years) II):-75mg/kg (0.0075% m/m) for other items in direct skin contact* III):- 300mg/kg (0.03% m/m) for items not in direct skin contact *All clothing items are considered to be intended for direct skin contact Released Formaldehyde: - Values must not exceed 75mg/kg (0.0075% m/m) DEPENDING ON FINAL PRODUCT END USE ADDITIONAL REQUIREMENTS MAY APPLY. CHECKS SHOULD BE MADE WITH THE RELEVENT TESCO TECHNICAL MANAGER. Alternatives:Use pure finishes where possible. In the case of applications such as flock or appliqu then formaldehyde containing agents should be avoided. Where this is not possible the above standards must apply to be included as part of (and not separate from) the whole sample test result (i.e. base material plus application together must not exceed above values).

6.3.2

CERTAIN HEAVY METALS

Restrictions apply as to the extent of heavy metals allowed in textiles, this being according to the voluntary Oeko-tex standard which has been adopted as law in certain European countries. FINISHED PRODUCTS INTENDED FOR CHILDREN WILL FURTHER BE REQUIRED TO COMPLY WITH TOXICITY TO HEAVY METALS AS DESCRIBED IN EN71-3. REFER TO PRODUCT GUIDELINES FOR MORE DETAIL. ATTENTION MUST BE PAID IN PARTICULAR TO PRINTS, PIGMENTS, COATINGS & EMBELLISHMENTS.

Page 21 of 45

Maximum permissible limits according to Oeko-tex are:Antimony Arsenic Cadmium Copper Cu Chromium Cr Cobalt Co Lead Mercury Hg Method of Analysis:Extract using EN ISO 105 E04 (solution ii) analysis according to BS 6810-2 : 2005. Alternatives:It is acceptable to operate within the above limits but where possible the use of fabrics, prints & finishes containing these metal elements should be avoided. 30mg/kg (0.0030% m/m) 0.2mg/kg (0.00002% m/m) 0.1mg/kg (0.00001% m/m) 25mg/kg (0.0025% m/m) 1mg/kg (0.0001% m/m) 1mg/kg (0.0001% m/m) 0.2mg/kg (0.00002% m/m) 0.02mg/kg (0.000002% m/m)

Page 22 of 45

7.

APPENDICES 7.1 RESIDUAL pH AND SKIN IRRITATION

In addition to the whole content of this document suppliers need to be aware that in order to avoid skin irritation problems on finished products intended for skin contact Tesco operates restrictions on residual pH values on finished goods as follow :The pH value of finished goods must fall within the maximum permitted range of 4.8 to 7.5 in accordance with ISO3071. Suppliers need to be aware of these criteria with evidential proof of pH values being made available to Tesco on demand. 7.2 ENVIRONMENTAL CONSIDERATIONS

As part of Tescos commitment to good environmental practice it is a requirement that all suppliers should take a pro active approach to all environmental issues. In this respect it is a Tesco requirement that all suppliers have proper Environmental Management Systems in place to cover not only relevant environmental issues within their organisation but also demonstrate a continuous commitment & improvement in environmental areas. It is recommended that Environmental Management Systems cover the following areas within a suppliers organisation. The list is by no means exhaustive and suppliers should also take full ownership of environmental issues by ensuring proper documentation of environmental policy, organisational responsibilities and accountabilities. Health & Safety. Water management & effluent control. IT IS MANDATORY THAT EFFLUENT IS CONTROLLED TO LOCAL AND NATIONAL IN-COUNTRY REGULATIONS AT ALL SITES INVOLVED IN THE MANUFACTURE OF TESCO PRODUCTS INCLUDING SUB-CONTRACT UNITS EG. LAUNDRIES & PRINT HOUSES.

Pollution control Best & most efficient use of energy Best practices for raw material usage Recoverable and recyclable components and packaging Packaging minimisation Waste disposal This is a matter of your own self assessment but it is a Tesco requirement to assess
Page 23 of 45

with you what best practices you have in place to pay regard to environmental considerations. In this regard Tesco will, in any event, expect you to:a) Have proper environmental planning with regard to:I) II) III) b) All legal requirements associated with the environment. Management & staff training. Objectives and forward commitments to be achieved in this respect.

Have proper documentation in respect of the foregoing. The use of KPIs (Key Performance Indicators) is suggested in this respect.

TESCO WILL EXPECT DOCUMENTARY PROOF OF YOUR ENVIRONMENTAL COMMITMENT TO BE AVAILABLE FOR INSPECTION AND AUDIT ON REQUEST. c) A responsible person in your organisation to take ownership of and accountability for environmental issues.

7.3

STORAGE & HANDLING OF CHEMICALS (INCLUDING DYESTUFFS) USE OF SUPPLIERS DATA SHEETS (ALSO KNOWN AS MATERIAL SAFETY DATA SHEETS [MSDS])

The storage and handling of chemicals and other agents must comply with the following criteria:a) b) The suppliers recommendations Regard to the health and safety of the operative handling the chemicals / agents.

In all cases Tesco are committed to ensuring best practices in this area and therefore it is your responsibility to ensure both you and your suppliers properly comply with the best working practices to ensure the health and safety of your operatives. The following are mandatory:a) Authentic supplier data sheet all chemicals must be available and understood. Recommendations concerning health, safety, correct storage & handling, operative protection and environmental consideration must be acted upon. Worker health and safety is a critical issue. Failure to comply will result in non-compliances being raised during Tesco audits. We recommend all data sheets are available at point of chemical usage and separately available to management if required. b) Proper protective clothing must be provided for all operatives with overalls, goggles, face masks, protective gloves, headgear etc available and worn as required. c) A high standard of cleanliness and ventilation is required in all
Page 24 of 45

areas where chemicals are being metered, weighed or otherwise handled. In particular the weighing of dry powder substances should only take place where there is a proper dust extraction system such a down draft ventilation system. d) Proper equipment to deal with chemical spillages and cleaning up of such spillages must be available with proper regard being paid to handling of hazardous or otherwise environmentally unfriendly chemicals. Disposal must be handled by authorized waste disposal companies. e) Smoking, eating or drinking is strictly forbidden in any areas where chemicals are being handled. Designated areas for smoking, eating & drinking must be provided.

7.4

APPROVED TESTING HOUSES

Testing of goods to ensure compliance with this document must be effected at an approved testing house at supplier cost with test results being made available to the Tesco Technical Manager. The relevant Technical Manager will agree with you a schedule of conformance testing for the product in question and a time scale for test result submission. Any non-conformance which may affect production, lead times and deliveries must be communicated to the relevant Tesco buying department immediately test results are known. Additionally Tesco will randomly check production to ensure conformance criteria are being met with the consequences of any non-conformance being fully borne by the supplier. All conformance testing within the UK must be carried out by a UKAS accredited test house (www.ukas.com).Outside of the UK only laboratories which have multilateral or international agreements with UKAS for those test methods may be used. FOR A SUMMARY OF UKAS MULILATERAL AGREEMENTS PLEASE REFER TO TESCO GROUP LABORATORY ACCREDITATION POLICY (POLICY DOCUMENT 079). In placing conformance testing business with any laboratory it is important to appreciate that whilst the laboratory in question will be accredited for a range of test they may not be able to offer the particular test required. In this event another testing laboratory must be used.

Page 25 of 45

7.5

DYESTUFF SUPPLIERS

It is strongly recommended that dyestuffs are only supplied by members of ETAD (Ecological & Toxilogical Association of Dyes & Organic Pigment Manufacturers) Please visit the ETAD web site at www.etad.com to find the latest information concerning ETAD members list or contact ETAD directly at:P.O.Box 4005 Basel, SWITZERLAND, Telephone: - + 41 61 690 9966 Fax: + 41 61 691 4278

You are advised that trace elements and metal impurities which arise during the manufacture of dyes & pigments must comply with ETAD limits PLEASE SEEK WRITTEN CONFIRMATION FROM YOUR SUPPLIERS THAT ETAD LIMITS IN THIS RESPECT ARE BEING ACHIEVED.

Page 26 of 45

7.6 7.6.1

PROHIBITED AZO COLOURANTS & PREMETALISED DYE AZO DYES: PROHIBITED AROMATIC AMINES AS SPECIFIED IN EU COMMISSION DIRECTIVE 2004/21/EC

Prohibited Substance 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 4--amino biphenyl Benzidine 4-chloro-o-toluidine 2-napthylamine o-aminoazotoluene 4-nitro-o-toluidine 4-chloroaniline 4-methoxy-m-phenylenediamine 4,4-diaminodiphenylmethane 3,3-dichlorobenzidene 3,3-dimethoxybenzidene 3,3-dimethylbenzidine 3,3dimethyl-4,4-diamino-diphenylmethane p-cresidine 4,4-methylene-bis-( 2-chloro-aniline) 4,4-oxydianiline 4,4-thiodianiline o-toluidine 4-methyl-m-phenylenediamine 2,4,5-trimethylaniline o-anisidine 4-amino azobenzene 2,4-xylidene 2,6-xylidine

CAS No 92-67-1 97-87-5 95-69-2 91-59-8 97-56-3 99-55-8 106-47-8 615-05-4 101-77-9 91-94-1 119-90-4 119-93-7 838-88-0 120-71-8 101-14-4 101-80-4 139-65-1 95-53-4 95-80-7 137-17-7 90-04-0 60-09-3 95-68-1 87-62-7

Page 27 of 45

7.6.2

AZO DYES: PROHIBITED AZO DYES AS SPECIFICED IN EU COMMISSION DIRECTIVE 2004/21/EC

Prohibited Substance A mixture of :Disodium(6-(4-anisidino)-3sulfonato-2-(3,5-dinitro-2oxidophenyl-lazo)-1naphtholato)(1-(5-chloro-2oxidophenylazo)-2naphtholto) chromate (1-) & Trisodiumbis(6-(4anisidino)-3-3sulfonato-2(3,5-dinitro-2oxidophenyllazo)-1-naphtholato) chromate(1-)

CAS No Not allocated

EC No 405-665-4

Page 28 of 45

7.7

PROHIBITED FLAME RETARDANTS AS SPECIFIED IN EU COUNCIL DIRECTIVES 82/264/EC & 2003/11/EC

Prohibited Substance 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Tris (2,3-dibromopropyl ) phosphate (TRIS) Polybromobiphenyls (PBBs) Tetrabromobisphenol A (TBBPA) Tris -(aziridinyl)-phosphine oxide (tris (1-aziridinyl ) phosphine oxide) (TEPA) Pentabromyldiphenyl ether (Penta BDE) Octabromodiphenyl ether (Octa BDE ) Decabromodiphenyl ether (Deca BDE ) Bis (2,3-dibromopropyl) phosphate Tri-o-cresyl phosphate Tris (2-chloroethyl) phospahate (TCEP) Hexabromocyclododecane 2,2-Bis (bromomethyl) -1,3-propanediol Tris (1,3-dichloro-isopropyl) phosphate (TDCP) Chloroparaffines

CAS No 126-72-7 59536-65-1 79-94-7 5455-55-1 32534-81-9 32536-52-0 1163-19-5 5412-25-9 78-30-8 115-96-8 3194-55-6 3296-90-0 13674-87-8 85535-84-8

Page 29 of 45

7.8

PROHIBITED DISPERSE DYES AS SPECIFIED IN SECTION 30 OF THE GERMAN FOOD & COMMODITIES LAW

Prohibited Disperse Dye 1 2 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Disperse Blue1 Disperse Blue 3 Disperse Blue 7 Disperse Blue 26 Disperse Blue 35 Disperse Blue 102 Disperse Blue 106 Disperse Blue 124 Disperse Brown 1 Disperse Red 1 Disperse Red 11 Disperse Red 17 Disperse Orange 1 Disperse Orange 3 Disperse Orange 11 Disperse Orange 37 Disperse Orange 76 Disperse Yellow 1 Disperse Yellow 3 Disperse Yellow 9 Disperse Yellow 23 Disperse Yellow 39 Disperse Yellow 49

CAS No 2475-45-8 2475-46-9 3179-46-9 3860-63-7 12222-75-2 12222-97-8 12223-01-7 61951-51-7 12236-00-9 2872-52-8 2872-48-2 3179-89-3 2581-69-3 730-40-5 82-28-0 12223-33-5 51811-42-8 119-15-3 3832-40-8 6373-73-5 6250-22-3 12236-29-2 54824-37-2

Page 30 of 45

7.9

PROHIBITED OTHER COLOURANTS SPECIFIED IN SECTION 30 OF THE GERMAN FOOD & COMMODITIES LAW

Prohibited Substance Acid Red 26 2 3 4 5 6 7 Basic Red 9 Basic Violet 14 Direct Black 38 Direct Brown 6 Direct Brown 95 Direct Red 28

CAS No 3761-53-3 569-61-9 632-99-5 1937-37-7 2602-46-2 16071-86-6 573-58-0

7.10

PROHIBITED ORGANO TIN COMPOUNDS AS SPECIFIED BY TESCO SUPPORTED INDUSTRY BAN

Prohibited Substance 1 2 3 4 5 Tributyltin (TBT) Trichlohexyltin (TCyHT) Trioctyltin (TOT) Triphenyltin (TPhT) Tripropyltin (TPT)

CAS No 56573-85-4

668-34-8

Page 31 of 45

7.11

PROHIBITED SOLVENTS AS PER MONTREAL PROTOCOL

Prohibited Substance 1 2 3 4 5 6 7 8 9 10 11 12 Benzene Dimethylacetamide Dimethylformamide Ethylene Glycol Monobutyl Ether Fomaldehyde Methylene Chloride n- Hexane 4,4methylene bis (2-chloroaniline) Phenol Tetrachloroethylene Tetrachloromethane Trichloroethylene

CAS No 71-43-2 127-19-5 68-12-2 110-80-5 50-00-0 75-09-2 110-54-3

108-95-2 127-18-4 56-23-5 79-01-6

Page 32 of 45

7.12

RESTRICTED PESTICIDES AS SPECIFIED IN EU & NATIONAL LEGISLATION INCLUDING SECTION 30 GERMAN FOOD & COMMODITIES LAW

Restricted Substance 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Aldrine Catafol Chlordane Chlordecone (Kepone) Chlordimerform Chlorobenzilate DDD DDE DT Bibromochloropropane (DBCP) Dieldrine Dinoseb DTTB (Timiperone) Endrine Ethylene Dibromide Heptachlor Hepatchloroperoxide Hexachlorobenzine Alpha - Hexachlorcyclohexane Beta - Hexachlorcyclohexane Gamma - Hexachlorcyclohexane Lindane Isodrin
Page 33 of 45

CAS No 309-00-2 2425-06-1 57-74-9 143-50-0 6164-98-3 510-15-6 72-54-8 72-55-9 50-29-3 1996-12-08 60-57-1 88-85-7 57648-21-2 72-20-8 106-93-4 76-44-8 1024-57-3 118-74-1 319-84-6 319-85-7 319-86-8 58-89-9 465-73-6

Restricted Substance cont 24 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Kelevane Metamidophos Methoxychlor Mirex Monocrotophos Monomethyldibromodiphenylmethane Monomethyldichlorodiphenylmethane Monomethyltetrachlorodiphenylmethane Parathion Pararthion - Methyl Perthane Phosphamidone Quintozene Strobane Telodrin (Isobenzan) Toxaphene (Camphechlorine) Certain Halogenated Biphenals (1) Certain Halogenated Terphenyls (2) Certain Halogenated Naphthalenes (3) 2-(2,4,5 - Trichlorophenoxy) propionic acid and its salts 2-(2,4,5 - Trichlorophenoxy) propional compounds 2,4,5 - Trichlorophenoxyacetic acid and its salts 2,4,5 - Trichlorophenoxyacetyl compounds

CAS No 4243-79-1 10265-92-6 72-43-5 2385-85-5 6923-22-4 99688-47-8

76253-60-6 56-38-2 298-00-0 72-56-0 13171-21-6 82-68-8 8001-50-1 297-78-8 8001-35-2

Page 34 of 45

(1) = Of formula :- C12HnX10-n where X= Halogen & n=1,2.9 (2) = Of formula :- C18HnX14-n where X= Halogen & n=1,2.13 (3) = Of formula :- C12HnX8-n where X =Halogen & n=1,2.7

7.13

RESTRICTED PHTHALATES AS PER EU DIRECTIVE 1999/815/EEC & EU DIRECTIVE 2005/84/EC Restricted Substance CAS No 28553-12-0 117-81-7 117-84-0 26761-40-0 85-68-7 84-74-2

1 2 3 4 5 6

Di-isonony phthalate (DINP) Di (ethylhexyl) phthalate (DEHP) Di-n-octyl phthalate (DNOP) Di-iso-decyl phthlate (DIDP) Butyl benzyl phthalate (BBP) Di butyl phthalate (DBP)

7.14

PROHIBITED & RESTRICTED APEOs AS PER EU DIRECTIVE 2003/53/EC Prohibited Substance CAS No 25154-52-3 27193-28-8

1 2

Nonylphenol (NP) Octylphenol (OP) Restricted Substance

1 2

Nonylphenolethyoxylates (NPEs) Octylphenolethyoxylates (OPEs)

9016-45-9 9063-89-2

Page 35 of 45

8.

SUPPLIERS SITE AUDIT AND MANAGEMENT, ENVIRONMENT & ETHICS AUDIT Introduction This documentation is for suppliers of textile goods, for use as a management tool when carrying out assessment of dyers, printers, and finishers. The purpose of this documentation is to ensure a standard assessment format across our business, ensuring commonality of approach & reporting. The document has been prepared in such a manner that it can be easily managed during routine visits to processors and it is anticipated that the enclosed audit document should be completed on an annual basis for each processor used for Tesco production. As a guideline expectation, it is appropriate to carry out this assessment for suppliers/processors handling in excess of 10,000 metres raw materials for Tesco production in any given season. It is however important to note that effective document completion can only be done by a full site visit. A nominated person at the primary supplier company should be responsible for ensuring completion of the document and its availability for Tesco inspection as required. If no such resource exists within the primary supplier please contact the relevant Tesco Technical manager to discuss the use of an alternative third party. Included with the document is a Corrective Actions & Improvement Plan form which in the case of a serious discrepancy found should be completed with the processor, with a copy being left with them. The agreed time scale for any corrections and improvements must be reasonable considering the nature of the problem. It must be followed up to ensure compliance at the end of the agreed time scale with further more frequent audits to ensure on going compliance if required. Please examine the document and if you have any queries or suggestions as to its usage please contact the relevant Technical Manager at Tesco. Your relevant Tesco contact will discuss its implication with you in due course.

Page 36 of 45

8.1

SITE AUDIT DOCUMENT FOR TESCO SUPPLIERS TESCO STORES LTD SITE AUDIT DOCUMENT FOR TESCO SUPPLIERS SUPPLY CATEGORY:- DYERS, PRINTERS & FINISHERS

Name of Supplier Dyer, Printer & Finisher:Name of Processor, Address & Contact Date of Assessment

ALL DYERS, PRINTERS & FINISHERS MUST HAVE IN THEIR POSSESSION & CONFORM TO THE REQUIREMENTS OF THE TESCO RESTRICTED SUBSTANCES DOCUMENT

INCOMING RAW MATERIALS:- Wet & Dry Dyestuffs, Chemicals, etc

Establish origins of raw materials to ensure they are from reputable suppliers - e.g. ETAD approved sources or established known suppliers Defined schedule of checks in place to ensure incoming materials conform to agreed specifications including the TESCO RESTRICTED SUBSTANCES DOCUMENT. Availability from processors supplier of their own conformance results. Material Data Safety Sheets, evidence of conformance to the requirements of the TESCO RESTRICTED SUBSTANCES. Proper storage facilities

RSLT: G, A, or R & COMMENTS

GUIDANCE NOTES

Past evidence has shown products which have been cloned or have originated from cheap non established sources do not conform to proper standards and are not process reliable. Processors should be aware of buying cheap chemicals new or second hand on the open market. Procedures for checking incoming goods should be enough to ensure the quality & physical/ chemical aspects of the goods conform to agreed standards & specifications. Sufficient procedures must be in place to identify non conforming goods and reject them. Some conformance properties of incoming goods will be difficult or impracticable to verify in the factory hence reliance on processors suppliers own results with extra independent verification will be required. Ask to see representative incoming documentation confirming the conformance of goods.

Raw materials must be stored in a proper manner appropriate to their status (liquids, dry materials etc). Storage areas must be clean, dry & properly ventilated with materials clearly labelled & identified. Liquids & dry chemicals must be kept in separate storage facilities with incompatible chemicals segregated. When not in use containers must be sealed. Stores should also be kept secure & locked when not in use with authorised access only. Raw materials often have defined shelf lives hence a proper stock rotation system must be in place to ensure no out of date materials used. Ask to see the system used.

Evidence of stock control & stock rotation must be provided

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INCOMING RAW MATERIALS:Greige Cloth & other Raw Materials

Defined schedule of checks in place to ensure all incoming goods conform to agreed specifications including the TESCO RESTRICTED SUBSTANCES DOCUMENT Availability from the processors supplier of their own conformance results. This to include laboratory test results as necessary & evidence of conformance to the requirements of the TESCO RESTRICTED SUBSTANCES DOCUMENT. Proper storage facilities

RSLT: G, A, or R & COMMENTS

GUIDANCE NOTES

Procedures for checking incoming goods should be enough to ensure quality & physical aspects of the goods conform to the agreed standards & specifications. Sufficient procedures must be in place to identify non conforming goods & reject them

Some conformance properties of incoming goods will be difficult or impracticable to verify in the factory hence reliance on suppliers own results with extra independent verification as necessary will be required. Ask to see documentation verifying the conformance of goods

All unprocessed goods must be clearly marked as to their origin, batch & lot number and be kept clean, dry and in good order Certain greige types can deteriorate over long tern storage so proper systems must be in place to ensure proper stock rotation of goods to be put into work. Ask to see the system used. A proper area is required to ensure effective positive release of approved goods A proper area is required to ensure non conforming goods are not used in error & are available for return to the supplier

Evidence of stock control & stock rotation

Segregation & defined area where approved goods are held Segregation & defined area where rejected goods are held

PROCESS CONTROL:Wet & Dry Dyestuffs, Chemicals etc

Raw materials unpacked in proper manner & packaging materials properly disposed of

RSLT : G, A, or R & COMMENTS

GUIDANCE NOTES

Processor should ensure all packaging materials are disposed of so as to ensure no environmental hazard or risk. Due regard must be made of raw material suppliers recommendations in this respect. Check suppliers are conforming to requirements and check packaging disposal records Evidence of requirements should be available and understood by all operatives. Ask to see such evidence and speak with operatives to ensure they are clear as to interpretation of instructions etc. Be sure that all preparation areas are clean & well ventilated

All raw materials prepared for processing in correct manner according to raw material suppliers recommendations & requirements with due regard to the hazardous nature of any raw materials All recipe formulations, mixings etc must be recorded in a manner that they can be traced or verified on a batch by batch, process by process basis with evidential test results as required. Manufacturing records must be kept and be available for inspection. It is recommended that within a production run there is no mixing of chemical s from different sources

Processor should ensure compliance in this respect to minimise process errors. Availability of conforming test results to ensure consistence of recipe formulations must be available. Ask to see manufacturing records and test results relating to process control

Page 38 of 45

PROCESS CONTROL :Greige cloth & production routes

All greige cloth etc unpacked in the proper manner & packaging materials properly disposed off

RSLT: G, A, or R & COMMENTS

GUIDANCE NOTES

Processor should ensure all packaging material disposed of to ensure no environmental hazard or risk. Suppliers packaging disposal recommendations to be followed at all times with checks made to ensure required procedures followed Processor should follow this procedure so that in the event of query any non conforming piece in process can be identified and isolated. It should be possible for each piece in process to be traceable and identified at its exact stage of production Consistent process controls ensure a consistent & conforming finished product. Processor should have established procedures ate each stage of process to ensure product conformance. Ask to see process records showing proper regard has been paid to critical factors such as process temperature & time Unfinished production can deteriorate. A complete process cycle should be effected as quickly as possible. Bottle necks which may cause a process delays should be identified and eliminated Chemical spillages, wet floors etc present a safety hazard. Emitted process fumes can be particularly dangerous and should be properly extracted

Greige cloth to be batched or assembled for processing in a piece/ batch traceable manner

Production controls to be established at all stages of processing to ensure conformance with regard to such parameters as process time, temperature, chemical dosage etc.

Part processed cloth should not be left unfinished for extended periods. Establish processing periods for production in question Production areas should be clean, dry (considering practicalities of process) & be well ventilated

FINISHED FABRIC INSPECTION & CONFORMANCE

Finished fabric inspected & made up according to agreed standards & procedures. Packaging materials must conform to agreed standards ( e.g. BHT free etc ) and be sufficiently robust to withstand warehousing & transit All finished production must be ticketed or other wise marked in a manner that in the event of later query it can be traced.

RSLT: G, A, or R & COMMENTS

GUIDANCE NOTES

It is important that agreed inspection procedures are followed to ensure only goods that achieve the agreed inspection standards are despatched. Packaging must be robust so that goods do not arrive in a damaged state

Processors should in practice mark all goods with their batch number and process order number , piece length, net & gross weight if necessary, useable width, colour name & number, and supplier order number. Such information should also appear on the packing lists The processor is responsible for ensuring his product conforms to the agreed standard prior to despatch. He should be able to prove this on demand against every batch or production lot made available to the garment maker and maintain proper records. Any process failures resulting in reject cloth should be corrected forthwith to ensure no delivery delay. The garment maker is not responsible for the instigation & cost of testing uncut finished fabric. This matter remains that of the fabric supplier

Test & conformance results according to the agreed specification and testing frequency available. Where failures occur supply should have a defined recovery / replacement procedure established. All suppliers must be able to carry out basic testing to confirm their production. Where certain testing is not possible an approved outside test house must be used. IT IS STRESSED IT IS THE PROCESSORS RESPONSIBILITY TO ENSURE FABRIC CONFORMANCE & PROVIDE TEST RESULST ON HIS PRODUCTION. In the event of fabric storage prior to despatch warehouses must be clean, tidy with goods identifiable from stock.

Check warehouses to ensure conformance here

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8.2

SITE AUDIT RESULT GRADES

G - GREEN

PASS

All requirements of clause met. Further audit in 6 months time. System noted in the clause functions but needs improvement. Seek time scale for the improvement and re audit in six months time System noted in clause is not in place or is non functional and MUST be corrected forthwith to ensure continuing Tesco business. Complete Corrective Actions & Improvement Plan document and re audit within the agreed time scale for the discrepancy to be rectified A system that does not apply.

A - AMBER

MINOR QUERY

R-RED

FAIL

N/A

NOT APPLICABLE

ALL CORRECTIVE ACTIONS TO BE CONFIRMED IN WRITING TO PROCESSOR

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8.3

MANAGEMENT, ENVIRONMENT & ETHICS DOCUMENT FOR TESCO SUPPLIERS TESCO STORES LTD MANAGEMENT, ENVIRONMENT & ETHICS DOCUMENT FOR TESCO SUPPLIERS SUPPLY CATEGORY:- DYERS, PRINTERS & FINISHERS

Name of Supplier Dyer, Printer & Finisher:Name of Processor, Address & Contact Date of Assessment

MANAGEMENT ATTITUDE & ORGANISATION

Does management demonstrate a commitment to you as a customer with respect to the supply of first choice goods to defined standards on a right first time on time basis. Is he Customer Focussed? Are management responsibilities within the factory clearly defined with management accountability at all levels and a proper chain of command Does the factory have an effective procedural & quality manual in place the content of which is known & understood by all levels of management. Does management have any defined procedures in this respect to ensure conformance to the manual. Does management have a defined procedure with respect to: a) Quality audits. b) Health & Safety compliance. c) Environmental compliance. d) Worker welfare matters. Can management demonstrate their commitment to the above criteria Does the factory have any other accreditations such as ISO 9000, OKOTEX etc Appropriate risk assessment necessary on any new supplier

RSLT: G, A, or R & COMMENTS

GUIDANCE NOTES

Management must demonstrate a proper response to you as a customer - to your reasonable requests, suggestions and other input.

Smooth running of any operation demands clearly defined management responsibilities and accountability with proper communication at all levels.

The manual should cover such aspects as production control, process control, planned maintenance, corrective actions in the event of failure , customer liaison and in house procedures to ensure smooth running of the operation

Management should be able to demonstrate their understanding of quality issues, health & safety legislation, workers rights & welfare (comply with local labour laws) and environmental issues. Forward thinking towards all these criteria is required

Such accreditations can be useful in assessing management attitude towards quality & commitment.

Processor must be able to demonstrate his past reliability in supply and conformance to all requirements defined above

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ENVIRONMETAL COMPLIANCE

RSLT: G, A, or R & COMMENTS

GUIDANCE NOTES

Does processor have a defined environmental policy in place and how committed is he to matters such as process controls to reduce water & energy consumption Does the processor conform to all legal requirements as regards environmental matters. This includes:a) Effluent control to local legislative requirements. b) Energy control to local legislative requirements Defined, separated, segregated and clean areas to be provided for :a) Eating & Drinking b) Smoking c) Personal Hygiene - toilet facilities etc. Fire Fighting equipment suitable for dealing with the production and other fires must be available. All fire exits must be readily accessible & clearly marked All chemical storage areas must be clean, tidy and ventilated. Weighing areas must be ventilated. First Aid facilities appropriate to the environment must be provided

Ask to see such a policy and establish processors commitment towards it. Ask to see any environmental manual that may exist

Seek evidential proof here and seek further opinion from management and operatives. Ask to see monitoring evidence of effluent control & disposal. Ask to see any data showing proper energy management.

Inspection of such facilities should be carried out on demand and should include a canteen if available. In case of no canteen adequate storage facilities for food brought on site must be provided

Please inspect to ensure compliance

Please inspect to ensure compliance

Please inspect to ensure compliance

Please inspect to ensure compliance with facilities readily available, clean, tidy & segregated

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ETHICAL COMPLIANCE

RSLT:G, A, or R & COMMENTS

GUIDANCE NOTES

Proper employment & ethical policies in place for the employment of all workers:full time, part time, home workers etc. The factory MUST NOT employ anyone under the age of 15 or the minimum legal age (if greater than 15) in the country where the processor is located. Workers on night work, hazardous work, heavy labour must be over 18. The factory must not use forced or bonded labour. The factory is not allowed to seek retention of employees personal papers such as identity documents , passports etc. The factory must pay wages to meet the basic needs of employees plus some discretionary income. Minimum wage legislation must be complied with. Workers must be free, at their own discretion to join workers representative bodies or trade unions.

Check any written agreements in this respect be it from the factory, employment agency or other party. Mark Amber if some form of policy exists, Red if no policy exists Confirm local legal requirement in this respect. If a person looks under age ask to see his / her identity card or other proof of age. If under age employee is found refer matter back to Tesco at once. Mark Red if under age employment found

All workers must be of voluntary employment. Mark Red if forced or bonded labour used. All workers must be free to leave their employ after reasonable notice. Any salary holding deposit must not exceed 10% of the monthly wage. Check the local legal requirements here. The minimum wage is based on normal working hours excluding overtime. Mark Red if legal minimum wage not paid

Establish if there is any workers committee or trade union. Mark Amber if there is no record of worker representation, mark Red if worker representation banned. Check local legislative hours of work & that they are not excessive. Mark Amber if overtime is considered routine or Red if there is no process for monitoring working hours Check for such things as rest breaks, time off, holiday pay etc. Mark Amber if workers contracts do not include hours of work, rest breaks, holidays etc, Mark Red if no contracts exist Randomly check with work force by asking about their treatment in this respect Check for conformance here during site visit

Hours of work must not be excessive & must comply with legislation,

Work is on the basis of recognised employer / employee relationship.

Workers must not be submitted to physical or verbal abuse. Workers must be provided with appropriate protective clothing as necessary and appropriate to their place of work. For example n case of handling of dry powders such as dyestuffs etc gloves, face masks, head gear & overalls must be worn. In the event worker accommodation is provided it must be clearly segregated from the factory, be safe & fit for purpose. Single accommodation for men & women must be segregated.

It is recommended this be checked on the first visit and thereafter annually. Any inspection must be discreet & not cause worker embarrassment.

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8.4

MANAGEMENT, ENVIRONMENT & ETHICAL AUDIT RESULT GRADES

G - GREEN

PASS

All requirements of clause met. Further audit in 6 months time System noted in the clause functions but needs improvement. Seek time scale for the improvement, confirm in writing and re audit in 6 months time. System noted in clause is not in place or is unfunctional and MUST be corrected forthwith to ensure continuing Tesco business. Complete Corrective Actions & Improvement Plan document and re audit within the agreed time scale for the discrepancy A system that does not apply.

A - AMBER

MINOR QUERY

R-RED

FAIL

N/A

NOT APPLICABLE

ALL CORRECTIVE ACTIONS TO BE CONFIRMED IN WRITING TO PROCESSOR

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8.5

SUPPLIER: CORRECTIVE ACTIONS & IMPROVEMENT PLAN SUPPLIER: ON BEHALF OF TESCO STORES LTD

ASSESSMENT DYERS, PRINTERS, FINISHERS & OTHER PROCESSORS CORRECTIVE ACTIONS AND IMPROVEMENT PLAN

PROCESSOR NAME PROCESSOR ADDRESS DATE OF ASSESSMENT ASSESSOR NAME

DESCREPANCY NOTED

REMEDIAL ACTION REQUIRED

TO BE COMPLETED BY (DATE)

I, being an appointed supplier of . (insert garment supplier name) have read the above noted document & agree to take the remedial action required within the time scale noted :SIGNED:- _______________________ Processor, Date ______________________ POSITION IN COMPANY:- _______________________________________________ Copy to a) Processor & b) Garment Maker Assessor
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