BRC/RILA Global Standard for Consumer Products, Issue 3 Frequently Asked Questions

1. Is there an easier way to say the BRC/RILA Global Standard for Consumer Products, Issue 3? BRC/RILA CP-3 or simply “CP-3”. 2. In general, what is the purpose or intent of the BRC/RILA CP-3? The BRC/RILA CP-3 seeks to harmonize the numerous and variant retail requirements into one standard as a way to assess factory processes to ensure they have the capability to produce safe products. 3. Is the CP-3 focused on product? Process? The CP-3 is focused on the manufacturing process and quality assurance processes of consumer products. 4. What are the differences between the BRC/RILA CP-3, ISO 9000, and the current retail audit standards? The BRC/RILA CP-3 is exclusively intended for the production of consumer products. When implemented properly, ISO 9000 is a good standard. However, retailers have found that there are often gaps in how ISO 9000 is implemented at individual factories, including verification of legitimate certification. The BRC/RILA CP-3 has many of the same or similar substantive requirements as ISO 9000, and seeks to institute measures to avoid gaps. The BRC/RILA CP-3 also includes provisions related to technical product requirements covering safety and legality. Additionally, the CP-3 will be supported by sector specific guidance to assist in compliance and allows for several levels of certification of the production process. Finally, robust, scored, factory audits can be verified by a secure and searchable database of certified manufacturing sites. 5. What are the key benefits for a supplier or factory? The BRC/RILA CP-3 will reduce duplicative audits that are currently required by multiple retailers. Factories that are audited to the CP-3 can also expect to have fewer failures by implementing systems that promote more consistent production. For factories who are already implementing high-level quality management systems, they should expect the BRC/RILA CP-3 to be consistent with their existing programs, and the audit process should not be a burden.

6. How does this relate to other certification programs? Does this program replace other programs (i.e. UL, TIA, TSCP, etc.)? The CP-3 seeks to harmonize various retail requirements currently in use. Those requirements by and large already specify, for example, a UL certification on appropriate consumer products. This will not change and the BRC/RILA CP-3 seeks to complement already existing standards and certification requirements. 7. What is the timing of the release of the CP-3? General and Sector Guidance? The CP-3 was published in May 2010. A CP-3 General Guideline is available as well. Sector Guidance will be published incrementally following the CP-3 publication. 8. Is there a global interest in the BRC/RILA CP-3? What is the level of retail support/endorsement? RILA Technical Advisory Committee members support the content of the BRC/RILA CP-3 and are committed to developing guidance and an effective audit instrument for factory sites. Parts of this agenda included the completion in December 2010 of a U.S. retail pilot program for the CP-3 in China. 9. How will confidentiality in the supply chain be maintained? For example, the relationships between a factory and a vendor/agent, and between a vendor and a retailer? There are several levels of password protected security on the BRC database. Part of this protection includes the company or site having exclusive control over ‘who has access to what’. The audit owner (i.e. who pays for the audit - this may be an agent for example) is confirmed by, and set up on the database by the certification body. This audit owner determines and controls which customers can view their audit reports on the BRC database. 10. Will the BRC/RILA CP-3 have a “mark” on products? There will be no identifying BRC/RILA CP-3 mark or logo on consumer products. 11. Does the BRC/RILA CP-3 replace consensus-based product specific safety standards? No, the BRC/RILA CP-3 does not contain product specific requirements or tests; rather it spells out an audit process for evaluating a manufacturer’s production process and ensures that factories have appropriate systems in place to confirm that their products are made in compliance with suitable product safety standards for the region of intended sale. Therefore the BRC/RILA CP-3 does not supersede consensus-based product-safety standards, such as those developed, published and maintained by Standard Development Organizations (SDOs) and accredited by the American National Standards Institute (ANSI) or Standards developed via similar processes elsewhere in the world. These product standards will continue

to be an important part of the North American product safety system, and be the basis for traditional third-party product safety certification. 12. Does the BRC/RILA CP-3 replace the need for third-party safety certification of products? No, the BRC/RILA CP-3 will not replace retailers’ use of third-party product safety certificates; rather it is intended to support and reinforce retailers’ reliance on third-party certification of products to appropriate consensus product safety standards. Third-party product safety certification programs have been one of the effective tools in evaluating and demonstrating compliance of products to relevant safety requirements. 13. Will third-party certified products be eligible for a streamlined or shortened audit process under the BRC/RILA CP-3 program? BRC and RILA do not prescribe the manner in which the requirements of the CP-3 are achieved, so although full audits will be necessary, companies who already have good systems in place will find that their preparedness is likely to result in shorter and simpler audits. Additionally, while the sector specific guidance is currently in the early stages of development, RILA and the BRC anticipate that third-party certified products will satisfy a number of the process audit requirements, especially those covering product risk assessments. 14. Under the BRC/RILA CP-3, how can manufacturers and suppliers determine whether their products are subject to product safety standards and third-party certification? BRC and RILA intend to indicate the standards and the third-party certification requirements in the forthcoming sector specific guidance. Products already subject to retailer-driven or regulatory third-party testing or certification requirements will be subject to the same requirements under the CP-3 and audits will confirm that these requirements have been met. 15. Does the scope of the BRC/RILA CP-3 include social compliance? No, the BRC/RILA CP-3 focuses exclusively on the process for the safe and legal manufacture of consumer products. 16. Does the BRC/RILA CP-3 satisfy components of a reasonable testing program? The BRC/RILA CP-3 process includes an audit of factories that serves as part of, and a complement to, other measures and requirements as part of an overall reasonable testing program.