Chemical Management Handbook v 2.

Chemical Management Handbook v 2.0, Dated August 2020

Foreword

As an internationally operating lifestyle company, we take the responsibility for our

environment very seriously and are aware of our social responsibility. Therefore,
sustainability is an inner attitude in our daily work. It is our commitment to constantly
improve our business activities by making the interaction between people and the
environment as responsible as possible.

We started our journey to Zero Discharge since 2016 with our own MRSL which was
successfully integrated into our supply chain activities. As we need to strengthen our
activities for achieving Zero Discharge, we adopt the widely accepted industry best
practice ZDHC MRSL.

In partnering with us, we need the responsibility from our suppliers to ensure that all
legal requirements concerning labor compliance, occupational health and safety,
product safety and environmental safety are fully complied with.

This Chemical Management Handbook aims to provide some guidance for our
partners to develop their own chemical management processes and system which
helps to accomplish a better sustainable supply chain and compliance. This
Chemical Management Handbook will be reviewed and updated from time to time
depending on upcoming new requirements. Suppliers are welcome to interact with
us to provide comments and suggestions. We always look forward to working
together, sharing better information and practices in these corporate documents.

Chemical Management Handbook v 2.0, Dated August 2020 1

Table of Contents
Foreword 1

Acronyms and Abbreviations 3

Overview 4

Keys for Chemical Management 6

Initial Steps for Building Chemical Management System 7

Establish Management Commitment 7
Creating Standard Operating Procedures 7
Creating Chemical Master List and Building Chemical Inventory 7
Chemical Hazard Determination and Risk Assessment 8
Setting up Roles and Responsibilities 10

Chemical Management Work Practice 11

Chemical Labelling 11
Secondary Containment 12
Personal Protective Equipment 12
Storage 13
MSDS 14
Waste and Disposal 14
Training and Emergency Preparedness 15
Regular Review 15

amfori BEPI for Assessing Chemical Management Performance 16

TOM TAILOR Contacts 17

Appendix 18-36

Commitment Letter 36

Chemical Management Handbook v 2.0, Dated August 2020 2

Acronyms and Abbreviations

BEPI Business Environmental Performance Initiative

(a.k.a. amfori BEPI)
BEPI SAQ BEPI Self-assessment Questionnaire
CMO Chemical Management Officer
CMR Carcinogenic, Mutagenic or Toxic for Reproduction
CMS Chemical Management System
DWR Durable Water Repellent
ED Endocrine / Hormonal Disruptors
GHS Globally Harmonized System of Classification and Labelling of
Chemical
GI General Instructions
KPI Key Performance Index
MRSL Manufacturing Restricted Substances List
MSDS Material Safety Data Sheet
PBT Persistent, bio accumulative and toxic
PPE Personal Protective Equipment
REACh Registration, Evaluation, Authorization and Restriction of
Chemicals
RSL Restricted Substances List
SDS Safety Data Sheet
SOP Standard Operating Procedure
SVHC Substances with Very High Concern (as defined by REACH)
TSDS Technical Safety Data Sheet
TTS Tom Tailor Sourcing Offices

Chemical Management Handbook v 2.0, Dated August 2020 3

Overview

In textile and apparel industry, lots of chemicals are being consumed in processing
and manufacturing of a product. Wet processing on textiles, garments and trims are
especially highly dependent on chemicals.

While scientists and chemists are still working on researches, there are readily
available literatures confirming some chemicals are hazardous and can be harmful
for the environment, marine lives and human beings.

Though organizations, associations and other stakeholders have already been

working on regulations for chemical thresholds, contaminations and residues still
exist. Hence, a Chemical Management System/ Mechanism (CMS) across the
supply chain must be continuously improved and fully implemented. Having a proper
chemical management would result in a safer product, lesser health risks and
workplace accidents, better environmental protection and conservation.

The baseline for building the chemical management tool is the Manufacturing
Restricted Substances List (MRSL/RSL) which sets the minimum requirements for
chemical input and output for suppliers, partners and processing facilities. It can be
found in the Appendix of our chemical handbook.

Scope

TOM TAILOR wants to ensure compliance with laws and regulatory requirements,
like, in markets where TOM TAILOR products are sold and produced/ sourced. TOM
TAILOR looks forth to go beyond to DETOX its supply chain through eliminating
hazardous chemicals.

The procedures set forth in the coming pages, therefore apply to all suppliers of
products sold by TOM TAILOR, irrespective of their method of sourcing.

This includes suppliers, processing facilities and subcontractors of:

 Garments (including dye house, laundry, fabric mill)
 Home Textiles
 Shoes and Bags: the products supplied must comply with the requirements of
CADs RSL. The link to the current version can be found in the Appendix.

Chemical Management Handbook v 2.0, Dated August 2020 4

That are handled by:
 Our Sourcing Offices (TTS)
 Sourcing agencies
 Importers
 Licence partners

And supplying to:

 TOM TAILOR lines

Definition of Hazardous Chemicals:

“Hazardous Chemicals” is a very broad and generic term. It means any substance,
item, chemical, or agent that could cause harm to humans, animals, or the
environment, either by itself or through interaction with other factors.

Hazardous chemicals are frequently used in the workplace as raw materials,

solvents, cleaning agents, or catalysts, etc. These are normally classified per the risk
they pose to health and property.

Possible hazards are:

 Health and Safety Hazards
 Physical Hazards
 Fire Hazards
 Explosive Hazards
 Systemic Effects
 Target Organ Effects

Regarding physical safety concerns, flammability, corrosion, explosion and reactivity

properties should always be considered.

Chemical Management Handbook v 2.0, Dated August 2020 5

Keys for Chemical Management

The following are keys for a better chemical management for suppliers, and should
be set as foundations for building suppliers’ own chemical management system:

● Demonstrate management commitment through establishing “chemical

policy”, it should be endorsed by an authorized official and communicated
within the organisation
● Strictly comply to environmental regulations and in-house chemical policy,
review and update them from time to time base on international, national, and/
or industrial standards
● Apply and maintain the proper license(s) and/ or permit(s) for the usage and
storage of any hazardous substances onsite per respective regulations
● Put in place a Responsible Personnel (or Team) who must have good
understanding and knowledge of chemicals; training and education program
should be available to ensure everyone’s knowledge on chemical
management is kept up-to-date
● Only purchase the suitable chemicals and amounts required; reduce
inventories and store only what is almost immediately needed
● Keep abreast of safe chemical and technology updates, maintain “Positive
List” and substitute hazardous chemicals whenever possible, or adopt new
technologies to replace chemical intensive processes
● Improve inter-facility and intra-facility delivery of chemicals to avoid leakages
● Minimize hazardous waste disposal, fully comply to international and/ or
national standards
● Automate repetitive high risk tasks by machine if possible
● Increase operational safety for workers and the community, including but not
limited to: ensure good ventilation at the workplace, provision of suitable PPE
● Conduct regular review/ audit to ensure the procedures are properly followed,
corrective actions and revision to the procedures should be done where
needed

In addition to adopting the above keys into one’s chemical management system, it
will be good to understand that in every system development, “Plan-Do-Check-Act”
(PDCA) is a common approach for continuous improvement to ensure the
management system is robust and sustainable. Hence, PDCA should be an
important method reiterating the chemical management system implementation.

Chemical Management Handbook v 2.0, Dated August 2020 6

Initial Steps for Building Chemical Management System

Establish Management Commitment

The Supplier Management has to clearly define their commitment in regards to

chemical management, and the scopes, goals and requirements should be well-
defined and properly communicated within the organization.

In general, the scopes, goals and requirements are related to the interests of internal
and external stakeholders. Senior management of the supplier must adhere to the
commitment when creating policies, practices and procedures, also deliver and drive
the same to all related units and workers, from top to the bottom.

Creating Standard Operating Procedures

Standard Operating Procedures (SOP) needs to be created to clearly define the

responsibilities and tasks that are required from the responsible departments, teams,
units and personnel.

Procedures on communications, process workflow, detailed handling and reporting,

regular review and checking should be established and devised.

Creating Chemical Master List and Building Chemical Inventory

As an easy step for suppliers to start with their chemical management system, a
preferred industrial practice is to create a Chemical Master List and a Chemical
Inventory Record. Every single chemical must be registered and tracked. This
database is useful for the PDCA of chemical management system subsequently.

From the Master List and Inventory List, supplier needs to record below key
information of their chemicals (most of them can be found from the MSDS/ TDS):

● Type of chemicals (e.g. dye, pigment, detergent, softener, emulsifier, resin,

etc.)
● Name of chemical (e.g. Bionic-Finish Eco)
● Name of chemical brand (e.g. Rudolf GmbH)
● Name of chemical supplier/ provider (e.g. ABC Chemical Supply Service Ltd.)
● Contact of chemical supplier/ provider (e.g. Name, email, telephone)
● CAS number for each active chemical ingredient (e.g. Benzene, CAS no.: 71-
43-2)
● Known or potential hazards/ toxicity (e.g. carcinogenic, hormonal disruptor)
● Safety precautions and first aid measures

Chemical Management Handbook v 2.0, Dated August 2020 7

 ● Inventory of Incoming Chemicals (e.g. 500 Litre of Bionic Finish Eco received
on 1st August, 2016)
● Inventory in Production Unit (e.g. 200 Litre of Bionic Finish Eco in fabric
finishing unit on 1st July, 2016)
● Log on whether the chemical is: 1) Bluesign certified, 2) Oekotex certified,
3) third-party tested to confirm free of hazardous substances, and/ or
4) with chemical supplier’s/ provider’s self-declaration

In collecting the above information, a massive chemical database will be established.

Subsequent chemical review together with necessary testing will help to find out and
identify problematic chemicals. Further down to this, suppliers can apply the
understanding of the chemicals to identify the level of risk and hazards for the related
process. Decision can be subsequently made to phase out or replace the unwanted
chemicals as next step.

Chemical Hazard Determination and Risk Assessment

It is the process of evaluating available scientific evidence in order to determine if a

chemical is hazardous pursuant to commitment and/ or customers’ requirements
(e.g. MRSL).

This evaluation identifies the hazards of a chemical that may pose to the
environment, and human being. (Please refer to “Definition of Hazardous
Chemicals”.)

Hazard determination sets the baseline for a further estimation and assessment of
risk. Hazard refers to an inherent property of a substance that is capable of causing
an adverse effect. Risk refers to the probability that an adverse effect will occur with
specific exposure conditions. Thus, a substance will present the same hazard in all
situations due to its innate chemical or physical properties and its actions on cells
and tissues. However, considerable differences may exist in the risk posed by a
substance, depending on how the substance is contained or handled, personal
protective measures used, and other conditions that result in or limit exposure.

It is advised that supplier chemical management responsible team or personnel

should always keep abreast of the latest regulatory updates (producing countries
and importing countries), customer requirements, industrial standards/ best
practices, and maintain communication with chemical suppliers to ensure
maintenance of a proper benchmark for eliminating undesirable chemicals, and
replacing them with better option available. The responsible team should set targets
and implementation plan for such elimination, reduction of substitution of hazardous
substances to ensure continuous improvement.

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In working with chemical suppliers, below steps could be taken for increased
assurance to MRSL compliance:
 Purchase from those who could provide Bluesign certificate (Blue/ Green)
 Purchase from those who could provide Oekotex certificate
 Purchase from those who could provide test reports of the particular
chemicals on sourcing list
 Purchase from those who could provide a declaration (signed by recognized
company official) on MRSL compliance (in the form of self-declaration, and
chemical information list)

*Chemical suppliers should provide valid MSDS/ TSDS of the particular chemicals
purchased, and local language version should be available too for operational use.

In sourcing chemicals, preferences should be given to those “Green chemicals” and

those on “Positive Lists”.

Fig. Sample workflow

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Setting up Roles and Responsibilities

A fundamental chemical management system requires people to manage and

execute. Top management or senior leadership must commit and ensure the
availability of resources essential to establish, implement, maintain and improve the
system from time to time. Resources include human resources, skills and
knowledge, organizational infrastructure, technology and hardware, and financial
resources.

Each organization may have its own infrastructure and organisation hierarchy setup
to run the chemical management system. In general, the roles and responsibilities
should at least cover –

Role Responsibility
Chemical  Reports to top management and senior leadership
Management  Responsible for day-to-day management of chemical
Officer (CMO) management system
 Responsible for setting up goals and commitment for the
organization, ensuring compliance to applicable
requirements
 Responsible for tracking progress, monitoring KPIs and
goals to supply chain partners
Regulatory  Ownership of building, maintaining and updating the local,
Compliance national and international regulatory compliance
Officer (RCO) requirements within the organization
 Addressing new or changing compliance requirements to
CMO that could affect the business and operation of the
organization
 Responsible for RSL and MRSL compliance and
communication with supply chain partners
Technical  Responsible for production process and product chemical
Officer (TO) knowledge
 Responsible for working together with RCO to
communicate the necessary technical information with
supply chain partners; and provide technical support to the
organization
 Responsible for chemical hazard determination and
assessment
 Responsible for exploring safer alternatives (e.g.
chemicals, technology)

Chemical Management Handbook v 2.0, Dated August 2020 10

Chemical Management Work Practice

For chemical management work practices, we will need to establish documented

procedures for different areas, and implement accordingly, but below are the keys.

Chemical Labelling

Chemical containers and packaging should allow for clear identification of chemical
substances. Hazard and risk information needs to be delivered to people who will
have contacts with the chemical. Internationally standardized labels (e.g. GHS),
markings, symbols, warning statements are commonly used to serve above purpose.

Suppliers should ensure incoming chemicals are with proper labels on packaging
upon receipt. Simplified labels with essential information in local language including
chemical name, and warning sign should be used whenever smaller portions are to
be disseminated or distributed for use in the factory premise.

Any unidentifiable chemicals found in the workplace should be cleared and properly
handled to avoid contamination of the production floor.

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Secondary Containment

A secondary containment is one that is designed to catch hazardous materials if the

container leaks or the chemical spills. Such containment is crucial to keep the
chemicals contained so they do not contaminate soil, air or water.

The secondary containment can be in the form of absorbent material, special pallets,
or barrels, and it should comply with the following:
 Chemically compatiable with the materials to be stored in them
 Designed in accordance with the total volume of containers to be hold with
respect to the principles for whichever is better: (may refer to US OSHA or
other resources for more guidance)
o At least 10% of the total volume chemicals to be stored
o Able to hold 110% of the largest container to be stored

 Clean, leakage- and crack-free

 Discharges into the secondary containment must be cleaned immediately and
properly disposed

Personal Protective Equipment

While it is critical to avoid hazards and risks at the first place when designing the
workshop and adopting particular process workflow, PPE, as a last resort though,
should always serve to protect employees from being hurt by an unexpected
accident or expected incident in daily operations.

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Information on the use of appropriate PPE should be found in the MSDS for each
chemical. PPE must at least protect operators’:
 Eyes by wearing protective or safety eyeglasses or goggles
 Skins by wearing appropriate protective gloves, apron and shoes
 Respiratory system by wearing appropriate masks

For areas where chemicals are used, PPE usage warning signs and respective
instructions should be posted to guide the proper usage, and respective PPE should
be provided free for use by employees – regular maintenance and replacement of
such PPE should be done to ensure the protection.

***Caution***
Suppliers should ensure work environment assessment in relation to occupational
health and safety is conducted on a regular basis and when there are changes in the
production process, so as to make sure the setup is safe to operators. If potential
hazards are identified, suitable measures and PPEs should hence be provided as
protection for employees.

In addition to work environmental assessment, suppliers should provide occupational

health examinations for operators before/ during/ after they hold the position that
involves dealing with chemicals. It is also advised that regular job rotation should be
exercised for such operators.

Storage

With respect to the potential hazards that chemicals may bring, precautions must be
taken in storing chemicals at the workplace.

Where appropriate, chemical storage/ warehouse is better set in an isolated building

with restricted access. Such area must be encased with sound construction to stand
from weather, well ventilated, free of obstruction, kept dry and clean.

Chemicals should be stored in accordance with their properties and compatibilities,

e.g. acids should never be put together/ near alkaline, oxidants and flammable
chemicals should be stored individually and/ or special rooms/ cupboard to ensure
safety.

Signage (chemical names, warning and hazard labels, etc.) and MSDS should be
available as identification for ease of segregation and onsite handling.

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On the work floor, only daily usage amount of chemicals should be kept to avoid any
accidents. Inventory log for tallying the amount getting in and out of the chemical
storage/ warehouse should be kept for integrity checking.

If suppliers may have any aboveground/ underground tanks onsite for chemical
storage, the rules above should apply as well, and regular integrity testing of such
tanks should be conducted. They should also ensure any license or permit
appropriate should be valid in place.

MSDS

For every chemical product, it should have its own MSDS/ TSDS/ SDS. Suppliers
should obtain such information from the chemical suppliers/ dealers/ agencies for
understanding thoroughly what chemicals are being used onsite, and what sort of
measures need to be taken.

MSDS should include 16 items, namely:

1. Chemical product and chemical supplier/ agency information
2. Hazards identification
3. Composition/ information on ingredients
4. First aid measures
5. Firefighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/ personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transportation information
15. Regulatory information
16. Other information

Waste and Disposal

Many production processes generate waste. The disposal can be to air, water or soil.
The hazards, risks and toxicity of disposed waste chemicals should be identified and
measured.

In best practice, recycle or reuse the waste is ideal whenever possible. However, if
recycle or reuse is not applicable, organization needs to make sure the waste and
disposal will be treated before discharging or releasing to public. The waste should
be properly handled by qualified service providers and the hazardous and toxic
impact to human and environment must comply with the regulation and should be as
low as possible.

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Suppliers should establish waste handling procedures to include hazardous and non-
hazardous waste with identifying the sources and way of handling accordingly to
ensure all waste generated in the premise is handled properly.

Attention should be paid for effluent treatment if suppliers run any wet-processing
units. For effluent discharge, legal compliance is a baseline, and suppliers should
strive for excellence with adopting ZDHC Wastewater Guidelines.

https://www.roadmaptozero.com/post/updated-zdhc-wastewater-guidelines-v1-1-released

Training and Emergency Preparedness

Suppliers should ensure operators who deal with chemicals directly as part of their
daily work are familiar with the risks and hazards such chemicals may bring to them,
and hence follow accordingly on the proper work procedures and take protective/
safety measures.

Orientation, regular training and daily briefing to such operators regarding health and
safety requirement and measures, and work standards are important. The Chemical
Management Team should include training as part of their work plan.

Emergency preparedness is as important to be at the core of the organisation setup

through establishment of emergency procedures, hardware equipment installation
and regular drills. Such emergency procedures should be registered to government
authorities where appropriate and communicate with employees to ensure
understanding and follow up.

Hardware equipment including firefighting equipment and spare water tanks for
wastewater should be in place and well maintained to minimise impact in case.

With all these setup, it is crucial to ensure employees onsite understand well what to
do in case of emergency. Hence, regular drills should be conducted with
performance recorded for improvement planning.

Regular Review

Internal audits and management reviews should be conducted to check whether the
daily operation is consistent with the policy and procedures set. This is a good way
to identify loopholes and rooms for improvement to be made in terms of revision of
the procedures, communications, training, etc.

Suppliers could also consider seeking for third party certification programmes to
build up robust chemical management system.

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amfori BEPI for Assessing Chemical Management Performance

amfori Business Environmental Performance Initiative (as BEPI in short) is an

initiative that enables companies to respond to key environmental issues and trends
and drive improvements in the supply chains via the tools provided.

TOM TAILOR as a member of amfori, has launched BEPI in the supply chain since
August 2019, and this is applicable to all our suppliers and factories (production
sites) (except license suppliers).

BEPI has covered a comprehensive scope of 11 Environmental Performance Areas

(EPAs):

All our active Tier 1 suppliers/ factories are subjected to completion of the BEPI Self-
assessment questionnaire (SAQ) which covers the above 11 EPAs and respective
data collection for reflecting the environmental performances of such suppliers/
factories on a regular basis.

While the EPAs highlighted with a “star” is considered more relevant to our supply
chain, average score of “Pollution Prevention and Chemicals” and “Wastewater/
Effluent” becomes the “Chem-Index” for our assessing the chemical management
performance of our suppliers/ factories.

Our suppliers/ factories should hence follow this Chemical Handbook to drive
changes and maintain a good management system for eventually achieving “Green”
results:
Green 61-100 Considered good, or a strength
Yellow 41-60 As mediocre, and possibly a weakness
Red 0-40 As weakness

Please refer to these links for more information about BEPI:

 BEPI Platform: https://platform.bepi-intl.org/ (Login required)
 amfori Resources Platform: https://www.amfori.org/resources

Chemical Management Handbook v 2.0, Dated August 2020 16

TOM TAILOR Contacts

In case of any questions, the following persons can be contacted:

Quality Department/ Laboratory

Ms. Yvonne Nauheimer, [email protected]
Ms. Antje Majnaric, [email protected]
Ms. Heike Tober, [email protected]

CSR Department
Ms. Claudia Landgraf, [email protected]
Ms. Tilky Wang, [email protected]

Chemical Management Handbook v 2.0, Dated August 2020 17

 APPENDIX

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Table of Contents in Appendix:

General Information 20
Chemical Test Package 20
Legal Requirements 21-22
REACh, SVHC, POP Regulation 21-22
RSL, MRSL and CADs RSL 23-35
RSL adults 24-27
RSL Baby’s, Kids 28-31
RSL Substances and CAS numbers 32-35
Commitment Letter 36

Chemical Management Handbook v 2.0, Dated August 2020 19

General Information

All chemical tests have to be organized by the supplier himself, and need to be done
at accredited laboratories, SGS and Bureau Veritas.

All costs for tests have to be paid by suppliers.

TOM TAILOR reserves the right to ask for rechecks and random tests.

If a consignment of goods does not meet these requirements, TOM TAILOR will
either reject the goods or they will be processed in Hamburg.

In both cases the respective costs incurred will be charged back to the supplier.

Test results have to be entered in PLM system and test report documents have to be
uploaded as PDF file.

Partners without PLM System login account have to send all test reports to the QA
testing department ([email protected]; [email protected]).

Chemical Test Package (CTP)

The Chemical Test Package is a random test and for certain selected styles by
TOM TAILOR Laboratory. All limits for the parameters are mentioned in the TOM
TAILOR Restricted Substances List (RSL).

Test application will be requested in PLM system for all necessary articles.

Chemical Management Handbook v 2.0, Dated August 2020 20

Legal Requirements
REACh, SVHC, POP Regulation

The European Union transposed the reform of the chemicals legislation by the
European Regulation (EC) 1907/2006. This regulation is also known under the
keyword “REACh” (Regulation for Registration, Evaluation, Authorisation and
Restriction of Chemicals). Since 1st June 2007 the regulation has a direct effect in
each member state of the European Union.

REACh aims at protecting health and environment through a safe handling with
chemicals. For this reason it contains rules about the registration, evaluation, licence
and limitation of chemicals (so-called “substances” in the regulation). The safe use of
chemicals must be ensured, particularly with regard to the protection of human
health and environment (ground, air, water) as certain key priorities of the REACh
regulation.

Substances of very high concern (SVHC) are defined in Article 57 of Regulation (EC)
No 1907/2006 (“the REACH Regulation”) and include substances which are
Carcinogenic, Mutagenic or toxic to Reproduction (CMR), meeting the criteria for
classification in category 1 or 2 in accordance with Directive 67/548/EEC,
Persistent, Bioaccumulative and Toxic (PBT) or very Persistent and very
Bioaccumulative (vPvB) according to the criteria in Annex XIII of the REACH
Regulation.

The supplied goods have to correspond to the prohibition and limitation of toxic
substances as they are laid down in the Annex XVII of the Regulation(EG)
1907/2006, which can be downloaded from the following website, and which forms
an essential part of this agreement:

https://echa.europa.eu/substances-restricted-under-reach

The supplied products are not allowed to include more than 0.1 % (this corresponds
to 1000 mg/kg or 1000 ppm) of a substance of very high concern registered in the
actual (date of delivery) REACh-“Candidate-List”, which can be downloaded from
the following website:

http://echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp

The mentioned weight limit of 0.1 % refers to the weight of the respective products.
In case of a compound product, the weight of each separate component is relevant
(ECJ, judgment of 10. September 2015, C-106/14), for example the weight of yarn,
of inlays, buttons or zippers.

Chemical Management Handbook v 2.0, Dated August 2020 21

The products supplied must comply with the requirements of the POP Regulation
(EC) No. 850/2004 applicable at the time of delivery. In particular, the limit values
defined in Annexes I to V must be complied with. The current version of the POP
Regulation can be found under the following link:

https://eur-lex.europa.eu/legal-
content/DE/ALL/?uri=uriserv:OJ.L_.2019.169.01.0045.01.DEU
and
https://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32020R0784&from=EN.

The supplier is obliged to inform himself regularly about the current version of the
POP Regulation.

Chemical Management Handbook v 2.0, Dated August 2020 22

TOM TAILOR RSL, MRSL and CADs RSL

The delivered products correspond in each item to applicable legal requirements and
Restricted Substances List (RSL) of TOM TAILOR, the RSL is a part of each order
and is enclosed.

Shoes and bags supplied must comply with the requirements of CADs RSL.
The present version can be found under the following link:

https://www.cads-shoes.com/en/rsl

The supplier is obliged to inform himself regularly about the current version of the
CADs RSL.

In addition, only textile auxiliaries and colourants that comply with the limits of the
Manufacturing Restricted Substances List (MRSL) of the Zero Discharge of
Hazardous Chemicals Programme (ZDHC) in the version applicable at the time of
delivery are used for the production of the goods supplied, which can be downloaded
from

https://www.roadmaptozero.com/mrsl_online/

This contains the permissible pollutant concentrations for various substance groups
in the chemicals used. We reserve the right to verify compliance with this
requirement by submitting the chemical register and the confirmations of the
chemical suppliers.

RSL

Please find following Restricted Substances Lists (RSL) for TOM TAILOR.

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 COMMITMENT TO COMPLYING WITH
TOM TAILOR CHEMICAL MANAGEMENT PROGRAMME

I hereby confirm that:

1. We have received, read and thoroughly understood the TOM TAILOR Chemical
Management Handbook, Version 2.0 (August 2020), including Chemical
Management System setup guidance, and the latest version of REACh, POP
requirements and MRSL/ RSL.

2. We acknowledge that compliance with the TOM TAILOR Chemical Management

programme is a contractual obligation and undertaking, accordingly, to meet the
Chemical requirements in all orders involving production, marketing and/ or
distribution placed by any of the format of the TOM TAILOR.

3. We undertake to disclose and formally demand TOM TAILOR Chemical

Management requirement implications to the whole supply chain of production
including but not limited to production facilities, sub-contractors, sub-processors and
wet processing units, etc. relevant entities.

4. The TOM TAILOR:

a. Reserves the right to check: 1) compliance with TOM TAILOR Chemical
Management requirement regarding any goods supplied, by any method, at
any time, and/ or at any stage of the production, marketing or distribution
processes, and 2) the appropriate disclosure of Chemical Management.
b. Reserves the right to cancel any order for any goods where non-compliance
with TOM TAILOR Chemical Management Programme/ requirement
regarding any test and/ or inspection carried out pursuant to the printout has
been established.
c. Reserves the right to cancel or destroy, or to order destruction of the goods
subject to the cancelled order, subject to the fact that the cancellation of the
relevant order shall entail the non-existence of the obligation to pay any sum
whatsoever for the goods failing to comply with TOM TAILOR Chemical
Management Programme/ requirement.
d. Holds the Supplier as solely responsible for any and all damages caused by
the goods failing to comply with TOM TAILOR Chemical Management
Programme/ requirement.
e. Reserves the right to stop business with the Supplier whenever the cases of
non-compliance to the TOM TAILOR Chemical Management Programme/
requirement occurs more than 3 times in a year.

Place, Date: Name and position of the signatory in bold

letters:

____________________ ______ ______________________________ __

Name of the Company in bold letters: Signature, Company stamp:

Chemical Management Handbook v 2.0, Dated August 2020 36