childrens safe product requirements - 4 10 2015

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Confidential | Proprietary | Effective 2015 | V.1 Children’s Safe Product Requirements Introduction We have delivered high quality merchandise to our customers for over 149 years. It is the partnerships we have built with our vendors, suppliers, testing labs and other agencies that ensure we meet these high quality standards with every product. Our policies, processes, guidelines and requirements are set forth to help us achieve our goals of staying consistent with quality, fit, exceeding safety regulations and delivering the best products in children’s clothing to the customer. Statement of Understanding The Children’s Safe Product Requirements (also referred to as “document”) was created as a general reference guideline. Carter’s makes no representation or warranty, expressed or implied, as to the completeness of the procedures or requirements in this document, or that such procedures or requirements satisfy all applicable orders, decrees, statutes, regulations or other laws (collectively, the “Legal Requirements”). This document is not to be considered or used as all inclusive and is subject to change with or without prior notice.

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Children Safe Product Requirements

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  • Confidential | Proprietary | Effective 2015 | V.1

    Childrens Safe Product Requirements

    Introduction

    We have delivered high quality merchandise to our customers for over 149 years. It is the partnerships we have built with our vendors, suppliers, testing labs and other agencies that ensure we meet these high quality standards with every product. Our policies, processes, guidelines and requirements are set forth to help us achieve our goals of staying consistent with quality, fit, exceeding safety regulations and delivering the best products in childrens clothing to the customer. Statement of Understanding The Childrens Safe Product Requirements (also referred to as document) was created as a general reference guideline. Carters makes no representation or warranty, expressed or implied, as to the completeness of the procedures or requirements in this document, or that such procedures or requirements satisfy all applicable orders, decrees, statutes, regulations or other laws (collectively, the Legal Requirements). This document is not to be considered or used as all inclusive and is subject to change with or without prior notice.

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 2

    Table of Contents_____________________________________ When using online, click the Main Titles or the Subtitles below to jump to that section in the document. To return to the Table of Contents, click the white up arrow ( ) in the blue title bar.

    I. General Safety Requirements .............................................................................................................................. 3

    1. Small Parts (Tension Test, Graspable Definition) 2. Sharp Points and Sharp Edges 3. Restricted Substances

    II. Belts ...................................................................................................................................................................... 5

    III. Drawstrings ......................................................................................................................................................... 6

    1. Definitions 2. General Requirements 3. Functional Drawstrings, Ties and Cords (Chart, Point of Measurement) 4. Non-Functional Drawstrings, Ties and Cords (Chart, Point of Measurement) 5. Miscellaneous

    IV. Embellishments .................................................................................................................................................. 9

    1. General Requirements 2. Applied Lace or Eyelet 3. Beads 4. Bows 5. Decorative Tapes and Trims 6. Embroidery 7. Fringe 8. Loops 9. Yarn Floats and Metallic Yarn 10. Pompoms 11. Rhinestones (Heat Transfer) 12. Rhinestones (Pronged) 13. Rosettes and Appliques 14. Sequins 15. Tassels

    V. Hardware ........................................................................................................................................................... 16

    1. General Requirements 2. Knee Safety Zone 3. Buttons 4. Hook and Loop Closures (Velcro) 5. Toggles 6. Other Metal Hardware (Snaps, Grommets, Hasp, Sliders, D-Rings, Hook and Eye, Metal Hardware)

    VI. Miscellaneous ................................................................................................................................................... 18

    1. Bibs 2. Faux (Fake) Fur 3. Footed Garments 4. Hats and Caps 5. Feathers (any kind) and Natural Fur 6. Neck Ties 7. Scarves 8. Sleeve Tabs 9. Swim Shorts and Shorts Liners 10. Toxicity, Skin Irritants and Gel Filled Products

    VII. Zippers .............................................................................................................................................................. 20

    1. Safety Requirements 2. General Requirements 3. Decorative Pulls

    VIII. Best Practices .................................................................................................................................................. 23

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 3

    I. General Requirements___________________________ The general safety requirements covered in this section apply to all Carters products.

    Definition By US law, a small part is defined as a toy or other item intended for children under three (3) years of age that can completely fit into a specially designed test cylinder. (See image 1) If the object completely fits into the test cylinder (pictured), it is considered a choking hazard and is prohibited by US law.

    A small part can be a whole item or a piece of an item that breaks off during testing which simulates use and abuse by children. Carters uses a special Tension Test (see Tension Test below) to simulate use and abuse by children. The Tension Test is identical in procedure to the Consumer Product Safety Commission (CPSC), but uses more stringent requirements. Tension Test Requirements All graspable (see References on page 4) components attached to garments and accessories which include, items covered in Sections II VII, such as sequins, rosettes, zippers, toggles, buttons, bows, rhinestones, pompoms, etc. that could potentially become a small part after Tension Testing. Textile pieces which are under inch in all directions do not need to be tested. Other exceptions are noted within this document.

    Test Method The main body of the item is secured in the

    test apparatus. An appropriate test clamp is attached from

    the opposite side to securely grasp the component being tested.

    A force of 20.2 lbs. is applied over a period of five (5) seconds and is maintained for an additional ten (10) seconds. (see Brand Standards Chart on page 4).

    Result If during or after tension is applied the

    component does not break off and become a small part (as defined in Section 1. Small Parts), it will pass. o Two-dimensional pieces of fabric or yarn

    that become removed during the Tension Test are not considered to be a hazardous small part because they pose little choking risk. (See Image 2 and Image 3).

    Image 2

    Image 3

    1. Small Parts

    Image 1

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 4

    References: Graspable (Definition) According to Consumer Product Safety Commission (CPSC) guidelines, an item is graspable if: It can be gripped between the thumb and the

    forefinger, and or between the teeth of a child.

    If a 0.040 thick feeler gauge (see image 4) can be placed between the component and the main body. Feeler Gauge is a hemispherical or tapered component with a gap

    greater than 0.040 inches between the component and the main body.

    Brand Standards Chart As an international brand with high safety and quality standards, Carters uses higher requirements than the US Regulation: US Regulation

    Carters Requirements

    Age Range 3 and Under All Childrens Products Tension Test Requirement

    15 lbs. for 10 seconds

    20.2 lbs. for 10 seconds

    Scope

    Toys and other specific articles intended for use by children

    All types of Childrens Products

    Childrens products or parts of products may contain sharp points or edges before or after simulating use and abuse testing.

    Sharp Point The item(s) is considered hazardous if it fails the Consumer Product Safety Commissions (CPSC) Sharp Point Test before or after simulated use and abuse testing. (see Image 1) How it is measured: A potential sharp point is placed against a 1 lbs. weighted fixture that is then positioned to rest upon the potential sharp point. If the light comes on, it is considered a sharp point and is not permitted for children under eight (8) years of age.

    Sharp Edge The item(s) is considered hazardous if it fails the CPSC Sharp Edge Test before or after simulated use and abuse testing. (see Image 2)

    Image 2

    How it is measured: A piece of tape is wrapped around the end of the rod and the potential sharp edge is placed against the rod while it rotates. If the edge cuts at least inch, it is considered a sharp edge and is not permitted for any children of any age.

    Image 4

    2. Sharp Points and Sharp Edges

    Image 1

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 5

    The use of certain chemicals and substances in Childrens Products is restricted and or prohibited. Please refer to the Quality Manual in

    the Minimum Test Requirements Section for the scope of the restrictions and limits. A list of the most common restricted substances is listed in this section for a quick reference only. This list is reviewed regularly and

    substances may be added with or without prior notice.

    Lead Phthalates Formaldehyde Chromium Antimony Arsenic Barium Cadmium Mercury Selenium

    II. Belts_______________________________________

    Sizes 0-24M All belts must be permanently attached to the

    garment to prevent removal. o Excludes size 2T. o Exceptions, rigid cord belts and braided

    belts.

    All Sizes over 24 months Not required to be attached.

    Other Requirements Belts without Buckles (All Sizes) When untied, and measured from the last

    loop, free ends must not fall below the hem of the garment.

    Must have belt loops at both side seams. For Korea In an untied state, free ends of belts cannot

    exceed 5.5 inches in length from the point where they are to be tied when the garment is opened to its largest and laid flat. (see Image 1).

    When the belt is pulled to the intended size as during wear, free ends cannot exceed 11 inches.

    Belts with Buckles When buckled in the middle hole and

    measured from where the strap exits the buckle, the strap end must not exceed: o 3 inches for sizes 0-5T o 5 inches sizes larger than 5T

    3. Restricted Substances

    1. Requirements

    Image 1

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 6

    Free Ends Toggles and knots are not permitted on free

    ends, but free ends can be wrapped instead. Fringe length restrictions:

    o 0-24 month inch maximum. o Other sizes 2 inches maximum.

    Fringe must be securely attached so it does not easily pull out.

    Belts on Childrens Bathrobes Width cannot be less than 1 inches. Must not hang below the hem of the garment

    when untied and measured from the last belt loop.

    All sizes must be securely and permanently attached to the garment.

    Adjustable Waistbands Must be securely attached to the garment

    with a bartack to prevent removal. Wal-Mart and Sams Club All belts for sizes 0-5T must be permanently

    and securely attached at the waist of the garment to prevent removal.

    For China Refer to III. Drawstrings section 2. General

    Requirements under For China.

    III. Drawstrings__________________________________

    1. Definitions Functional Drawstring, Cord or Tie Any non-retractable cord, ribbon, or tape of any material with two (2) loose ends to pull together to adjust parts of a garment to provide for closure or to adjust the size of the garment opening. (See Image 1). This definition is not limited to cords, ribbons, tapes that pass through a channel.

    Image 1

    Non-functional (Decorative) Drawstring, Cord or Tie Any textile or non-textile material with two (2) loose ends that has no drawstring functionality and is not used to adjust the size of the garment opening or to fasten the garment. (See Image 2).

    Image 2

    Continuous Drawstring Any textile or non-textile material that passes through a channel around the total circumference of the garment and has no loose ends and is used to adjust the size of the garment opening.

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 7

    Elastic Cord or Tie Cord with high stretchability with complete or nearly complete recovery. (See image 3).

    Image 3

    Halter Neck Cord or Tie Functional cord, or fabric worn around the back of the neck to hold the garment together leaving the back and shoulders bare. (See image 4).

    2. General Requirements (when permitted) Cannot emerge from the back of the

    garment. Cannot be tied at the back of the garment. Not permitted on the hem of a garment if it

    finishes at or below the ankle or below the elbow.

    Ends must be secured with a heat seal, laser cut, or be double turned and secured with a lock stitch. If a plastic sleeve is used, must withstand 20.5 lbs. of force (pull test).

    If hem of garment finishes below the hip it must not hang below the hem and must be enclosed inside the garment or lie flat to the garment.

    Must be secured to the garment with a bartack at its midpoint so that the string cannot be pulled out through one side and become an entrapment hazard.

    When used at sleeves (above the elbow including the shoulder) it should be secured from where it exits the channel with one of the following: o With a bartack no further than inch

    from the buttonhole or eyelet.

    o With a bartack on the outside of a sleeve.

    All drawstrings, functional cords and decorative cords that finish at the ankle of any garment (ex: coats, skirts, pants), must be completely enclosed inside the garment.

    Toggles and knots Are not permitted on free ends.

    Beads Not permitted for sizes 0-5T. Permitted for sizes 4 and above but not

    allowed at the free ends. For China A tied belt and or sash is 3cm in width and

    above. A drawstring and or functional cord, (i.e.

    chain, ribbon etc.) is 3cm in width or less that passes through a channel, loop or eyelet, and adjust the size of the opening, adjust part of the garment, or fasten the garment.

    Image 4

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 8

    3. Functional Drawstrings, Ties and Cords

    About this chart: Measurement is taken from point of attachment. Can be no longer than the maximum length listed below. Wal-Mart (WMT) and Sams Club (Sams) is listed separately for maximum length.

    4. Non-Functional (Decorative) Drawstrings, Ties and Cords

    About this chart: Measurement is taken from point of attachment. Can be no longer than the maximum length listed below. Wal-Mart (WMT) and Sams Club (Sams) is listed separately for maximum length.

    Area of Garment Item Used 0 - 24 Months 2T- 5T 4 - 18 Hood and Neck Any Not Permitted Not Permitted Not Permitted

    Waist Area (Tops)

    Drawstrings Not Permitted Not Permitted Not Permitted Ties and Cords tops with center front opening Not Permitted Not Permitted Not Permitted

    Ties and Cords tops without center front opening

    4 WMT or Sams: 3

    5 WMT or Sams: 3

    5 WMT or Sams: 3

    Waist Area (Bottoms) Measurement is for what is visible when garment is fully extended

    Drawstrings 3 3 3

    Ties and Cords 4 WMT or Sams: 3 5

    WMT or Sams: 3 5

    WMT or Sams: 3 Hem below the waist and above the ankle Measurement is for what is visible when garment is fully extended

    Drawstrings Not Permitted 3 3

    Ties and Cords

    3

    3

    3

    Sleeves above the elbow including shoulder around the circumference of the arm, and below elbow

    Drawstrings Not Permitted Not Permitted Not Permitted

    Area of Garment Item Used 0 - 24 Months 2T- 5T 4 - 18 Hood and Neck Any Not Permitted Not Permitted Not Permitted

    Waist Area (Tops)

    Drawstrings Not Permitted Not Permitted Not Permitted Ties and Cords tops with center front opening Not Permitted Not Permitted Not Permitted

    Ties and Cords tops without center front opening

    4 WMT or Sams: 3

    5 WMT or Sams: 3

    5 WMT or Sams: 3

    Waist Area (Bottoms) - must be securely attached with a bartack from the exit point.

    Drawstrings 4 5 5

    Ties and Cords 4 WMT or Sams: 3 5

    WMT or Sams: 3 5

    WMT or Sams: 3

    Hem below the waist and above the ankle Any

    3 WMT or Sams: not permitted

    3 WMT or Sams: not permitted

    3 WMT or Sams: not

    permitted At Sleeves above the elbow including shoulder

    Any 3

    WMT or Sams: not permitted

    3 WMT or Sams: not permitted

    5 WMT or Sams: not

    permitted

    At Sleeves below the elbow Any Not Permitted Not Permitted Not Permitted

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 9

    5. Miscellaneous Elastic Cords and or Ties Must not be used in the hood and neck area

    of the garment. Cord locks should lie flat against garment. Elastic cords must not have more than 1 inch

    protruding from the opening when fully extended.

    Retractable Cords For the head, neck, waist and bottom areas: Fully retractable drawstrings or ties are

    exempt from American Society for Testing Materials (ASTM) specifications and or Consumer Product Safety Commission (CPSC) guidelines.

    Halter Neck Cord or Tie No Free ends allowed in the head and neck

    area. Hook and loop, self-fabric, buttons or snap

    closure is required.

    Continuous Drawstrings Not permitted on any size or on any area of

    the garment. Rouching Considered a

    functional drawstring or tie (as defined in III. Drawstrings, Section 1 Definitions).

    How to Measure With drawstring or tie not in its rouched (pulled) state, measure the visible part of the drawstring or tie from the exit point to the end.

    Maximum length of the rouching drawstring and or tie:

    o 0-5T - Not permitted on any size or on any area of the garment.

    o 4 and above 3 inches maximum.

    IV. Embellishments______________________________ 1. General Requirements If non-graspable Must withstand ten (10) home launderings

    without becoming loose or detached.

    If graspable Must meet general safety requirements.

    The use of glitter as an embellishment is not permitted in infant sizes. 2. Applied Lace or Eyelet The following are subject to the General Requirements as defined in Section I. Laces (image 1) Applied Lace Crochet Lace Chunky Knit Sweaters (image 2)

    Image 1 Image 2

    Image 1

  • Confidential | Proprietary | Effective 2015 | V.1

    3. Beads

    All Size Ranges: Glass, Metal or Wood Beads Not permitted.

    Individual Bead Attachment Double thread (24

    tex or larger). Single thread (60 tex). End of thread must be knotted. Double back stitch on underside. Floats < inch / Thread ends < inch.

    Rows and Clusters Attachment (image 1) Double thread (24 tex or larger). Single thread (60 tex). Slip knot thread after each 3 beads. Final tie-off requires double knot. Back design with fusible backing to avoid

    abrasive surface on underside. Caviar Bead Transfer, (Image 2) 0-24 month not

    permitted. 2-5T and 4-6X and

    above - must retain 90% pattern integrity after 10 wash and dry cycles.

    4. Bows

    Requirements: Must be attached with at least one bartack at

    the center. No toggles or knots at the end of tails.

    End must be secured with a heat seal, laser cut, or double turned and secured with a lock stitch.

    This table provides the maximum lengths for fixed bow loops and tail ends. (excludes Wal-Mart and Sams see chart below)

    Sizes 0-24M Sizes 2T-5T Sizes >5T

    Loop Tail Loop Tail Loop Tail

    Fixed Bows Located in the Hood Neck, Ankle or Below the Elbow

    2" 1.5" 2" 1.5" 3" 2"

    Fixed Bows Located in the Chest Area 3" 3" 3" 3" 3" 5.5"

    Fixed Bows In all areas other than those listed above

    4" 4" 4" 4" 4" 5.5"

    Wal-Mart and Sams Requirements:

    This table provides the maximum lengths for fixed bow loops and tail ends.

    Sizes 0-5T Sizes >5T Loop Tail Loop Tail

    Fixed Bows Located at the Hood Neck, Ankle or Below the Elbow

    3" 3" 3" 5.5"

    Fixed Bows In all areas other than those listed above

    1.5" 1" 1.5" 1"

    Image 1

    Image 2

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 11

    5. Decorative Trims and Tapes Subject to the General Requirements as

    defined in Section I.

    6. Embroidery Requirements Any embroidery application with an abrasive

    backside that comes into direct contact with the skin must have a backing material Over the Back (OTB) to prevent scratching. (See Images 1 through 3)

    Image 1 - Front Image 2 - Back

    Image 3 - Backing

    7. Fringe

    Requirements Must be sewn on, (not fused, glued or

    bonded). (image 1) Must withstand a 1.5 lbs. pull force when

    strands are pulled individually. On embroidered designs, fringe length

    can be no longer than inch. 8. Loops Belt Loops Must lie flat against the garment and not

    exceed 3 inches in total loop circumference to reduce entrapment risk, as shown in Image 1 with the red circle.

    For Wal-Mart or Sams Club, belt loop can be no longer than 1 inches between bartacks, as shown in image 2 with red line.

    Image 2

    Image1

    Image 1

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 12

    Locker Loops Must be located in the center back neck on

    the inside of the garment (not at yoke). Must not exceed 3 inches in total loop

    circumference (as shown in image 3 with red circle).

    Hanger Loops Not permitted on sizes 0-5T. For sizes 4 and up, loops should be

    constructed of clear elastic tape. Cannot exceed 3 inches in total loop

    circumference.

    Hammer Loops (image 4) For sizes 0-24 months, the entire loop must

    be sewn down. One end must be

    secured in side seam and the other in the pocket seam with reinforced stitching and must lie flat against the garment.

    Must be secured on the underside at the center of the fold with a bartack.

    Exposed length of hammer loop cannot

    exceed 3 inches from the pocket or side seam to the end of the bartack.

    Button Loops Can only be as

    long in length as required for fastening, otherwise not permitted. (See image 5).

    Looped Tabs Must be secured in the seam of the garment.

    (see image 6) If the label extends out more than inch

    from the garment, it must be stitched perpendicular to the attachment seam to prevent a finger entanglement.

    Image 6

    9. Yarn Floats and Metallic Yarn Yarn Floats Socks must not be longer than inch in

    area below the ankle for following size ranges: o 3-12 months o 12-24 months o 2-4 years

    Mittens floats not permitted. Sweaters and Cardigans inch maximum. Other garments 3/8 inch maximum length.

    Metallic Yarn

    Size Range: All Cannot be abrasive

    on either face or reverse surface (see Image 1).

    Wal-Mart USA, Sams and Wal-Mart Canada Sizes 0-9 month -

    metallic yarns not permitted on any items

    Image 3

    Image 4

    Image 5

    Image 1

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 13

    10. Pompoms

    Attached Must be sewn directly

    onto the garment or hanging from trim. See image 1.

    Note: When embedded into a tape trim, ie. popcorn trim it subject to the General Requirements as defined in Section I.

    Must not be glued, fused or bonded onto the fabric.

    Pompom made of Individual Yarns The yarns must be sewn into one central

    core. (See Image 2)

    The individual yarns must pass a 1.5 lbs. tension test in addition to the 20.2 tension test on the entire pompom.

    Pompom on Ends of Items Must not be attached to the end of a

    drawstring, cord, scarf or tie with free ends.

    For use on Hats or Caps May be used on the crown of the hat or from

    loose hanging chinstraps, not both.

    Wal-Mart or Sams Club sizes 0-5T Must not be made from hand knitting or

    sweater yarn.

    11. Rhinestones (Heat Transfers) Requirements for all Size Ranges: (see Image 1) No sharp or jagged edges. Note: Points of

    tear drop, oblong, and square shape stones can potentially present sharp edges.

    Additional Requirements for Sizes 0-5T Stones not to be applied over sugar glitter or

    topical print area as the uneven surface contributes to weakened attachment.

    Additional Requirements for Wal-Mart USA and Sams Club Sizes 0-5T - not permitted.

    Additional Requirements for Wal-Mart Canada Sizes 0-4T - not permitted. Sizes 4-6X - must not be constructed of

    glass or metal. Jewels on Tulle, image 2 Sizes 0-5T - not permitted. Sizes 4-6X - not recommended.

    Image 1

    Image 2

    Image 1

    Image 2

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 14

    12. Rhinestones (Pronged) Sizes 0-5T Not permitted. Sizes 4-6X and above No sharp or jagged

    edges; outer or inner surfaces.

    Must not be attached by hand.

    Additional Requirements for Wal-Mart USA and Sams Club Sizes 0-5T - not permitted.

    Additional Requirements for Wal-Mart Canada Sizes 0-4T - not permitted. Sizes 4-6X - must not be constructed of

    glass. 13. Rosettes and Appliques Requirements Whole flowers must pass tension test of 20.2

    pounds.

    Individual petals (if graspable) must pass attachment strength test requirement of 9.0 lbs.

    Any decoration with an abrasive backside that comes into direct contact with the skin must have a backing material (OTB) to prevent scratching.

    14. Sequins Requirements for all Size Ranges: No metal sequins. No sharp edges. If stitched, must be attached by machine with

    lockstitch. Must not be hand stitched. Maximum length thread end is inch. Heat transfer sequins are acceptable, if

    securely applied.

    Note: Sequins attached with 1 to 2 points of attachment are considered graspable. To reduce the likelihood of it being graspable, increase to 4 points per sequin minimum. (see Image 1)

    Image 1

    Image 1 Image 2

    Image 1

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 15

    Additional Requirements for Wal-Mart USA and Sams: Sizes 0-5T - 5 points of attachment around

    each sequin. Heat transfer sequins not permitted.

    Additional Requirements for Wal-Mart Canada: Sizes 0-4T - not permitted Sizes 4-6X - 2 or 3 points of attachment

    around each sequin. One point for paillette sequins.

    Chain Stitch Sequins Not permitted if criteria that sequins be

    attached by machine with lockstitch is not met.(see image 2)

    Sequin Placement to Minimize Scratching Must be offset from edge of garment so as to

    not scratch bare skin of child. o Image 3 acceptable o Image 4 unacceptable

    Image 3

    Image 4

    All-Over Sequins Sizes 0-5T - must be covered with tulle. Sizes 4-6X and above - tulle recommended

    (See image 5)

    15. Tassels

    Attachment Must be sewn to the fabric (not fused, glued

    or bonded). Must not be attached to the end of a

    drawstring, cord, scarf, or ties with free ends. Individual Yarns Individual yarns composing the tassel must

    withstand a 1.5 lbs. tension test, in addition to the entire tassel tension requirement of 20.2 lbs.

    Hats or Caps Permitted only on sizes over 5T. Can be placed on the crown of the hat or

    from loose hanging chinstraps no longer than 3 inches, but not both.

    Wal-Mart or Sams Club sizes 0-5T Must not be made from hand knitting or

    sweater yarns.

    Image 2 Image 5

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 16

    V. Hardware____________________________________

    1. General Requirements Must be non-ferrous (no iron or steel). Must not be made of wood, cork, leather,

    mother of pearl (shell) or glass materials.

    Must not have sharp edges, rough edges, or

    exposed prongs and must be free of rust and corrosion.

    2. Knee Safety Zone Area The Knee Safety Zone Area is determined by

    placing the center point of the Rectangle at the center of the knee.(See image 1)

    Is a rectangular area on each leg of the pants around the knee where no hard components may be placed due to possible discomfort or injury.

    Knee Safety Zone Area dimensions:

    Size Knee Safety Zone Rectangle Area

    Newborn 3.5 L x 3 W Infant (3m, 6m, 9m, 18m, 24m)

    3.5 L x 3.5 W

    Toddler (2T-5T) Childrens (4-6X/7)

    5 L x 4 W Image 1

    3. Buttons Requirements: Must be attached by lockstitch; not by hand

    or another type of machine stitch. Must be attached using spun poly thread.

    Sizes 0-5T: Fabric buttons not permitted. Two-piece buttons not permitted

    4. Hook and Loop Closures (Velcro) Requirements Must be attached by lockstitch. Only loop side (fuzzy side) may come in

    contact with skin. Corners must not be sharp when tested (as

    described in II General Requirements

    Section 2. Sharp Points and Sharp Edges), and must have rounded edges.

    Lowest profile (lowest pile height) fastener that fulfills purpose must be used in order to minimize abrasiveness.

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 17

    5. Toggles Requirements May be used on all sizes. May only be used on drawstrings, ties and or

    cords (functional or not), with no free ends. A loop may be used to attach a toggle button

    from one side of a garment to the other, provided the loop is no more than 3 inches in length. (See Image 1 circumference of circle (in red shown) must not exceed 3 inches.

    Image 1

    Decorative cord locks May be used on all sizes provided: The cord must be securely attached to the

    garment. Elastic cords are permitted only for sizes

    over 12 months. Must be securely contained within the loop

    and not removable. Cord and toggle must sit flush to the

    garment. (See examples: image 1 pig-nose toggle and image 2 cord lock.)

    Cord must be bartacked no more than 3/8 inch from its point of exit.

    Functional Cord Locks May only be used on sizes 2T and up provided: Cord is securely attached to the garment

    with a bartack to eliminate the cord being removed from the garment.

    The circumference of the loop formed by the lock must not be longer than 3 inches when the garment is cinched to the body.

    The cord must fully retract when the channel is extended.

    Must be securely contained within the loop to prevent removal.

    Must not be at knees, elbows, or other places where possible injury or discomfort exists.

    Must not be attached to a continuous drawstring.

    Not permitted in the hood or neck area.

    6. Other Hardware (Snaps, Grommets, Hasp, Sliders, D-Rings, Hook and Eye, Metal Hardware) Requirements Some hardware may require fabric backing

    to pass tension test. Must not be attached by hand.

    o Exception - hook and eye closures. Must be attached using approved machinery. Must withstand washing and drying using

    suggested care instructions with no degradation.

    Press Fasteners If made of plastic must be pre-applied to a

    twill tape and then applied to a garment.

    Hasps, Sliders and D-Rings (Looped Hardware) Required to be welded closed (to prevent

    possible detachment). o Exception - Twist Loop Hardware

    from Mississippi Trading, Inc. Must be attached close enough to the

    garment to prevent any entrapment. Buckles and D-Rings Not permitted at the free end of any ties and

    or belts on sizes 0-24 months.

    Image 2

    Image 3

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    VI. Miscellaneous________________________________ 1. Bibs Requirements

    Free ends are not permitted in the head and or neck area.

    Must not contain PVC in any area of the bib.

    2. Fake (Faux) Fur Requirements Maximum pile length for childrens clothing:

    o 0-24 month - inch o Other sizes 2 inch maximum

    0-24 months no visual evidence of shedding.

    Must be securely attached so fur cannot be pulled out easily.

    3. Footed Garments Requirements All footed garments, mittens and gloves with

    embroidery in the toe, foot or finger and or hand area must have a second layer of fabric sewn into the garment to cover the embroidery.

    4. Hats and Caps Requirements Chinstraps Permitted provided they are not continuous. Must not be longer

    than 8 inches. Must not have knots,

    toggles or ornamentation of any type on the loose ends.

    Ears - no catch points, must be reviewed on a case by case basis.

    Pompoms, Tassels or other Decorations Not permitted on the crown

    of hat or cap with individual ties or loose hanging chinstrap. o If no loose hanging

    chinstraps or individual ties, decorations are permitted on the crown.

    Image 1

    Image 2

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 19

    5. Feathers (any type) and Natural Fur Not permitted on any size childrens clothing.

    6. Neck Ties Requirements

    For sizes 0-5T, all neck ties must be faux in design and include a break-away feature.

    Break-away feature must break away at a maximum of 15 lbs.

    7. Scarves Traditional Scarves Traditional scarves must be

    designed, labeled and marketed only for children 4 years of age and older. (see Image 1)

    For ages 4-7, the maximum length of scarf including fringes, etc., is 36 inches.

    For ages 8+, maximum length of scarf including fringes, etc., is 39 inches.

    Pompoms cannot be located on the ends.

    Infinity Scarves Infinity scarves must be designed, labeled

    and marketed for children sizes 4-8 only (see Image 2)

    Image 2

    8. Sleeve Tab Requirements 0-24 months must be non-functional (stitched

    down to garment interior, excluding the extension for the closure).

    Functional tabs acceptable for sizes 2T-16 o When buttoned, the loop created by

    the tab and garment must not exceed 3 inches in total circumference.

    o When unbuttoned and hanging loose, the tab cannot extend below the bottom edge of the sleeve or pant leg.

    Image 1

    Image 1

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 20

    9. Swim Short and Shorts Liners Requirements Must be constructed of micromesh fabric,

    with a minimum of 15 wales x 15 courses per inch.

    10. Toxicity, Skin Irritants and Gel Filled Products Requirements Must comply with applicable sections of

    American Society for Testing Materials (ASTM) F963 and Consumer Product Safety Improvement Act (CPSIA).

    Must pass microbiological test and not contain petroleum distillates (CFR Title 16, Part 1500.231).

    Third party certification is required showing any liquid used in a garment is non-toxic. No skin irritants of any type may be left on the product.

    VII. Zippers____________________________________ 1. Safety Requirements Zipper Guard All sizes Zipper guards must be used on

    metal zippers that are intended to come in direct contact with the skin

    0-9 months zipper guard required on all SleepnPlay (SNP). (Image 1)

    Sleepwear Sizes 0-5T zipper pulls must be solid (no

    holes). Plastic zipper only.

    Upper Body Garments Sizes 0-3T Zipper pull holes must have

    dimensions of at least 6 millimeters across at its widest point and 4 millimeters across at its longest point. Holes must be elliptical in shape (one dimension greater than the other) to avoid finger entrapment issues. (Image 2)

    Image 1

    Image 2

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 21

    Ring Pulls 0-5T not permitted. Sizes 4 and above permitted as long as

    diameter inside ring is no larger than 1 inch maximum.

    Sleepwear not permitted on any size. Tabs Sizes 0-5T tab covering zipper slider and

    pull required at top front neck for SNP and one piece sleepers. (Image 3)

    2. General Requirements All zippers are subject to additional

    applicable testing as defined in testing protocols (see Quality Manual).

    Must be sourced as a complete unit (Zipper, Stops, and Slider).

    Must have Fully Autolock or Semi-Autolock sliders.

    Top and bottom stops are required for all zippers.

    Coil Zippers are required to have plastic stops.

    Invisible or concealed zippers are permitted to be used for back closure only. o They are not permitted on sizes 0-5T for

    Wal-Mart or Sams Club garments. 3. Decorative Pulls Fabric pulls must be

    secured through the eye of the zipper pull with a bartack and tacked down in the center. Maximum 1 inch length.

    All pulls must be 1 ply or 2 plies sewn together with no loop formed. (No looped pulls may be used.)

    Filled pulls for sizes 0-5T are not permitted. For sizes 4 and above they must be sewn down on all sides.

    Elastic Decorative Pulls or Tabs Not permitted on girls sizes below 7; boys

    sizes below 8. Permitted on girls 7-16 and boys 8-18 with a

    maximum 1 inch length in relaxed state.

    Decorative Fabric, Plastic and Rubber Pulls Not permitted on sizes 0-5T. Permitted on sizes 4 and above with a

    maximum length of 2 inches. (see table below for exact lengths)

    Placement of Decorative Fabric Pulls

    0-9 Months (max length)

    > 9 Months (max length)

    Pockets 2 2 Center Front Plackets 1.5 1.5 Sleeve Panel, Cuff Opening of Shirt or Jacket

    not permitted

    1

    Leg Panel, Bottom Hem of Skirt,Skort,Short,Pant

    not permitted

    1

    For China Market Zip pulls,

    including any embellishment, must not hang below the bottom hem of garments designed to finish at the ankle.

    Image 3

    Image 1

    Correct Incorrect

  • Carters Childrens Safe Product Requirements| V.1 | Issued: 04/10/2015 CONFIDENTIAL | PROPRIETARY 22

    VIII. Best Practices_______________________________

    Recommendations which will minimize safety issues and concerns: Infant and Toddler: The use of glitter is not permitted for infants The use of riveted studs and rhinestones

    (image 2) The use of coated faux sequins/ studs/

    rhinestones. (image 3 & 4) The use of embroidery in place of

    rhinestones. (image 5) All sizes: The use of non-graspable heat transfer

    sequins is recommended in place of lock stitch sequins.

    Image 5

    Embroidery left Rhinestones right

    Image 1 collars down

    Toddler on left Childrens on right

    Image 2 collars up

    Toddler on left Childrens on right

    Image 3

    Faux Sequins

    Image 4 Faux Rhinestones