crayola global supply chain quality requirements global supply chain quality requirements

Crayola Global Supply Chain Quality Requirements

Global Supply Chain

Quality Requirements

Revision 1 February 2014

Crayola Global Supply Chain Quality Requirements Dear Supplier Partner, In 1885 Edwin Binney and C. Harold Smith formed a partnership to produce a variety of products, including pigments, slate pencils and chalk. In 1903, the company produced the first wax crayon and coined the name Crayola. More than 110 years later, Crayola, LLC is still providing products that delight children and inspire their limitless creativity. Product safety and quality are central to our brand equity and are the reason parents and caregivers trust Crayola to provide creative experiences for the children they care about. The mission of the Crayola Global Quality organization is to ensure, through Quality Planning and Execution, that all Crayola products deliver the desired consumer experience. Our Global Quality Assurance approach is a collaborative effort between quality professionals in our corporate offices as well as on the ground around the world. We consider our suppliers to be critical partners in this effort. We are committed to work together respectfully to meet our common goal of delighting consumers and we expect our supplier partners to act with integrity in this spirit of collaboration. This revision of Crayola’s Global Supply Chain Requirements builds on our learning since the original document was distributed in 2012. Key changes include:

• Expanded expectations for Preventive/Planned Maintenance, particularly careful monitoring of tool life (Section II.F.)

• Requirements for managing high risk materials such as chemicals (Section III.B.) • Clearer definition of Ethical Standards requirements for subcontractors and suppliers

producing Crayola branded materials such as packaging (Appendix A1.4). • Updated product safety and regulatory requirements to reflect changes in legislation

globally (Appendix A2, A8, A15, A16, A17 and A18). • Expanded wood and paper sourcing requirements (Appendix A10). • New CPSIA requirements, including Production Test Plan (Appendix A15)

Please review all of this information carefully. Working together, we can continue to build the Crayola brand worldwide while staying true to the vision of our founders. Thank you for your support and cooperation.

Bonnie J. Hall Vice President Global Quality and Continuous Improvement


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Page # I. Management/Organization 3-4

A. Management Commitment B. Integrity C. Defined/Documented Organization D. Business Continuity Planning E. Independent Quality Assurance/Quality Control Function F. Internal Audit/Quality System Review G. Employee/Operator Training

II. Process Control 5-6

A. Process Control Methods/Risk Assessment B. Documentation Control C. Sourcing Materials and Services D. Inventory Control E. Change Control/Change Management F. Preventive/Planned maintenance G. Record Retention

III. Quality Assurance/Quality Control 7-10

A. Incoming/In-process Quality Assurance/Control B. High Risk Material Management C. Finished Product Quality D. Pre-Shipment Inspections E. Plant Sanitization F. Calibration System G. Corrective Action/Preventive Action H. Product Recall/Crisis management

IV. Product Safety/Product Integrity 11

A. Product Compliance B. Date Coding C. Foreign Object Control D. Glass Control E. Sharp Tools Control F. Pest control G. Control of Restricted Substances


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Page # V. Continuous Improvement 12

VI. Systems certifications 13-14 A. Ethical standards B. Quality Management System C. Global Security Verification D. Environmental Management/Responsible Sourcing E. Licensor Manufacturing Agreements

Appendices

A1. Crayola global supply chain code of conduct 15-20 A2. Crayola global product safety and regulatory requirements 21-32 A3. Crayola Plant Sanitization process 33 A4. Supply Chain Security 34 A5. Quality planning in the product development process 35-36 A6. Sample Submission for QA Testing and Evaluation 37-39 A7. Product and Packaging Traceability Control 40-44 A8. Electronic and Electrical Products QA requirements 45-46 A9. Cut and Sewn Products QA requirements 47-52 A10. Wood and Paper requirements 53-54 A11. Raw Materials Supplied to Crayola Manufacturing 55-56 A12. Contract manufacturing 57-58 A13. Direct import shipments of finished goods 59-60 A14. Distributor Requirements – including local market compliance 61-64 A15. Compliance with the US Consumer Product Safety Improvement Act 65-66 A16. Compliance with the EU Toy Safety Directive 67-71 A17. Compliance with CCPSA 72 A18. Compliance with NOM 73


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I. Management/Organization

A. Management Commitment The organization’s top leadership must foster a culture of quality and customer focus.

B. Integrity Crayola expects all its business partners to act with responsibility and integrity. All suppliers are required to establish and enforce an integrity policy that clearly outlines their standards of business conduct. All business activities must be handled in fairness and with transparency. No money or favor should ever be offered or requested in exchange for unfair advantage.

Crayola employees are required to take personal responsibility for ethical conduct by complying with the letter and the spirit of applicable laws, rules and regulations; performing with professionalism, respect, honesty, fair dealing and accountability; and by doing everything in our power to prevent unethical activity by voicing concerns, asking questions and reporting potentially unethical situations.

Crayola and our customers have strict ethical policies that govern our interactions with suppliers and customers. Suppliers should consult with Crayola management on any suspected violations.

C. Defined/Documented Organization The supplier will have a clearly defined organization with adequate staffing to accommodate the activities necessary to supply quality product to Crayola.

The organization will be documented on an organization chart or similar document.

D. Business Continuity Planning Suppliers should have a business continuity plan that provides for continuing operations in the event of an interruption caused by natural or man-made incidents. Such incidents include fires, earthquakes, floods, vandalism, supply chain interruptions, or other loss of use of critical infrastructure. Business continuity plans will include the supplier’s analysis of potential disruptions, plans to recover from the potential disruption, and periodic review of the plan to ensure currency.

E. Independent Quality Assurance/Quality Control function Suppliers must have an independent Quality Assurance/Quality Control organization, responsible for executing the suppliers’ QA/QC program.

Suppliers must have a Quality manual that documents their quality system.

F. Internal Audit/Quality System Review Suppliers must have an established process to verify the effectiveness of process and management controls. Typically this would be accomplished through a comprehensive internal audit process, including management review.


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G. Employee/Operator training Suppliers will have an adequate employee training program established to ensure that personnel are trained and qualified to perform essential tasks.

All employees must be trained and competent in all relevant instructions and quality procedures.

Records of training, including attendance, must be documented and kept on file.


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II. Process Control

A. Process control methods/risk assessment Suppliers must have a documented method of controlling production from sourcing of raw materials through shipment of finished product. Process control methods must be adequate to ensure compliance to all applicable safety, legal, and product quality requirements.

The supplier’s system of process control must be documented, controlled and audited by trained personnel.

B. Documentation control The supplier must have a system in place to control, approve and issue process technical documentation – including drawings, specifications, and bills of materials that support the production of Crayola items.

The process should ensure that only the current document revision is available to be accessed.

A system to review controlled documents, including policies and procedures must be established. This system will include controls needed to ensure that internal documents that control compliance to customer requirements are updated as required. The system should include a minimum review frequency.

C. Sourcing materials and services The supplier must have a process in place to ensure that Crayola material specifications are accurately communicated to the suppliers’ sources of materials and components.

The supplier must have a process to qualify raw materials and components to ensure that using alternate sources of supply does not compromise the quality, safety, or integrity of the product.

Subcontracting production or labor without prior written consent of Crayola is strictly prohibited. Suppliers are responsible for ensuring that all approved subcontractors are in compliance with Crayola Global Supply Chain Quality Requirements, including ethical standards and product specifications.

D. Inventory control The supplier must have a system to manage shelf life items. There should be evidence that an effective inventory management (FIFO) system is in place.

Supplier factories will have an effective system to segregate defective material (finished goods, raw materials, components and work-in-process) from acceptable material. There will be effective controls to prevent defective material from being integrated with acceptable material.

Storage of materials must prevent contamination, damage, or deterioration.

Supplier factories must have an effective method to account for Crayola supplied or Crayola specified ingredients, raw materials, and components. Significant inventory discrepancies will be investigated, with root cause identified and corrective action(s) implemented.


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E. Change control/Change management Crayola products will be tested at launch, in accordance with the established Product Safety Turnover document (included in the Design Turnover Document), to ensure they comply with all applicable product safety regulations and standards.

All changes in product design, manufacturing process, or sourcing of materials/component parts must be reported to Crayola. No change may be implemented prior to Crayola approval.

F. Preventive/Planned Maintenance The supplier must have an effective facility maintenance program, including a preventive maintenance schedule and adequate documentation of demand maintenance activity.

Since worn or poorly maintained production tooling can result in product quality and safety issues, careful attention must be paid to ensure all tools, but especially injection molds, are in good working condition. All injection tooling must be built to last for a minimum number of cycles, as specified by Crayola Operations Engineering, and a mechanical counter must be in place to record usage. Suppliers are required to inform Crayola when injection tooling reaches 80% of its designated cycle life so it can be inspected and plans for replacement can be developed, if necessary.

The following records must be maintained and available for inspection:

1. Tooling repair history 2. Tooling cycles record over time 3. Routine maintenance history The destruction of any production tooling owned by Crayola must be approved by Crayola and the destruction documented and witnessed.

G. Record retention Records documenting the safety and quality compliance of product produced for Crayola must be maintained for 10 years from date of creation, unless otherwise approved or directed by Crayola Global Quality Assurance.


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III. Quality Assurance/Quality Control

A. Incoming/In-process quality assurance/control The supplier will have a system in place to effectively ensure that all materials and components used to create products for Crayola meet all supplier and Crayola requirements for that material.

B. High Risk Material Management Some materials by their nature introduce more risk into the manufacturing process. Chemicals, in particular, are receiving much greater scrutiny in the marketplace and their use requires a special set of skills to ensure both product and worker safety.

Any Crayola supplier working with chemicals or formulations must have a comprehensive chemical safety management plan that addresses proper storage and handling as well as appropriate controls to ensure safe use.

Pigments and colorants are a special set of chemicals that must be carefully controlled. Pigments used to produce Crayola products must be tested by lot by an entity other than the primary manufacturer (e.g. toll processer, third party laboratory, etc.) prior to use to ensure heavy metal contamination does not exceed Crayola requirements. XRF or HD-XRF is recommended. Finished product suppliers producing crayons or chalk must source their dry color/pigment through Crayola.

Recycled materials, particularly resins, also have risk of contamination associated with them. Crayola does not permit the use of post-consumer recycled resin in our products. Post-industrial recycled resin is permitted when the source is well known and tightly controlled. Crayola must approve the use of recycled resin in our products. In the event this approval is received, the materials must be tested by lot prior to use per QCI-00-090.

C. Finished product quality It is never acceptable to ship defective material to Crayola without prior authorization from the Crayola QA team.

In the event that Crayola authorizes a supplier to ship material that does not comply with all Crayola product requirements, that authorization will be provided on a Temporary Deviation Notice authorized by Crayola Global Quality Assurance.

D. Pre-shipment Inspection It is Crayola's Policy that the first shipment of a new product or from a new supplier must undergo a pre-shipment inspection in accordance with these guidelines. The logistics of this inspection may vary based on region or supplier history. Based on the results of the first pre-shipment inspection, previous supplier history, or perceived risk associated with a product, Crayola may require that subsequent shipments be inspected as well. Crayola may, at its discretion, conduct the actual inspection using Crayola/Hallmark personnel, retain a third party firm, or authorize the supplier to conduct the inspection. If the products are being shipped via the Direct Import Process, the FOB customer may also require their own inspection.


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It is the responsibility of the supplier to ensure a pre-shipment inspection is carried out well in advance of the shipment window in case remedial action is required. If the supplier is authorized to self-inspect, the inspection must be carried out by qualified individuals independent of the production staff. Suppliers in China shall liaise with CHK PI department and suppliers in South East Asia shall liaise with Premium Deluxe Designs Limited to ensure that the agreed date for an inspection is adhered to. Failure to do so will result in the charges being passed to the supplier. Final inspection must be carried out when a minimum of 90% of the shipment has been manufactured and products are packed into shipping cartons. The inspection shall be carried out based on an approved Inspection by Attributes sampling protocol (BS6001, Military Standard 105, or ANSI/ASQ Z1.4). The AQL's applied will be as follows unless otherwise stated:

Critical 0% Major functional 0.4% Major visual 1.5% Minor 4.0%

Definitions and examples of these defects are given below. Critical Defects -- AQL= 0. Any defect related to the safety of the product. All product MUST COMPLY. Examples would include drop test failures which liberate small parts in product for children under 3, failure to comply with CPSIA standards, etc. Major Functional Defects -- AQL=0.4 Any defect that causes the product not to function. Examples would include dry markers, broken crayons, motors that don't function, etc. Major Visual Defects -- AQL=1.5 Any defect which seriously affects the item's appearance or produces significant final assembly problems (component or WIP). Examples would include incorrect assortments, significant printing issues on package, etc. Minor Defects -- AQL= 4.0 Any defect which moderately detracts from the final product appearance, limits functionality, or causes slight production problems (component or WIP). Examples would include small voids in crayon points, minor blemishes on marker barrels or packaging, etc. The definitions of defect types and the examples shown are not a comprehensive list and products may be inspected for further parameters and defects that are not listed. NOTE THESE DEFECT DEFINITIONS AND AQL REQUIREMENTS APPLY TO ANY SHIPMENT OF CRAYOLA PRODUCTS AND SHIPMENTS MAY BE REJECTED BASED ON THESE REQUIREMENTS. Functional testing is also carried out as part of the inspection to ensure that the product is fit for purpose. Pre-shipment inspection for every 1st shipment to Crayola should include screening to verify compliance to heavy metal requirements (XRF or wet chemical analysis) All samples for inspection must be selected at random by the inspector.


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The final inspection result will be reported as follows:

PASS - number of defects does not exceed the AQL's and product matches the approved production sample. HOLD - the approved production sample is not available and the number of defects does not exceed the AQL's. A product may also be reported as "HOLD" if the inspected items are different to the approved production sample. FAIL - if the number of defects exceeds the AQL's or if inspected items are different than the approved sample. Any rework must be conducted over 100% of production to ensure that all potential occurrences of the defect are corrected where possible or removed and destroyed where not.

No products can be shipped until inspections are completed and approved by Crayola's Global QA Team. Documentation of pre-shipment inspections results will be maintained by the factory and provided to Crayola LLC upon request.

E. Plant Sanitization Crayola products that contain liquids, gels, or putties (including modeling compounds) must meet the requirements of USP 61 and European Pharmacopoeia 7th edition (2011). Supplier developed formulations must also meet the requirements of USP 51 and European Pharmacopoeia 7th edition (2011).

Supplier facilities that produce or process Crayola products or formulations that contain a preservative system must meet Crayola’s minimum standards for plant sanitization in order to prevent contaminating these products by the manufacturing process or compromising the preservative system.

Manufacturing facilities processing Crayola formulations containing a preservative system will be audited by Crayola or a 3rd party to evaluate the effectiveness of the facilities’ plant sanitization process.

Details on the Crayola Plant Sanitization process are included as Appendix 3.

F. Calibration system All measuring equipment (mechanical, electrical, process) used to evaluate the conformance of Crayola products will be calibrated at regular intervals.

Calibration standards must be traceable to a national or equivalent standard.

The current calibration status must be clearly indicated on the instrument which will include the status, date of calibration and date calibration is due.

All measuring equipment must be recorded in a measurement instrument/gauge log (electronic files are acceptable). The gauge log must include gauge description, serial number, calibration frequency, and calibration/repair history.


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G. Corrective action/Preventive action Suppliers must have a process to identify the root cause of significant product and process failures and implement appropriate and effective corrective/preventive actions to avoid recurrence. Lean and six sigma methodologies are encouraged.

Crayola may provide training, tools and templates to facilitate; however, the supplier is responsible for training management and employees on industry standard problem solving methods.

Root cause investigation must thoroughly investigate the origin of the failure. Restating the failure is not an acceptable root cause investigation.

The corrective and preventative actions must address the root cause and be verified through a planned monitoring program, which may include internal and external tests, audits, and data collection.

The investigation and resolution must be clearly documented and retained. The learning from the resolution may be applied to other products and processes which may benefit from the action. Management system documentation such as test programs and standard operating procedures must be updated appropriately.

H. Product Recall/Crisis management In the event a Crayola product is subject to recall or retrieval from our retail partners, suppliers will have a process to identify affected products, locate suspect product as quickly as possible, isolate and contain the suspect product from further shipment, and retrieve suspect product for analysis and disposition. Suppliers to Crayola must have a process to notify Crayola of product in violation of any global safety requirement.

Crayola will make all determinations of disposition upon notification.


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IV. Product Safety/Product Integrity

A. Product Compliance Crayola products will be in compliance with all applicable safety and regulatory requirements in all countries of distribution.

Global Product Safety Requirements are specified in Appendix 2. Country or region specific requirements are described in detail in Appendices 15 through 18 of this document.

B. Date coding Products and packaging must be date coded in compliance with Crayola’s date coding format, provided in Appendix 6 of this document.

C. Foreign object control Suppliers must have an established process to prevent foreign objects from being incorporated into Crayola products. The foreign object control process must include an audit of tools and materials after any preventive or demand maintenance on process equipment.

D. Glass control Suppliers must establish a glass breakage procedure, which details actions required in the production area if broken glass is detected.

E. Sharp tools control Suppliers must have an effective method for preventing the sharp tools used in their manufacturing facilities from being inadvertently included with Crayola product in the consumer packaging.

The use of sharp tools with breakaway blades is prohibited.

F. Pest control Production facilities must have an effective program to prevent contamination of Crayola product by animals, insects, and other pests. All types of domestic animals are prohibited in any part of the factory or exterior areas.

G. Control of Restricted Substances Facilities processing materials or components that are at risk for containing restricted substances (heavy metals, phthalates, or other restricted substances that may affect the safety of Crayola products) must have sufficient controls to ensure that these substances are not contained in Crayola products above legal or specification limits. Factories must have adequate controls to prevent cross-contamination of materials within their facilities.


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V. Continuous Improvement

Crayola is committed to Continuous Improvement as a way to improve quality and efficiency while controlling costs. We expect our suppliers to have a CI Strategy in place for their business that addresses the critical elements of lead time reduction, defect elimination, and improved process capability. Our best suppliers will embrace the concepts of LEAN and Six Sigma as essential enablers to their business.

We encourage our suppliers to collaborate with us in their Continuous Improvement efforts and to identify opportunities to partner with us to improve the overall value chain. This might include supplier participation in Crayola sponsored training or events or Crayola engagement in a supplier’s CI process or event.


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VI. Systems certifications

A. Ethical standards Crayola is an ICTI CARE “Date Certain” company. As such, we are obligated to source finished goods from factories engaged in the ICTI CARE process where that process is active. Factories in the ICTI CARE process are required to provide all ICTI CARE process audits and Corrective Actions to Crayola for review. In the regions of the world where ICTI CARE is not active, Crayola will audit suppliers to the same standard as the ICTI CARE process. Crayola may, at its discretion, accept other industry or global ethical standard audits (e.g. SA8000, Hallmark Code of Conduct). Suppliers must provide copies of these audit reports to Crayola along with their corrective action plan. Subcontractors and Branded Material Suppliers are required to conduct business according to Crayola ethical standards detailed in Appendix 1.4. Subcontractors and Branded Material Suppliers are not required to engage in the ICTI CARE process. Demonstrated compliance to an industry recognized ethical standards program will typically satisfy the expectations. Appendix 1 contains additional information on Crayola’s ethical standards requirements.

B. Quality Management System At Crayola’s discretion, suppliers will be audited by Crayola Global QA or one of our 3rd party lab partners for compliance to Crayola specific process requirements, as outlined in this document.

Some Crayola customers that take delivery of our products through a direct import program will require their own factory audits be conducted. The most common Quality System Audits that Crayola has agreed to in individual cases are the Wal-Mart FCCA audit and the British Retail Consortium audit. When factories hold certification to ISO 9001 and have been audited to Crayola requirements, Crayola will advocate that our customers accept these audits in lieu of their program. While we have had some success with this approach, our customers generally reserve the right to require that factories be audited under their specific programs.

There are also specific countries that have their own requirements, which may require that a factory’s Quality Management System be audited to permit product sale in that country. Brazil and Thailand are specific examples.

Certifications to published International Standards are encouraged, but may not preclude an audit by Crayola to validate compliance with our specific requirements.

C. Supply Chain Security Crayola suppliers are expected to develop and implement a comprehensive plan to provide security procedures throughout their operations. The general requirements of an adequate security plan are described in Appendix 4.


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D. Environmental Management/Responsible Sourcing Crayola encourages suppliers to seek 3rd party certification demonstrating continuous improvement in environmentally responsible practices.

Paper/Wood/Wood pulp: Use of paper and wood from known, legal, sustainable, well-managed wood sources is required. Crayola encourages certification by credible 3rd parties, including – but not limited to – FSC. The use of recycled content, whenever product functional or quality standards are not compromised, is encouraged. Further details regarding Crayola’s paper and wood fiber sourcing policies are listed in Appendix 10.

E. Licensor Manufacturing Agreements Crayola contracts with other companies and brands to license their content for use in our products. Some licensing contracts contain requirements regarding facility or manufacturing authorizations. The requirements for these authorizations may include a current ethical standards audit or product safety testing/review. Some licensed properties require manufacturing licensing or approval by the Licensor. Suppliers should notify Crayola if they have registered with any Licensor, in order to effectively communicate Licensor authorization status. Crayola will communicate our license contract requirements when necessary.


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A1: Crayola global supply chain code of conduct

Violation of the ethical standards policy below may result in cancellation by Crayola of any purchase orders or supply agreements without any liability to Crayola or its subsidiaries.

1.0 Scope

These requirements are applicable to all domestic and international Crayola LLC operating facilitiesmanufacturing locations, suppliers, subcontractors, branded material suppliers and licensees.

2.0 Purpose

Crayola’s sourcing and procurement standards are consistent with our corporate beliefs and values. We view suppliers and their supply chain as an integral element of our business success and strive to select suppliers who adopt strong ethical standards, conduct their respective operations in a manner that respects the rights of the individuals they employ, provide a safe workplace that meets all regulatory compliance requirements, and demonstrate careful stewardship of the environment. Additionally, the Crayola Code of Conduct Audit Program is structured to allow Crayola LLC and suppliers the opportunity to review program requirements, ensure compliance, work on improvements to exceed minimum standards and openly discuss issues and concerns.

3.0 Application

As Crayola LLC expands its sourcing and marketing activities to meet our customers’ requirements, we recognize that the selection of source locations and suppliers has an impact on Crayola’s reputation and brand image.

The guidelines that follow allow Crayola to appropriately select new suppliers and locations for procurement as well as identify and resolve potential problems as they arise.

Crayola’s Code of Conduct Policy contains four key elements:

1. Workplace Standards and Practices 2. Audit Program 3. Source Location Guidelines 4. Subcontracting and Supplying Branded Material These guidelines are subject to revision in Crayola’s continuing effort to improve its sourcing and procurement practices.

A1.1 Workplace Standards and Practices

Crayola LLC expects its suppliers and their subcontractors to operate their facilities and conduct employee relations in an ethical manner and to meet the requirements stipulated by law in their respective host countries. This includes, but is not limited to, laws and regulations relating to labor, compensation, work hours, health and safety, and the environment.


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Other specific guidelines are as follows: Labor Practices All employment must be strictly voluntary. Crayola LLC suppliers and their subcontractors will never use forced or prison labor, including bonded labor, human trafficking, or slave labor in the supply of materials, products, or services. The International Labor Organization defines the following types of forced labor (also called involuntary servitude by the US Department of State or indentured labor by the US Department of Labor):

Prison labor The contracting out of prison labor or forcing of prisoners to work for profit-

making enterprises. Bonded labor Another form of debt bondage, it often starts with the worker agreeing to

provide labor in exchange for a loan, but quickly develops into bondage as the employer adds more and more "debt" to the bargain.

People trafficking Individuals are forced or tricked into going somewhere by someone who will

profit from selling them or forcing them to work against their will, most often in sexual trades. Many countries are both "origins" and "destinations" for victims.

Slavery A "physical abduction" followed by forced labor.

• Crayola prefers that its suppliers hire no worker under the age of 16. If local regulations stipulate compulsory

education up to an age greater than 16, that regulation will apply. Under no circumstances will Crayola accept employment of workers under age 14, which is the compulsory education limit in some locales.

• Factories must respect the workers’ right of free association and should not interfere with the legal exercise of the right of free association.

• Corporal punishment and physical or mental coercion are prohibited. • Every employee shall be treated with respect and dignity. No employee shall be subject to any physical, sexual,

psychological or verbal harassment or abuse. • Employers must not discriminate in hiring or employment practices on grounds of age, race, gender, national

origin, political or other opinion.

Compensation • Suppliers will not pay less than the minimum wage (including trainees) in accordance with local labor laws or the

prevailing market rate, whichever is higher. Workers will be fairly compensated to a similar standard for overtime work.

• Room and board, transportation, and other benefits will not be deducted from cash compensation in meeting or exceeding local salary standards. Other benefits must meet or exceed local laws and standards.


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Work Hours • All overtime, as defined by local regulations or practice will be strictly voluntary and will be duly compensated. • As a normal practice, the maximum number of working hours must not exceed 60 hours per week. Local

government regulations will be followed if they require fewer than 60 hours per week. • As a normal practice, workers should receive a minimum of one day off in seven days.

Health and Safety • Employers must provide a safe and healthy work environment. • Fire prevention equipment must be accessible (in factory and dormitory facilities) and employees must conduct

prevention and evacuation training. • Dormitory housing should provide clean and adequate space for employees with sanitary facilities and water

supply. • Restrooms should be clean and available for all employees.

Environment • All local laws and regulations must be met and operations conducted in a manner that conserves resources. • All waste materials and production by-products should be disposed of properly and in an environmentally

responsible manner. A1.2 Audit Program

Crayola’s Code of Conduct audit program is structured to provide the opportunity to review program requirements, ensure compliance, affect continuous improvements to exceed standards, and openly discuss issues and concerns. The audit process assumes open and free access to suppliers, their subcontractors and branded material suppliers at Crayola’s request and will be conducted solely at the discretion of Crayola management. ICTI CARE As a member of the Toy Industry of America, Crayola is committed to the International Council of Toy Industries CARE (Caring, Awareness, Responsible, and Ethical) program to promote ethical manufacturing in the toy industry supply chain worldwide. This program is currently focused in China, Hong Kong and Macau, where global toy production is concentrated, and has expanded to Indonesia, Malaysia and Vietnam. Crayola has made a commitment to the Toy Industry of America to source finished products only from ICTI CARE certified manufacturers in this region after June 2009.

Where ICTI CARE is implemented, it is expected that Crayola finished goods factories will engage in the ICTI CARE process as outlined at the ICTI CARE website (http://www.icti-care.org). Suppliers engaged in the ICTI CARE process will be required to provide a copy of the detailed audit report to Crayola’s QA organization, which includes the Product Integrity organization in the Hallmark Hong Kong (CHK-PI) office. When the ICTI CARE program audit indicates that the supplier factory did not achieve certification, the following policies will apply:

• Suppliers who are placed on PROBATION by ICTI-CARE but who are still actively engaged in the process and are

demonstrating a good faith effort toward resolving issues will maintain their standing as Crayola suppliers so long as they are working diligently to implement a thorough Corrective Action Plan (CAP). The Crayola QA Department or CHK-PI team will provide support and expertise. Suppliers are required to utilize this assistance to restore their ICTI-CARE certification as soon as possible.

http://www.icti-care.org/


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• Suppliers who are TERMINATED by ICTI-CARE are considered to be seriously negligent and/or deceptive in their implementation of our Code of Conduct requirements. In this case, we may complete existing purchase orders but no additional purchase orders will be placed until the ICTI-CARE certification is reinstated.

• Suppliers who have previously been certified by ICTI-CARE but do not successfully renew their certification (or by

evidence of an Audit Report with Recommended Results) within 6 months of the expiry date of their certificate are considered to be non-compliant. In this case, we may complete existing purchase orders, but no additional purchase orders will be placed until the ICTI-CARE certification is renewed.

For finished goods suppliers outside of the ICTI CARE region and identified critical raw material, component or service providers globally, Crayola will use a 3rd party audit company to conduct an ethical standards audit to the ICTI CARE requirements. In general, these audits will be conducted annually. Crayola may, at its discretion, accept other industry or global ethical standard audits (e.g. SA8000, Hallmark Code of Conduct). Suppliers must provide copies of these audit reports to Crayola along with their corrective action plan. After the audit is conducted, any areas requiring improvement will be addressed directly with the supplier, resulting in corrective action steps and an improvement program. Audit reports and Corrective Action Plans will be reviewed by Crayola Quality Assurance for completeness and to ensure that the proposed corrective actions adequately address audit findings. Any additional guidance based on this review will be formally communicated to the Supplier through the Crayola Global Sourcing organization. A follow up audit to verify that corrective actions have been adequately implemented may be directed by Crayola QA. Failure to implement improvement in a timely manner can result in order cancellation by Crayola of any purchase orders or supply agreements without any liability to Crayola or its subsidiaries.

A1.3 Source Location Guidelines

• It is incumbent upon Crayola managers to assess not only the need to conduct sourcing operations in the host country in support of our customers, but also to evaluate any inherent risk to our staff or to Crayola’s reputation and image. Because Crayola LLC is a subsidiary of Hallmark Cards, Inc., Hallmark's Policy 124 for conducting International Business provides a framework for this process.

• Political, economic and social unrest should not place Crayola employees and agents at excessive risk.

• The host country must not – in Crayola LLC’s view – have an endemic child labor or human rights problem that

would transcend our ability to control or positively influence the host country by our presence.

• All applicable trade agreements and local laws, including those applicable to importing into the U.S. and other countries, must be followed as well as adherence to the Foreign Corrupt Practices Act. Concurrently, Crayola LLC Sourcing Department employees are not allowed to accept gifts/advantages from any supplier and must sign an adherence statement annually to this effect.


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A1.4 Subcontracting and Supplying Branded Material

Definitions Subcontracting: • A direct supplier arranges for another supplier to produce finished merchandise where substantial

manufacturing occurs to render the product a finished article. • A direct supplier arranges for another supplier to do the work that the primary supplier agreed to provide to

Crayola.

Supplying Branded Material: • Producing a part or component containing a Crayola or licensed partner logo. • Producing packaging material containing a Crayola or licensed partner logo. • Further handling of merchandise containing a Crayola or licensed partner logo (i.e. handwork, affixing

attachments, packing, transporting, storing.) Requirements for Subcontractors • Suppliers must disclose all subcontractors prior to the subcontractor receiving, handling or conducting work on

the material. • Subcontractor disclosure must be in writing and include the facility location, contact information, work which

will be done and the assessment which the supplier will conduct. • Crayola will review the information to confirm Requirements of Subcontractors and Suppliers of Branded

Materials below are acceptable. • Crayola will provide written approval to begin work at the subcontractor.

Subcontracting without prior written consent is strictly prohibited. Requirements of Subcontractors and Suppliers of Branded Materials • Suppliers are required to keep records of all facilities and manufacturing locations which provide subcontracted

or branded materials to the supplier. • Crayola may request copies of a supplier’s subcontractor and branded material suppliers list at any time.

Suppliers must provide the list in English within 48 hours. • Suppliers must communicate the ethical standards in the Global Supply Chain Quality Requirements to the

subcontractors and branded material suppliers. • Suppliers must verify the subcontractors and branded material suppliers meet the following zero tolerance and

critical ethical standards requirements defined in this document: Child Labor, Underage Labor, Forced Labor, Corporal Punishment / Harassment, Discrimination, Serious Health and Safety Conditions, Restricted Freedom of Association, Minimum Wage per Local Law, Falsifying Records and Bribery. Acceptable methods of verification include an existing 3rd party audit, supplier audit by a qualified employee or contractor, or audit by a qualified Crayola employee or partner of Crayola such as Hallmark Hong Kong (CHK-PI).

• Crayola may request documentation to demonstrate suppliers of branded material meet the ethical standards. If the documentation is not available, Crayola may require appropriate and timely investigation. Failure to accommodate the investigation may require Crayola to cease business with the supplier.


Rev. 1 (2/2014) 20

Homeworking Crayola LLC strongly discourages the use of homeworking for production. The use of homeworking without prior written consent is strictly prohibited. Verification of compliance is the responsibility of the supplier. Homeworking of licensed product is strictly prohibited. If homeworkers are to be used, all local laws and Crayola’s Code of Conduct must be followed. At a minimum: The age of workers must be verified and comply with the Crayola requirements • Hours and wages must be tracked • Homeworkers must be guaranteed proper compensation Licensed Materials: Suppliers, subcontractors and branded material suppliers which handle licensed images must be disclosed to Crayola prior to production or handling of the licensed material. Documentation such as Facility Authorization and Merchandise Authorization applications may be required to satisfy licensed partner contracts. Licensed material cannot be produced until the documentation has been completed. Brand Protection All suppliers, subcontractors and branded material suppliers must protect the reputation of Crayola. Illegal operations such as counterfeiting, releasing confidential information, copying art work or other actions which violate intellectual property rights are forbidden.


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A2: Crayola global product safety and regulatory requirements

1.0 Scope

These requirements apply to all new or refreshed products manufactured for Crayola LLC, distributed in the Crayola global distribution system, or bearing the licensed Crayola logos or trademarks.

2.0 Crayola Global Specifications

All Crayola products must be designed, engineered and produced to meet or exceed all applicable Safety, Toxicity, Regulatory and Labeling requirements for applicable product categories exported to destined international markets including the United States, European Union, Canada, Mexico, Australia, China, Japan, and the Middle East. Suppliers are responsible for the compliance of all materials and components incorporated into Crayola product. It is strongly recommended that suppliers engage a 3rd party laboratory for testing support to ensure compliance with all applicable requirements. Crayola requires that all finished product be tested and formulas reviewed to verify compliance with all applicable requirements prior to first shipment. Products must also meet Crayola Global Design & Engineering Guidance for Children Under 3 (attached at the end of this document) and any requirements imposed by our retailer partners. To the greatest extent possible, Crayola has incorporated our customers’ requirements into this document Suppliers should consult Crayola Sourcing for the most current interpretation and implementation of Safety and Regulatory requirements.

3.0 Regulations and Standards Applicable to Crayola’s Children Products

All Toys and Children Products • Federal Hazardous Substances Act (FHSA) • Child Safety Protection Act (CSPA) • Consumer Product Safety Improvement Act of 2008 (CPSIA) • American Society for Testing and Materials (ASTM) F963 • EC Regulation 1907/2006 REACH, as amended • EU Toy Safety Directive 2009/48/EC • European Standard for the Safety of Toys - EN 71 • EU Biocide Regulation 528/2012 • Canada Consumer Product Safety Act - CCPSA • Australian/New Zealand Standards - AS/NZS ISO 8124 • California Safe Drinking Water and Toxic Enforcement Act of 1986 (CA Proposition 65) • All U.S. State ‘chemicals of concern lists’ (or similar)


Rev. 1 (2/2014) 22

Heavy Metals Surface coatings must not contain total lead content in excess of 40 mg/kg and substrate materials must not contain total lead content in excess of 90 mg/kg. Total Cadmium content must not exceed 100 mg/kg for all surface coatings and substrates. All materials must comply with the requirements of the latest US Federal or State Legislations with testing methods acceptable to CPSC. The following global standards, regulations and bans apply: • Consumer Product Safety Improvement Act of 2008 (CPSIA) • ASTM F963, Section 4.3.5.2, • Title 16 CFR 1303-Ban of Lead-Containing Paint • EU Toy Safety Directive 2009/48/EC • EN-71 Part 3 - Migration of Certain Elements • Canada Consumer Product Safety Act - CCPSA • AS/NZS ISO Part 3- Migration of Certain Elements • EC Regulation 1907/2006 Annex XVII - Total cadmium, phthalates, nickel and azo dyes

Art Materials

All Art Materials • Must maintain the ACMI (The Art & Creative Materials Institute) AP Seal including approval from a board-

certified Toxicologist that the material meets the CFR Title 16 Part 1500 Federal Hazardous Substances Act, ASTM D4236 and LHAMA.

• Must maintain EU TRA. • Must maintain Canadian TRA • For Writing Instruments only – must meet Safety Caps, BS7272-1, Specification for Safety Caps and End

Closures, BS7272-2, Specification for End Closures. • Must meet European Safety of Toys EN71 Part 9 Organic Chemical Compounds Requirements Brushes for Art Material • Natural Bristle/Hair- Documentation certifying that hair is cleansed, dressed, double-boiled or sanitized for

entry into the United States. • Natural Bristle/Hair – Must comply with the following microbiological limits: Total Plate Count : 1000

cfu/gram, Total Coliform: <0.3 MPN/gram

Bathtub Art Materials (Paint, Ink, Modeling compound, etc.) • Must maintain the ACMI (The Art & Creative Materials Institute) AP Seal including approval from a board-

certified Toxicologist that the material meets the CFR Title 16 Part 1500 Federal Hazardous Substances Act, ASTM D4236 and LHAMA.

• Must maintain EU TRA. • Must meet EN71 Part 9 Organic Chemical Compounds Requirements • Must comply with European Cosmetics Directive EC No. 1223/2009. • Bathtub art materials must be formulated with FDA colorants.

Face Cosmetics/Body Art Materials • Play cosmetics must conform to the requirements of the U.S. Federal Food, Drug and Cosmetic Act, 21 CFR

700-740 and 21 CFR 70, 73, 74, 81 and 82. • Must conform to the requirements of the cosmetic regulations of the Canada Food and Drugs Act. • Must comply with European Cosmetics Regulation 1223/2009. • Cosmetics/ Face Paints must contain less than 5 ppm lead (CA Prop 65).


Rev. 1 (2/2014) 23

• Health Canada: Heavy metals must not exceed the following limits: Lead 10 ppm, Arsenic 3 ppm, Cadmium 3 ppm, Mercury 3 ppm, Antimony 5 ppm.

• Appropriate safety testing (eye irritation, skin irritation, oral toxicity, and sensitization) must be completed and results made available (Animal testing is prohibited).

• For products intended to be used on the face, all color additives must be approved for use on the entire area of the face without use restrictions. No acute or chronic health warnings are permitted for children under 8 years.

• Product configuration and package design should be clearly differentiated from core Crayola items/products so as not to promote skin contact and art material abuse.

• Must not contain talc, formaldehyde, phthalates, or toluene. Food Contact Items • Must comply with 21CFR174-178 - Indirect Food Additives and 21CFR181 – Prior Sanctioned Food

Ingredients. • Must also meet 21CFR170.39 – Threshold of Regulation for Substances used in Food Contact Articles. • Must not contain Biphenol-A, Test to EN14350-2 Child Use and Care Articles-Drinking Equipment, Migration

of Bisphenol-A, must not exceed 0.03 ppm.

Jewelry • Must comply with Maryland and Connecticut total cadmium in children's jewelry and must not exceed 75

ppm. • Must comply with ASTM F2923 Children's Jewelry Safety Standard. • Must comply with Illinois Cadmium-Safe Kids Act and Minnesota soluble cadmium in children’s jewelry and

must not exceed 75 ppm. • Must comply with EC Regulation 1907/2006 (as amended) Nickel Release. Cosmetics • Manufacturing facilities must rigorously adhere to good manufacturing practices and must certify

compliance to US FDA Cosmetic Good Manufacturing Practice (cGMP) and the European Cosmetic Regulation No. 1223/2009 (Article 8, relevant harmonized standard ISO 22716).

• Must meet the COLIPA guidelines on Microbial Quality Management • Finished Product must be tested to the US Pharmacopeia Methods <51> for Cleanliness and Preservative

Effectiveness and meet the pathogen requirements of USP Microbiological Test: <61> Microbial Limit Test and the total plate count and mold and yeast count requirements of the U.S. Cosmetic, Toiletry, and Fragrance Association (CTFA).

All Biocritical Products (subject to sterility and preservative effectiveness testing) • All biocritical products must be produced under sanitary conditions as described in Appendix 3: Plant

Sanitation. • Finished Product must be tested to the US Pharmacopeia Method: <51> for Cleanliness and Preservative

Effectiveness and meet the pathogen requirements of USP Microbiological Test: <61> Microbial Limit Test Finished Product must meet Crayola Microbiological Test Method (MTM) A-8, Microbial Quality.

• Paint Products, Paste, Glue and Marker Inks must meet the Crayola MTM A-2, Preservation Testing requirements.

• Modeling Compounds must meet the Crayola MTM A-5, Preservation Testing requirements.


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Packaging and packaging components All packaging must comply with the Toxics in Packaging Clearing House (formerly NEWMOA /formerly CONEG) Model, Toxics Reduction Laws: (U.S.) and the European Directive on Packaging and Packaging Waste (94/62/EC). The combined concentration limit for lead, cadmium, mercury and hexavalent chromium shall not exceed 100 PPM.

Chemical Materials

• Polycarbonate components in products intended for children under 13 years old must not contain Bisphenol-A.

• No talc, natural latex rubber or PVC is permitted in Crayola products. • Any crayon, modeling clay, powder or chalk shall not contain any detectable levels of asbestos. • All toys and art materials must comply with the European Safety of Toys EN 71 Part 9 - Organic Chemical

Compounds for EU markets. • Foam and textile products for children under age 3 must not contain TCEP [Tris (2-choloroethyl) phosphate]

(New York Children and Babies Act). • Products must not contain TDCPP [tris(1,3-dichloro-2-propyl) phosphate] and TCEP [tris(2-chloroethyl)

phosphate] at a level greater than 0.1% by weight in any component. • Material Safety Data Sheets (MSDS) are required for all chemical components and mixtures.

DMF (Dimethyl Fumarate, CAS:624-49-7) All products and components, including corrugated cartons and boxes, must comply with 2009/251/EC requiring Member States to ensure that products containing the biocide dimethylfumarate (above 0.1 mg/kg) are not placed or made available on the market.

REACH

All products entering commerce in the EU market must comply with requirements defined by the REACH Regulation (Registration, Evaluation, Authorization and restriction of Chemicals), as administered by ECHA (the European Chemical Agency). This includes providing weighed percentage chemical ingredients Bill of Substances (BOS) and volumes for annual assessment and subsequent pre-registration and/or registration (if applicable). Chemicals factored into a total mass > 1 tonne per year per registrant, and those considered SVHC (Substances of Very High Concern) regardless of volume are regulated, when used in products and in concentrations > 0.1% w/w of Articles or if they are intended to be released from Articles.

TSCA

All chemical substances must comply with all applicable rules or orders under the TOXIC SUBSTANCE CONTROL ACT (TSCA), as amended, for the US market. Soft PVC and Plasticized Materials Crayola does not allow the use of PVC in products and will not introduce any new products or packages containing PVC. Existing packages containing PVC are to be changed to more environmentally sustainable materials as soon as practical.

All products and packages made on behalf of Crayola must comply with CPSIA Section 108 and the EU Regulation 1907/2006 for regulated phthalates (DEHP+DBP+BBP <0.1%, DINP+ DIDP+DnOP <0.1%). In addition, products and packages must not contain di-n-hexyl phthalate (DnHP) at greater that 0.1%.


Rev. 1 (2/2014) 25

Plastic Film All flexible plastic film and film formed into a pouch or bag must be a minimal thickness of 1.5 mils (.0015 Inches/.0381 mm) or have a minor dimension of 3.94 inches (100 mm) or less. For children less than 3 years old, flexible plastic film and film formed into a pouch or bag must be a minimum 2 mil (.002 inches/.051 mm).

Plastic Bags

For children ages 3+: Plastic bags, flexible plastic film and film formed into a pouch or bag must be a minimum thickness of 1.5 mils (.0015 Inches/.0381 mm) or have a minor dimension of 3.94 inches (100 mm) or less. For children less than 3 years old: Plastic bags, flexible plastic film and film formed into a pouch or bag must be a minimum thickness of 2 mil (.002 inches/.051 mm). In addition, all plastic bags with a thickness of less than 3 mil (.003 inches/.076 mm), including those produced with film formed into a pouch or bag having: (a) one side measuring 7 inches (177.8 mm) or greater, Or (b) a stretched opening perimeter of 14 inches (355.6 mm) or greater requires labeling as noted below: WARNING: PLASTIC BAGS CAN BE DANGEROUS. TO AVOID DANGER OF SUFFOCATION, KEEP THIS BAG AWAY FORM BABIES AND CHILDREN. IF BAG WILL BE DISTRIBUTED INTO THE EUROPEAN COMMUNITY: Type size of Warning should be minimum 5mm in height IF BAG WILL BE DISTRIBUTED INTO CANADA: The following warning must be included whenever the English warning is required: LES SACS DE PLASTIQUE PEUVENT ÊTRE DANGEREUX. POUR ÉVITER LE DANGER DE SUFFOCATION, NE LAISSEZ PAS CE SAC À LA PORTÉE DES BÉBÉS NI DES ENFANTS.”

Electrical and Electronic Products Battery-operated Toys • Must meet EN62115 for Electrical Toys Safety for European Markets. • Must meet Canadian CSA Standard for electrical toys for Canada market. • Batteries or products containing batteries must meet the requirements of Battery and Accumulator

Directives (2006/66/EC).

A/C electric-powered Products • Must meet US Federal Hazardous Product Act, 16 CFR 1505 requirements for Electrically Operated Toy or

Other Electrically Operated Articles Intended for Use by Children. • Must meet EN62115 for Electrical Toys Safety for European Markets. • Electric-powered products for US market must be UL certified and the manufacturer must demonstrate

compliance with the appropriate safety requirements both in product and production process. For Canada market, CUL certification with similar requirements is also required for product distribution.

• Must meet Canadian CSA Standard for electrical toys for Canada.


Rev. 1 (2/2014) 26

Electromagnetic Compatibility • Products for USA - Verification for unintentional radiators and certification of intentional radiators as

required by Code for Federal Regulations, Title 47, Part 15. • Products for Canada (ICES-003) - Compliance with US FCC also complies with Canadian Specification (Class

B). • Products must meet EU Directive on Electromagnetic Compatibility (EMC), 2004/108/CE. Must be tested to

EN55014, Parts 1&2

RoHS and WEEE Must comply with the Restriction of Hazardous Substances (RoHS) Directive, as amended on control of lead, cadmium, mercury, hexavalent chromium (or chromium VI), polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE) flame retardants, and The Waste Electrical and Electronic Equipment (WEEE) directive prevents waste by encouraging reuse and recycling. LED’s in Children's Products Crayola requires testing to International Standards IEC 60825-1 Safety of Lasers Products and/or IEC 62471 Photobiological Safety of Lamps and Lamp Systems depending on the product type and the market distribution of the product. Individual product specifications will identify the appropriate IEC standard testing required for the product. Sound-Producing Toys Noise Level must comply with: • ASTM F963 • EN71-1 • CCPSA • AN/NZS ISO 8124-1 • Crayola product specifications may require a more stringent acoustic decibel level. Battery Type Specification Must meet Safety Labeling for Battery Operated Toys as described in: • ASTM F963-Standard Consumer Safety Specification on Toy Safety and • EN 62115, the European Standard for the Safety of Electric Toys. Button cell batteries may not be used in Crayola products.

Composite Wood Products

Supplier shall submit DOC (Appendix 1.2) and test certificate that the composite woods meet California Air Resources Board (CARB) requirements for restricted materials -- specifically formaldehyde: In addition, for USA shipment, the finish product shall carry the following label: Crayola LLC MM/YYYY California 93120 Compliant for Formaldehyde


Rev. 1 (2/2014) 27

4.0 Product Safety Review All new Crayola product designs must be reviewed by the Crayola Product Safety and Risk Review Committee, a cross-functional team led by the Manager of Product Safety. The Committee looks at proposed product designs, materials, chemicals, ingredients, microbial contamination risks, electronic components, and age grading. The committee provides a broad perspective of potential risks that could arise due to: • product use and misuse by consumers • children’s abilities to understand the product and physically manage the product safely (age grading) • regulatory issues • potential legal risks • consumer and environmental activists focusing on product vulnerabilities

Engineering models and samples must be reviewed by Crayola Product Safety Group (and 3rd party lab as needed) to ensure potential safety concerns are avoided during engineering development and changes. Any changes made to a Crayola product after production approval must be submitted for approval with reference samples and supporting data. A 3rd party lab report may be required in these cases.

5.0 Crayola Global Design & Engineering Guidance for Under 3 Children’s Products

Crayola products are carefully designed, developed and safety tested to meet or exceed international regulatory and safety requirements and to ensure the highest level of integrity with respect to consumer protection and satisfaction. For this reason, Crayola has established special Global Design & Engineering Guidance for Under 3 Children’s Products as described in the following pages.


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CONFIDENTIAL Test Age (Months) Crayola Global Design & Engineering

Guidance for Children Under 3

Small Parts 0 to <36 mos. Shall not fit into the Crayola small parts test cylinder when subjected to a l lb. load (cylinder is 10% larger than standard cylinder)

Products having the potential to liberate small parts during abuse or other toy testing must have 2 forms of attachment (double retention system) or be redesigned to eliminate the potential of liberating the small part.

Drop 0 to <18 mos.

>18 to 36 mos.

5’2” (1.57 m), 10 drops

5’2” (1.57 m), 10 drops

Exemptions: Base area >400 sq. in. (0.26 sq. m) or volume > 3cu. ft. (0.08 cu. m)

Tension

Tension – Eyes and other hard attached small parts on Stuffed Toys

0 to <18 mos.

>18 to 36 mos.

Follow EN71-1 methodology using 90N dead-weight arrangement.

Follow EN71-1 methodology using 90N dead-weight arrangement.

For eyes and other hard attached small parts on stuffed toys:

30 lbs. (133.5 N) Max. test load is to be maintained for 10 seconds.

Compression 0 to <18 mos.

>18 to <36 mos.



Flexure 0 to <18 mos.

>18 to <36 mos.

17 lbs. (75.6 N) for 30 cycles at a rate of 1 cycle/2 sec w/60 sec. rest period after each 10 cycles. (1 cycle = (2) 120 degree flex arcs)

17 lbs. (75.6 N) for 30 cycles at a rate of 1 cycle/2 sec. w/60 sec. rest period after each 10 cycles. (1 cycle = (2) 120 degree flex arcs


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Test Age (Months) Crayola Global Design & Engineering Guidance for Children Under 3

Torque 0 to < 18 mos.

>18 to <36 mos.

4 in-lbs. (0.45 Nm) Max. test load is to be maintained for 10 seconds.

4 in-lbs. (0.45 Nm) Max. test load is to be maintained for 10 seconds.

Small balls 0 to <36 months

Min. dimension not less than 1.93” diameter.

Pompoms 0 to 36 months Not pass thru a 1.93” diameter test hole gauge under their own weight. Strands that are removed in the abuse tests shall not allow the pompom to disassemble easily to produce a bunch of individual strands

Hemispheric Shaped Objects (toy cups, bowls, or one half egg-shaped objects (nearly round, oval or elliptical opening w/the minor & major inner diameters between 2.5” (64 mm) & 4.0” 102 mm), volume < 6 oz. (177 ml), depth > 0.5” (13 mm).

0 to 36 months Must have at least 2 openings w/a min. minor dimension of 0.156” (4 mm) at least 0.5” (13 mm) from the rim.

If openings are in the base, they must be at least 0.8” (20 mm) apart. If the openings are not in the base they shall be placed at least 30 degrees but not more than 150 degrees apart.

OR

The plane of the open end shall be interrupted by a divider that extends to within 0.25” (6 mm) or less from the plane of the open cup end.

OR

Have 3 openings that are at least 100 degrees apart, located between 0.25” (6 mm) and 0.5” (13 mm) from the rim. Openings shall have a min. dimension of 0.156” (4 mm)

OR

Have a scalloped edge around the entire rim. The max. center distance between each peak shall be 1” (25 mm) and the min. depth shall be 0.25” (6 mm).

Note: Objects intended for drinking (tea set cups, etc.) are required to be subjected to an EC Type Examination.

Exemptions: non-detachable components of larger toys; containers that are part of package and intended to be discarded.


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Preschool Play Figures

With: Round, spherical or hemispherical end attached to a simple cylindrical shape: overall length less than 2.5” (64 mm)

0 to 36 months Not enter and penetrate past the full depth of a rattle gauge with a 1.85” (47 mm) diameter hole x 1.18” (30 mm) depth under their own weight.

Certain toys with spherical, hemi-spherical, or circular flared ends weighing < 1.1 lb. (0.5 kg)

0 to 36 months Not enter and penetrate past the full depth of a “rattle” gauge with a 1.85” (47 mm) hole x 1.18” (30 mm) depth under their own weight.

Excludes stuffed toys or stuffed parts of toys or fabric parts.

Battery Powered Toys 0 to 36 months

(all Crayola branded battery operated toys)

Batteries shall not be accessible without the use of a Phillips head screwdriver.

Cords on toys 0 to 36 months Cords shall have a minimum thickness of .059” (1.5 mm) while under a tension force of 5.6 lbs (25 N).

Cord on Toy Bags

0 to 18 months Bags with an opening perimeter of 13 inches or more shall not have a drawstring or cord as a means of closing.

Cords and Elastics

0 to 18 months Shall be less than 8.66” (220 mm) long under a 5.6 lb. (25 N) load. If the cord or elastic or multiple cords or elastics can tangle or form a loop in connection with any part of the toy, including beads or other attachments on the end of cords or elastics, the loop shall not permit the passage of the head probe designated in ASTM F963 Sec. 4.14.


Rev. 1 (2/2014) 31


Self-Retracting Pull Cords

0 to 18 months Shall not retract more than 0.25” (6 mm) with a 2 lb. (0.9 kg) dead weight hanging from the fully extended cord and the toy held firmly in the most favorable position for retraction.

Monofilament cords shall not be used.

Cords and Elastics on Pull Toys

0 to 36 months Cords and elastics used on pull toys shall not be provided with beads or other attachments including knots that could tangle to form a loop.

Functional Sharp Edges and Points

0 to 36 months

(up to 4 years)

Functional sharp edges and points shall not be accessible or become accessible during or after the use and abuse tests.

Circular Holes in Rigid Materials

0 to 36 months (and all Crayola branded products)

If circular holes or holes that would have a 4-point contact/interference with a 9/16” (14.5mm) rod in any rigid material can admit a ¼ in. (6-mm) diameter rod to a depth of 3/8 in. (10 mm) or greater, it shall also admit 9/16” (13 mm) diameter rod.

Phthalates 0 to 36 months

(all Crayola branded products)

No regulated phthalates may be added. Must comply with CPSIA Section 108 and EC Regulation 1907/2006 Phthalate Content for total phthalate content in toys and childcare articles. Limit for global product distribution is <0.05.

Plastic Films 0 to 36 months


Plastic films used in products shall have a minimum nominal thickness of 2 mil. Some uses may necessitate the use of a 4 mil minimal thickness film.

Marbles 0 to 36 months Not Allowed

Latex Balloons 0 to 36 months


Not Allowed


Rev. 1 (2/2014) 32


PVC 0 to 36 months Products must not be manufactured with PVC.

Bisphenol A 0 to 36 months Polycarbonates or other components must not contain.

Use EN71-3 style determination of components (ie. printed paper is tested as a single component and coatings on plastic are isolated).

Apply a 0.1% by weight limit to each component.

Battery Box (non-bath)

0 to 36 months Product must have a rib-in-channel battery box seal design.

Stickers 0 to 36 months Sticker must be made of paper.

EVA Foam 0 to 36 months Must meet 50 lb. (222.4 N) bite and 23 lb. (102.3 N) tension test. Max. test load is to be maintained for 10 seconds.

Rattles 0 to 36 months The C-weighted peak sound pressure (Lcpeak) of the rattle should not exceed 95 dB.

TCEP (Tris (2-chloroethyl) phosphate

0 to 36 months Not Allowed

Suction Cups 0 to 36 months Must be greater than 1.75 inches in diameter.

Paper/Cardboard 0 to 36 months Must be less than 400g/m2. The product will then be exempt from the small parts testing for the EU.


Rev. 1 (2/2014) 33

A3: Crayola Plant Sanitization process

1.0 Scope

Crayola Suppliers must maintain sanitary working conditions. Manufacturers of materials subject to sterility and preservative effectiveness tests must demonstrate capability to consistently meet requirements of Crayola global product safety and regulatory requirements.

2.0 Sanitization Process Verification

All processes associated with manufacturing Crayola products should be managed to assure preservative effectiveness and finished product sterility.

Manufacturing facilities must incorporate programs to verify employees, equipment, components, intermediate products, and finished goods are clean and sanitary. The verification process may include a review of Standard Operating Procedures as well as surface area, component, and product sterility tests.

All manufacturing facilities of microbially susceptible materials are subject to 3rd party microbiological assessment prior to and during production or handling of Crayola products. The assessment is designed to review and verify standard operating procedures. The assessment includes document (sanitization procedure) review, a factory tour, and collection of samples from the factory environment. The samples are cultured and organisms are identified. Results of the assessment are communicated to determine a corrective action plan. Follow up assessments may be conducted to verify corrective actions are in place. Organisms may be retained by Crayola or our designated lab for use in verifying the effectiveness of our formulation preservative systems.

We can separate micro requirements into 3 areas: 1) Raw and intermediate materials, 2) Finished Product, and 3) Manufacturing Environment.

1. Raw and intermediate materials (e.g. water used for producing ink, ink, pre-mixes):

Exceed USP 61 requirements to meet: Gram positive bacteria < 500 cfu/ml; Gram negative bacteria < 10 cfu/ml; Mold and yeast < 10 cfu/ml; No pathogens

2. Finished Product:

Finished product must meet microbiology standards as defined in product specifications.

3. Manufacturing Environment:

Factory assessment micro evaluations do not yield pass/fail results. The findings are used to communicate improvement opportunities with our suppliers. The equipment and workers are not required to be sterile, however continuous improvements should strive to prevent contamination of finished product.


Rev. 1 (2/2014) 34

A4: Supply Chain Security

Crayola suppliers are expected to develop and implement a comprehensive plan to provide security procedures throughout their operations. The general requirements of an adequate security plan are described below. The supplier is expected to have written security procedures in place that address these requirements.

The C-TPAT requirements below are the industry standard for supply chain security

1.0 Physical Security All buildings should be constructed of materials which resist unlawful entry and protect against outside intrusion. Other essential elements of facility security include: • Adequate locking devices for external and internal doors, windows, gates and fences. • Segregation and marking of international, domestic, high-value and dangerous goods cargo within the

facility by a safe, caged or otherwise fenced-in area. • Adequate lighting provided inside and outside the facility to include parking areas. • Parking area for private vehicles separate from the shipping/loading dock and cargo areas. • Internal and external communications systems in place to contact internal security personnel or local law

enforcement.

2.0 Access Controls Unauthorized access to the shipping, loading dock and cargo areas should be prohibited. Controls should include: • The positive identification, recording and tracking of all employees, visitors and vendors. • Procedures for challenging unauthorized/unidentified persons.

3.0 Procedural Security

Measures for the handling of incoming and outgoing goods should include the protection against the introduction, exchange, or loss of any legal or illegal material. Security controls should include: • Having a designated security officer to supervise the introduction/removal of cargo. • Properly marked, weighed, counted and documented products. • Procedures for affixing, replacing, recording, tracking and verifying seals on containers, trailers and railcars. • Procedures for detecting and reporting shortages and overages. • Procedures for tracking the timely movement of incoming and outgoing goods. • Proper storage of empty and full containers/trailers/railcars to prevent unauthorized access. • Procedures to notify Customs and Border Protection in cases where anomalies or illegal activities are

detected or suspected by the company. 4.0 Education and Training Awareness

A security awareness program should be provided to employees. The program should include instruction on how to recognize internal conspiracies, maintain product integrity, and determine and address unauthorized access. The program should offer incentives for active employee participation in security controls.

5.0 Threat Awareness A threat awareness program should be established and maintained by security personnel to recognize and foster an awareness of the threat posed by terrorists and contraband smugglers at each point in the foreign-based logistical chain. This program should include routine briefings and issuance of memoranda illustrating smuggling trends, seizures and information on terrorist threats along routes or areas along the logistics chain.


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A5: Quality Planning in the Product Development Process

1.0 Scope All products developed by or for Crayola shall go through this quality planning process to ensure flawless execution regarding product safety, quality, and performance.

2.0 Quality Planning and Flow

2.1 Design Turnover: Project Turn Over Package is released from Product Development for commercialization.

2.2 Design Review: The design review process, led by Crayola Product Engineering with Crayola QA and the selected supplier/producer, is intended to highlight potential design issues and suggest possible design improvements based on preliminary designs or working models.

2.3 Final Release: The product design finalized, incorporating any revisions identified in the Design Review process, and release to the manufacturer with authorization to procure tooling.

2.4 Tool Start: Once tooling fabrication process begins, the supplier/manufacturer should submit the tooling plan to Crayola.

2.5 First Shot: Once the production tooling is completed, delivered to the supplier/manufacturer and de-bugged, parts are submitted to Crayola Product Engineering and Crayola QA for evaluation.

2.6 First Engineering Prototype (EP1): EP1 samples are representative of the first attempt to assemble a complete product. It shall consist of all parts and may require hand modification to be successful. EP1 samples enable the debugging of the product and production tooling.

2.7 Second Engineering Prototype (EP2): Subsequent Engineering Prototype submissions allow for the evaluation of the product after a significant design or tooling change in the product commercialization process.

2.8 Final Engineering Prototype: Final Engineering Prototype samples will be representative of production quality product. These samples will be used for assessment of product compliance to specifications and for laboratory (internal and external) testing. The minimum running quantity per SKU should be 200 pcs.

(The Supplier’s QA organization must conduct internal safety and reliability testing and assessment on all EP and FEP samples. EP and FEP report and reference samples should be submitted to Crayola Product Engineering and Crayola QA for assessment and approval.)

2.9 Pre-Production: Pre-production samples must be from production tooling, using production processes and production materials. Pre-production samples are to be made from a pilot run of the production line. These samples are used for assessment of production capability and manufacturability of the product. The minimum running quantity per SKU should be 500 pcs.

A complete Pre-production report must be provided by the Supplier within 3 working days after a Pre-Production run. Based on the information provided in this report, Crayola may convene a meeting with the Supplier’s Product Engineering/Quality Engineering/Production staff to review the data and results.

Pre-production samples will be sent to Crayola QA in Easton. Upon completion of the pre-production review, Crayola will authorize production start.

Signed Sample: Suppliers should submit signed samples to Crayola QA for signature. These samples will be returned to the Supplier and will be used as reference sample for QC Inspection.


Rev. 1 (2/2014) 36

2.10 Production Start: The production is released to full running after receiving the followings:

• Full compliance Test Approval • Ship Test approval • PP Report Approval, Eaton Sign-off Sheet, Crayola approved samples • Finalized Product Specs release to Supplier and Inspection • Running change cut-off quantity and conditions (if necessary)

2.11 First Inspection: Crayola QA will arrange for inspection of the first production run of product – as specified in paragraph III.C. earlier in this document. The disposition of any findings or failures will be provided by Crayola QA. Post-production samples, if required, will be selected and sent to Crayola QA in Easton for reference.

Flow of Product Development & Qualification


Rev. 1 (2/2014) 37

A6: Sample Submission for QA testing and evaluation

1.0 Scope All samples and documents submitted to Crayola Global QA, including regional buying offices with QA/PI resources, for review and evaluation for project QA requirements.

2.0 General Requirement of Sample Submission

2.1 All samples must be produced from materials and assembly processes representative of the development phase (see A4). For example, FEP samples should reflect final engineering design changes and PP samples should reflect manufacturability with production grade materials and processes.

2.2 Samples should be reviewed and in-house tested by Supplier (or 3rd party Lab if needed) prior to

submitting for Crayola testing. Samples must meet the following requirements: a) Sample quantity as required b) Sample material and construction representative of development phase c) Samples must be protected from shipping damage. 2.3 Samples submitted must be accompanied by a “PRODUCT EVALUATION AND TESTING REQUEST” form

(sample below) with a clear description of samples and reason for submission.

3.0 Sample size

3.1 A table of required sample quantities is attached at the end of this appendix. This table identifies the number of finished goods required for:

a) Preconditioning & reliability testing b) Full compliance testing by 3rd party laboratories in Crayola program c) Post Production evaluated by Crayola LLC (Easton, US) 3.2 If there are questions regarding the quantity of samples required, please contact Crayola QA.

4.0 Testing Charges

Crayola LLC will pay for compliance testing of our product conducted by a 3rd party testing lab if the product is submitted on behalf of Crayola. If re-testing is required due to a test failure that is the Supplier’s responsibility, the cost of that testing will be charged to the Supplier. In cases where a surcharge is incurred for expedited service, these charges may also be charged to the Supplier if the Supplier is responsible for the schedule delay.


Rev. 1 (2/2014) 38

5.0 Declaration of Conformity In rare occasions, vendor supplier maybe asked to submit Declarations of Conformity as support for on-production line approval such as over-labeling for packaging rework. Supplier will be asked to provide sufficient testing sample quantity, relevant compliance data, certificates, reports, photos and possibly confirmation back-up samples to CHK, PDDL or Easton QA.

5.1 Sample Delivery Samples should be delivered to Crayola’s offices as specifically instructed:

Easton, PA (USA) Office Crayola LLC 1100 Church Lane Easton, PA 18044-0431, USA Tel: (610) 253 - 6272

Hallmark Hong Kong Office Hallmark Cards (HK) Ltd. 6/F., Harbourfront Landmark 11 Wan Hoi Street Hunghom, Kowloon, Hong Kong Tel: (852) 2309 9000

Hallmark Shenzhen Office HC (Shenzhen) Company Ltd. 7/F., China Nuclear Building Shennan Zhong Road Futian District, Shenzhen, PRC, China PC 518031 Tel: (86) 755 8251 9000

Crayola Qingdao office HC (SZ) Company Ltd. QD Branch Room 2409, Sunshine Plaza, No.61 XiangGang Middle Road, Qingdao City, PRC PC:266071 Tel: （86）532 8909 2391

Binney & Smith (Europe) Ltd. Bedford Heights Manton Lane Bedford, UK MK41 7PH England +44 (0) 1234 363014

Premium Deluxe Design Limited Fideco Tower, Suite 1705, 17th Floor, 81-85 Ham Nghi Blvd., District 1 Ho Chi Minh City 700000, Vietnam T: +84 8 38215628


Rev. 1 (2/2014) 39

Date __________________________

Product Evaluation and Testing Request

Stock # _________________________ Vendor __________________________ P.O. #

Description

Specification # _____________________ Issue # _____________________ No. of Samples Submitted

Test Required – Verification ___________________ First Lot ____________________ Ship

Other _____________________ For Reference Purpose Note Below

Remarks

Signed ____________________________________


Rev. 1 (2/2014) 40

A7: Product and Packaging Traceability Control

1.0 Scope

The U.S. Consumer Product Safety Improvement Act requires manufacturers to have a tracking label or other distinguishing permanent mark on any consumer product primarily intended for children twelve and younger. In order to comply with this requirement, both the product and packaging must be marked with the tracking label. Crayola requires that all of our retail products comply with this requirement. As a result, some component suppliers will also be required to mark their products with a tracking label. Crayola will use our 5 digit alphanumeric date code format for all tracking labels.

2.0 Traceability System

2.0.1 Daily production batches and ingredients should be traceable back to the certified raw materials used in the final product produced or packed-out on specific dates, by means of “Date Code” through vendor supplier’s internal tracking system 2.0.2 Suppliers must have a process to ensure that high risk materials, such as surface coatings, writing inks, soft plastics, etc., used in Crayola products are in compliance with Crayola requirements. The process should include adequate manufacturing process controls and material testing (internal or 3rd party, when required).

3.0 Date Code Application

All products manufactured and shipped on behalf of Crayola must meet the following date code requirements. In any case where the requirements cannot be met, any discrepancy must be approved by Crayola Global QA prior to production.

3.1 Date code on carton.

3.1.1 Date codes shall be stamped with blue or black ink on at least one side panel of the carton near the bar code.

3.1.2 Date codes must not cover or interfere with any shipping mark. 3.1.3 Date codes shall reflect the actual manufacturing date, so a pre-printed date code on the carton is

not acceptable. 3.1.4 Date codes must be legible from a distance of 5 feet and letters should be approx. 1” (25mm) high 3.1.5 The date code consists of 5 alphanumeric characters as shown in the Crayola Product Date Code

Procedure shown below.

3.2 Date code on retail package.

3.2.1 Date code shall be cold punched, laser printed, or ink-jet printed on the package near the UPC code. 3.2.2 Date code must not cover or interfere with any package graphics. 3.2.3 Date code shall reflect the actual manufacturing date, so a pre-printed date code on carton is not

acceptable. 3.2.4 Date code must be legible from a distance of 12” and letters should be approx. 3mm high. 3.2.5 The date code consists of 5 alphanumeric characters as shown below.


Rev. 1 (2/2014) 41

3.3 Date code on product 3.3.1 The main part or critical part of a product must carry a date code. Date code shall be cold punched,

ink-jet printed, or stamped on the product. 3.3.2 The date code shall be visible without destroying the product, but it shall not affect the overall

aesthetics of the product. If necessary, consult Crayola PE/QE for the location. a) For a main part with sewn-in-label, the date code shall be stamped or ink-jet printed on the

sewn-in-label. The date code must not be smeared when being rubbed. b) For molded parts, the date code shall be cold punched or ink-jet printed on the parts. c) For electronic products, the date code shall be near the battery door, but not on the battery

door. d) For Crayon and Marker sets, the date code must be either on retail package directly or on

printed insert cards if clear pouch package is used. Individual suppliers may choose to apply date code on each stick for better traceability control.

e) Date code must be printed or stamped on main or critical component. It is generally not acceptable to place date codes on disposable packaging such as shrink film.

3.4 Process Identification

A sixth alpha-numeric digit maybe added for significant identification, such as a specific production line, ink color, or product revision running change etc.

3.5 Manufacturer’s Code

The 3rd digit of the Date Code is the Manufacturer’s Code which is used to identify specific manufacturer who produced the encased product. All Crayola suppliers must follow the Crayola assigned code. Crayola will assign a Manufacturer’s Code to you. If you do not know your Manufacturer’s Code, please contact Crayola Global QA.

4.0 Bar Code Application

4.1 Barcode information approved and released by Crayola are required on retail package blister card and shipping carton.

4.2 In the cases where printed barcode on shipping carton Kraft paper material is not read-able by Crayola approved barcode scanner which may result in shipment reject, white stock sticker label must be used for improved barcode over labeling on shipping carton and must cover all four sides of the impacted carton.

5.0 Records and Audits

5.1 All direct suppliers are subject to process audit by Crayola QA or a 3rd party lab designated by Crayola any time before and/or during production. Where specific concerns exist, Crayola may also conduct process audits or a record review to ensure that Crayola date code and traceability requirements are being met.

5.2 Records for process audit include materials, WIP, finished goods and packaging batches, test gauges and equipment calibration (conducted by qualified party and verified by direct vendor QA). All records must be kept per section II. G. Record Retention in the Crayola Global Supply Chain Quality Requirements (this document).


Rev. 1 (2/2014) 42

A.7A Crayola Product Date Code Procedure

1.0 Scope

All products purchased, manufactured and sourced by Crayola LLC (All locations).

2.0 Purpose

To provide a uniform system of date coding for globally produced products that conform to all current regulatory requirements.

3.0 Objective

To facilitate the identification and segregation of discrepant product located within or outside of Crayola LLC control for quality, regulatory, and safety reasons either within a shipping location or in the field. As a secondary objective, date coding will facilitate warehouse inventory rotation.

4.0 Responsibility

Coding of products in accordance with this policy is the responsibility of the manufacturer of the product.

5.0 General

Product sell unit (retail package) date coding is mandatory for all products manufactured or purchased by Crayola LLC. A five digit alphanumeric system, or other system as approved by Crayola LLC Corporate Quality, will be utilized, as outlined in Section .6.2, Table II. Additionally, product case (shipping container) coding is mandatory for all products manufactured or purchased by Crayola LLC. A five digit alphanumeric system will be utilized, as outlined in Section .6.2, Table I.

6.0 Coding Requirements

Sell unit (retail package) and case (shipping container) date coding will contain a minimum of five (5) alphanumeric characters as demonstrated in Table I below. Additional digits (i.e. time, shift, etc.,) may be added at the end of this sequence at the discretion of the manufacturing location.


Rev. 1 (2/2014) 43

Date coding will utilize the following five position sequencing:

Table I

A 4 E 0 2

Month Year Manufacturing Facility Day or date

(Above example signifies product manufactured January 02, 2014, in Easton)

5 Digit (XXXXX) Dating Sequence for Production Facilities

X X X X X

Alpha-Month Numerical-Year

Alpha-Production Facility

Day of Month

A = January 2 = 2012 Production facility letter * 0 1

B = February 3 = 2013 0 2

C = March 4 = 2014 0 3

D = April 5 = 2015 0 4

E = May 6 = 2016 0 5

F = June 7 = 2017 0 6

G = July 8 = 2018 0 7

H = August 9 = 2019 0 8

J = September 10 = 2020 0 9

K = October 11 = 2021 1 0

L = November 12 = 2022 1 1

M = December 13 = 2023 1 2

Etc. Etc. Etc.

* Identified in Crayola LLC Corporate Procedure 2.5.8 Production Facility Date Code Matrix


Rev. 1 (2/2014) 44

7.0 Primary Package Date Code Location Guidelines

Sell Units (Retail Packages)

A date code shall be placed on all Crayola LLC sell units (retail packages) and its components, where practicable. When deciding where to place the date code on a retail package or component, the following options must be considered in order of preference, with number 1 is the most preferred and number 3 being the least preferred. However, all locations (1-3) are acceptable.

1. Bottom of package as positioned on shelf or peg. 2. Back of package as positioned on shelf or peg. 3. Left or right side of package as positioned on shelf or peg. Note: A date code shall not be placed on the main graphics panel unless there is no other attainable alternative. In no circumstance can a date code cover the brand identity (the Crayola logo). In the event that additional labor and technology are required due to product composition, QA will determine if date coding on the primary product package will be allowed to meet regulatory requirements.

8.0 Case (Shipping Container) Date Code Location Guidelines

A date code shall be placed on all Crayola LLC cases (shipping containers). The date code is to follow, at minimum, the same 5-digit alphanumeric format identified in section .6 above. Placement of date code must conform to the following guidelines:

1. Without exception, location of the date code stamp should be on the longest side panel of the shipping case. 2. Date code font size is to be 1 inch (25 mm) or readable at 3 feet (1 meter). 3. Date code placement may not over-write other text or graphics. 4. Date code placement may not cover the Crayola LLC logo.

9.0 Production Facility Coding System

A production facility date code matrix will be maintained by Corporate Quality Assurance in the Crayola LLC - Corporate Procedure 2.5.8 - Production Facility Date Code Matrix, Table 1, visible to Crayola LLC employees only, for identification of alpha code to manufacturing facility. Duplication of production facility alpha codes is acceptable, since product manufacturing location will be distinguishable by product type.

Date code placement on individual product sticks or components, when mechanically available, will follow the format used in Crayola LLC - Corporate Procedure 2.5.8 - Production Facility Date Code Matrix, Table 2.


Rev. 1 (2/2014) 45

A8: Electronic and Electrical Products QA requirements

1.0 Scope

Crayola electronic and electrical product suppliers and component manufacturers should work closely with Crayola to produce safe and lead-free product and meet emerging legislation and requirements on chemicals control in the US and international markets.

2.0 General Requirements

2.1 Products, materials and components must meet US and international Safety and Regulatory standards and those outlined in Appendix 2 of this document. Only RoHS compliant and lead-free materials can be used in Crayola products. Plastic resins, pigments, electronic components, coated wires, solder, PCB printed circuit boards and accessories must be from qualified suppliers with test certificates and SDS(s), as applicable.

2.2 EU Required warnings for electrical and electronic products: 2.2.1 The following items must be included on the product for products distributed in the EU:

• A “wheelie bin” to inform the consumer that the product cannot be disposed of in household waste.

• A “date made” • Product code number • Crayola logo/trademark • CE mark

2.2.2 The EU required warnings for product packaging are included in a graphic at the end of this appendix.

2.3 Supplier purchase orders for components and materials to be used in any electrical or electronic product must include detailed specifications and requirements. BOM/BOS must be provided. Suppliers should work closely with Crayola and component suppliers to provide advanced notification of lead-free material transition, material obsolescence, specification changes, product identification changes, product marking changes and package label changes.

2.4 All materials must be stored, handled and manufactured under isolate and RoHS compliant equipment and

facilities, not to be mixed up with potentially contaminated ingredients for other customers. Electronic and electrical products must be kept dry and dust free.

2.5 Products that are classified as electrical or electronic toys are subject to applicable standards and require

early safety design review, labeling input and engineering to minimize foreseeable risks: • Electrical Hazards (e.g. electric shock) • Thermal Hazards (e.g. high temperature, overheating) • Photochemical Hazards (e.g. LED / Laser strength) • Noise Level Hazards (e.g. close to ear toys for young children)

2.6 Electronic products are normally powered by battery cells. However different battery brands may vary slightly in sizes and voltages. Products should be tested using battery types from the destined country of distribution during development.


Rev. 1 (2/2014) 46

2.7 Batteries or products containing batteries must meet the requirements of Battery and Accumulator Directives (2006/66/EC).

2.8 All battery compartments must require a screwdriver (or other tool) for access.

2.8.1 Prohibitions

• All batteries or accumulators, whether or not incorporated into appliances, that contain more than 0.0005% mercury by weight.

• Portable batteries or accumulators, including those incorporated into appliances that contain more than 0.002% of cadmium by weight. This prohibition would not apply to emergency and alarm systems, including emergency lighting, medical equipment, or cordless power tools.

2.8.2 Marking requirement of batteries and accumulators under 2006/66/EC

Refer to the following size requirements: • Cylindrical cells: 1.5% of surface area (Maximum 5 x 5 cm) • Other battery types: 3% of the surface area on the largest side (Maximum 5 x5 cm) • When the size of the battery, accumulated or battery pack is such that the symbol would be

smaller than <0.5 x 0.5 cm, a symbol at least 1 x 1 cm shall be printed on the packaging. For the product containing battery, the above marking shall also present on the package and instruction sheet, adjacent to the WEEE logo

2.9 UL Requirements

2.9.1 AC powered electrical products should meet UL certification, which require that the producing

manufacturer is equipped with proper testing equipment and procedures, as well as UL certified production line audit.

2.9.2 All products with electrical components must be UL listed or must be made up of UL components.

Inquire supplier’s program for safety testing of electrical components. 2.9.3 UL certification program does not cover Toy Safety standards such as ASTM or CCPSA, therefore

product should be submitted for Toy standards compliance testing separately.


Rev. 1 (2/2014) 47

A9: Cut and Sewn Products QA requirements

1.0 Scope These requirements are applicable to all Crayola brand plush, stuffing and sewn-up toy products for children of all ages.

2.0 Crayola Safety, Quality and Inspection Specifications

Product must meet: • Crayola Product Design Specifications • Safety and Quality Specifications by Crayola LLC • Product and material safety and regulatory requirements • Crayola Global Design & Engineering Guidance for Children Under 3 (as outlined in Appendix 2 (A2) of this

document) • Crayola product specifications • QA Test Specifications, Inspection Sampling plans • Acceptance Criteria as approved by Crayola

3.0 Marking

3.1 The product must have a sewn-in label to indicate below information:

3.1.1 For USA market • Pennsylvania PA registration number • “All new material” • Country of origin • Company name and address (optional)

Example: ALL NEW MATERIAL (List of materials) Reg. No. _____________ Made in _____________

3.1.2 For Canada market • See specific Canadian requirements for labeling of cut/sewn textile items below.

3.2 Sewn-in seam labels must be fabric. Sewn-in seam labels on plush and soft toys must not be looped. Sewn-

in seam labels must not release during abuse testing.


Rev. 1 (2/2014) 48

4.0 Design Requirements

4.1 Product construction must consider double-retention design to avoid any hazard of small parts, sharp points and/or sharp edges after foreseeable use and abuse.

4.2 Products with stuffing materials composed of small parts (e.g. plastic pellets, foam pellets) must be sewn

into an inner bag. 4.3 Product must meet requirements as per signed Design Approval (D.A.) sample. 4.4 All seams must have sufficient seam allowance to meet pull test requirement.

5.0 Process Control

5.1 Raw materials in-coming control 5.1.1 Vendor must have quality procedure ensuring all in-coming materials meet Crayola’s requirements as

per signed sample.

5.1.2 All stuffing material must meet applicable Crayola requirements, and must be new and free of foreign objects such as insects, bird feathers, rodents or other animal infestation, metal scraps, wood splinters, plastic, glass, nails, needles, etc.

5.1.3 Each separate and individual roll of fabric or soft plastic material for each delivery must be sampled for

heavy metals and phthalate content testing by 3rd party testing or in-house XRF or HDXRF scanning.

5.2 Assembly-line control 5.2.1 Any sharp tools should be controlled for each process including die-cut, sewing, assembly and final

pack out. 5.2.2 Subassemblies involving cut-and-sew process and cut-and-sewn finished goods must be scanned by

certified metal detector before final pack out. 5.2.3 All metal detectors should be calibrated (with record) by technician periodically and

verified/challenged at least every shift.

6.0 Records and Audits

6.1 All direct vendors are subject to process audit by designated 3rd party audit firm or Crayola QA any time

before and/or during production. Direct vendors are responsible for ensuring subcontractor processes comply with all Crayola requirements and must have confirmatory documentation available for review by Crayola or designated 3rd party auditing firm.

6.2 Audit review records must be retained, including scheduled in-house test gauge and equipment calibration

conducted by a qualified party. All records must be kept for at least 3 years.


Rev. 1 (2/2014) 49

Crayola STUFFED TOY TAG Example

center line, or fold if printing front & reverse

OR Print Front & Reverse on minimum label size of 1 ¼” x 7/8”

©2014 CRAYOLA®

Mfd. for:

Crayola LLC

Easton, PA 18044-0431

Made in China

REG. NO. PA-XXXXX (CN)

Note 1: Minimum tag size does not include seam allowance.

Note 2: All printing in black ink on Tyvek, Valeron, white vellum cloth or a material of comparable quality, which shall not flake out when abraded.

Note 3: Supplier strips in:

A. Copyright Owner B. Distributor I.D. C. Country of origin D. REG. NO. (PA #) E. Stock # F. Contents. State “All new

materials” and then list: 1) Type of filler material (ex.

Polyester Fibers) 2) Plastic Pellets must be listed

as: a.) PP Plastic Pellets; or b.) PE Plastic Pellets; or c.) PVC Plastic Pellets

3) Internal stiffeners must be listed (ex. “plastic coated wire stiffener”)

4) Linings and padding are considered filler materials and must be listed; ex. “paper lining”, “foam lining”, “PU foam padding”.

5) Electronic or mechanical devices, noisemakers or rattles are not listed.

G. Care instructions.

2 5/8”

7/8”


Rev. 1 (2/2014) 50

CANADIAN CUT & SEWN OR STUFFED ARTICLE

LABELLING REQUIREMENTS

The following additional requirements apply to Cut & Sewn items produced for Canada:

1) All required labels MUST be bilingual

2) All textiles must have the CA #: XXXXX listed on the product. It may my listed on the stuffed article label, textile label, care instructions label, and/or the hangtag. We prefer to have it listed on the stuffed article label, textile label or care instructions label.

3) Those items that are NOT stuffed require a textile label.

Here is an example:

75% Rayon/Rayoune

21% Polyester

4% Other fibre/Autre Fibre

Product of XXXX

CA XXXX

4) Wash care instruction can be listed in symbols or written words, or both. This is not mandatory, but if written words are use they must be in both English and French

5) Any item that is partially or fully stuffed requires a stuffed article label, please cross-reference your item with the labels below: Stuffed article registration is required for the Provinces of Ontario, Manitoba and Quebec.


Rev. 1 (2/2014) 51

Prescribed Format for Furniture & Bedding: (Form 1)

6.4cm

Not to be removed until Delivered to the consumer

Ne pas enlever avant la

Livraison au consommateur

This article contains NEW MATERIAL

ONLY Cet article contient des

MATÉRIAUX NEUFS SEULEMENT

This label is affixed in compliance

with Provincial Law

Cette étiquette est apposée conformément à la loi de la province

Made by Fabriqué par

reg. no. No. de permis: xxxx-xxxx

Content Contenu

Polyethelene Foam / Mousse de Polyéthylène

Federal Requirement / Exigence Fédérale Outer Covering / Revêtement Extérieur

100% Polyester Loblaws Inc., Montreal H4N 3L4

Toronto M4T 2S8, Calgary T2E 7S9 Canada, 1-888-495-5111

CA #15372 MADE IN xxxx/ FABRIQUÉ EN xxxx

MINIMUM SIZE DOES NOT INCLUDE SEWING EDGES AND CONTENTS

NOTE:

Labels must be made of a white durable fabric or synthetic material (not paper) and printed in black ink only. Labels must be securely affixed to the article in a conspicuous area.


Rev. 1 (2/2014) 52

Prescribed Format for Clothing and Miscellaneous Items (Form 2):

Enlarged for viewing text only

Not to be removed until delivered to the consumer

Ne pas enlever avant la livraison au consommateur

This label is affixed in compliance with Provincial law

Cette étiquette est apposée conformément à la loi de la province

This article contains NEW MATERIAL ONLY

Cet article contient des MATÉRIAUX NEUFS SEULEMENT

Made by reg. no. Fabriqué par No. de permis: CONTENT CONTENU

Actual Size

Prescribed Format for Toys & Smaller Items

Not to scale

7 CM Not to be removed until

Delivered to the consumer

Ne pas enlever avant la livraison

au consommateur

This label is affixed in compliance

with Provincial law

Cette étiquette est apposée

conformément à la loi de la province

This article contains

NEW MATERIAL ONLY

Cet article contient des

MATÉRIAUX NEUFS SEULEMENT

Made by reg. no. Fabriqué par No. de permis:

CONTENT CONTENU

MINIMUM SIZE DOES NOT INCLUDE SEWING EDGES AND CONTENTS

2.5 CM

5.5 CM NEW MATERIAL ONLY

REG. NO. CONTENT

MATÉRIAUX NEUFS SEULEMENT NO. DE PERMIS:

CONTENU

1.3 CM


Rev. 1 (2/2014) 53

A10: Wood and Paper requirements

Crayola sustainable paper and wood policy

1.0 GENERAL STATEMENT

Crayola believes it is especially important to ensure today’s children have a healthy environment for their creative tomorrows. This holds true as it relates to the paper and wood fiber that we use in our Crayola products. Within our sourcing and production processes, we make choices consistent with this policy that help ensure our natural resources are well-managed, are protected, and will be available for future generations.

2.0 OUR POLICY

Crayola’s goal is to obtain 100% of its paper and wood fiber from known sources that promote responsible forestry management practices and to increase its use of fiber coming from sources with preferred environmental impacts.

3.0 SCOPE

This policy applies to all paper and wood fiber in product, packaging, and advertising materials made by or for Crayola.

4.0 SUPPLIER REQUIREMENTS

Crayola suppliers are required to maintain documentation identifying the source of all paper and wood/wood fiber components used in any product produced for Crayola. This documentation must include the provenance of the pulp used in paper production as well as details of the wood source (where grown, species, etc.) supplying the pulp mill. This information must be available to Crayola upon request.

5.0 PREFERRED ENVIRONMENTAL IMPACTS

Crayola is committed to increasing the use of paper and wood fiber that comes from sources demonstrating preferred practices of environmental impact and responsible forestry. Paper with preferred environmental impacts includes paper made with recycled fiber and fiber from chain-of-custody certified sources.

6.0 RESPONSIBLE FORESTRY MANAGEMENT

Crayola considers a number of factors in determining whether paper and wood fiber is produced using practices that encourage responsible forestry management. We determine whether the physical source of the timber is acceptable and whether the source is well-managed. Crayola will verify the source of the timber used to make the fiber, using tools such as Chain of Custody certification, site inspections, review of certification status, third party audits, questionnaires, interviews and documentation reviews.


Rev. 1 (2/2014) 54

7.0 UNACCEPTABLE SOURCES

The following unacceptable sources are not permitted in Crayola products or packaging: • The timber was harvested or traded in violation or circumvention of international laws, or the laws of the

relevant country, state or province. • The timber originates from high conservation value forests as identified by credible scientific sources, except

where the forest is certified under a credible certification system that ensures the high values are maintained. This includes timber or wood fiber sourced from Indonesia.

• The timber is “conflict timber” – timber whose trade drives violent armed conflict. • The timber was harvested or traded in a manner that violates internationally recognized human rights or

Crayola’s Code of Conduct standards. • The timber contains or was grown using genetically modified material. • The source of the timber is unknown.

8.0 WELL-MANAGED SOURCES We expect our paper and wood product suppliers to use sustainable practices in the management of forest resources and in the production of paper and wood fiber products such as:

• Maintenance and conservation of biological diversity • Protection of soil quality, riparian zones and water quality • Adherence to sustainable harvest levels • Protection of endangered species • Prompt reforestation • Recognition of an protection of the rights of indigenous peoples • Minimization of chemical use in forestry management • Elemental Chlorine Free (ECF) paper production

9.0 WASTE MANAGEMENT

Crayola strives to recycle paper waste generated during production of its products and through its corporate activities. Crayola continues to explore ways to reduce the amount of paper and paperboard used in its packaging.


Rev. 1 (2/2014) 55

A11: Raw Materials Supplied to Crayola Manufacturing

1.0 Scope

This appendix applies to all raw materials supplied to Crayola manufacturing facilities. 2.0 Overview

Raw materials will be procured from qualified suppliers who have demonstrated the capability to deliver materials in conformance to Crayola manufacturing design criteria and specifications. Raw material suppliers will be rated on their management systems to assure product quality and their demonstrated incoming material quality performance.

3.0 Raw Material Safety Contaminant Testing

All raw material suppliers are required to ensure their products meet Crayola’s standards for all potential safety contaminants identified in Crayola’s raw material specifications and utilized at Crayola manufacturing facilities. This testing, at a minimum, will be conducted on a yearly basis and shall be available upon request from Crayola.

4.0 Alternative Raw Material Sources The supplier must have a process in place to ensure that Crayola raw material specifications are accurately communicated to the suppliers’ sources of materials and components.

The supplier must have a process to qualify raw materials and components to ensure that using alternate sources of supply does not compromise the quality, safety, or integrity of the product.

A supplier must notify and await written approval from Crayola prior to utilizing and implementing an alternative raw material composition, source location, and/or process.

5.0 Process Control Suppliers must have a documented method of controlling production from sourcing of raw material components through shipment of finished raw material. Process control methods must be adequate to ensure compliance to all applicable safety, legal, and product quality requirements. The supplier’s system of process control must be documented, controlled and audited by trained personnel. Significant process changes are not permitted unless prior written approval is obtained from Crayola.

6.0 Quality Assurance The supplier will have a system in place to effectively ensure that all materials and components used to create raw materials for Crayola meet all supplier and Crayola requirements for that material. It is never acceptable to ship defective raw material to Crayola without prior authorization from the Crayola QA team. In the event that Crayola authorizes a supplier to ship a raw material that does not comply with all Crayola specifications, that authorization will be provided on a Temporary Deviation Notice authorized by Crayola Global Quality Assurance.

7.0 Defective Raw Material

Supplier factories will have an effective system and controls to segregate defective raw material from acceptable material and prevent shipment to Crayola.


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8.0 Corrective Action

If a raw material received by Crayola is determined to fall outside the specification, an electronic Corrective Action shall be issued to the supplier via our Material Discrepancy Form. The supplier is required to investigate the reported defective raw material and submit a root cause and corrective action within 30 Days that permanently resolves the reported issue.


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A12: Contract Manufacturing

QUALITY CONTROL PROGRAM - SUBCONTRACTORS AND CONTRACT PACKAGING SUPPLIERS

1.0 SCOPE This document applies to all organizations with which Crayola LLC contracts to assemble and package raw materials and work-in-process.

2.0 PURPOSE An outline is given of the quality expectations by Crayola LLC of finished products assembled by contract packagers and co-packers. This document acts as a guide for contract packagers and as a basis to which contracted product must conform.

3.0 PROCEDURE 1. Crayola LLC Quality Manual - Subcontractors and Contract Packers are responsible for compliance to the

applicable provisions of the Crayola LLC Quality Manual, as updated. Specific requirements in the Quality Manual relative to manufactured product assembly, inspection, identification and control must be maintained and are the responsibility of the subcontractor or co-packer.

2. Product Date Code – Product must comply with Crayola LLC Date Code Policy 2.5.6 (see Appendix 4 of this document) for product, primary package and shipping case date code placement and format. All product and packaging must comply with the most recent update of this policy.

3. Supplier Code of Conduct – Subcontractors and Co-Packers must comply with Crayola LLC Supplier Code of Conduct Policy (see Appendix 1). Crayola LLC sourcing and procurement standards are consistent with our corporate beliefs and values. We view suppliers and their subcontractors as an integral element of our business success and strive to select suppliers who adopt strong ethical standards, conduct their respective operations in a manner that respects the rights of the individuals they employ, provide a safe workplace that meets all regulatory compliance requirements, and demonstrate careful stewardship of the environment. All suppliers and subcontractors are responsible to comply with the most recent update of this policy.

4. Product Specifications – It is the responsibility of the supplier to have copies of and conform to requirements of the particular product specifications associated with the item they are producing.

5. Sampling Plan - Crayola LLC will utilize ANSI/ASQ Z1.4, "Sampling Procedures and Tables for Inspection by Attributes" for inspection and acceptance of material as identified in the product specification. Information on ANSI/ASQ Z1.4 can be obtained at www.asq.org.

6. Classification of Defects - The definitions of defect types and the examples shown are not a comprehensive list and products may be inspected for further parameters and defects that are not listed.

Critical Defects -- AQL= 0. Any defect related to the safety of the product. All products MUST COMPLY. Examples would include drop test failures which liberate small parts in product for children under 3, failure to comply with CPSIA standards, etc. Major Functional Defects -- AQL=0.4 Any defect that causes the product not to function as intended. Examples would include dry markers, broken crayons, motors that don't function, etc. Major Visual Defects -- AQL=1.5 Any defect which seriously affects the item's appearance or produces significant final assembly problems (component or WIP). Examples would include incorrect assortments, significant printing issues on package, etc. Minor Defects -- AQL= 4.0 Any defect which moderately detracts from the final product appearance, limits functionality, or causes slight production problems (component or WIP). Examples would include small voids in crayon points, minor blemishes on marker barrels or packaging, etc.

http://www.asq.org/


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7. Discrepant Product – Any material that is found not to conform to the product specifications through assessment as identified in step 6 above, will be placed on material hold and returned to the supplier through the Material Discrepancy process. A Corrective Action Request will be initiated to the supplier with the requirement that it is completed in full to identify actions that will be implemented to prevent the defect from occurring on subsequent shipments. All applicable charges will be assessed to the supplier for material, transit and storage of said defective material.


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A13: Direct Import shipments of finished goods Crayola products are sold to many major global retailers, who sometimes distribute our product into multiple global markets. With increasing frequency, our retailer partners are requesting us to provide some of our product to them through Direct Import (D.I.) programs to capitalize on economies and efficiencies in their logistics networks. As our customers implement these programs, they have also instituted their own factory, product and purchase order evaluation programs. Our Retailer partners’ DI programs are different, so it is not possible to provide a single reference of these requirements and keep it current. The following General QA Requirements are provided only as guidelines, individual DI program specifications will be available separately through Crayola Global QA, and will only be added into this manual as and when appropriate. It is expected that compliance with the Crayola Global Supply Chain Quality Requirements contained in this document will facilitate compliance with the Direct Import program requirements of our major retailer partners. Crayola strives to minimize supplier factory audit fatigue by offering information transparency.

1.0 D.I. Order General QA Requirements

1.0.1 Factory Audits

Facility Security Audit: Some DI customers require a facility security audit be conducted. Crayola will provide on-site factory assistance prior to the audit. The assistance can include a questionnaire, gap analysis audit, and CAPA coaching. Code of Conduct: Factories that will ship product directly to our customers must comply with the Ethical Standards and Integrity requirements contained in this document. ICTI certification typically satisfies retailer DI requirements. Some DI Customers maintain their own Code of Conduct Program audited by their own audit team. Whenever possible, Crayola will advocate that conformance to our supplier code of conduct is sufficient to demonstrate compliance to the retailer’s program. Crayola will share the ethical standards audit report of our factories with our customers, when those factories are involved in direct import programs with the customer. In all cases, our retailer partners retain the right to require that factories be audited under their ethical standards program. Factory Quality/Technical Audit: Some DI customers have their own supplier technical/quality assessment. Crayola will advocate that our supplier GSC-QMS audit is sufficient however the customer decision on acceptance of Crayola audits is final.

1.0.2 Sample Testing Requirements

It is reasonable to expect that product which will be shipped through a Direct Import program will be tested for compliance to all applicable product safety requirements for the market(s) in which that product will be distributed. Crayola’s DI customers generally direct the use of a specific approved laboratory. Pre-Production: Some Direct Import customers require the Supplier to provide samples for a pre-production review. This review may be to identify appropriate testing required or for other reasons deemed necessary by the customer. Production: Some Retailer Customers have additional requirements beyond US regulations and Crayola. Production samples may be collected by 3rd party lab from production line at specific percentages of production completion for compliance testing.


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Samples must be in-house tested by vendor (or 3rd party Lab if needed) prior to Retailer program sampling. Any failure in production testing will likely result in missing the required shipping window and could result in order cancellation. Any retesting, if authorized by Crayola or our customer, will be charged to the vendor. The sample sizes of various DI testing program may vary from 2 sets to 12 sets. See Appendix 6 (A6.1) for further information on sample size requirements.

1.0.3 Package labeling requirements

Some Retailers require warnings or labeling details that are not normally required by Crayola or regulations in the market of distribution. These requirements would be identified in a pre-production review and will be incorporated into product package graphics as required.

1.0.4 Retailer Certificate of Conformity

Retailer programs can include requirements that are more stringent than existing regulatory standards. When this is the case, these requirements will be specified in the retailer’s product testing protocol. Certain retailer programs require that suppliers hold a valid Certificate of Compliance, issued by a 3rd party lab, which attests that the product has successfully passed production testing. Suppliers should take note of Certificate validity and prepare to re-apply in advance of expiration.

1.0.5 CPSIA General Certificate of Conformity (GCC)

The US Consumer Product Safety Improvement Act requires that all products being shipped into the US be accompanied by a General Certificate of Conformity. Often this document will be prepared by the 3rd party testing lab directed by our Retailer partner. When 3rd party GCCs are not required, Crayola will issue the GCC document.

1.0.6 Shipping Window

All DI orders are under tight timeframe with limitations in areas of order confirmation, flawless production execution, test certificate validity and designated shipping window, without any exceptions.


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A14: Distributor requirements – including local market compliance

1.0 Scope This appendix applies to distributor partners who represent Crayola and manage product sales in those markets where Crayola does not have a local sales force.

2.0 Local market compliance

The distributor must ensure that all Crayola products distributed by them comply with local market requirements. In general, this will include communicating local market requirements to Crayola, verifying that any required testing and/or facility auditing has been performed, and ensuring that product packaging meets local regulatory requirements.

3.0 Compliance to Crayola ethical standards

International distributors of Crayola product must comply with the Ethical Standards and Integrity requirements contained in this document.

4.0 Compliance to Licensing contract requirements

Crayola LLC maintains content licensing agreements with other global brands and properties (licensors). Crayola’s licensors may require us to obtain global or market specific authorizations for products or manufacturing facilities.

5.0 Consumer complaint point of contact/data collection & communication

Distributors are expected to monitor consumer feedback in their local markets and provide prompt feedback to Global Quality Assurance regarding any issues consumers might experience with Crayola products. Crayola QA will investigate quality issues and partner with Consumer Affairs to provide direction on how to respond to consumers to maintain a positive impression of the Crayola brand. In the unlikely event a consumer experiences a personal injury or makes a liability claim, Crayola must be notified immediately (in English) using the reporting tool on the next two pages. The Crayola employee managing the distributor is responsible for ensuring this is completed in a timely manner and will typically be the primary contact with Consumer Affairs.


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CONSUMER AFFAIRS PRODUCT LIABILITY/PERSONAL INJURY ALERT PROCEDURE

OBJECTIVE: Consistently report all product liability and personal injury contacts to US Crayola Consumer Affairs to maintain a complete and accurate record of claims for the company. RESPONSIBILITY: All international offices and distributor partners. ================================================================================== Procedure to notify Crayola Consumer Affairs of product liability/personal injury incidents:

1) International offices (originator) should complete the Product Liability/Personal Injury Alert form (next 2 pages) for the following incidents: • Any incident that involves a product liability. • Any incident that involves personal injury. • Any incident that involves cessation of breath (including choking event where cessation of breath

has occurred). • Foreign object incidents that involve liability or injury. • Allergic reaction incidents that require medical attention. • Follow-up information received from a previously reported product liability or personal injury

incident. 2) Originator will email the completed form to Manager, Consumer Affairs at [email protected]. 3) Once the contact is reviewed, the Manager, Consumer Affairs will forward the document to the

Consumer Affairs Claims Representative for entering into the Consumer Response System. 4) Once the contact is recorded in the Consumer Response System, the claims’ representative will

complete the “FOR CONSUMER AFFAIRS USE ONLY” section of the form indicating:

• The reference number. • The date the information was entered into the Consumer Response System. • The claims representative’s name. • The date this form was emailed back to the originator.

5) The Claims Representative will email this form to the originator for their records.


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CONSUMER AFFAIRS

PRODUCT LIABILITY/PERSONAL INJURY ALERT If follow up to a previous contact, please provide original reference number: _________________________________ DATE: ______________________ COMPANY REPRESENTATIVE: __________________________________ COUNTRY: MEXICO AUSTRALIA UK EUROPE U.S. OR CANADA CONSUMER’S NAME: __________________________________________________________________________ CONSUMER’S ADDRESS: _______________________________________________________________________ CITY: _________________________________ STATE: ______________________________________________ ZIP/POSTAL CODE: __________________ TELEPHONE NUMBER: ____________________________________ WHO WAS USING THE PRODUCT(S): ( ) Adult ( ) Child Name: ____________________________ Age: _____ PRODUCT NAME: ____________________________________ PRODUCT #: _____________________________ PRODUCT COLOR: __________________________________ DATE CODE: _____________________________ EXPLAIN HOW THE PROBLEM OCCURRED (i.e. shaking the marker): EXPLAIN WHAT WAS DONE PRIOR TO CONTACTING THE COMPANY: (i.e. was prewashed used, doctor contacted): LIST DAMAGED ITEMS/SURFACES: _______________________________________________________________ ORIGINAL COST OF DAMAGED ITEMS: ____________________________________________________________ AGE OF DAMAGED ITEMS: ______________________________________________________________________ REIMBURSEMENT REQUESTED: ( ) Yes $: _________________________ ( ) No

Page 1 of 2


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COMPLETE THIS SECTION ONLY IF INJURY OCCURRED:

INJURED PARTY: ( ) Adult ( ) Child Name: __________________________________ Age (Child Only): ______ WAS THERE CESSATION OF BREATH? IF YES, FOR HOW LONG? _____________________________________ WHAT TYPE OF MEDICAL ATTENTION WAS REQUIRED? _____________________________________________ EXPLAIN CONDITION OF INJURED TODAY: Physician Contact Info: ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ Phone: _______________________ Fax: ________________________ Email: ______________________________________________________ IS FOLLOW-UP TO PHYSICIAN REQUIRED? ( ) Yes ( ) No

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

E-MAIL completed form and supporting documentation (scans of bills, receipts,

medical reports, pictures, etc. ) TO: [email protected]

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

FOR CONSUMER AFFAIRS USE ONLY:

Reference #: _______________________ Date entered: ______________________________ Representative: _____________________ Date emailed to originator: ____________________

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Page 2 of 2

mailto:[email protected]


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A15: U.S. Consumer Product Safety Improvement Act (CPSIA)

The United States Consumer Products Safety Commission’s Product Compliance and Testing Certification (“15 month”) Rule became effective February 2013. Crayola requires all factories maintain the following documentation and processes in order to satisfy the rule and ensure their quality management system consistently produces product in compliance with the CPSIA. The following requirements will provide a Reasonable Test Plan per the current CPSIA. 1.0 Production Test Plans:

Each factory must maintain Production Test Plans for each product manufactured for Crayola. When requested, factories must be able to provide Crayola with the Production Test Plan and supporting documentation in English within 24 hours. The factory is responsible for maintaining documentation supporting the Production Test Plan for 10 years after production of the product has stopped. A Production Test Plan must define in writing:

• Tests conducted or measurements taken; • Intervals or frequency which tests or measurements are taken; • Number of samples tested or measured; • Regulated attribute associated with the test or measurement;

The Production Test Plan must address each regulated attribute of the product; however functional attributes may be included as well. The Production Test Plan may include process-management techniques, such as control charts, statistical process control programs or failure modes and effects analyses (FMEAs); The Production Test plan must include an explanation describing how the techniques, tests, and/or measurements provide a high degree of assurance that the product complies with the applicable regulations. The following manufacturing materials and intervals should be included in the Production Test Plan: Supplier Qualification, Raw Material Testing, In-Process Testing, Finished Product Testing, and Periodic 3rd party Testing conducted by the factory. Production Test Plans must be reviewed to determine if any changes are needed when a material, process or design change occurs which could affect the attributes addressed in the Production Test Plan. The factory is responsible for reviewing and updating Production Test Plans periodically based on the materials and processes at the factory. Annual review is recommended.

2.0 Material Change Tracking

All changes in product design, manufacturing process, or sourcing of materials or component parts must be reported to Crayola. No change may be implemented prior to Crayola approval.


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3.0 Specifications Product specifications are provided by Crayola to the factory for each product. The specifications include Regulatory/Safety Information. Suppliers are responsible for producing product in conformance with specifications.

4.0 Certification Testing

The CPSIA requires certification testing for children’s products. Initial certification testing will be conducted by Crayola Product Safety or Quality Assurance during the product development process prior to distribution of each product.

5.0 Periodic Test Plan

Crayola will satisfy requirements of the Periodic Test Plan through annual recertification testing at a CPSC approved third party laboratories. Crayola Quality Assurance will work with regional quality teams and factories to execute the Periodic Test Plan.

6.0 Random Sampling:

Products used for testing to demonstrate compliance to the CPSIA must be random samples. Samples provided by the factory for this purpose must be representative of the production order.


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A16: Compliance with the EU Toy Safety Directive

1.0 Purpose

To provide guidelines for gathering relevant information required to provide compliance to the EU Toy Safety Directive 2009/48/EC and other applicable regulatory and voluntary standards

2.0 Scope

Products designed or intended (whether or not exclusively) for use in play by children under 14 years of age. Does not include;

• Christmas decorations • Detailed scale models for adult collectors • Sports equipment • Fireworks • Fashion jewelry etc.

3.0 Technical File requirements

Technical folder that must be retained by the manufacturer containing a specific list of documents for every product placed on the market.

• Must be maintained and kept for a minimum of 10 years after the last distribution of that product.

• File must be readily available to the regulatory authorities within 30 days of the request and in the language of the requesting authority, unless a shorter deadline is justified in the case of serious and immediate risk

• Failure to maintain and or provide access to file can result in fines and or even prosecution by the authorities (even if the product meets the regulations)

4.0 Product Marking and Documentation

4.1 Manufacturer’s & Product Name, Number and Photograph

Crayola products distributed in Europe must be permanently marked with “Binney & Smith (Europe) Ltd., Bedford Heights, Manton Lane, Bedford, MK41 7PH, England” and the product number.

In addition, the following must be included in the technical file:

• Product Name

• Product number

• Photograph of product

• Copy of Artwork

4.2 Test Reports

All relevant reports as applicable to the particular product and may include one or more of the following, and or others as deemed fit:

• EN 71 Stds. (Pts. 1 thru 12) – EU Product Standards. • BS 7272, Parts 1&2 – Marking and Writing Instruments • Phthalates (Annex XVII of EU Regulation 1907/2006 [REACH}


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• AZO Dyes (Annex XVII of EU.Regulation 1907/2006 [REACH} • Total Cadmium (Annex XVII of EU.Regulation 1907/2006 [REACH} • EN 62115 – Electrical Safety Of Toys • EN 60825-1 – LED & Laser Safety • Directive 2002/95/EC - RoHS Compliance • Directive 2002/96/EC – WEEE Compliance • Directive 2004/108/EC – EMC (EN 55014 Pts. 1 & 2) • Directive 2006/66/EEC – Batteries and Accumulators

4.3 REACH Compliance

REACH is the EU regulation on Registration, Evaluation, Authorization and Restriction of Chemicals (SVHC – Substances of Very High Concern) entered into force on 1st June 2007.

REACH aims to ensure a high level of protection of human health and the environment from the risks that can be posed by chemicals, the promotion of alternative test methods, and the free circulation of substances on the internal market and enhancing competitiveness and innovation.

REACH makes industry responsible for assessing and managing the risks posed by chemicals and providing appropriate safety information to their users. In parallel, the European Union can take additional measures on highly dangerous substances, where there is a need for complementing action at EU level.

4.4 Product Safety/Risk Review

This should include a complete analysis of the following properties of the product: • Physical • Mechanical • Electrical • Chemical • Flammability • Any other hazards that the product may present which could jeopardize the safety and health of the child when they are used as intended or in a “foreseeable” manner bearing in mind the behavior of children

4.5 Design Description

A detailed description of the design of the product and could include documents such as • Design drawings • Engineering Turnover documents • Assembly Specifications

4.6 Bill of Materials

A detailed list of components and materials in the product to include the component, the component material, and the material supplier. Material Safety Data Sheets will be provided for all component materials.


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4.7 Production Process Controls

A detailed description of the conformity assessment procedures followed by the manufacturer to ensure series production compliance and that all products are manufactured to the required standards: • Manufacturers name and address • ISO 9001 Certificate • Crayola Quality Management Systems Audit • Manufacturing Process Flowcharts

4.8 Transportation and Storage

• Who is responsible for transporting product in the region

• Address of places of storage of product in the region

4.9 Consumer Complaints

• Detailed logs of all consumer complaints

NOTE: Manufacturer must also take corrective actions and inform national authorities immediately if they have supplied a non-conforming product within the EU region.

4.10 EC Type examination (if applicable) - 93/42/CEE - ANNEX III

In the absence of a specified standard for the product, an EC Type examination certificate is required In order to demonstrate to the Notified Body how the product satisfies the Essential Health and Safety Requirements (EHSRs) of the Directive.

The documentation must allow an understanding of the design, the manufacture and the performances of the product and must contain the following items in particular:

• A general description of the type, including any variants planned • Design drawings, methods of manufacture envisaged, in particular as regards sterilization, and diagrams

of components, sub-assemblies, circuits, etc. • The descriptions and explanations necessary to understand the abovementioned drawings and diagrams

and the operation of the product, • A list of the standards referred to in Article 5 of the Directive, applied in full or in part, and descriptions

of the solutions adopted to meet the essential requirements if the standards referred to in Article 5 have not been applied in full

• The results of the design calculations, risk analysis, investigations, technical tests, etc. carried out

4.11 EC Declaration of Conformity

A Declaration of Conformity (DOC) is a declaration made by the manufacturer that the product in question is in conformity with the requirements of an EU Directive/s. It declares that they guarantee that each product sold is in conformity with the Directive(s) mentioned.

Basic requirements for DOC are as follows;

• Unique identification number • Name and address of manufacturer or authorized representative • Name of toy including a clear color image to enable the identification of the toy • “The “object of the declaration” is in conformity with relevant community harmonization legislation”


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• Reference to the relevant harmonized standards used, or reference to the specifications in relation to which conformity is declared

• “This declaration of conformity is issued under the sole responsibility of the manufacturer” • Company letterhead • Place and date of issue • Signed, for and on behalf of company (Name, Title incl.)

4.12 Batch Codes

As a pre-requisite to the generation of an EC Declaration, all finished goods suppliers of Crayola products that ship to the European market must fill out a Batch Code Form that includes the following information

• Vendor Name • PO number • Product SKU • Quantity • Batch/Date Code

4.12.1 This form is to be used only for products being shipped into the EU – i.e. France, Italy, UK etc. Products going to anywhere outside the EU, (e.g. USA) do not need to be recorded.

4.12.2 Completed forms must be submitted to the responsible Crayola QA office at least 1 week prior to each shipment.


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BATCH/DATE CODE REPORT FORM – Binney & Smith ( Europe) Ltd Email to [email protected] and [email protected] . Or FAX to: (610) 253-4814 & 44(0) 1234 358914 – before shipment Vendor Name PO Number Product Sku Quantity Batch /Date Code

Signed Date

SHEET MUST BE RETURNED BEFORE GOODS SHIPPED




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A17: Compliance with CCPSA

Crayola Suppliers must maintain compliance to standards established Health Canada and all other applicable regulations for selling products in Canada. The Canadian Consumers Product Act (CCPSA) S.C.2010, c 21 has been effective since June 20, 2011, replacing the Canadian Hazardous Product Act. The most updated legislations, section summaries and implementation timelines can be referenced on the following website, or contact Crayola Safety and Quality department managers. http://hc-sc.gc/ca/cps-spc/legislation

http://laws-lois.justice.gc.xa/eng/acts/C-1.68/index.html

Below are the regulations made under this act applicable to Crayola products:

1. Asbestos Products Regulations (SOR/2007-260) 2. Children’s Jewelry Regulations (SOR/2011-19) 3. Consumer Products Containing Lead (Contact with Mouth) Regulations (SOR/2010-273) 4. Glazed Ceramics and Glassware Regulations (SOR/98-176) 5. Phthalates Regulations (SOR/2010-298) 6. Science Education Sets Regulations (C.R.C., c. 934) 7. Surface Coating Materials Regulations (SOR/2005-109) 8. Toys Regulations (SOR/2011-17)

Other regulations

The Competition Act (R.S.C., 1985, c. C-34)

The Consumer Packaging and Labelling Act (R.S.C., 1985, c. C-38)

Textile Labelling Act (R.S.C., 1985, c. T-10)

Charter of the French Language (R.S.Q., chapter C-11) Bill 101 (for products sold in Province of Quebec)

Cosmetic Regulations (C.R.C., c. 869) -– changed July 20, 2012 heavy metals guidance Arsenic: 3 ppm, Cadmium: 3 ppm, Mercury: 3 ppm, Lead: 10 ppm, Antimony: 5 ppm

http://hc-sc.gc/ca/cps-spc/legislation

http://laws-lois.justice.gc.xa/eng/acts/C-1.68/index.html

http://laws-lois.justice.gc.ca/eng/regulations/SOR-2007-260/index.html





http://laws-lois.justice.gc.ca/eng/regulations/C.R.C.,_c._934/index.html




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A18: Compliance with NOM for Products Sold in Mexico

• Official Mexican Norm NOM-252-SSA1-2011 Biodisponibility of heavy metals for toys and stationery goods covered with paint or inks Chemical specifications and test method. Maximum limits for each element as follows:

mg/kg

Sb As Ba Cd Cr Pb Hg Se

Toys & Stationery Items 60 25 1000 75 60 90 60 500

Stationery Goods for Pre-School Children (including clay, crayons and finger-paint)

60 25 250 50 25 90 25 500

• Official Mexican Norm NOM-015-SCFI-2007

Commercial information for labeling toys

• Official Mexican Norm NOM-050-SCFI-2004. Commercial information for labeling general goods and products

• Official Mexican Norm NOM-003-SSA1-2006.

Sanitary requirements must meet the labeling for paint, ink, varnish, and lacquer • Official Mexican Norm NOM-004-SCFI-2006.

Commercial information for clothes, textiles and accessories labeling

• Official Mexican Norm NOM-030-SCFI-2006. Commercial information; Declaration of contents and quantity for commercial labels and specifications

• Official Mexican Norm NOM-140-SCFI-1999.

Stationery goods – scissors specification and test method Main specifications are: Cut angle maximum 10° Blunt tip radius minimum 3.97 mm No flash

• Official Mexican Norm NOM-008-SCFI-2002.

Unit measurement system to declare contents

• Official Mexican Norm NOM-1144 SEMARNAT-2004. International phitosanitary measures for wood pallets used for international commerce of goods and products

crayola global supply chain quality requirements global supply chain quality requirements

Documents