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4.3 Material and Chemical Inventory Requirement(s) Bronze level: Characterize all homogeneous materials in the product by concentration and generic material type or category/name. In addition, fully define the chemical composition of products that are released directly into the biosphere as part of their intended use (e.g., soaps, paints). For other product types, collect the chemical composition information necessary to assess at least 75% of the product. Silver level: Fully define the chemical composition of products released directly into the biosphere as part of their intended use (e.g., soaps, paints). For other product types, collect the chemical composition information necessary to assess at least 95% of the product. Gold level: Fully define the chemical composition of all homogeneous materials subject to review within the product. Platinum level: Fully define the chemical composition of all process chemistry that comes into contact with the product or its material constituents during the final manufacturing stage. 4.5 Material Health Optimization Strategy [...] For the Bronze and Silver levels, the strategy must include a plan for assessing and optimizing or eliminating all X/x-assessed and GREY/grey materials and chemicals subject to review. One or more material(s) or chemical(s) must be targeted for specific optimization actions in the near-term (defined as 0-3 years). Optimization work relevant to at least one material or chemical must have been completed during the three-year period between certification and recertification. 1 OVERVIEW 1.1 Purpose and Content This document describes the methodology used to assign an A, B, C, X, or GREY material assessment rating to each homogeneous material subject to review in a finished product that is applying for certification to the Cradle to Cradle Certified® Product Standard. The procedure uses toxicity data for individual chemical substances, and/or toxicity data on homogeneous mixtures where available, from peer-reviewed studies, authoritative lists, and other sources, as well as a qualitative exposure assessment that considers specific product manufacturing, use, and end-of-use scenarios to determine whether the material contains one or more substances that have the potential to adversely impact human or environmental health. The methodology applies to all types of homogeneous materials except those for which customized methodologies have been developed: • textile dyestuffs and pigments (see separate document, Colorants Assessment Methodology), • biological materials (see separate document, Biological Materials Assessment Methodology), • geological materials (see separate document, Geological Materials Assessment Methodology), • polymeric materials (see separate document, Polymer Assessment Methodology) • recycled content materials (see separate document, Recycled Content Assessment Methodology) Cradle to Cradle Certified® Product Standard, Version 4.1 User Guidance 4.3 Material and Chemical Inventory Required Documentation • For the Bronze through Gold levels: A C2CPII Bill of Materials Form or equivalent listing all materials in the product or product group seeking certification (a Bill of Materials form is available to Cradle to Cradle Certified assessors). o If a Bill of Materials Form is provided in the supplier’s own format, the checklist from the C2CPII Bill of Materials Form (Overview & Attestation tab) must be followed. • For the Platinum level: o A description of what substances are used during the processes constituting the final manufacturing stage of the product and how process chemicals subject to review were determined. o A separate C2CPII Bill of Materials Form or equivalent for process chemistry. • For each material to be assessed: o Full composition information that can be unambiguously attributed to the relevant manufacturer(s), formulator(s), or other supplier(s) and cross referenced with the Bill of Materials. ▪ If full composition information cannot be obtained, safety data sheets (SDSs) may be collected for general composition information. However, an SDS alone is insufficient to determine full chemical composition. ▪ If neither full composition information nor an SDS can be obtained, data collection must be sufficient to otherwise identify the need for additional material testing (e.g., for biological, recycled content, and geological material testing). o Recommended: A signed declaration regarding any substances listed in Annex VI to CLP that are present in the material above any of their Specific Concentration Levels (SCLs). Note: CMR & SVHC declarations are an alternative for achieving the Silver level Section 4.6 Using Optimized Materials requirements when full chemical composition cannot be obtained. Obtaining these declarations for all materials will also provide additional assurance that substances with low Specific Concentration Limits (which may be at risk of being overlooked in the data collection and disclosure process) are identified.

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Cradle to Cradle Certified® Product Standard Version 4.1 4 // Material Health Requirements Material Health Assessment Methodology, February 2022 1 OVERVIEW Cradle to Cradle Certified® Product Standard, Version 4.1 User Guidance 4 // Material Health Requirements

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Section 4.1 restrictions are based on leading chemical regulations or directives. The chemical regulations or directives included are those currently in effect in the European Union (EU) under the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation, the Persistent Organic Pollutants Regulation (POPs), the Restriction of Hazardous Substances Directive (RoHS), the EU Toy Safety Directive, and the Cosmetics Products Regulation, Annexes II, III, and V (see legend at right). These restrictions are grouped into a list that applies to all homogeneous materials subject to review in all products (REACH and POPs) and three supplementary lists (RoHS, Toy Directive, and Cosmetics Products Regulation), which include additional restrictions specific to certain product types. Each list is accessible through the tabs starting with ""4.1"", or through the links below the Legend table. The applicable thresholds from the cited regulations or directives may not be exceeded for the listed restricted substances present in any homogeneous material subject to review in a certified product. Some substances may be present on multiple lists with differing thresholds or restriction conditions. In such cases, the most conservative applicable restriction must be met. Consult the regulations or directives at the top of each Section 4.1 list for the maximum allowable concentrations for each substance. The restrictions outlined in Section 4.1, derived from various regulations and directives, are applied in accordance with the scope, derogations, and exemptions specified in each respective citation. Consequently, products and materials that contain restricted substances, but adhere to the cited regulations or directives due to applicable scope, derogations, or exemptions, are considered to be compliant with the requirements in this section of the standard. Although the regulations and directives cited in this section only apply to products sold in the EU, the requirements in Section 4.1 apply to all Version 4.1 C2C Certified products. Therefore, certified products not sold in the EU but that are in scope according to these regulations are still required to be in compliance with the restrictions on this list. For more information on these requirements, see the C2C Certified Product Standard, Version 4.1, Section 4.1. Additionally, consult the European Chemicals Agency (ECHA) links at the top of each Section 4.1 list for an expanded set of chemical names and CAS numbers, as well as the restriction notes for substances where applicable. Legend Persistent Organic Pollutants Banned by Stockholm Convention and/or EU Commission EU Commission Regulation No 2019/1021 All products

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Section 4.1: Compliance with Leading Chemical Regulations Overview and Scope

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4 // Material Health Requirements Category Intent Chemicals and materials used in the product are selected to prioritize the protection of human health and the environment, generating a positive impact on the quality of materials available for future use and cycling. Requirements Summary To achieve a desired level within the category, the requirements at all lower levels must also be met. 4.6: Product is optimized for Material Health (i.e., all x-assessed chemicals replaced or phased out). - Gold, Platinum 3.2 Information Sources [...] As a first pass to screen for widely recognized and well established hazards, the use of authoritative hazard lists such as those issued by the International Agency for Research on Cancer (IARC), California’s Proposition 65 List, and lists maintained by various countries based on category criteria of the Globally Harmonized System for Classification and Labeling (GHS) will often be helpful. Some of these lists are explicitly cited in the methodology and within endpoint criteria. In instances where multiple lists cited in the methodology would lead to conflicting hazard ratings, as per the established criteria, the result from the list yielding the most conservative Cradle to Cradle Certified hazard rating (in the order RED, YELLOW, GREEN) is to be used. Cradle to Cradle Certified Version 4.1 Restricted Substances 4.6x-Assessesd Chemicals Carcinogenicity Known, presumed, or suspected carcinogen. GHS Category 1A, 1B, 2 H350, H351 MAK III 1, 2, 3B IARC Group 1, 2A, 2B TLV A1, A2, A3 Mutagenicity •Evidence of mutagenicity supported by positive results in vitro or in vivo GHS Category 1A, 1B, 2 H340, H341 MAK IX 1, 2, 3A, 3B Reproductive and Developmental Toxicity •Known, presumed, or suspected of causing adverse effects to sexual function and fertility and/or to the development of an embryo or fetus based on human or animal studies. •Oral NOAEL < 50 mg/kg BW/day •Inhalation NOAEL <0.25 mg/L 6-8 h/day GHS Category 1A, 1B, 2 H360, H361 MAK Group A or B [See rest of table in 4.6x-Assessesd Chemicals sheet of Excel file]

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Cradle to Cradle Certified® Product Standard Version 4.1 4 // Material Health Requirements Material Health Assessment Methodology 3.2 Information Sources Cradle to Cradle Certified Version 4.1 Restricted Substances 4.6x-Assessesd Chemicals

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2.2 Products Not Eligible for the Bronze Achievement Level in Material Health Children’s products, cosmetics, and personal care products are not eligible for certification at the Bronze achievement level in the Material Health category (i.e., they must meet the Silver achievement level requirements or higher in Material Health). The intent is to ensure they do not contain carcinogens, mutagens, or reproductive toxicants (CMRs); persistent, bioaccumulative, and toxic substances (PBTs); very persistent and very bioaccumulative substances (vPvBs); or substances that cause an equivalent level of concern. 2.3 Products Not Eligible for the Bronze or Silver Achievement Level in Product Circularity Eligible single-use plastic products and plastic packaging products (when certified as a separate product) are not eligible for certification at the Bronze or Silver achievement level in the Product Circularity category (i.e., they must meet the Gold or Platinum achievement level requirements in Product Circularity). The intent is to ensure alignment with the Cradle to Cradle principles for these typically noncircular product types. An exemption is made for plastic packaging that is part of a refill/reuse system (e.g., soap refill pouches), which may be certified at any achievement level in the Product Circularity category Cradle to Cradle Certified® Product Standard, Version 4.1 User Guidance Further Explanation The following product types are not eligible for Cradle to Cradle certification: 1. Products that are contrary to the intent of the Cradle to Cradle principles, including: [...] h. Products for which the core functionality is intrinsically tied to toxic active ingredients, thus rendering the product non-optimizable (e.g., herbicides, insecticides, rodenticides, and antimicrobial products with x-assessed antimicrobial agents) or textiles/apparel with such products intentionally added, i. Disinfectants (including those used for human hygiene) containing active ingredients/substances that are not approved for use per leading regulations. This is defined as disinfectants containing substances that are not approved for use in the relevant product type per the European Union’s Biocidal Products Regulation (e.g., antimicrobial cleaning products, soaps, or hand sanitizers/hand rubs with triclosan or triclocarban),

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2 // Product Eligibility

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Section 4.1 Compliance with Leading Chemical Regulations: All Materials in All Products Substances on this list are subject to restriction in all homogeneous materials subject to review in a certified product according to Regulation (EC) No 1907/2006 (REACH), Annex XIV and Annex XVII, and Regulation (EU) 2019/1021 (POPs). The applicable thresholds from the cited regulations may not be exceeded for listed substances present in any homogeneous material subject to review in a certified product. Although REACH and POPs only apply to products sold in the EU, the requirements in Section 4.1 apply to all C2C certified products. Therefore, certified products not sold in the EU but that are in scope according to these regulations are still required to be in compliance with the restrictions within. While all products are subject to the regulations listed on this tab, some REACH Annex XVII restrictions only apply to specific product and material types. Column E provides information on product and material applicability for each restriction. See REACH Annex XVII for more information on these product types. Instructions: Use the filter in Column E (Product/Material Applicability) to select all product and material types that apply to the product or material seeking compliance. In this list, All Products and Several - See Regulation should always be checked. Then, determine whether any substances in Column B are present. Listed substances must be included in supplier declarations to C2CPII (including name, CAS Number, and concentration). Substance name Reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and 4-heptylphenol, branched and linear (RP-HP) Reaction product of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and phenol, heptyl derivs. formaldehyde and formaldehyde releasers Formaldehyde Formaldehyde, oligomeric reaction products with aniline Section 4.1 Compliance with Leading Chemical Regulations: Cosmetics and Personal Care Products 4.1 Cosmetics & Personal Care Substances on this list are restricted in any homogeneous material subject to review that meets the following definition for a cosmetic or personal care formulation according to Regulation (EC) No 1223/2009. The applicable thresholds from the cited regulation may not be exceeded for listed substances present in any homogeneous material subject to review in a certified product. ‘Cosmetic product’ is defined according to Regulation (EC) No 1223/2009 as any substance or mixture intended to be placed in contact with the external parts of the human body (epidermis, hair system, nails, lips and external genital organs) or with the teeth and the mucous membranes of the oral cavity with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance, protecting them, keeping them in good condition or correcting body odours. Products not in scope according to this regulation are not required to meet the restrictions on this list. Although Regulation (EC) No 1223/2009 only applies to products sold in the EU, the requirements in Section 4.1 apply to all certified products. Therefore, certified products not sold in the EU but that are in scope according to this regulation are still required to be in compliance with the restrictions within. Substance name: [...] formaldehyde Paraformaldehyde Reaction products of paraformaldehyde with 2-hydroxypropylamine (3:2) Reaction products of paraformaldehyde with 2-hydroxypropylamine (1:1) Reaction product of acetophenone, formaldehyde, cyclohexylamine, methanol and acetic acid

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Section 4.1 Compliance with Leading Chemical Regulations: Cosmetics and Personal Care Products Section 4.1 Compliance with Leading Chemical Regulations: All Materials in All Products

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Further Explanation 2. Products that the program requirements were not written to address, including: [...] h. Nanomaterials (Note: Eligibility to be revisited once the Material Health Assessment Methodology is updated to more explicitly address the related human and environmental health issues.)

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2 // Product Eligibility

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4.2 Avoidance of Organohalogens and Functionally Related Chemical Classes of Concern Intended Outcome(s) Organohalogens, a class of substances associated with toxicity concerns in multiple use-cycle stages, are progressively avoided, beginning with high organohalogen content materials, classes of special concern, and functionally related, non-halogenated classes of equivalent concern (e.g., organophosphate ester flame retardants being used in lieu of halogenated flame retardants). Applicable Achievement Level(s) Bronze, Silver, Gold Requirement(s) Bronze level: Homogeneous materials subject to review are not and do not contain organohalogen substances of special concern, or functionally related, non-halogenated substances of equivalent concern (i.e., per- and polyfluoroalkyl substances (PFASs), halogenated flame retardants (HFRs) and organophosphate ester flame retardants (OPFRs), halogenated polymers, halogenated organic solvents, and other highly halogenated, carbon-based materials), above relevant thresholds. Certain exemptions apply. [...] For the Bronze level, the applicable restrictions for organohalogen substances of special concern are: [...] 2. HFRs: Halogenated flame retardants are defined as any chlorinated or brominated substance added to a material for the purpose of increasing heat/fire resistance or decreasing flammability. This restriction applies to the set of HFRs listed in the Cradle to Cradle Certified® Restricted Substances reference document for this section, regardless of the intended purpose/function in the material, and any halogenated substances intentionally added to the product for the purpose of increasing heat/fire resistance or decreasing flammability. In addition to the applicable Bronze level regulatory restrictions on specific HFRs (see Section 4.1), carbon-bonded chlorine and bromine within any flame retardant in the material (intentionally added or present as an impurity) must be < 1,000 ppm of the homogeneous material by weight (except in exempt materials/parts as noted below).

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4 // Material Health Requirements

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5.4 Material Compatibility for Technical and/or Biological Cycles Intended Outcome(s) Product materials with the highest capacity for biological and/or technical cycling have been intentionally selected, increasing the likelihood that such materials will retain their value and move through subsequent cycles of use. - Bronze, Silver, Gold, Platinum For a material to count toward the percentage of materials compatible with the intended cycling pathway(s) the following conditions must be met: 4. For solid materials intended for the biological cycle, one of the following conditions must be met: a. The material must biodegrade in the intended cycling pathway(s) within the time period and to the extent specified by a C2CPII-recognized compostability or biodegradability standard test. b. For paper and biological materials with ≥ 99% unmodified organic material: i. The material, at its maximum thickness and/or density, must disintegrate in the intended cycling pathway(s) within the time period and to the extent specified by a C2CPIIrecognized compostability or biodegradability standard test, and [...] c. For plastic materials, biologically derived materials, and biological materials with < 99% unmodified organic material (including paper that is < 99% cellulose), all of the following conditions must be met: i. The material must biodegrade in the intended cycling pathway(s) within the time period and to the extent specified by a C2CPII-recognized compostability standard test. ii. For any individual organic additives (e.g., pigments, inks, colorants, scents, secondary polymers, glues) present at a concentration of ≥ 1%, the additive must biodegrade in the intended cycling pathway(s) within a specific time period and to the extent specified by: 1. A C2CPII-recognized biodegradability standard test, or 2. The available scientific literature and/or research studies. [...] 5. For materials with unavoidable release to the environment during product use (e.g., tires, shoe soles, brake pads, apparel textile fibers), the fraction of material that on average is likely to be released to the environment from the total product over its lifetime may not be counted as compatible with the intended cycling pathway, unless it is biodegradable in the likely environment where release occurs. 8. For products that are liquid formulations (excluding wet-applied products), individual substances within the formulation, or the formulation as a whole may be evaluated when determining the percentage compatible for the biological cycle. a. When evaluating based on individual substance(s), the following conditions apply: i. For organic chemicals and surfactants to count toward the percentage compatible, the substance must biodegrade in the intended cycling pathway(s) within the time period and extent specified by a C2CPII-recognized biodegradability standard test. In addition, 1. Organic chemicals with a log Koc < 4.5 must meet the OECD definition for ultimate biodegradability (aerobic), and 2. Organic chemicals with a log Koc ≥ 1.5 must meet the OECD definition of anaerobic biodegradability. [...] b. When evaluating the formulation as a whole, if one of the following requirements have been met the product counts as 100% compatible for the biological cycle: i. The formulation has demonstrated ready biodegradability in both anaerobic and aerobic conditions as demonstrated by a C2CPII-recognized biodegradability standard test. (The formulation may also contain benign mineral nutrients.) ii. For consumable consumer products (e.g., shampoo, detergents), the material must biodegrade in the intended cycling pathway(s) within the time period and to the extent specified by a C2CPII-recognized biodegradability standard test. For the Gold level: The use of materials with high-value cycling potential (i.e., high-quality material as defined in #1-2 below) is required. [...] 2. Select liquid formulations (e.g., soaps, cleaning products, lubricants) must meet minimum percent ready biodegradability and/or anaerobic biodegradability requirements; testing may be required. (Note: > 90% biodegradation of organic substances is required in some cases.)

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5 // Product Circularity Requirements

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4 // Material Health Requirements Category Intent Chemicals and materials used in the product are selected to prioritize the protection of human health and the environment, generating a positive impact on the quality of materials available for future use and cycling. Requirements Summary To achieve a desired level within the category, the requirements at all lower levels must also be met. 4.6: Product is optimized for Material Health (i.e., all x-assessed chemicals replaced or phased out). - Gold, Platinum 3.2 Information Sources [...] As a first pass to screen for widely recognized and well established hazards, the use of authoritative hazard lists such as those issued by the International Agency for Research on Cancer (IARC), California’s Proposition 65 List, and lists maintained by various countries based on category criteria of the Globally Harmonized System for Classification and Labeling (GHS) will often be helpful. Some of these lists are explicitly cited in the methodology and within endpoint criteria. In instances where multiple lists cited in the methodology would lead to conflicting hazard ratings, as per the established criteria, the result from the list yielding the most conservative Cradle to Cradle Certified hazard rating (in the order RED, YELLOW, GREEN) is to be used. Cradle to Cradle Certified Version 4.1 Restricted Substances 4.6x-Assessesd Chemicals Starting at the Gold level, Section 4.6 restricts the use of X/x assessed materials and chemicals in the product. Only A/a, B/b, and C/c assessed materials and chemicals may be used in the product. Background on C2C Certified Material Health Assessment The C2C Certified Material Health Assessment Methodology involves evaluating each chemical constituent of a material for 20 human and environmental health hazard endpoints to assign hazard ratings, which can be Green, Yellow, Red, Purple, or Grey. Chemicals that retain endpoints with 'RED' or 'PURPLE' risk flags following an exposure assessment are considered hazardous and assessed as 'x'. Additional Information The C2C Certified Material Health assessment process is further discussed in the C2C Certified Product Standard Section 4.4: Assessing Chemicals and Materials and in the Material Health Assessment Methodology (MHAM). The C2C Certified exposure assessment process is further discussed in the Exposure Assessment Methodology (EAM). Aquatic Toxicity Acute •Classified as GHS Category 1 or 2 (fish, daphnia, or algae) •96 hour fish LC50 ≤ 10 mg/L (experimental or modeled) •48 hour daphnia L(E)C50 ≤ 10 mg/L (experimental or modeled) •72/96 hour L(E)C50 ≤ 10 mg/L (experimental or modeled) Chronic •Fish, daphnia, or algae NOEC ≤ 1 mg/L for chronic toxicity (experimental or modeled) GHS Category 1 or 2 - Acute (fish, daphnia, or algae) GHS Category 1, 2, or 3 - Chronic (fish, daphnia, or algae) H400, 410, H411, H412, H413

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Cradle to Cradle Certified® Product Standard Version 4.1 4 // Material Health Requirements Material Health Assessment Methodology 3.2 Information Sources Cradle to Cradle Certified Version 4.1 Restricted Substances 4.6x-Assessesd Chemicals

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4.4 Assessing Chemicals and Materials Intended Outcome(s) To encourage continued improvement of Material Health, an increasing percentage of the product’s chemicals and materials are assessed. By the time a product reaches the Gold level, all materials and chemicals subject to review within the product have been assessed as compatible with human and environmental health according to the Cradle to Cradle Certified Material Health Assessment Methodology. Applicable Achievement Level(s) Bronze, Silver, Gold, and Platinum Requirement(s) Bronze level: Assess at least 75% of the product. Silver level: Assess at least 95% of the product. Gold level: Assess 100% of the product. Platinum level: Assess 100% of the product AND all process chemistry that comes into contact with the product or its material constituents during the final manufacturing stage.

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4 // Material Health Requirements

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Section 4.1 restrictions are based on leading chemical regulations or directives. The chemical regulations or directives included are those currently in effect in the European Union (EU) under the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation, the Persistent Organic Pollutants Regulation (POPs), the Restriction of Hazardous Substances Directive (RoHS), the EU Toy Safety Directive, and the Cosmetics Products Regulation, Annexes II, III, and V (see legend at right). These restrictions are grouped into a list that applies to all homogeneous materials subject to review in all products (REACH and POPs) and three supplementary lists (RoHS, Toy Directive, and Cosmetics Products Regulation), which include additional restrictions specific to certain product types. Each list is accessible through the tabs starting with ""4.1"", or through the links below the Legend table. The applicable thresholds from the cited regulations or directives may not be exceeded for the listed restricted substances present in any homogeneous material subject to review in a certified product. Some substances may be present on multiple lists with differing thresholds or restriction conditions. In such cases, the most conservative applicable restriction must be met. Consult the regulations or directives at the top of each Section 4.1 list for the maximum allowable concentrations for each substance. The restrictions outlined in Section 4.1, derived from various regulations and directives, are applied in accordance with the scope, derogations, and exemptions specified in each respective citation. Consequently, products and materials that contain restricted substances, but adhere to the cited regulations or directives due to applicable scope, derogations, or exemptions, are considered to be compliant with the requirements in this section of the standard. Although the regulations and directives cited in this section only apply to products sold in the EU, the requirements in Section 4.1 apply to all Version 4.1 C2C Certified products. Therefore, certified products not sold in the EU but that are in scope according to these regulations are still required to be in compliance with the restrictions on this list. For more information on these requirements, see the C2C Certified Product Standard, Version 4.1, Section 4.1. Additionally, consult the European Chemicals Agency (ECHA) links at the top of each Section 4.1 list for an expanded set of chemical names and CAS numbers, as well as the restriction notes for substances where applicable. • Persistent Organic Pollutants Banned by Stockholm Convention and/or EU Commission EU Commission Regulation No 2019/1021 – All products

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Section 4.1: Compliance with Leading Chemical Regulations Overview and Scope

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4 // Material Health Requirements Category Intent Chemicals and materials used in the product are selected to prioritize the protection of human health and the environment, generating a positive impact on the quality of materials available for future use and cycling. 4.2: Product does not contain organohalogen substances of special concern, or functionally related, non-halogenated classes of equivalent concern, above relevant thresholds. - Bronze, Silver, Gold, Platinum 4.2: Product does not contain materials with > 1% carbon-bonded halogens by weight, or recognized PBTs or vPvBs. Product does not contain EU CLP Cat.1 and 2 CMRs or substances causing an equivalent level of concern, or exposure is unlikely or expected to be negligible. - Silver, Gold, Platinum Section 4.2: Highly Halogenated Materials Highly halogenated materials are defined as materials containing a sum total of 10% or more of carbon-bonded fluorine, chlorine, and/or bromine by weight. In addition to specific restrictions on PFASs, HFRs, and OPFRs, the use of highly halogenated materials is restricted at all C2C Certified achievement levels. A non-comprehensive list of common highly halogenated materials is provided below. See the Cradle to Cradle Certified Product Standard, Version 4.1 User Guidance, Section 4.2 for more information on this restriction, including exemptions at the Bronze and Silver levels. List of common highly halogenated materials Polyvinyl Chloride (PVC) Neoprene Dyes and pigments Polystyrene Products with Teflon coating Foam and fiberglass insulation Flame retardants (see HFRs tab) Chlorinated solvents Adhesives 4.1 Electronics (RoHS) Section 4.1 Compliance with Leading Chemical Regulations: Electrical and Electronic Equipment (EEE) Substances on this list are restricted in all homogeneous materials subject to review in electrical and electronic equipment (EEE) according to Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS). The applicable thresholds from the cited directive may not be exceeded for listed substances present in any homogeneous material subject to review in a certified product. EEE is defined according to RoHS as equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields and designed for use with a voltage rating not exceeding 1000 volts for alternating current and 1500 volts for direct current. Products not in scope according to this directive are not required to meet the restrictions on this list. Although RoHS only applies to products sold in the EU, the requirements in Section 4.1 apply to all C2C certified products. Therefore, certified products not sold in the EU but that are in scope according to this directive are still required to be in compliance with the restrictions within. Lead Mercury Cadmium Hexavalent chromium Polybrominated biphenyls (PBB) Polybrominated diphenyl ethers (PBDE) Bis(2-ethylhexyl) phthalate (DEHP) Butyl benzyl phthalate (BBP) Dibutyl phthalate (DBP) Diisobutyl phthalate (DIBP) Section 4.1 Compliance with Leading Chemical Regulations: Children's Toy Products [...] Cadmium Chromium (III) Chromium (VI) Cobalt Copper Lead Manganese Mercury Nickel [...]

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Cradle to Cradle Certified® Product Standard Version 4.1 4 // Material Health Requirements Cradle to Cradle Certified Restricted Substances List (RSL) 4.2 Highly Halogenated

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Section 4.1 Compliance with Leading Chemical Regulations: All Materials in All Products Substances on this list are subject to restriction in all homogeneous materials subject to review in a certified product according to Regulation (EC) No 1907/2006 (REACH), Annex XIV and Annex XVII, and Regulation (EU) 2019/1021 (POPs). The applicable thresholds from the cited regulations may not be exceeded for listed substances present in any homogeneous material subject to review in a certified product. Although REACH and POPs only apply to products sold in the EU, the requirements in Section 4.1 apply to all C2C certified products. Therefore, certified products not sold in the EU but that are in scope according to these regulations are still required to be in compliance with the restrictions within. While all products are subject to the regulations listed on this tab, some REACH Annex XVII restrictions only apply to specific product and material types. Column E provides information on product and material applicability for each restriction. See REACH Annex XVII for more information on these product types. Instructions: Use the filter in Column E (Product/Material Applicability) to select all product and material types that apply to the product or material seeking compliance. In this list, All Products and Several - See Regulation should always be checked. Then, determine whether any substances in Column B are present. Listed substances must be included in supplier declarations to C2CPII (including name, CAS Number, and concentration). Substance Name Azocolourants and Azodyes

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Section 4.1 Compliance with Leading Chemical Regulations: All Materials in All Products

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4.2 Avoidance of Organohalogens and Functionally Related Chemical Classes of Concern [...] For the Bronze level, the applicable restrictions for organohalogen substances of special concern are: [...] 2. HFRs: Halogenated flame retardants are defined as any chlorinated or brominated substance added to a material for the purpose of increasing heat/fire resistance or decreasing flammability. This restriction applies to the set of HFRs listed in the Cradle to Cradle Certified® Restricted Substances reference document for this section, regardless of the intended purpose/function in the material, and any halogenated substances intentionally added to the product for the purpose of increasing heat/fire resistance or decreasing flammability. In addition to the applicable Bronze level regulatory restrictions on specific HFRs (see Section 4.1), carbon-bonded chlorine and bromine within any flame retardant in the material (intentionally added or present as an impurity) must be < 1,000 ppm of the homogeneous material by weight (except in exempt materials/parts as noted below). 4. Halogenated polymers, halogenated organic solvents, and other highly halogenated, carbon-based materials: Any material containing a sum total of 10% or more of carbon-bonded fluorine, chlorine, and/or bromine by weight is considered a highly halogenated carbon-based material and is thus not permitted for use (except in exempt materials/parts as noted below).

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4 // Material Health Requirements

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4.3 Material and Chemical Inventory 3. Exemption: A product may contain a maximum of 1% exempt components by weight. The exemption is allowed for minor, commodity type components including sewing thread and solid, preformed fasteners and bearings. Homogeneous materials and substances in these component types may be exempt from review if the following conditions are met: a. Metallic components are in compliance with the Restriction of Hazardous Substance (RoHS) directive. Section 4.1 Compliance with Leading Chemical Regulations: All Materials in All Products Substances on this list are subject to restriction in all homogeneous materials subject to review in a certified product according to Regulation (EC) No 1907/2006 (REACH), Annex XIV and Annex XVII, and Regulation (EU) 2019/1021 (POPs). The applicable thresholds from the cited regulations may not be exceeded for listed substances present in any homogeneous material subject to review in a certified product. Although REACH and POPs only apply to products sold in the EU, the requirements in Section 4.1 apply to all C2C certified products. Therefore, certified products not sold in the EU but that are in scope according to these regulations are still required to be in compliance with the restrictions within. While all products are subject to the regulations listed on this tab, some REACH Annex XVII restrictions only apply to specific product and material types. Column E provides information on product and material applicability for each restriction. See REACH Annex XVII for more information on these product types. Instructions: Use the filter in Column E (Product/Material Applicability) to select all product and material types that apply to the product or material seeking compliance. In this list, All Products and Several - See Regulation should always be checked. Then, determine whether any substances in Column B are present. Listed substances must be included in supplier declarations to C2CPII (including name, CAS Number, and concentration). Substance name: Cadmium and its compounds Chromium trioxide Chromium VI compounds Lead and its compounds Lead carbonates Lead sulphates Lead sulphate PbSO4 Mercury compounds Mercury Section 4.1 Compliance with Leading Chemical Regulations: Electrical and Electronic Equipment (EEE) Substances on this list are restricted in all homogeneous materials subject to review in electrical and electronic equipment (EEE) according to Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS). The applicable thresholds from the cited directive may not be exceeded for listed substances present in any homogeneous material subject to review in a certified product. EEE is defined according to RoHS as equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields and designed for use with a voltage rating not exceeding 1000 volts for alternating current and 1500 volts for direct current. Products not in scope according to this directive are not required to meet the restrictions on this list. Although RoHS only applies to products sold in the EU, the requirements in Section 4.1 apply to all C2C certified products. Therefore, certified products not sold in the EU but that are in scope according to this directive are still required to be in compliance with the restrictions within. Section 4.6: x-Assessed Chemicals Starting at the Gold level, Section 4.6 restricts the use of X/x assessed materials and chemicals in the product. Only A/a, B/b, and C/c assessed materials and chemicals may be used in the product. Background on C2C Certified Material Health Assessment The C2C Certified Material Health Assessment Methodology involves evaluating each chemical constituent of a material for 20 human and environmental health hazard endpoints to assign hazard ratings, which can be Green, Yellow, Red, Purple, or Grey. Chemicals that retain endpoints with 'RED' or 'PURPLE' risk flags following an exposure assessment are considered hazardous and assessed as 'x'. Additional Information The C2C Certified Material Health assessment process is further discussed in the C2C Certified Product Standard Section 4.4: Assessing Chemicals and Materials and in the Material Health Assessment Methodology (MHAM). The C2C Certified exposure assessment process is further discussed in the Exposure Assessment Methodology (EAM). Toxic Metals Chemical contains a toxic metal compound (antimony, arsenic, cadmium, chromium VI, cobalt, lead, merucry, nickel, thallium, tin (organotins only), radioactive elements, and/or vanadium), and is present at > 100 ppm within a homogeneous material. 3.3.20 Toxic Metals Definition Antimony, arsenic, cadmium, chromium VI, cobalt, lead, mercury, nickel, thallium, tin (organotins only), radioactive elements, and vanadium are considered toxic metals in the Cradle to Cradle Certified methodology. In general, these metals have shown toxic effects regardless of the speciation of the metal, even if incorporated in an organo-metal structure. Rating Criteria If a substance has any of the toxic metals listed above in its molecular structure and that substance is present at a concentration of 100 ppm or higher in a homogeneous material subject to review, the chemical receives a RED rating for this endpoint. If a substance does not have any of the toxic metals listed above in its molecular structure, or the substance is present below 100ppm in the homogeneous material subject to review, the substance receives a GREEN rating for this endpoint, [...]

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Cradle to Cradle Certified® Product Standard Version 4.1 4 // Material Health Requirements Cradle to Cradle Certified Version 4.1 Restricted Substances Section 4.1 Compliance with Leading Chemical Regulations: All Materials in All Products Section 4.1 Compliance with Leading Chemical Regulations: Electrical and Electronic Equipment (EEE) Material Health Assessment Methodology, February 2022 3.3.20 Toxic Metals

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8.3 Monitor and Verify Performance Intended Outcome(s) Performance on upholding human rights is monitored and verified, ensuring that corrective actions are taken when poor performance is identified and increasing the level of assurance that risks to human rights are addressed. Cradle to Cradle Certified® Product Standard, Version 4.1 User Guidance Required Documentation [...] *The following evidence is required for each policy element (Section 8.2 Human Rights Policy #2a-j) to demonstrate that performance has been measured for the applicant company and all final manufacturing stage facilities: [...] g) Safe and healthy work: Documentation of compliance with applicable laws and regulations governing the work environment, including the following: [...] iii. Hazardous materials handling procedures: Copies of past health and safety reports, preferably conducted by an internal audit or third-party audit firm, to identify any type of health and safety violations. This must include evidence of/that: • Compliance with all applicable laws and regulations governing ‘Chemical and Hazardous Substances’. • An inventory of chemical and hazardous substances used in the workplace is maintained. • Chemicals used at the workplace are registered for the intended used when applicable. All local safety standards and applicable laws are adhered to. • Material safety data sheets (MSDSs) are prominently posted in both storage and use zones, and maintained in languages understood by workers. • Chemicals and hazardous substances are properly labelled as per label instructions of local safety standard and MSDSs are maintained

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8 // Social Fairness Requirements

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4.3 Material and Chemical Inventory Requirement(s) Bronze level: Characterize all homogeneous materials in the product by concentration and generic material type or category/name. In addition, fully define the chemical composition of products that are released directly into the biosphere as part of their intended use (e.g., soaps, paints). For other product types, collect the chemical composition information necessary to assess at least 75% of the product. Silver level: Fully define the chemical composition of products released directly into the biosphere as part of their intended use (e.g., soaps, paints). For other product types, collect the chemical composition information necessary to assess at least 95% of the product. Gold level: Fully define the chemical composition of all homogeneous materials subject to review within the product. Platinum level: Fully define the chemical composition of all process chemistry that comes into contact with the product or its material constituents during the final manufacturing stage. 4.5 Material Health Optimization Strategy [...] For the Bronze and Silver levels, the strategy must include a plan for assessing and optimizing or eliminating all X/x-assessed and GREY/grey materials and chemicals subject to review. One or more material(s) or chemical(s) must be targeted for specific optimization actions in the near-term (defined as 0-3 years). Optimization work relevant to at least one material or chemical must have been completed during the three-year period between certification and recertification. 1 OVERVIEW 1.1 Purpose and Content This document describes the methodology used to assign an A, B, C, X, or GREY material assessment rating to each homogeneous material subject to review in a finished product that is applying for certification to the Cradle to Cradle Certified® Product Standard. The procedure uses toxicity data for individual chemical substances, and/or toxicity data on homogeneous mixtures where available, from peer-reviewed studies, authoritative lists, and other sources, as well as a qualitative exposure assessment that considers specific product manufacturing, use, and end-of-use scenarios to determine whether the material contains one or more substances that have the potential to adversely impact human or environmental health. The methodology applies to all types of homogeneous materials except those for which customized methodologies have been developed: • textile dyestuffs and pigments (see separate document, Colorants Assessment Methodology), • biological materials (see separate document, Biological Materials Assessment Methodology), • geological materials (see separate document, Geological Materials Assessment Methodology), • polymeric materials (see separate document, Polymer Assessment Methodology) • recycled content materials (see separate document, Recycled Content Assessment Methodology)

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Cradle to Cradle Certified® Product Standard Version 4.1 4 // Material Health Requirements Material Health Assessment Methodology, February 2022 1 OVERVIEW

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APPENDIX 2 INTERMEDIATE AND OTHER PROFESSIONAL USE PRODUCTS: VERIFICATION & COMMUNICATION REQUIREMENTS [...] b. Are customers adequately informed regarding the relevant hazard(s)? 48 The applicant must provide evidence that customers are adequately informed regarding the sensitization and/or corrosion/irritation hazard(s), as applicable. The answer must be YES to either of the following questions: i. Are the relevant hazard(s) communicated via regulatory pathways (e.g., safety data sheet or other regulatory document)? Information must be provided on the safety data sheet (SDS) or other regulatory document(s) that effectively inform users of relevant hazards. When determining how hazards are communicated, assessor must consider EU & US OSHA requirements for the relevant industry, OSHA compliance, and SDS indications. Hazard communication through SDS or other regulatory pathways fulfills this requirement. ii. In regions where hazard communication is NOT required by regulation, does the applicant proactively and effectively communicate relevant hazards directly to downstream users via non-regulated pathways? In regions where hazard communication is not required by local regulations, hazard information must be provided on the product label, technical data sheets, or the company website. c. Are downstream customers trained and required to use personal protective equipment? The answer must be YES to either of the following questions: ii. In regions where PPE training and use is NOT required by regulation, has the applicant taken proactive steps to train, or to make training available to, all downstream professional users covering all applicable hazard endpoints? The applicant must provide evidence that customers are adequately trained regarding safe handling of the product, such that it is possible to state that contact or repeated (i.e., once a month or more frequent) contact for corrosion/irritation and sensitization respectively is unlikely to occur. Training may be done by the applicant, an entity contracted by the applicant, or an industry association to which the applicant belongs. Note: This requires proactive action by applicants to ensure that training is provided to professional users. All of the following are required in order to answer ‘yes’ to this question (Appendix 2B, c, ii): • Description of the applicant company’s procedure for training professional customers on safe handling of the product, including a list of designated staff (i.e., job titles). • Job description(s) for staff providing safety trainings. Training of customers on the safe use of the applicant’s products must be a defined responsibility for one or more staff. • Safety training materials as provided to the customer. For example, PowerPoint presentations and/or online guidance and resources. The training information must specifically address the hazards and risks relevant to the certified product(s). Cradle to Cradle Certified® Product Standard, Version 4.1 User Guidance 8.3 Monitor and Verify Performance *The following evidence is required for each policy element (Section 8.2 Human Rights Policy #2a-j) to demonstrate that performance has been measured for the applicant company and all final manufacturing stage facilities: g. Safe and healthy work: Documentation of compliance with applicable laws and regulations governing the work environment, including the following. Provide this information for each final manufacturing stage facility separately. iii. Hazardous materials handling procedures: Copies of past health and safety reports, preferably conducted by an internal audit or third-party audit firm, to identify any type of health and safety violations. This must include evidence of/that: • Employees who are involved in handling, clean-up and disposal of chemicals and hazardous substances received regular training on emergency response plans and actions (with training records maintained).

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Exposure Assessment Methodology, January 2024 APPENDIX 2 INTERMEDIATE AND OTHER PROFESSIONAL USE PRODUCTS: VERIFICATION & COMMUNICATION REQUIREMENTS Cradle to Cradle Certified® Product Standard, Version 4.1 User Guidance 8 // Social Fairness Requirements

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3.2.2 Assessing Environmental Risks and Opportunities Intended Outcome(s) Opportunities for improvement are identified and understood as a result of an assessment of environmental risks. Applicable Achievement Level(s) Bronze Requirement(s) Identify environmental risks and opportunities for the applicant company, including all final manufacturing stage facilities and for the certified product. The risk and opportunity assessment must include: 1. A company-level risk assessment, based on conducting desk research at a minimum, to identify known and likely environmental risks associated with the applicant company’s own operations, final manufacturing facilities, the product’s supply chain, product use, product cycling and end of use, relevant communities, potentially affected groups, and other relevant stakeholders. The following issues are de facto high risk for all large companies (defined as companies with ≥ 250,000 employees) and potentially high risk for all other companies: [...] b. Environmental pollution (air, fresh and marine water, soil), [...] The following issues are de facto high risk for final manufacturing stage facilities or for the product, as noted in the scenarios below: e. Air pollution is a high-risk issue for: i. Final manufacturing stage facilities with on-site combustion power plants (including biomass combustion). ii. Final manufacturing stage facilities at which processes commonly known to be airpollutant-intense take place. This includes (but is not limited to): Smelting metals, refining oil, producing cement, using high volumes of organic solvents, and incinerating waste. g. Water and/or soil quality (i.e., pollution) are high-risk issues for: i. Final manufacturing stage facilities with pollutant-intense processes (as defined per the Water & Soil Stewardship requirements). ii. Final manufacturing stage facilities for which stormwater discharge is regulated per the corresponding regional regulatory permitting system. In regions where stormwater is not regulated, any facility within the specific categories of industrial activity that must be covered under the U.S. National Pollutant Discharge Elimination System is de facto high risk for this issue. iii. Products that are primary contributors to microfiber and microplastic pollution (i.e., textile and apparel products made from synthetic fibers that are wet processed and/or that require washing with water during the use phase, tires, and plastic pellets). 2. Identification of best practices employed to address the high risks. Note: These may be best practices that are already in place, best practices planned for future implementation, and/or best practices employed by others that could potentially be implemented by the applicant in future. 3. Information regarding the actual and potential impact(s) and importance of each of the risks identified. 4. Prioritization of the risks and opportunities identified. 3.2.3 Monitor & Verify Performance Intended Outcome(s) Performance on protecting the environment is monitored and verified for tier 1 suppliers, ensuring that corrective actions are taken when poor performance is identified and increasing the level of assurance that environmental risks are addressed. Applicable Achievement Level(s) Silver Requirement(s) Request data measuring performance against the environmental policy from tier 1 suppliers associated with high-risk issues as identified per the risk assessment. At recertification, demonstrate continued efforts to obtain performance data and evidence of tracking corrective actions that may be necessary at tier 1 supplier locations. For the Silver level: 1. Environmental performance data must be requested from all tier 1 suppliers providing components and materials that are subject to review (as defined in Material Health Section 4.3) that are associated with high-risk issues as identified per the Section 3.2.2 risk assessment. 2. If data are outdated or not available, the applicant must arrange for the data to be collected. 3. Data must be generated within the past 24 months. 4. Corrective actions must be planned or ongoing for any poor performance issues identified. At recertification, the applicant must demonstrate progress on: a. Encouraging suppliers to complete corrective actions, b. Tracking whether timelines are adhered to, and c. Taking steps to suspend or terminate relationships with suppliers that fail to make progress on remediation.

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3 // General Requirements

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7.3 Quantifying Water Use Intended Outcome(s) Water withdrawals, discharge, and consumption at facilities manufacturing the product(s) are quantified, creating a baseline against which reductions can be measured, and helping to identify areas for improvement. Applicable Achievement Level(s) Bronze Requirement(s) Quantify annual water withdrawals, discharge, and consumption for all final manufacturing stage facilities. ---- Data must be collected on the following and the data sources indicated: 1. Withdrawals by source and water type. 2. Discharges by receiving body/destination. 3. Capacity of on-site treatment equipment. 4. Consumption by source. 5. Total amount and percentage of water recycled and reused. Facilities that withdraw or purchase ≥ 100,000 m3 of water per year are considered as having high-volume processes.

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7 // Water & Soil Stewardship Requirements

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7.1 Characterizing Local and Product-Relevant Water & Soil Issues Intended Outcome(s) Through the assessment and understanding of water- and soil-related impacts attributable to the product, including local water availability and quality issues relevant to the product’s manufacturing facilities, opportunities to address the impacts are identified. Applicable Achievement Level(s) Bronze and Silver Requirement(s) Bronze level: Characterize water and soil related issues for all final manufacturing stage facilities and issues relevant to the product. Silver level: Characterize water and soil related issues at select tier 1 supplier facilities. ---- For the Bronze Level: For all final manufacturing stage facilities: [...] 4. Describe effluent and sludge treatment process(es). 7.2 Effluent Quality Compliance Intended Outcome(s) Final manufacturing stage facilities are in compliance with regulatory and/or industry best practice effluent limitations. Applicable Achievement Level(s) Bronze, Silver, and Gold Requirement(s) Bronze level: For the final manufacturing stage, treat effluent (either on- or off-site) prior to discharge to the environment and adhere to effluent quality regulations or guidelines. For off-site, independently operated effluent treatment facilities (if any), request data that will demonstrate if the facility is complying with all applicable laws and regulations. Silver level: For privately owned, off-site, independently operated effluent treatment facilities (if any), treat effluent prior to discharge to the environment and adhere to effluent quality guidelines or regulations. Alternatively, if privately owned, off-site, treatment facilities are out of compliance, create a strategy to address the issue and report on progress at recertification. Gold level: For government owned, off-site, independently operated effluent treatment facilities (if any), treat effluent prior to discharge to the environment and adhere to effluent quality guidelines or regulations. Alternatively, if government owned off-site treatment facilities are out of compliance, create a strategy to address the issue. Gold level recertification: For off-site, independently operated effluent treatment facilities (both private and government owned, if any), implement the Silver or Gold level strategy (as applicable) to address any issues with off-site treatment facility compliance. Facilities discharging effluent directly to surface or groundwater must comply with the corresponding regional regulatory (if any), international, or industry best practice effluent quality guidelines for direct discharge. (Note: Facilities discharging via a sewer system that does not route to an effluent treatment facility with at least secondary treatment capabilities or equivalent are discharging directly to surface or groundwater for the purposes of this requirement.) For the Bronze level: For final manufacturing stage facilities meeting this requirement based on regulatory compliance, the parameters addressed in the permit must also be consistent with leading regulations, international guidelines, or industry best practice. Leading regulations are defined as those that include a functioning mechanism through which water quality-based limits are set. Final manufacturing stage facilities discharging process effluent to an off-site, independently operated effluent treatment facility (e.g., publicly owned treatment works, central effluent treatment plant, or wastewater treatment plant) with at least secondary treatment must comply with required pretreatment limits, if any. For the Silver level: Final manufacturing stage facilities discharging process effluent to a privately owned, off-site, independently operated effluent treatment facility (e.g., central effluent treatment plant or wastewater treatment plant) with at least secondary treatment must demonstrate that the treatment facility is treating the effluent received to quality standards in line with the corresponding regional regulatory (if any) or international guidelines. If the off-site treatment facility is out of compliance, the issue must be addressed by recertification at the Gold level (see Gold level section that follows). For the Gold level: Final manufacturing stage facilities discharging process effluent to a government owned, off-site, independently operated effluent treatment facility (e.g., publicly owned treatment works or wastewater treatment plant) with at least secondary treatment must demonstrate that the treatment facility is treating the effluent received to quality standards in line with the corresponding regional regulatory (if any) or international guidelines. If the off-site treatment facility is out of compliance, the issue must be addressed by recertification at the Gold level. Methods of addressing the issue may include demonstrating that the manufacturing facility is not contributing to the issue, the manufacturing facility is complying with regional regulatory (if any), international, or industry best practice effluent quality guidelines for direct discharge, moving the manufacturing plant, or demonstrating that the third party has corrected the issue. Effluent testing When effluent must be tested for verification purposes, sampling and testing must be conducted according to the methods specified by regulatory permits, the off-site, independently operated effluent treatment facility, and/or other guidelines as relevant. The analytical laboratory conducting the tests must be accredited or certified for the specific analysis per ISO 17025, NELAP, or equivalent. 7.8 Transparency IntendedOutcome(s) Water use and effluent quality data for final manufacturing stage facilities are available to stakeholders, demonstrating the manufacturer’s commitment to water stewardship. Applicable Achievement Level(s) Silver and Platinum Requirement(s) Silver level: Make water use data for final manufacturing stage facilities available to stakeholders. Platinum level: Make effluent quality data for the final manufacturing stage facilities available to stakeholders. ---- The data must include: 1. For the Silver through Platinum levels, withdrawals by source and stress level, consumption, and discharge by level of treatment and destination. 2. For the Platinum level, effluent quality test reports as required for verification of the Effluent Quality Compliance requirements (see Section 7.2). 7.10 Optimizing Effluent and Sludge Quality at the Facility Level Intended Outcome(s) Effluent and sludge at final manufacturing facilities are managed with the aim of protecting local water quality and ecosystem health. Applicable Achievement Level(s) Platinum Requirement(s) For the final manufacturing stage facilities: • Establish a comprehensive effluent and sludge quality management system, and • Optimize the effluent and sludge produced as a result of all manufacturing processes used at the facility. Optimizing Effluent and SludgeQuality 1. For conventional water quality parameters, facility(ies) releasing effluent directly to surface or groundwater (defined in Section 7.2) must comply with the more stringent of the limitations indicated by either their permits or as follows: a. pH: 6-9 b. Biological Oxygen Demand (BOD): 25 mg/L c. Chemical Oxygen Demand (COD): 100 mg/L d. Total Suspended Solids (TSS): 30 mg/L e. Ammonia (as N): 10 mg/L f. Total nitrogen: 10 mg/L g. Total phosphorus: 2.0 mg/L h. Temperature: < 3 °C increase i. Color: 7 m-1 (436 nm; yellow) 5 m-1 (525 nm; red) 3 m-1 (620 nm; blue) j. Oil and grease: 10 mg/L k. Coliform: 400 bacteria/100 ml

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7 // Water & Soil Stewardship Requirements

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7.3 Quantifying Water Use Intended Outcome(s) Water withdrawals, discharge, and consumption at facilities manufacturing the product(s) are quantified, creating a baseline against which reductions can be measured, and helping to identify areas for improvement. Applicable Achievement Level(s) Bronze Requirement(s) Quantify annual water withdrawals, discharge, and consumption for all final manufacturing stage facilities. ---- Data must be collected on the following and the data sources indicated: 1. Withdrawals by source and water type. 2. Discharges by receiving body/destination. 3. Capacity of on-site treatment equipment. 4. Consumption by source. 5. Total amount and percentage of water recycled and reused. Facilities that withdraw or purchase ≥ 100,000 m3 of water per year are considered as having high-volume processes.

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7 // Water & Soil Stewardship Requirements

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7.1 Characterizing Local and Product-Relevant Water & Soil Issues Intended Outcome(s) Through the assessment and understanding of water- and soil-related impacts attributable to the product, including local water availability and quality issues relevant to the product’s manufacturing facilities, opportunities to address the impacts are identified. Applicable Achievement Level(s) Bronze and Silver Requirement(s) Bronze level: Characterize water and soil related issues for all final manufacturing stage facilities and issues relevant to the product. Silver level: Characterize water and soil related issues at select tier 1 supplier facilities. ---- For the Bronze Level: For all final manufacturing stage facilities: [...] 4. Describe effluent and sludge treatment process(es). 7.2 Effluent Quality Compliance Intended Outcome(s) Final manufacturing stage facilities are in compliance with regulatory and/or industry best practice effluent limitations. Applicable Achievement Level(s) Bronze, Silver, and Gold Requirement(s) Bronze level: For the final manufacturing stage, treat effluent (either on- or off-site) prior to discharge to the environment and adhere to effluent quality regulations or guidelines. For off-site, independently operated effluent treatment facilities (if any), request data that will demonstrate if the facility is complying with all applicable laws and regulations. Silver level: For privately owned, off-site, independently operated effluent treatment facilities (if any), treat effluent prior to discharge to the environment and adhere to effluent quality guidelines or regulations. Alternatively, if privately owned, off-site, treatment facilities are out of compliance, create a strategy to address the issue and report on progress at recertification. Gold level: For government owned, off-site, independently operated effluent treatment facilities (if any), treat effluent prior to discharge to the environment and adhere to effluent quality guidelines or regulations. Alternatively, if government owned off-site treatment facilities are out of compliance, create a strategy to address the issue. Gold level recertification: For off-site, independently operated effluent treatment facilities (both private and government owned, if any), implement the Silver or Gold level strategy (as applicable) to address any issues with off-site treatment facility compliance. Facilities discharging effluent directly to surface or groundwater must comply with the corresponding regional regulatory (if any), international, or industry best practice effluent quality guidelines for direct discharge. (Note: Facilities discharging via a sewer system that does not route to an effluent treatment facility with at least secondary treatment capabilities or equivalent are discharging directly to surface or groundwater for the purposes of this requirement.) For the Bronze level: For final manufacturing stage facilities meeting this requirement based on regulatory compliance, the parameters addressed in the permit must also be consistent with leading regulations, international guidelines, or industry best practice. Leading regulations are defined as those that include a functioning mechanism through which water quality-based limits are set. Final manufacturing stage facilities discharging process effluent to an off-site, independently operated effluent treatment facility (e.g., publicly owned treatment works, central effluent treatment plant, or wastewater treatment plant) with at least secondary treatment must comply with required pretreatment limits, if any. For the Silver level: Final manufacturing stage facilities discharging process effluent to a privately owned, off-site, independently operated effluent treatment facility (e.g., central effluent treatment plant or wastewater treatment plant) with at least secondary treatment must demonstrate that the treatment facility is treating the effluent received to quality standards in line with the corresponding regional regulatory (if any) or international guidelines. If the off-site treatment facility is out of compliance, the issue must be addressed by recertification at the Gold level (see Gold level section that follows). For the Gold level: Final manufacturing stage facilities discharging process effluent to a government owned, off-site, independently operated effluent treatment facility (e.g., publicly owned treatment works or wastewater treatment plant) with at least secondary treatment must demonstrate that the treatment facility is treating the effluent received to quality standards in line with the corresponding regional regulatory (if any) or international guidelines. If the off-site treatment facility is out of compliance, the issue must be addressed by recertification at the Gold level. Methods of addressing the issue may include demonstrating that the manufacturing facility is not contributing to the issue, the manufacturing facility is complying with regional regulatory (if any), international, or industry best practice effluent quality guidelines for direct discharge, moving the manufacturing plant, or demonstrating that the third party has corrected the issue. Effluent testing When effluent must be tested for verification purposes, sampling and testing must be conducted according to the methods specified by regulatory permits, the off-site, independently operated effluent treatment facility, and/or other guidelines as relevant. The analytical laboratory conducting the tests must be accredited or certified for the specific analysis per ISO 17025, NELAP, or equivalent. 7.8 Transparency IntendedOutcome(s) Water use and effluent quality data for final manufacturing stage facilities are available to stakeholders, demonstrating the manufacturer’s commitment to water stewardship. Applicable Achievement Level(s) Silver and Platinum Requirement(s) Silver level: Make water use data for final manufacturing stage facilities available to stakeholders. Platinum level: Make effluent quality data for the final manufacturing stage facilities available to stakeholders. ---- The data must include: 1. For the Silver through Platinum levels, withdrawals by source and stress level, consumption, and discharge by level of treatment and destination. 2. For the Platinum level, effluent quality test reports as required for verification of the Effluent Quality Compliance requirements (see Section 7.2). 7.10 Optimizing Effluent and Sludge Quality at the Facility Level Intended Outcome(s) Effluent and sludge at final manufacturing facilities are managed with the aim of protecting local water quality and ecosystem health. Applicable Achievement Level(s) Platinum Requirement(s) For the final manufacturing stage facilities: • Establish a comprehensive effluent and sludge quality management system, and • Optimize the effluent and sludge produced as a result of all manufacturing processes used at the facility. Optimizing Effluent and SludgeQuality 1. For conventional water quality parameters, facility(ies) releasing effluent directly to surface or groundwater (defined in Section 7.2) must comply with the more stringent of the limitations indicated by either their permits or as follows: a. pH: 6-9 b. Biological Oxygen Demand (BOD): 25 mg/L c. Chemical Oxygen Demand (COD): 100 mg/L d. Total Suspended Solids (TSS): 30 mg/L e. Ammonia (as N): 10 mg/L f. Total nitrogen: 10 mg/L g. Total phosphorus: 2.0 mg/L h. Temperature: < 3 °C increase i. Color: 7 m-1 (436 nm; yellow) 5 m-1 (525 nm; red) 3 m-1 (620 nm; blue) j. Oil and grease: 10 mg/L k. Coliform: 400 bacteria/100 ml

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7 // Water & Soil Stewardship Requirements

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7.1 Characterizing Local and Product-Relevant Water & Soil Issues Intended Outcome(s) Through the assessment and understanding of water- and soil-related impacts attributable to the product, including local water availability and quality issues relevant to the product’s manufacturing facilities, opportunities to address the impacts are identified. Applicable Achievement Level(s) Bronze and Silver Requirement(s) Bronze level: Characterize water and soil related issues for all final manufacturing stage facilities and issues relevant to the product. Silver level: Characterize water and soil related issues at select tier 1 supplier facilities. ---- For the Bronze Level: For all final manufacturing stage facilities: [...] 4. Describe effluent and sludge treatment process(es). 7.2 Effluent Quality Compliance Intended Outcome(s) Final manufacturing stage facilities are in compliance with regulatory and/or industry best practice effluent limitations. Applicable Achievement Level(s) Bronze, Silver, and Gold Requirement(s) Bronze level: For the final manufacturing stage, treat effluent (either on- or off-site) prior to discharge to the environment and adhere to effluent quality regulations or guidelines. For off-site, independently operated effluent treatment facilities (if any), request data that will demonstrate if the facility is complying with all applicable laws and regulations. Silver level: For privately owned, off-site, independently operated effluent treatment facilities (if any), treat effluent prior to discharge to the environment and adhere to effluent quality guidelines or regulations. Alternatively, if privately owned, off-site, treatment facilities are out of compliance, create a strategy to address the issue and report on progress at recertification. Gold level: For government owned, off-site, independently operated effluent treatment facilities (if any), treat effluent prior to discharge to the environment and adhere to effluent quality guidelines or regulations. Alternatively, if government owned off-site treatment facilities are out of compliance, create a strategy to address the issue. Gold level recertification: For off-site, independently operated effluent treatment facilities (both private and government owned, if any), implement the Silver or Gold level strategy (as applicable) to address any issues with off-site treatment facility compliance. Facilities discharging effluent directly to surface or groundwater must comply with the corresponding regional regulatory (if any), international, or industry best practice effluent quality guidelines for direct discharge. (Note: Facilities discharging via a sewer system that does not route to an effluent treatment facility with at least secondary treatment capabilities or equivalent are discharging directly to surface or groundwater for the purposes of this requirement.) For the Bronze level: For final manufacturing stage facilities meeting this requirement based on regulatory compliance, the parameters addressed in the permit must also be consistent with leading regulations, international guidelines, or industry best practice. Leading regulations are defined as those that include a functioning mechanism through which water quality-based limits are set. Final manufacturing stage facilities discharging process effluent to an off-site, independently operated effluent treatment facility (e.g., publicly owned treatment works, central effluent treatment plant, or wastewater treatment plant) with at least secondary treatment must comply with required pretreatment limits, if any. For the Silver level: Final manufacturing stage facilities discharging process effluent to a privately owned, off-site, independently operated effluent treatment facility (e.g., central effluent treatment plant or wastewater treatment plant) with at least secondary treatment must demonstrate that the treatment facility is treating the effluent received to quality standards in line with the corresponding regional regulatory (if any) or international guidelines. If the off-site treatment facility is out of compliance, the issue must be addressed by recertification at the Gold level (see Gold level section that follows). For the Gold level: Final manufacturing stage facilities discharging process effluent to a government owned, off-site, independently operated effluent treatment facility (e.g., publicly owned treatment works or wastewater treatment plant) with at least secondary treatment must demonstrate that the treatment facility is treating the effluent received to quality standards in line with the corresponding regional regulatory (if any) or international guidelines. If the off-site treatment facility is out of compliance, the issue must be addressed by recertification at the Gold level. Methods of addressing the issue may include demonstrating that the manufacturing facility is not contributing to the issue, the manufacturing facility is complying with regional regulatory (if any), international, or industry best practice effluent quality guidelines for direct discharge, moving the manufacturing plant, or demonstrating that the third party has corrected the issue. Effluent testing When effluent must be tested for verification purposes, sampling and testing must be conducted according to the methods specified by regulatory permits, the off-site, independently operated effluent treatment facility, and/or other guidelines as relevant. The analytical laboratory conducting the tests must be accredited or certified for the specific analysis per ISO 17025, NELAP, or equivalent. 7.8 Transparency IntendedOutcome(s) Water use and effluent quality data for final manufacturing stage facilities are available to stakeholders, demonstrating the manufacturer’s commitment to water stewardship. Applicable Achievement Level(s) Silver and Platinum Requirement(s) Silver level: Make water use data for final manufacturing stage facilities available to stakeholders. Platinum level: Make effluent quality data for the final manufacturing stage facilities available to stakeholders. ---- The data must include: 1. For the Silver through Platinum levels, withdrawals by source and stress level, consumption, and discharge by level of treatment and destination. 2. For the Platinum level, effluent quality test reports as required for verification of the Effluent Quality Compliance requirements (see Section 7.2). 7.10 Optimizing Effluent and Sludge Quality at the Facility Level Intended Outcome(s) Effluent and sludge at final manufacturing facilities are managed with the aim of protecting local water quality and ecosystem health. Applicable Achievement Level(s) Platinum Requirement(s) For the final manufacturing stage facilities: • Establish a comprehensive effluent and sludge quality management system, and • Optimize the effluent and sludge produced as a result of all manufacturing processes used at the facility. Optimizing Effluent and SludgeQuality 1. For conventional water quality parameters, facility(ies) releasing effluent directly to surface or groundwater (defined in Section 7.2) must comply with the more stringent of the limitations indicated by either their permits or as follows: a. pH: 6-9 b. Biological Oxygen Demand (BOD): 25 mg/L c. Chemical Oxygen Demand (COD): 100 mg/L d. Total Suspended Solids (TSS): 30 mg/L e. Ammonia (as N): 10 mg/L f. Total nitrogen: 10 mg/L g. Total phosphorus: 2.0 mg/L h. Temperature: < 3 °C increase i. Color: 7 m-1 (436 nm; yellow) 5 m-1 (525 nm; red) 3 m-1 (620 nm; blue) j. Oil and grease: 10 mg/L k. Coliform: 400 bacteria/100 ml

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7 // Water & Soil Stewardship Requirements

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4.1 Compliance with Leading Chemical Regulations Intended Outcome(s) In alignment with leading regulations that aim to protect human health and the environment, the use of well-known toxic chemicals in the product is avoided. Applicable Achievement Level(s) Bronze Requirement(s) The product complies with leading chemical regulations. Note: In addition to the chemical restrictions in this section, products seeking certification are also subject to the applicable chemical restrictions in Sections 4.2 and 4.6. 4.3 Material and Chemical Inventory Intended Outcome(s) An increasing percentage of the product’s material and chemical composition is known so that possible risks the materials and chemicals may pose to human health and the environment can be assessed and strategies for using safer chemistry can be developed. Applicable Achievement Level(s) Bronze, Silver, Gold, and Platinum Requirement(s) Bronze level: Characterize all homogeneous materials in the product by concentration and generic material type or category/name. In addition, fully define the chemical composition of products that are released directly into the biosphere as part of their intended use (e.g., soaps, paints). For other product types, collect the chemical composition information necessary to assess at least 75% of the product. Further Explanation Generic Material Type The generic material type is the descriptor of the material that would be included in commercial descriptions, technical manuals, or on bills of materials (e.g., aluminum, polyethylene, steel, wood, cotton, adhesive, paint). Wherever possible, the most specific descriptor known and/or the trade name of the material should also be reported (e.g., 6061 aluminum, DOWLEX™ polyethylene, 304 stainless steel, oak wood, GOTS-certified cotton, Prismatic “INK BLACK” powder coat, 3M Super 77 Spray Adhesive, etc.) as this will facilitate information collection for the higher-level Material Health requirements. ---- Characterizing Materials in the Product The concentration of each material as a percentage of the total product weight must be determined. Fully Defining the Chemical Composition of Materials Toxicological assessment of a material requires disclosure of its full chemical composition from the supplier(s)/formulator(s) controlling the chemical composition. A homogeneous material is considered fully defined when the chemical names and chemical identifiers are known for all chemicals subject to review. Required Documentation [...] • Analytical testing reports demonstrating that any Section 4.1 restricted substances with the potential for being present in the material are below relevant restriction limits o Test reports must be conducted within two years prior to the start of the application. o Biological, geological, and recycled content materials require both analytical testing and a Regulatory Compliance Declaration or regulatory statement of compliance. Analytical testing for these materials does not include all Section 4.1 restricted substances. o If a biological, geological, or recycled content material does not contain any intentionally added inputs (e.g., additives, finishes, coatings, pesticides) or known contaminants, the supplier may provide a statement attesting as such in lieu of providing a Regulatory Compliance declaration or statement of compliance. For exempt metallic components (as defined per Section 4.3 Material and Chemical Inventory), the following is required: • Evidence of Restriction of Hazardous Substances (RoHS) compliance. For textile chemical formulations (e.g., a textile dye formulation), a ZDHC ChemCheck report or equivalent report or declaration verifying ZDHC MRSL compliance may be used to demonstrate Section 4.1 compliance. The report or declaration must demonstrate conformance to ZDHC level 1 at a minimum. If this compliance pathway is used, a Regulatory Compliance declaration is not required.

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4 // Material Health Requirements

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4.1 Compliance with Leading Chemical Regulations Intended Outcome(s) In alignment with leading regulations that aim to protect human health and the environment, the use of well-known toxic chemicals in the product is avoided. Applicable Achievement Level(s) Bronze Requirement(s) The product complies with leading chemical regulations. Note: In addition to the chemical restrictions in this section, products seeking certification are also subject to the applicable chemical restrictions in Sections 4.2 and 4.6. ---- The product and its homogeneous materials subject to review comply with leading chemical regulations, as defined by the applicable Bronze level regulatory restrictions in the Cradle to Cradle Certified® Restricted Substances reference document. The Bronze level regulatory restrictions include restrictions that apply to all products, restrictions that apply to children’s toy products, and restrictions that apply to cosmetics and personal care products. See Section 4.3 for more information on how to define homogeneous materials subject to review in a product seeking certification. For textile chemical formulations, the product may alternatively comply with the most recent version of the Zero Discharge of Hazardous Chemicals (ZDHC) Manufacturing Restricted Substances List (MRSL) or equivalent. Further Explanation Pathways to Demonstrate Compliance with Leading Chemical Regulations [...] 4. Material Health Assessor Verification (alternate compliance pathway for suppliers who are unable to sign ANY Regulatory Compliance Declaration): • For this pathway, suppliers provide a signed and attested Version 4.1 Supplier Bill of Materials Form indicating that the composition information is complete and represents all intentional inputs and known contaminants to the Cradle to Cradle Certified Material Health Assessor, who reviews the composition, confirms regulatory compliance, and signs the C2CPII Supplier Regulatory Compliance Declaration. • For this pathway, the supplier can provide a signed and attested Bill of Materials using: o C2CPII Version 4.0 or Version 4.1 Supplier Bill of Materials Form OR, o A Bill of Materials form in the supplier’s own format. Note that the supplier Bill of Materials must include the same information requested in C2CPII’s Bill of Materials. [...] Defining Homogeneous Materials Subject to Section 4.1 Restrictions Substances listed on the Section 4.1 spreadsheet tabs in the Cradle to Cradle Certified® Restricted Substances reference document are restricted in all homogeneous materials subject to review. Homogeneous materials are defined as materials of uniform composition throughout that cannot be mechanically disjointed, in principle, into different materials. Examples of homogeneous materials are polypropylene, steel, shampoo, glass cleaner, nylon yarn, finish, and coating. Examples of nonhomogeneous materials are powder-coated steel, a printed bottle label, plywood, laminate, and chair casters. Additional detail regarding the homogeneous material definition as well as interpretations regarding how to apply it to specific product and materials can be found in the Methodology for Defining Homogeneous Materials. [...] Required Documentation [...] For textile chemical formulations (e.g., a textile dye formulation), a ZDHC ChemCheck report or equivalent report or declaration verifying ZDHC MRSL compliance may be used to demonstrate Section 4.1 compliance. The report or declaration must demonstrate conformance to ZDHC level 1 at a minimum. If this compliance pathway is used, a Regulatory Compliance declaration is not required.

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4 // Material Health Requirements

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5.3 Increasing Demand: Incorporating Cycled and/or Renewable Content Intended Outcome(s) Demand for circularly sourced materials is increased as a result of the increased use of cycled or renewable materials in the product, helping to close the loop and advance the circular economy. Negative impacts of virgin material use are also minimized. Applicable Achievement Level(s) Bronze, Silver, Gold, and Platinum Requirement(s) Bronze level: For select commonly cycled product and material types, incorporate the required percentage of cycled and/or renewable content into the product using an approved method. Alternatively, publicly disclose an explanation of the limitation(s) preventing achievement of the required minimums. Silver level: Incorporate a percentage of cycled and/or renewable content into the product equal to or greater than industry averages and/or consistent with common practice. Develop a plan for increasing the use of post-consumer recycled and/or responsibly sourced renewable content, and demonstrate progress toward achieving the plan at recertification. Alternatively, publicly disclose an explanation of the limitation(s) preventing achievement of the required percentage(s). Further Explanation Developing a Plan and Demonstrating Progress At the Silver level it is required to Develop a plan for increasing the use of post-consumer recycled and/or responsibly sourced renewable content and demonstrate progress toward achieving the plan at recertification. At a minimum, the plan for increasing the use of post-consumer recycled and/or responsibly sourced renewable content must include the type and source of content intended to be included or increased in the product, a timeline with targets for increasing the content, and a method for achieving these increases. A plan is also required at the Gold level, but not at the Platinum level, because the technically feasible maximum amount of cycled content is required at Platinum. A progress report on achieving the plan must be provided at recertification and action towards achieving it must have occurred. Ideally this will have resulted in an increased amount of cycled or responsibly sourced renewable content in the product. However, other actions towards achieving that goal also receive credit. Examples of progress include: • Using an increased amount of cycled and/or responsibly sourced renewable content in the product. • Conducting research and development activities aimed at removing barriers to using an increased amount of cycled content. This type of research may be necessary (for example) when technical specifications or Material Health requirements make the use of recycled content difficult. In this case, progress may require conducting performance tests of products containing cycled materials to determine if the required technical specifications can be maintained when cycled content is used. • Actions taken to increase the available supply of cycled and/or responsibly sourced renewable content available for use. For example, investments that support development of new cycling technologies, investments to increase local recovery and processing capacity or improved sorting capability, or (for renewable material) financial or in-kind support of supplier(s) efforts to obtain a responsible sourcing certification. Note that progress is required at recertification.

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5 // Product Circularity Requirements

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6.2 Quantifying Electricity Use and Greenhouse Gas Emissions Intended Outcome(s) Electricity use and greenhouse gas emissions associated with final manufacturing and the product’s embodied greenhouse gas emissions have been quantified and verified, creating a baseline against which reductions can be measured, and helping to identify areas for improvement. Applicable Achievement Level(s) Bronze, Silver, Gold, and Platinum Requirement(s) Bronze level: Quantify annual electricity use and greenhouse gas emissions associated with the final manufacturing stage of the product. Silver level: For construction products and building materials used to construct primary building elements (i.e., products for which life cycle assessment is common practice), quantify the embodied greenhouse gas emissions associated with the product from resource extraction through final manufacturing or end of use, and produce an Environmental Product Declaration (EPD) that has been critically reviewed by a third-party. Gold level: For other product types, quantify the embodied greenhouse gas emissions associated with the product from resource extraction through final manufacturing or end of use and, if self-reported, conduct an internal review. Platinum level: For all product types, conduct a third-party critical review of the quantification of embodied greenhouse gas emissions associated with the product from resource extraction through end of use and produce an Environmental Product Declaration (EPD).

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6 // Clean Air & Climate Protection Requirements

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3.2.4 Strategy for Environmental Policy Implementation Intended Outcome(s) A framework for monitoring and measuring progress toward achievement of environmental performance targets and for identifying areas for improvement is established. Applicable Achievement Level(s) Bronze Cradle to Cradle Certified 14 ® Product Standard Version 4.0 User Guidance Further Explanation Priority Risks and Opportunities (Requirement #1): At a minimum, the strategy is expected to focus on the priorities determined per the risk and opportunity assessment (see Section 3.2.1). Time-bound Performance and Impact Objectives (Requirement #2): The specific objectives and related targets included in the strategy will depend on the priority action areas identified in requirement #1. Examples of performance objectives and related targets include: • Consistent compliance with all applicable environmental laws and regulations at all final manufacturing facilities with a target of zero instances of permit exceedance • Minimizing waste with a related target to increase recycling of manufacturing ‘waste’ by a certain percentage within a designated timeframe 5 // Product Circularity Requirements Category Intent Products are intentionally designed for their next use and are actively cycled in their intended cycling pathway(s). 5.4: ≥ 50% of materials by weight are compatible with the intended cycling pathway(s) (i.e., recyclable, compostable, or biodegradable). - Bronze, Gold, Silver, Platinum 5.2: Partnerships for cycling (recovery and processing) of the product have been initiated. If the product is intended for cycling via municipal systems, materials are compatible with those systems. - Gold, Silver, Platinum 5.3: Percentage of cycled and/or renewable content, by weight, is equal to or higher than industry averages and/or is consistent with common practice. Alternative: Limitations that prevent achievement of this requirement are publicly reported. - Gold, Silver, Platinum 5.4: ≥ 70% of materials by weight are compatible with the intended cycling pathway(s) (i.e., recyclable, compostable, or biodegradable).

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3 // General Requirements 5 // Product Circularity Requirements

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7.2 Effluent Quality Compliance Intended Outcome(s) Final manufacturing stage facilities are in compliance with regulatory and/or industry best practice effluent limitations -Bronze, Silver, and Gold 7.7 Assessing and Optimizing Product-Relevant Chemicals in Effluent and Sludge Intended Outcome(s) - Bronze, Silver, Gold and Platinum Chemicals entering receiving waters and soils as a result of product manufacturing have been intentionally selected based on their preferred safety attributes. 7.10 Optimizing Effluent and Sludge Quality at the Facility Level Intended Outcome(s) Effluent and sludge at final manufacturing facilities are managed with the aim of protecting local water quality and ecosystem health. - Platinum

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7 // Water & Soil Stewardship Requirements

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5.4 Material Compatibility for Technical and/or Biological Cycles Intended Outcome(s) Product materials with the highest capacity for biological and/or technical cycling have been intentionally selected, increasing the likelihood that such materials will retain their value and move through subsequent cycles of use. Applicable Achievement Level(s) Bronze, Silver, Gold, and Platinum [...] For a material to count toward the percentage of materials compatible with the intended cycling pathway(s) the following conditions must be met: 1. Homogeneous materials that need to be separated in order to be cycled must be separable by the entity implementing the intended cycling pathway with given instructions and no additional special knowledge. 2. For products that are installed prior to use (e.g., in a building, a vehicle, or fixed within a sidewalk), it must be possible to extract the product from the installed location. 3. For products and materials intended for technical municipal cycling (i.e., municipal recycling), the product and/or material must be compatible for municipal cycling systems (e.g., painted plastics and plastic laminated paper are not currently compatible for municipal recycling).

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5 // Product Circularity Requirements

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3.2.2 Assessing Environmental Risks and Opportunities Intended Outcome(s) Opportunities for improvement are identified and understood as a result of an assessment of environmental risks. Applicable Achievement Level(s) Bronze Requirement(s) Identify environmental risks and opportunities for the applicant company, including all final manufacturing stage facilities and for the certified product. ---- The following issues are de facto high risk for final manufacturing stage facilities or for the product, as noted in the scenarios below: [...] h. Waste generation is a high-risk issue for: i. Final manufacturing stage facilities in countries with highly inadequate waste management. This is defined as countries with open dumps. ii. Final manufacturing stage facilities for which hazardous waste is regulated per the corresponding regional regulatory permitting system (e.g., for facilities required to hold hazardous waste permits). In regions where hazardous waste is not regulated, any facility

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3 // General Requirements

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5.7 Product Designed for Disassembly Intended Outcome(s) The product may be easily disassembled into discrete materials compatible for its intended cycling pathway(s) making it more likely that a large percentage of the materials in the product will be cycled. [...] Applicable Achievement Level(s) Silver, Gold, and Platinum [,...] For the Silver level, the plan for increasing the ease of product disassembly must include at least one of the design or communication elements required at the Gold level. For the Gold and Platinum levels, the following design and communications elements define “ease of disassembly” and are required as applicable for ≥ 90% (for Gold) and ≥ 99% (for Platinum) of materials by weight: 2. Processes that result in the loss of specific materials in the product in order to recover other materials (e.g., burning plastics to recover metals) must be avoided.

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5 // Product Circularity Requirements

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7.2 Effluent Quality Compliance [...] For the Bronze level: [...] Final manufacturing stage facilities discharging process effluent to an off-site, independently operated effluent treatment facility (e.g., publicly owned treatment works, central effluent treatment plant, or wastewater treatment plant) with at least secondary treatment must comply with required pretreatment limits, if any. For the Silver level: Final manufacturing stage facilities discharging process effluent to a privately owned, off-site, independently operated effluent treatment facility (e.g., central effluent treatment plant or wastewater treatment plant) with at least secondary treatment must demonstrate that the treatment facility is treating the effluent received to quality standards in line with the corresponding regional regulatory (if any) or international guidelines.

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7 // Water & Soil Stewardship Requirements

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3.2.2 Assessing Environmental Risks and Opportunities Intended Outcome(s) Opportunities for improvement are identified and understood as a result of an assessment of environmental risks. Applicable Achievement Level(s) Bronze Requirement(s) Identify environmental risks and opportunities for the applicant company, including all final manufacturing stage facilities and for the certified product. The risk and opportunity assessment must include: 1. A company-level risk assessment, based on conducting desk research at a minimum, to identify known and likely environmental risks associated with the applicant company’s own operations, final manufacturing facilities, the product’s supply chain, product use, product cycling and end of use, relevant communities, potentially affected groups, and other relevant stakeholders. The following issues are de facto high risk for all large companies (defined as companies with ≥ 250,000 employees) and potentially high risk for all other companies: [...] b. Environmental pollution (air, fresh and marine water, soil), [...] The following issues are de facto high risk for final manufacturing stage facilities or for the product, as noted in the scenarios below: e. Air pollution is a high-risk issue for: i. Final manufacturing stage facilities with on-site combustion power plants (including biomass combustion). ii. Final manufacturing stage facilities at which processes commonly known to be airpollutant-intense take place. This includes (but is not limited to): Smelting metals, refining oil, producing cement, using high volumes of organic solvents, and incinerating waste. 6.1 Air Emissions Compliance Intended Outcome(s) The final manufacturing stage facilities where the product is manufactured are in compliance with regulatory and/or industry best practice air emissions limitations. Applicable Achievement Level(s) Bronze Facilities must comply with the corresponding regional regulatory (if any), international, or industry best practice air emissions guidelines. Compliance with all applicable laws and regulations, including compliance with regional regulatory air emissions limitations, is required as a baseline. For final manufacturing stage facilities meeting this requirement based on regulatory compliance, the parameters addressed in the permit must also be consistent with leading regulations, international guidelines, or industry best practice. Leading regulations are defined as those that include a functioning mechanism through which ambient air quality-based limits are set (i.e., assessment of the existing ambient air quality is used to inform and set the permitted limits with the goal of maintaining high quality standards).

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3 // General Requirements 6 // Clean Air & Climate Protection Requirements

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6.1 Air Emissions Compliance Intended Outcome(s) The final manufacturing stage facilities where the product is manufactured are in compliance with regulatory and/or industry best practice air emissions limitations. Applicable Achievement Level(s) Bronze Requirement(s) Final manufacturing stage facilities comply with air emissions regulations or guidelines. ---- Facilities must comply with the corresponding regional regulatory (if any), international, or industry best practice air emissions guidelines. Compliance with all applicable laws and regulations, including compliance with regional regulatory air emissions limitations, is required as a baseline. For final manufacturing stage facilities meeting this requirement based on regulatory compliance, the parameters addressed in the permit must also be consistent with leading regulations, international guidelines, or industry best practice. Leading regulations are defined as those that include a functioning mechanism through which ambient air quality-based limits are set (i.e., assessment of the existing ambient air quality is used to inform and set the permitted limits with the goal of maintaining high quality standards).

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6 // Clean Air & Climate Protection Requirements

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2.1 Products Eligible for Certification [...] Further Explanation The following product types are not eligible for Cradle to Cradle certification: [...] 3. Products that are not in compliance with applicable local, state, and federal laws and regulations. 3.2.4 Strategy for Environmental Policy Implementation Intended Outcome(s) A framework for monitoring and measuring progress toward achievement of environmental performance targets and for identifying areas for improvement is established. Applicable Achievement Level(s) Bronze Requirement(s) Develop a strategy for implementing the environmental policy and report on implementation progress at each recertification. ---- Further Explanation The requirements in this section apply to the applicant company. [...] Time-bound Performance and Impact Objectives (Requirement #2): The specific objectives and related targets included in the strategy will depend on the priority action areas identified in requirement #1. Examples of performance objectives and related targets include: • Consistent compliance with all applicable environmental laws and regulations at all final manufacturing facilities with a target of zero instances of permit exceedance.

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2 // Product Eligibility

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Requirements Summary To achieve a desired level within the category, the requirements at all lower levels must also be met. 7.2: Final manufacturing facilities comply with water quality regulations or guidelines (i.e., permits, international guidelines, or industry best practice). Data to demonstrate the compliance status of off-site, independently operated, effluent treatment facilities (if any) are requested. (Bronze, Silver, Gold, Platinum) 7.2: Privately owned, off-site, independently operated effluent treatment facilities (if any), comply with effluent quality guidelines or regulations. Alternatively, a strategy to address the issue has been developed. (Silver, Gold, Platinum) 7.2 Effluent Quality Compliance Intended Outcome(s) Final manufacturing stage facilities are in compliance with regulatory and/or industry best practice effluent limitations. Applicable Achievement Level(s) Bronze, Silver, and Gold Requirement(s) Bronze level: For the final manufacturing stage, treat effluent (either on- or off-site) prior to discharge to the environment and adhere to effluent quality regulations or guidelines. For off-site, independently operated effluent treatment facilities (if any), request data that will demonstrate if the facility is complying with all applicable laws and regulations. Silver level: For privately owned, off-site, independently operated effluent treatment facilities (if any), treat effluent prior to discharge to the environment and adhere to effluent quality guidelines or regulations. Alternatively, if privately owned, off-site, treatment facilities are out of compliance, create a strategy to address the issue and report on progress at recertification. 7.10 Optimizing Effluent and Sludge Quality at the Facility Level Intended Outcome(s) Effluent and sludge at final manufacturing facilities are managed with the aim of protecting local water quality and ecosystem health. [...] Optimizing Effluent and SludgeQuality 1. For conventional water quality parameters, facility(ies) releasing effluent directly to surface or groundwater (defined in Section 7.2) must comply with the more stringent of the limitations indicated by either their permits or as follows: [...] Applicants who would be required to comply with effluent limits more stringent than what indicated by their permits may alternatively publicly disclose an explanation of the conditions and/or trade-offs preventing the facility from meeting the more stringent limits. Note: For the Bronze level: 3. If identified, the following issues of high concern must be resolved prior to certification or recertification: [...] e. Missing or deficient permits (i.e., business license, building permit, and environmental permit(s) if required by local regulations),

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7 // Water & Soil Stewardship Requirements

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3.2.1 Environmental Policy Intended Outcome(s) The applicant company has formally committed to protecting the environment through company policy approved at the executive level. Applicable Achievement Level(s) Bronze Requirement(s) Commit to protecting the environment through company policy. ---- The policy or policies must: 1. Establish expectations for the applicant company, the supply chain, communities, potentially affected groups, and other relevant stakeholders. 2. Include the company’s commitment to address any high-risk environmental issues identified via the risk assessment, including any de facto high-risk issues. (If no high-risk issues were identified, the policy may address environmental protection in a general way.) 3. Define staff responsibilities for implementation. 4. Be formally approved by a duly empowered officer of the applicant company or by the Board of Directors. 3.2.2 Assessing Environmental Risks and Opportunities Intended Outcome(s) Opportunities for improvement are identified and understood as a result of an assessment of environmental risks. Applicable Achievement Level(s) Bronze Requirement(s) Identify environmental risks and opportunities for the applicant company, including all final manufacturing stage facilities and for the certified product. ---- The risk and opportunity assessment must include: [...] 3.2.3 Monitor & Verify Performance Intended Outcome(s) Performance on protecting the environment is monitored and verified for tier 1 suppliers, ensuring that corrective actions are taken when poor performance is identified and increasing the level of assurance that environmental risks are addressed. Applicable Achievement Level(s) Silver Requirement(s) Request data measuring performance against the environmental policy from tier 1 suppliers associated with high-risk issues as identified per the risk assessment. At recertification, demonstrate continued efforts to obtain performance data and evidence of tracking corrective actions that may be necessary at tier 1 supplier locations.

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3 // General Requirements

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3.2.6 Environmental Management Systems Intended Outcome(s) An environmental performance management system is in place, ensuring that environmental performance of the applicant company and product is improved over time. Applicable Achievement Level(s) Silver and Gold Requirement(s) Silver level: For the applicant company and for all final manufacturing stage facility(ies), implement management system(s) that support achievement of the environmental policy commitments within company and facility operations. Gold level: Implement a responsible sourcing management system that supports achievement of the environmental policy commitments within the product’s supply chain. [...] 8.6 Management Systems Intended Outcome(s) A management system for people and procedures is in place, ensuring that necessary corrective actions are taken, actions are effective, and that performance on respecting human rights is ultimately improved. Applicable Achievement Level(s) Silver and Gold Requirement(s) Silver level: Implement a management system that supports achievement of the human rights policy commitments within company operations. Gold level: Implement a responsible sourcing management system that supports achievement of the human rights policy commitments within the product’s supply chain. [...]

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3 // General Requirements 8 // Social Fairness Requirements

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8.1 Human Rights Policy Intended Outcome(s) The applicant is formally committed to respecting and upholding human rights as defined by international standards. Applicable Achievement Level(s) Bronze Requirement(s) Commit to respect human rights, as enshrined in municipal law and internationally recognized human rights standards, through company policy. ---- The policy must: [...] 2. Include the company’s commitment to support the following (Note: These are the expectations that must be established and are referred to as “required policy elements” in other sections of the standard): [...] f. Freedom of association and collective bargaining, Cradle to Cradle Certified® Product Standard, Version 4.1 User Guidance Definition of Human Rights Human rights are rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status. Human rights include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression, the right to work and education, and many more. Everyone is entitled to these rights, without discrimination (https://www.un.org/en/globalissues/human-rights). Internationally recognized human rights are defined in the International Bill of Human Rights (which includes the Universal Declaration of Human Rights, codified through the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights), as well as the eight International Labor Organization (ILO) Core Conventions set out in the Declaration on Fundamental Principles and Rights at Work. The ILO Core Conventions are: • Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87)

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8 // Social Fairness Requirements

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8.1 Human Rights Policy Intended Outcome(s) The applicant is formally committed to respecting and upholding human rights as defined by international standards. Applicable Achievement Level(s) Bronze Requirement(s) Commit to respect human rights, as enshrined in municipal law and internationally recognized human rights standards, through company policy. ---- The policy must: [...] 2. Include the company’s commitment to support the following (Note: These are the expectations that must be established and are referred to as “required policy elements” in other sections of the standard): [...] f. Freedom of association and collective bargaining, Cradle to Cradle Certified® Product Standard, Version 4.1 User Guidance Definition of Human Rights Human rights are rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status. Human rights include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression, the right to work and education, and many more. Everyone is entitled to these rights, without discrimination (https://www.un.org/en/globalissues/human-rights). Internationally recognized human rights are defined in the International Bill of Human Rights (which includes the Universal Declaration of Human Rights, codified through the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights), as well as the eight International Labor Organization (ILO) Core Conventions set out in the Declaration on Fundamental Principles and Rights at Work. The ILO Core Conventions are: [...] • Right to Organise and Collective Bargaining Convention, 1949 (No. 98)

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8 // Social Fairness Requirements

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8.1 Human Rights Policy Intended Outcome(s) The applicant is formally committed to respecting and upholding human rights as defined by international standards. Applicable Achievement Level(s) Bronze Requirement(s) Commit to respect human rights, as enshrined in municipal law and internationally recognized human rights standards, through company policy. The policy must: 1. Establish human rights expectations for the applicant company, the supply chain, communities, potentially affected groups, and other relevant stakeholders. 2. Include the company’s commitment to support the following (Note: These are the expectations that must be established and are referred to as “required policy elements” in other sections of the standard): c. Elimination of all forms of forced or compulsory labor, or activities that are known to lead to forced labor (e.g., human trafficking), Cradle to Cradle Certified® Product Standard, Version 4.1 User Guidance e Further Explanation Definition of Human Rights Human rights are rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status. Human rights include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression, the right to work and education, and many more. Everyone is entitled to these rights, without discrimination (https://www.un.org/en/globalissues/human-rights). Internationally recognized human rights are defined in the International Bill of Human Rights (which includes the Universal Declaration of Human Rights, codified through the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights), as well as the eight International Labor Organization (ILO) Core Conventions set out in the Declaration on Fundamental Principles and Rights at Work. The ILO Core Conventions are: • Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87) • Right to Organise and Collective Bargaining Convention, 1949 (No. 98) • Forced Labour Convention, 1930 (No. 29) and its 2014 Protocol • Abolition of Forced Labour Convention, 1957 (No. 105) • Minimum Age Convention, 1973 (No. 138) • Worst Forms of Child Labour Convention, 1999 (No. 182) • Equal Remuneration Convention, 1951 (No. 100) • Discrimination (Employment and Occupation) Convention, 1958 (No. 111) • Occupational Safety and Health Convention, 1981 (No. 155) • Promotional Framework for Occupational Safety and Health Convention, 2006 (No. 187)

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8 // Social Fairness Requirements

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8.1 Human Rights Policy Intended Outcome(s) The applicant is formally committed to respecting and upholding human rights as defined by international standards. Applicable Achievement Level(s) Bronze Requirement(s) Commit to respect human rights, as enshrined in municipal law and internationally recognized human rights standards, through company policy. ---- The policy must: [...] 2. Include the company’s commitment to support the following (Note: These are the expectations that must be established and are referred to as “required policy elements” in other sections of the standard): [...] d. The abolition of child labor and adequate protections for workers above the legal working age and below age 18, [...] Cradle to Cradle Certified® Product Standard, Version 4.1 User Guidance 8.2 Assessing Risks and Opportunities [...] Further Explanation Definition of Human Rights Human rights are rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status. Human rights include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression, the right to work and education, and many more. Everyone is entitled to these rights, without discrimination (https://www.un.org/en/globalissues/human-rights). Internationally recognized human rights are defined in the International Bill of Human Rights (which includes the Universal Declaration of Human Rights, codified through the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights), as well as the eight International Labor Organization (ILO) Core Conventions set out in the Declaration on Fundamental Principles and Rights at Work. The ILO Core Conventions are: [...] • Minimum Age Convention, 1973 (No. 138)

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8 // Social Fairness Requirements

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8.1 Human Rights Policy Intended Outcome(s) The applicant is formally committed to respecting and upholding human rights as defined by international standards. Applicable Achievement Level(s) Bronze Requirement(s) Commit to respect human rights, as enshrined in municipal law and internationally recognized human rights standards, through company policy. ---- The policy must: [...] 2. Include the company’s commitment to support the following (Note: These are the expectations that must be established and are referred to as “required policy elements” in other sections of the standard): [...] d. The abolition of child labor and adequate protections for workers above the legal working age and below age 18, [...] Cradle to Cradle Certified® Product Standard, Version 4.1 User Guidance 8.2 Assessing Risks and Opportunities [...] Further Explanation Definition of Human Rights Human rights are rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status. Human rights include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression, the right to work and education, and many more. Everyone is entitled to these rights, without discrimination (https://www.un.org/en/globalissues/human-rights). Internationally recognized human rights are defined in the International Bill of Human Rights (which includes the Universal Declaration of Human Rights, codified through the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights), as well as the eight International Labor Organization (ILO) Core Conventions set out in the Declaration on Fundamental Principles and Rights at Work. The ILO Core Conventions are: [...] • Worst Forms of Child Labour Convention, 1999 (No. 182)

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8.2 Assessing Risks and Opportunities Intended Outcome(s) Opportunities for improvement are identified and understood as a result of an assessment of human rights risks. Applicable Achievement Level(s) Bronze and Gold Requirement(s) Bronze level: • Assess human rights risks and identify opportunities for improvement for the applicant company, including all final manufacturing stage facilities, and tier 1 suppliers. (Note: Tier 1 suppliers are defined as suppliers to the final manufacturing stage, including in cases where the applicant is using contract manufacturing.) • Demonstrate ongoing efforts to improve visibility and assess risks within the certified product’s supply chain (i.e., beyond tier 1). Gold level: Assess human rights risks and identify opportunities for improvement associated with the product’s components and raw materials (regardless of supply chain tier). Cradle to Cradle Certified® Product Standard, Version 4.1 User Guidance Further Explanation Definition of Human Rights Human rights are rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status. Human rights include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression, the right to work and education, and many more. Everyone is entitled to these rights, without discrimination (https://www.un.org/en/globalissues/human-rights). Internationally recognized human rights are defined in the International Bill of Human Rights (which includes the Universal Declaration of Human Rights, codified through the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights), as well as the eight International Labor Organization (ILO) Core Conventions set out in the Declaration on Fundamental Principles and Rights at Work. The ILO Core Conventions are: [...] • Equal Remuneration Convention, 1951 (No. 100) 8.11 Fostering a Culture of Social Fairness Intended Outcome(s) Socially fair business practices in its governance and management approach are applied by the applicant company. This is reflected by a diverse, inclusive, and engaged workforce and through training, remuneration, and payment of a living wage. Applicable Achievement Level(s) Platinum Requirement(s) Foster a diverse, inclusive, and engaged work environment in which social fairness operates as a core part of recruitment, training, remuneration, performance evaluation, and incentive structures. ---- The following are required: [...] 4. Social performance indicators must include ethnicity-, race-, sex- and age-disaggregated data on hiring, compensation, promotion, demotion, training and mentoring for employees of all levels. Exception: If applicable local laws do not permit collection of all or a portion of the required data, the pertinent portion of the requirement is waived. 5. Data must be evaluated for pay equity, including a comparison of the average wages by ethnicity, race, and gender for work of equal value, and the ratio of the compensation of the CEO or equivalent to the median and average wage of a full-time worker. The exception noted in #4 applies. 6. Pay equity data must be published externally and made publicly accessible. An explanation of differences that may be realized or quantified over time must be included. The exception noted in #4 applies.

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8.1 Human Rights Policy Intended Outcome(s) The applicant is formally committed to respecting and upholding human rights as defined by international standards. Applicable Achievement Level(s) Bronze Requirement(s) Commit to respect human rights, as enshrined in municipal law and internationally recognized human rights standards, through company policy. The policy must: 2. Include the company’s commitment to support the following (Note: These are the expectations that must be established and are referred to as “required policy elements” in other sections of the standard): a. Elimination of discrimination with respect to employment and occupation including, but not limited to, ethnicity-, race- and gender-based discrimination Cradle to Cradle Certified® Product Standard, Version 4.1 User Guidance 8.2 Assessing Risks and Opportunities [...] Further Explanation Definition of Human Rights Human rights are rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status. Human rights include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression, the right to work and education, and many more. Everyone is entitled to these rights, without discrimination (https://www.un.org/en/globalissues/human-rights). Internationally recognized human rights are defined in the International Bill of Human Rights (which includes the Universal Declaration of Human Rights, codified through the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights), as well as the eight International Labor Organization (ILO) Core Conventions set out in the Declaration on Fundamental Principles and Rights at Work. The ILO Core Conventions are: • Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87) • Right to Organise and Collective Bargaining Convention, 1949 (No. 98) • Forced Labour Convention, 1930 (No. 29) and its 2014 Protocol • Abolition of Forced Labour Convention, 1957 (No. 105) • Minimum Age Convention, 1973 (No. 138) • Worst Forms of Child Labour Convention, 1999 (No. 182) • Equal Remuneration Convention, 1951 (No. 100) • Discrimination (Employment and Occupation) Convention, 1958 (No. 111) • Occupational Safety and Health Convention, 1981 (No. 155) • Promotional Framework for Occupational Safety and Health Convention, 2006 (No. 187)

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8 // Social Fairness Requirements

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8.1 Human Rights Policy Intended Outcome(s) The applicant is formally committed to respecting and upholding human rights as defined by international standards. Applicable Achievement Level(s) Bronze Requirement(s) Commit to respect human rights, as enshrined in municipal law and internationally recognized human rights standards, through company policy. ---- The policy must: 1. Establish human rights expectations for the applicant company, the supply chain, communities, potentially affected groups, and other relevant stakeholders. 2. Include the company’s commitment to support the following (Note: These are the expectations that must be established and are referred to as “required policy elements” in other sections of the standard): [...] g. Safe and healthy work, including: i. Access to water, sanitation, and hygiene (WASH), ii. Emergency preparation and response, iii. Hazardous materials handling procedures, iv. Management systems that address health and safety risks, and v. Appropriate building construction, electrical, and fire safety. h. Provision of the legal minimum wage and all legally mandated benefits including employer contributions for social security benefits and services, Cradle to Cradle Certified® Product Standard, Version 4.1 User Guidance 8.2 Assessing Risks and Opportunities [...] Further Explanation Definition of Human Rights Human rights are rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status. Human rights include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression, the right to work and education, and many more. Everyone is entitled to these rights, without discrimination (https://www.un.org/en/globalissues/human-rights). Internationally recognized human rights are defined in the International Bill of Human Rights (which includes the Universal Declaration of Human Rights, codified through the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights), as well as the eight International Labor Organization (ILO) Core Conventions set out in the Declaration on Fundamental Principles and Rights at Work. The ILO Core Conventions are: • Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87) • Right to Organise and Collective Bargaining Convention, 1949 (No. 98) • Forced Labour Convention, 1930 (No. 29) and its 2014 Protocol • Abolition of Forced Labour Convention, 1957 (No. 105) • Minimum Age Convention, 1973 (No. 138) • Worst Forms of Child Labour Convention, 1999 (No. 182) • Equal Remuneration Convention, 1951 (No. 100) • Discrimination (Employment and Occupation) Convention, 1958 (No. 111) • Occupational Safety and Health Convention, 1981 (No. 155) • Promotional Framework for Occupational Safety and Health Convention, 2006 (No. 187)

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8.3 Monitor and Verify Performance Intended Outcome(s) Performance on upholding human rights is monitored and verified, ensuring that corrective actions are taken when poor performance is identified and increasing the level of assurance that risks to human rights are addressed. Applicable Achievement Level(s) Bronze, Silver, and Gold Requirement(s) Bronze level: For final manufacturing stage facilities, measure performance against the human rights policy and confirm the completion of corrective actions associated with issues of high concern including child labor, forced labor, corruption/bribery, and immediate threats to life and safety. For any other poor performance issues, plan corrective actions and, at recertification, demonstrate progress on addressing the issues. Silver level: Request data measuring performance against the human rights policy from all high-risk tier 1 suppliers. At recertification, demonstrate continued efforts to obtain performance data and evidence of tracking corrective actions that may be necessary at tier 1 supplier locations. Gold level: For components and raw materials associated with high risk of child labor, forced labor, or support of conflict, specify or certify to a C2CPII-recognized certification (if available) or equivalent that includes performance requirements aligned with the human rights policy. [...] Required Documentation Bronze Level [...] *The following evidence is required per issue of high concern (Section 8.3 Monitoring & Verification #2a-g): [...] c. Corruption/bribery: Written policies and procedures that document its commitment to the anticorruption and bribery process, including documented consequences for violating the policy. Copies of training content and training schedules to ensure all employees understand the policies and procedures. Existence of whistleblowing channels to support reporting issues.

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8.2 Assessing Risks and Opportunities Intended Outcome(s) Opportunities for improvement are identified and understood as a result of an assessment of human rights risks. Applicable Achievement Level(s) Bronze and Gold Requirement(s) Bronze level: • Assess human rights risks and identify opportunities for improvement for the applicant company, including all final manufacturing stage facilities, and tier 1 suppliers. (Note: Tier 1 suppliers are defined as suppliers to the final manufacturing stage, including in cases where the applicant is using contract manufacturing.) • Demonstrate ongoing efforts to improve visibility and assess risks within the certified product’s supply chain (i.e., beyond tier 1). Gold level: Assess human rights risks and identify opportunities for improvement associated with the product’s components and raw materials (regardless of supply chain tier). ---- For the Bronze level, the risk and opportunity assessment must include all rights required to be included in the policy commitment per Section 8.1 (see the “required policy elements”) at a minimum. The assessment must include: 1. A company-level risk assessment based on conducting desk research, at a minimum, to scope and identify: a. Known, likely, and potential human rights risks associated with the applicant company’s own operations, final manufacturing stage facilities, the product’s supply chain, product use, product cycling, relevant communities, potentially affected groups, and other relevant stakeholders. 2. A tier 1 supplier risk assessment based on knowledge of supplier industry/sector and locations to identify high-risk supplier facilities including those in: [...] b. Locations that are reputed to have conflict, corruption, widespread human rights violations, and/or weak governance.

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8.3 Monitor and Verify Performance Intended Outcome(s) Performance on upholding human rights is monitored and verified, ensuring that corrective actions are taken when poor performance is identified and increasing the level of assurance that risks to human rights are addressed. Applicable Achievement Level(s) Bronze, Silver, and Gold Requirement(s) Bronze level: For final manufacturing stage facilities, measure performance against the human rights policy and confirm the completion of corrective actions associated with issues of high concern including child labor, forced labor, corruption/bribery, and immediate threats to life and safety. For any other poor performance issues, plan corrective actions and, at recertification, demonstrate progress on addressing the issues. Silver level: Request data measuring performance against the human rights policy from all high-risk tier 1 suppliers. At recertification, demonstrate continued efforts to obtain performance data and evidence of tracking corrective actions that may be necessary at tier 1 supplier locations. Gold level: For components and raw materials associated with high risk of child labor, forced labor, or support of conflict, specify or certify to a C2CPII-recognized certification (if available) or equivalent that includes performance requirements aligned with the human rights policy. ---- Required Documentation Bronze Level [...] *The following evidence is required per issue of high concern (Section 8.3 Monitoring & Verification #2a-g): [...] c. Corruption/bribery: Written policies and procedures that document its commitment to the anticorruption and bribery process, including documented consequences for violating the policy. Copies of training content and training schedules to ensure all employees understand the policies and procedures. Existence of whistleblowing channels to support reporting issues.

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7.9 Positive Impact Project Intended Outcome(s) Water and/or soil quality, water quantity, or the health of aquatic and/or soil ecosystems within the catchment(s) where the manufacturer, employees, customers, and/or suppliers are located is improved through initiation or participation in a collaborative project. ApplicableAchievement Level(s) Gold and Platinum Requirement(s) Gold level: Implement a project that will positively impact local and/or product-relevant water or soil issues. Platinum level: Demonstrate the impact of the positive impact project using quantitative metric(s). ---- The project must: 1. Reach beyond the final manufacturing stage facility and into the value chain and/or local community and aim to positively impact aquatic and/or soil ecosystems, local communities, water and/or soil quality and/or water quantity within the catchment(s) where the manufacturer, employees, customers, and/or suppliers are located. 2. Include direct involvement by company employees and/or senior management. 3. Address one or more of the issues identified in the Characterize Local and Product-Relevant Water and Soil Issues requirement (Section 7.1) or otherwise be material to the applicant company. Further Explanation The requirements in this section apply to the applicant company. Selecting a Positive Impact Project Applicants are highly encouraged to select positive impact projects that focus on issues identified in the Characterize Local and Product Relevant Water and Soil Issues requirement (Section 7.1). If the project selected focuses on an issue separate from those identified in Section 7.1 (i.e., otherwise material to the company as permitted in requirement #3), the applicant must provide an explanation of how this issue was chosen and the explanation must demonstrate that the project is relevant to at least one stakeholder group (e.g., employees, local communities, customers, suppliers, other species, or entire ecosystems). Example projects include: • Participation in collective action projects, if any are occurring locally. May include partnering with NGOs (e.g., WWF) focusing on water issues. • Participation in water stewardship industry initiatives (e.g., working to innovate solutions to product relevant water issues such as microfiber pollution for synthetic textiles). • Participating in a local wetland restoration project. • Working with local conservation organization(s) to advocate for increased protection of upstream forest cover (which is relevant to preserving water quality). • Providing drinking water and/or sanitation to the local community when there is lack of access. Actions that occur only once (e.g., a single volunteer engagement) will not receive credit. Once implemented, the project must be ongoing with actions occurring regularly (annually at a minimum). A project that has not yet been implemented (i.e., is only in the planning stage) does not receive credit. The project must go beyond simply making donations unless it is demonstrated that donations occur.

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7 // Water & Soil Stewardship Requirements

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5.3 Increasing Demand: Incorporating Cycled and/or Renewable Content [...] Approved methods The required percentages may be achieved based on minimum content, average content, rolling average content, and/or via a credit method (i.e., mass balance) approach. Note: Credit method (i.e., mass balance, also referred to as mass balance allocation method) is as defined by ISO 22095. The method(s) employed and percentage(s) achieved must be reported publicly via the Cradle to Cradle Certified® Circularity Data Report (see Cradle to Cradle Certified® Circularity Data Report reference document). For chemical recycling, the technology pathway (e.g., depolymerization or pyrolysis followed by hydrocracking or solvent purification), available alternatives, rationale for selecting chemically recycled material over mechanically recycled, and a quantitative or qualitative description of the known and likely environmental and human health related impacts and trade-offs, must also be reported. For the Bronze, Silver, Gold, and Platinum levels: [...] 3. For biological and biologically derived materials associated with extensive evidence of ecosystem destruction due to land conversion and/or poor management practices (e.g., palm oil, wood, peat) to count as renewable, the material must be certified to a C2CPII-recognized responsible sourcing standard, or an alternative equivalent to certification must be in place, that requires: a. Compliance with all applicable laws and regulations of the country in which farming or harvesting operations occur. b. Operations that respect land rights and land use rights, and are unlikely to cause displacement of food production. c. Planning, monitoring, management, and continuous impact assessment for the farming and/or harvesting of material. d. Maintenance, conservation, or enhancement of biodiversity in the forest/vegetation or other ecosystem. e. Maintenance or enhancement of the productive function of the forest/vegetation or other ecosystem area and efficient use of harvested materials (e.g., rate of harvest does not exceed rate of regrowth in the long term). f. Maintenance or enhancement of the health and vitality of the forest/vegetation or other ecosystem and its protective systems (soil and water).

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5 // Product Circularity Requirements

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8.7 Grievance Mechanisms Intended Outcome(s) A mechanism is in place by which employees, customers, suppliers, and other stakeholders may safely report negative effects of business activities and operations and other social fairness concerns to the company in order to obtain redress for those impacts. Applicable Achievement Level(s) Silver and Gold Requirement(s) Silver level: Provide a grievance mechanism that permits company employees and other stakeholders to obtain redress for negative human rights impacts. For any contract final manufacturing stage facilities, request that a grievance mechanism be made available. Gold level: For contract final manufacturing stage facilities, ensure that a grievance mechanism is available that permits employees and other stakeholders to obtain redress for negative human rights impacts.

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8 // Social Fairness Requirements