Scope Certificate and Transaction Certificate Policy Feedback Form

Scope Certificate and Transaction Certificate Policy Feedback Form

TE-TXL-POL-203-V4.0
INTRODUCTION

The Policy for Scope and Transaction Certificates (TE-TXL-POL-203 – V4.0) details criteria and guidance for licensed certification bodies to issue scope and transaction certificates in accordance with any Textile Exchange standard

The revision of the Policy for Scope and Transaction Certificate has been made as part of the development of the Materials Matter Standard to ensure alignment with the new standards system.

As part of the policy revision process, Textile Exchange has initiated a public consultation period to gather feedback on the draft policy. This is an opportunity for all stakeholders to share their comments and thoughts on the proposed criteria.

Key Proposed Changes in the Policy for Scope and Transaction Certificates

The Policy for Scope and Transaction Certificates combines content from the SC Policy (ASR-103-V3.1), TC Policy (ASR-104-V3.1) and section E of the CCS Certification Procedures (CCS-102-V3.1) into a single policy with all relevant criteria. Some key proposed changes include but are not limited to a redesigned product appendix, consignee is replaced with “ship to” along with updates to the criteria, additional data fields for products on a TC which can be traced through the supply chain, and mandatory multi-standard scope certificates.

There are several areas of work which are not yet fully addressed in this draft. Textile Exchange welcomes open feedback on these topics, which include:
- Sector-specific challenges, particularly for sales from final manufacturers to brands and for animal fibers (wool, mohair, and alpaca) prior to the spinning stage.
- Further details about the calculation of material composition. Textile Exchange is developing specific calibration items on the topic of material composition which will be integrated into the final policy.
- Information about the Materials Matter Standard leadership criteria which are met by a specific certified organization (producer or first processor), or about any other optional criteria. This includes any information which is tracked through the supply chain for a specific product.
Please note, that the Template for Scope Certificates (TXL-TEM-203 – V4.0), Template for Transaction Certificates (TXL-TEM-204 – V4.0), and the Scope and Transaction Certificate Standard Specific Details (TXL-POL-204 – V1.0) documents are available for reference and are also open for feedback

Consultation Timeline

The Policy for Scope and Transaction Certificates draft will be open for feedback from January 3, 2025, until January 31, 2025.

Please use this form to submit your feedback after viewing the following policies and documents.
- Read through the draft Policy for Scope and Transaction Certificates here
- Read through the draft Template for Scope Certificates here
- Read through the draft Template for Transaction Certificates here
- Read through the draft Scope and Transaction Certificate Standard Specific Details here.

First, complete the following information:
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YOUR FEEDBACK

If you are clear on which topics, sections, or criteria of the policy draft you would like to comment on, feel free to go directly to the open feedback section and write your responses there.

To do this, select “no” when asked whether you would like to view guiding questions.
Guiding Topics & Questions for your Feedback

The following section has guiding topics and questions based on the key proposed changes in the policy. The topics are divided by whether they apply to scope or transactions certificates and are listed in the order they appear in the policy. The section and criteria reference are included for each topic in case you want to refer to the policy draft.

If there are specific questions you like to comment on, please do so in the text field below each question. You are also welcome to include any feedback that you have on each topic regardless of whether it is a direct answer to a guidance question.
Would you like to see the Guided Questions?
Guided Feedback Questions

General Feedback Questions
Should the Policy for Scope and Transaction Certificates be combined with all the relevant supporting documents (Template for Scope Certificates, Template for Transaction Certificates, and the Scope and Transaction Certificate Standard Specific Details) or do you prefer that these supporting documents remain separate from the policy?
Does the draft standard include all key topic sections and criteria that are needed or are there any critical criteria gaps that do not capture the operations of your organization?
Are there criteria in the current versions of the Policy for Scope Certificates (ASR-103 V3.1) or Policy for Transaction (ASR-104 V3.1) Certificates that you were hoping would be revised in the draft that remained unchanged?
Are there sections or criteria that feel not fully aligned with industry realities?
How do the criteria in the draft standard affect your organization and/or your primary stakeholders?

Topics and Questions for Scope Certificates
Mandatory multi-standard SCs (Section 2.3)

It is proposed that a certified organization or site may only be included on one scope certificate. In cases where an organization or site is certified to more than one standard, a multi-standard scope certificate must be issued.
Do you foresee any complications with this proposed criterion?
If your organization prefers separate scope certificates per each standard, can you explain why this is your preference?
Redesigned Products Appendix (Section 3.7.1)

The product appendix table outlines which products an organization may process or sell and must include the following information (as per the codes in ASR-213): product category, product detail, component (if applicable), raw material, and claims category. It is proposed that organizations may process or sell products based on any combination of listings in the product appendix table, instead of each product needing to be listed individually as is currently required. For more details, please refer to the Product Appendix Table in the Template for Scope Certificates here.
How will the streamlined product appendix impact your ability to manage product listings on scope certificates?
Do you see any challenges with removing raw material percentages from product listings?
What operational benefits or drawbacks do you anticipate with the new "claims categories" field instead of label grade?
If you are a brand or retailer, does creating more flexible product listings potentially add any uncertainty to your claims verification and due diligence process?

Topics and Questions for Transaction Certificates
Multi-shipment transaction certificates (section 4.3)

Criteria in the current Policy for Transaction Certificates (ASR-104 V3.1) requires an “agreement” between a buyer, seller, and seller’s CB to issue a multi-shipment transaction certificate. This language has been removed in the draft policy.
In what ways does this streamline the transaction certificate process for your organization?
Do you see any implications from removing this criterion which will cause problems for your organization?
Consignee replaced with "ship to" along with updated criteria (Section 5.9.2)

In response to industry feedback, Textile Exchange has updated the terminology and criteria related to consignees on transaction certificates. Please review the proposed criteria below, or in section 5.9.2 in the draft policy, and share your feedback on whether this addresses any potential concerns you have on this topic.

Proposed criteria: The ship to facility shall be identified for each shipment as the facility which the seller ships the product to, or the facility identified under the name "ship to" on the purchase order. The ship to facility for the products shall be specified, including name (shipToName) and address (shipToAddress).
- A facility which does not take physical possession of products shall not be named as the ship to.
- If the buyer is certified, the ship to facility should be a facility on the buyer's scope certificate where possible.
- If the ship to facility is listed on a scope certificate, the ship to facility’s TE-ID (shipToTeId) shall be specified. Otherwise, the ship to facility’s TE-ID (shipToTeId) should be specified when available.
- Where the ship to facility is at a port, the specific facility should be specified. It is also allowable for the port to be named. The name of the port may appear in shipToAddress1 when no street address is applicable.
How will changing "consignee" to "ship to" impact your current shipping and transaction certificate processes?
Do you foresee any logistical or operational issues with identifying the “ship to” facility on each transaction certificate?
Are there aspects of the proposed criteria which are not aligned with industry standard practices or the operations of your organization?
If your organization experienced difficulties due to the current criteria on consignee, are there difficulties which the proposed criteria do not address?
List of facilities taking physical possession for each product (Section 5.10.1 & 5.10.3k)

It is proposed that a transaction certificate will need to list all facilities which took physical possession of the product while it was owned by the seller, including both sites and subcontractors. Please refer to the policy criteria for further details.
Do you foresee any challenges or unexpected consequences from this proposed requirement?
Will this create any issues for your transaction certificate process as a buyer or seller?
Does this information provide your organization with valuable information?
Visibility of recycled feedstock waste source (section 5.10.9e)

Proposed criteria: The process code for the source of the reclaimed material as specified on the material declaration form (MDF). Only applicable for reclaimed and recycled materials. Required on transaction certificates from recycler.

If implemented, this criterion would require that waste feedstock information be listed on recycler transaction certificates. This would indicate whether the products on a transaction certificate came from textile-to-textile waste, for example.
Does visibility into the waste source of recycled material provide valuable information for your organization?
If you are a brand or supply chain site in tiers 1-3, do you think this information should be provided on all TCs beyond the recycler?
If you are a recycler or supply chain site, do you anticipate adding information from the material declaration form to transaction certificates to cause any unforeseen problems or issues for your transaction certificate process?
Visibility of recycler process codes/recycling method (section 5.10.9d)

Proposed criteria: The process code for the first processor of the material. Required on all transaction certificates for recycled materials.

If implemented, this criterion would require that the first processor code (as per ASR-213) of the recycler would be listed on all transaction certificates. This would indicate the recycling method for the products on a transaction certificate.
Is having the recycling method captured on each transaction certificate valuable information for your organization?
If you are a recycler or supply chain site, do you anticipate adding this information to cause any unforeseen problems or issues for your transaction certificate process?

END
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Scope Certificate and Transaction Certificate Policy Feedback Form

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Guided Feedback Questions

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