Frequently Asked Questions (FAQs) Regarding the Suspension of CU India
Updated: May 17, 2023
*Important note: as of 17 May 2023, the suspension of CU India has been lifted. As of this date, CU India may resume all certification activities related to Textile Exchange standards, such as (but not limited to) issuing transaction certificates including for certified products shipped while the suspension was in place.
Following are the most common questions received by Textile Exchange during the suspension period. We are still sharing these in case some aspects of the FAQ are still relevant to certified organizations in their processes today, but also for information that is helpful when there are disruptions in the certification process.
Background
The following information is intended to help clarify questions surrounding the suspension of the certification body, Control Union (CU) India. Textile Exchange remains committed to providing ongoing guidance as time progresses and new information is considered relevant and helpful for the community to receive collectively.
We recently issued a calibration that relates to this topic and a guidance document to help you understand, Textile Exchange’s Guidance Regarding the Suspension of CU India.
Additionally, we have issued a new Calibration 232 to address the topic of transfer audits during a CB suspension period. More information on this can be found below. We have also removed the October 1st, 2022 input TC eligibility requirement in Calibration 229, and allow for previously requested TCs to be eligible as part of the transfer as long as they have been input into dTrackit by the preceding or succeeding CB.
FAQs
Can you clarify the sequence of events leading up to the suspension on March 3, 2023?
Textile Exchange assurance for the implementation of our standards is designed around a third-party system that includes independent accreditation of certification bodies (CBs). A fundamental part of third-party credibility includes entrusting accreditation bodies with independent decision-making.
IOAS, CU India’s accreditation body, has suspended CU India’s accreditation to all Textile Exchange standards. The suspension was finalized and the information was made public after an unsuccessful appeal from CU India, effective March 3, 2023. This scope includes India, Bangladesh, and the Philippines, as well as all Textile Exchange standards CU India is accredited for.
Please note that IOAS has specified that CU India is not permitted to issue transaction certificates while the suspension is active, effective as of March 3, 2023.
During the suspension period, CU India may present corrective actions for IOAS to review. June 7th, 2023 is the deadline for IOAS to take a decision on whether Control Union has adequately corrected their non-conformities in order for the suspension to be lifted. If the suspension is not lifted by that date, CU India’s accreditation will be withdrawn from all of Textile Exchange standards and countries included in the current accreditation scope.
A positive outcome will mean that CU India corrects their non-conformities within the required timeframe, the accreditation body reviews and accepts the corrective actions, and the suspension of CU India is lifted for Textile Exchange scopes.
How does the suspension affect previously approved TCs?
Transaction certificates previously issued by CU India are still considered valid – unless otherwise notified by CU India or Textile Exchange.
How does the suspension affect currently pending TCs?
Transaction certificate applications that are currently pending are not allowed to be processed while CU India is suspended.
May materials be sold/shipped without a TC and still potentially have the TC issued?
Yes, material may still move through the supply chain without TCs. If the suspension of CU India is lifted, TCs may be issued subject to the standard timelines and requirements. If the suspension of CU India is not lifted, no TCs will be able to be issued for these products by CU India.
May expired TCs be re-issued?
There is no expiry date for TCs. As long as the TC was issued before the March 3rd 2023 suspension date, it can be used as an input TC in the next stage of processing. If the TC is past the 180-day issuance allowance, it may not be requested again to be reissued.
May material received without a TC still be processed at a certified site?
Yes, material received without a TC may still be processed at a certified site, however, no outgoing TC will be able to be issued until the incoming TC is received.
If I transfer to a new CB, will I need a new audit before my new SC is active, and therefore before TCs are issued, including previously requested TCs?
We have issued a calibration about this topic; you can learn more in our Guidance Regarding the Suspension of CU India.
When an organization transfers between certification bodies (from the “preceding certification body” to the “succeeding certification body”, including when the transfer occurs at recertification), the succeeding certification body may issue transaction certificates for shipments from the time when the organization was certified with the preceding certification body (i.e., previously requested TCs), provided that all the conditions of calibration# 229 are met. Please contact your certification body for more information.
A new audit will need to occur to maintain an active SC. Per Calibration 232 issued on April 18th 2023, a transfer audit may be conducted when the certification body has been suspended for the organization’s scope and is still suspended 7 calendar days before the date the transfer audit is conducted. Transfer audits are abbreviated audits intended to simplify the transition between certification bodies when there may be an urgent need outside of the recertification cycle.
See ASR-112-V2.0 C3.5 for more information about transfer audits.
There will be a cost associated with a new audit. The succeeding CB will be responsible for the costs associated with the audit.
How long should I expect the transfer to take place?
Each situation is unique in terms of different factors that need to be planned. The succeeding CB will be able to provide more information as to the transfer time based on the relevant factors as well as their availability.
At what point is a final product not eligible for claims and labeling?
Products are ineligible for claims and labeling in the following instances: a) the brand is not certified, or b) the brand is certified, but the final product TC from the direct supplier of that shipment is not available or has been invalidated.
Is it normal for TCs to be included in a CB suspension?
The scope of suspension decided by an accreditation body can vary depending on the type and extent of non-conformities found. The scope does not always include suspension of transaction certificate issuance. However, IOAS deemed this to be necessary in the current situation.
Will this happen again in the Textile Exchange system? If yes, what are you doing to ensure back up mechanisms are in place to ensure minimal disruption to the industry?
To maintain impartiality, we cannot influence the decision of accreditation bodies or the severity of the suspension scope. Our objectives are that mitigation is in place to keep CB suspensions rare, but they are an important and necessary tool to ensure the whole system functions as it should. Our primary focus is on the integrity of the certification system; while this is our focal point, we will do what we can to clearly communicate guidance and options to keep things moving and provide information that helps certified organizations make decisions.
In the immediate term, the calibration 229 issued in March provides a scope certificate transfer solution that allows TCs to be issued for shipments that occurred during the suspension period by a new CB based on the availability of TC data in Trackit.
In Calibration 229, why are seed and lint cotton omitted?
Due to the shift from national certification to voluntary systems, this is the highest risk point in the supply chain. For this reason, we have excluded TCs based on seed or lint cotton input TCs from Calibration 229. If the CU India suspension is not lifted, affected shipments may be unable to get OCS TCs. While we are disappointed by this potential scenario, our priority is ensuring confidence in our system.
Is it possible the scope of the suspension will change even if full re-accreditation is not achieved? i.e., Is it possible for specific standards or countries to be re-accredited?
Yes, this is a possibility. This decision would be up to IOAS and CU India.
Where do I find a list of approved CBs for India, Bangladesh, Philippines in case I want to consider transferring?
You can find a full list of CBs on our website here. (You can control/command f and search “India”).
How can I learn updates on CU India’s progress towards potential re-accreditation?
You can reach out directly to CU India or look on IOAS’s website for future updates. Textile Exchange is not able to comment on what other parties involved in this suspension choose to take action on. Please reach out directly to CU India for latest information on their activity.
Do you have any records about CB progress and which percentages/numbers of SCs/TCs from each CB are still not integrated in dtrackit.
To date we have received approximately 42k (~90%) SC records and 250k TC records in dTrackit. The progress varies between CBs. 20 CBs have provided >75% SC data while 8 are below 50%.
It is difficult to pin the percentage of TCs in dTrackit since we have not collected these prior to dTrackIt, but most CBs have been sending TCs dTrackit since October 2022.
Data completeness and quality is an aspect we are actively addressing. As an example, in some cases we may have a TC in dTrackit but the record cannot be authenticated because the authentication process calls for the provision of 6 fields and 2 are missing from what was provided by the CBs. To address this, we have released a restriction logic in our ingestion process and are actively working with CBs to close the gap.
[NEW] An organization has asked: Regarding Transaction Certificates (TCs) that have been applied for prior to the suspension period and are in CU India’s TC pipeline, there are supply chain partners who are certified by CU India but are now moving to other certification bodies. This transfer could take several weeks due to the limited capacity of other certification bodies. This would mean the time of TCs being issued will take longer and may exceed 180 days. Will Textile Exchange make an exception and allow TC issuance period to exceed 180 days due to this suspension?
If and when CU India’s suspension is lifted, they will be allowed to issue these TCs following our standard criteria. The nature of this question is what happens when the normal procedure for the 180-day timeline has passed in the case of transferring to a new CB. Textile Exchange has provided a limited exemption to CBs as follows:
EXEMPTION LANGUAGE
Exemption 334 – Control Union India TC applications over 180 days
Some transaction certificate applications were submitted to Control Union India within 180 days of the first shipment date but were left unprocessed upon the suspension of this certification body. When some organizations tried to apply Calibration 229 after transferring to another certification body, they found out that the application had gone over 180 days and Calibration 229 doesn’t address ASR-104-v3.0 A8.3 to allow the issuance of those transaction certificates.
Textile Exchange is granting all certification bodies a limited exemption to A8.3 of ASR-104-v3.0 to issue transaction certificates when more than 180 days pass by between the earliest shipment date and the certification body receiving a complete and valid application, provided that all of the following conditions are met:
1. The exemption is limited to sellers who were certified by Control Union India on March 3, 2023.
2. The seller has subsequently transferred from Control Union India to another certification body.
3. The complete and valid transaction certificate application is received by the certification body no later than June 1, 2023.
4. The criteria of Calibration 229 and all other applicable transaction certificate issuance criteria are met.
An organization has asked: if our Scope Certificate (SC) has expired or is about to expire (previously issued by Control Union) and the new Certification Body may take several weeks to issue a new scope certificate, can shipment of materials proceed?
Organizations need to have a valid SC at the time shipments are made for the product to be eligible for a Transaction Certificate (TC). CU India is allowed to recertify their current clients during the suspension. If an organization chooses to change CBs and the new CB cannot issue an SC before the expiry of the SC with CU India, the organization will have a gap in certification where no TCs are possible.
[NEW] An organization has asked: we have certification for other materials from Control Union (CB). Should we go for an annual renewal with CU India or search for another Certification Body?
Textile Exchange is not able to advise if organizations should change certification bodies, for our standards or any others. CU India clients for our standards are not required to change certification bodies at this time to remain certified or get a SC renewal. Information is provided in the FAQ to help organizations make decisions based on their circumstances. It is always best to check with your current CB for the latest information as part of this decision.
[NEW] An organization has asked: the GOTS input Transaction Certificate (TC) is no longer allowed to provide Organic Content Standard (OCS) certification. We have to provide farm certificates, etc., now to change over GOTS input TC to OCS output TC. With CU India suspension, this is further complicated as most of the ginners and spinners in India are with GOTS. Can we have a waiver for more time?
Following changes in our systems in 2022, Textile Exchange requires that additional documentation be provided when GOTS inputs are to be used for OCS certified products. We recognize that this adds complexity to TC applications. TCs with GOTS inputs will be able to be issued by CU India if and when the suspension is lifted, or by a new CB following a transfer if the criteria of Calibration 229 are met.
[NEW] An organization has asked: if we change Certification Bodies (CBs) for a new scope certificate, does our raw material supplier also need to get certified with a new CB?
CU India clients are not required to change certification bodies at this time. Any certified organization may buy from a supplier who is certified with any certification body for the same scope. Suppliers certified by CU India will not have TCs until the suspension is lifted.
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