WALMART USA APPAREL TESTING MANUAL. Revised: July 2010

WALMART USA APPAREL TESTING MANUAL Issued: May 6 th 2008

Table of Contents 1. Introduction...6 1.1. Color Process Flow Chart...7 1.2. Pre-Production and Production Testing Flow Chart...8 1.3. In-Store Quality Audit Flow Chart...9 2. Regulatory Compliance...10 3. Testing Process for Apparel...11 3.1. National Brands Testing Process...11 3.2. Private Brands Testing Process...11 3.3. In-Store Quality Audit Process...12 3.4. Walmart Exception Orders...14 3.5. Test Report Ratings...15 3.6. Defect Classification...15 3.7. Quality College...15 3.8. Testing Turn-Around Time...16 3.9. What to Submit...16 3.10. When to Submit Pre-Production and Production Samples...17 3.11. Where to Submit Pre-Production and Production Samples...18 3.12. Flammability Test Process for Children s Sleepwear...18 4. Children s Apparel...20 4.1. Private Brand Garments...20 4.2. Children s Apparel Mechanical Hazards...20 Small Parts 1

Small Parts Labeling Sharp Points Sharp Edges Abuse Testing Torque Testing Tension Testing 4.3. Apparel Trim/Hardware...22 4.3.1 Press Fasteners...22 Approved Press Fastener Suppliers 4.3.2 Zippers...23 Invisible Concealed Zippers Zipper Pulls Zipper Pull Attachments Approved Zipper Suppliers 4.3.3 Dungaree Clips (Hasps) and Sliders...26 Approved Dungaree Clips (Hasps) and Slider Suppliers 4.3.4 D-Rings...27 4.4. Drawstrings, Cords & Ties (Functional and Decorative)...27 Metal Chain Cords/Ties Maximum Length Requirements Neck Area and Hood Below the Ankle and Below the Elbow Chest, Leg, Waist, Hip, and Above the Elbow Areas Internal Functional Drawstring/Cord 4.5. Adjustable Waistbands...31 4.6. Sashes & Thin Ties Tied at Waist Area (Dresses and Tops)...32 4.7. Belts...33 4.8. Bath Robes...35 4.9. Fixed Bows...35 4.10. Functional & Decorative Loops...35 Belt Loops Back Neck (locker) Loops Hanger Loops Hammer Loops Under-Chin Ties on Hats 2

Under-Chin Straps on Hats 4.11. Hats/Caps...36 4.12. Halter Neck Style Garments and Baby Bibs...38 4.13. Neck Ties...38 4.14. Toggles & Toggle Buttons...39 Toggles Toggle Buttons Pig Nose Toggles (Cord Lock) / Spring Loaded Toggles Decorative Application Functional Application 4.15. Button and Buttonsew...40 Buttons Buttonsew 4.16. Hook & Loop Fastener Tape...41 4.17. Thread Ends & Float Threads...41 4.18. Decorative Trims & Embellishments...41 Appliqués & Embroidery Beads & Jewels Sequins Diamante (Rhinestones) & Metal Studs Pom-Poms & Fringe Fake (Faux) Fur Natural Feathers 4.19. Miscellaneous Requirements...42 4.20. General Wearing Apparel Flammability Requirements...43 4.21. Children s Sleepwear/Loungewear Flammability Requirements...43 4.22. Polyvinyl Chloride in Children s Bibs...44 5. Performance Specifications...45 5.1. General Requirements...45 5.2. Colorfastness Properties...46 3

5.3. Woven Fabrics...47 Woven Natural Cellulosic Woven Man-made Cellulosic Origin Woven Man-made Synthetic Woven Silk, Wool, Animal Hair Denim Woven Pile Fabrics 5.4. Knit Fabrics...52 Weft Knits Warp Knits Knit Undergarments Hosiery - Socks and Tights Sweaters 5.5. Leather/Suede Apparel...56 5.6. Accessories...56 Belts, Caps, Ear Muffs, Gloves, Hair Accessories, Hats, Mittens, Neckties, Scarves, Ski Headbands, Ski Masks, Stocking Caps, Suspenders and Pet Accessories 5.7. Products with Special Claims...58 5.8. Zipper Performance Standards...59 Appendix A...60 Defect Type Classifications Appendix B...70 Express Test Exceptions Appendix C...71 Corrective Action Plan (CAP) Process Appendix D...72 Children s Body Weight Tables Appendix E...73 Standard Fabric Testing Process for Walmart Private Brands 4

Appendix F...74 Approved Trim Suppliers Appendix G...75 Walmart Designated Independent Testing Facility Testing Laboratory Locations Information Communication to Suppliers Invoicing and Payment Terms Summary of Testing Charges 5

WALMART Stores, Inc. 1. Introduction and Process Flow Charts It is our goal to deliver quality products to the Customer in a faster and more cost effective way. This manual allows us to accomplish this. In addition to the above objectives this manual outlines the procedures, performance specifications and regulatory requirements for Walmart Apparel. Walmart relies on all suppliers to be knowledgeable about the current industry and regulatory requirements of the products they are supplying. Adherence to these standards is not optional. It is the suppliers responsibility to fully understand and accurately interpret the information in this manual. If you are in doubt as to the applicability of any law, standard, or regulation that applies to products that you intend to supply to Walmart, please seek advice from your legal counsel or Technical Representative. DO NOT RELY EXCLUSIVELY ON THIS MANUAL AS YOUR ONLY SOURCE FOR DETERMINING REGULATORY OR INDUSTRY STANDARDS. Walmart is committed to product safety. Our customers trust us and expect us to provide them with safe products. Therefore, we expect all suppliers to have the same commitment to this important aspect of quality. Changes to the Manual Supplier Sample Submissions - All suppliers, both Domestic and Direct Import have a choice to submit Color swatches (Lab Dips, Shade Bands, etc.) and Apparel items to either the Bentonville or Hong Kong laboratories. However, once a location is chosen, all subsequent testing for that item and coordinating items, including Color Evaluation, Pre-Production, Production and Retest must occur in the same facility. Corrective Action Process (CAP s) CAP s are required for Critical Regulatory Failures. CAP s are no longer required for Critical Walmart Failures. Consumer Testing Laboratories, Inc. (CTL) is the designated independent accredited testing facility for all Color Evaluation and Apparel items for the USA Retail Division of Walmart Stores, Inc. 6

1.1 CTL Color Approval Process, Apparel 1. Electronic Submits are sent to the testing laboratory ctlcolor@consumertesting.com or through your DataColor Track Software 2. Electronic Color Questions or standards are sent to the testing laboratory ctlcolorlab@consumertesting.com Save LDE as SBE Standard Submit SBE to Test Lab Submit Requested SB to Test Lab Yes Pass? Yes Pass? Restart SBE Process Continue, Restart SB Process No Submit LD to Test Lab Yes Pass? No Restart SBE Process After 2 failures, request review through the Test Lab Colorrev@consumertesting.com Yes No Submit LDE to Test Lab Pass? Restart LDE Process Submit Substrate to Test Lab Yes Is Electronic Color Required? No Restart LDE Process Yes After 3 failures, request review through the Test Lab Colorrev@consumertesting.com Submit SB to Test Lab Yes Pass? Continue, Restart SB Process No Submit LD to Test Lab Pass? No Restart LD Process No After 3 failures, request review through the Test Lab Colorrev@consumertesting.com Restart SB Process After 2 failures, request review through the Test Lab Colorrev@consumertesting.com 7

1.2 Pre-Production and Production Testing Process, Apparel Yes Send a memo defining the testing needs Sample + 2 yds of fabric sent to Test Lab for testing from Supplier Garment is Tested Rating? Pass/ Marginal Pass Approved to cut Garments Monitor the PO via the Host System Is Testing Needed? Supplier Improves the Garment and retests Fail Supplier sends all sizes/colors @ 10% complete point Verify Gold Seal Approval is done No Test Lab notes compliance in the System Pre-Production Garment is Tested Production Rating? Pass/ Marginal Pass SHIP SHIP Major & Critical Walmart Fail Critical Regulatory Pass /Marginal Pass Rating? Supplier resubmits sample for testing CAP is written and submitted to Test Lab. Test Lab evaluates CAP Fail Supplier and NY Apparel Office for Private Label and Supplier and Buyer/DMM for National Brands No Is CAP approved by Test Lab Yes Supplier resubmits sample for testing Rating? Fail Good/Marginal Pass SHIP Order Cancelled No Approved for shipment? Critical Regulatory Failures WM Compliance Dept. (only one retest may be approved) SHIP Yes Order Cancelled No Approved for shipment? Yes SHIP 8

1.3 In-Store Quality Audit Process, Apparel Test Lab identifies what styles are needed from the store by using the Walmart PO Test Lab researches each instore item via Retail Link to ensure availability of store inventory Major Failures Report sent to Supplier and NY Apparel Office for Private Label or Buyer/DMM for National Brands Test Lab personnel pulls identified items from stores (Full size/full color range) Pass/Marginal Pass Testing process (reference production testing process) Rating? Fail Critical Regulatory Failure generates immediate High Sampling Retest Critical Walmart or Major Failures -High Sampling Retest determined by NY Apparel Office for Private Brands or Buyer/DMM for National Brands High Sampling Retest required Rating? Fail Critical Failures Pass / Marginal Pass Critical Regulatory Critical Walmart Report sent to Supplier and Walmart Compliance Report sent to Supplier and NY Apparel Office for Private Label or to Buyer/DMM for National Brands who will notify Compliance Department for Product withdrawal Recall Product Walmart Compliance reports Recall to CPSC In-Store Quality Audit complete and report sent to supplier High Sampling Retest NOT required In-Store Quality Audit Basic replenishment - pulled seasonally and/or quarterly Fashion - pulled seasonally and/or quarterly Previous failed samples - pulled as soon as available in the store Non-compliant suppliers - pulled as soon as available in the store Special Pulls - as requested by Walmart Management 9

2. Regulatory Compliance Walmart Suppliers must comply with all laws, including Federal, State and Local laws as required under the Supplier Agreement. Walmart reserves the right to monitor compliance through inspection, testing or audits. Walmart Compliance Department manages regulatory and safety requirements for apparel. Walmart Compliance Department s regulatory requirements can be accessed through Retail Link using the web address provided below. https://retaillink.wal-mart.com/rl_posting/view_review.aspx?docid=2868&ukey=w4116 Walmart does not provide legal advice to its supplier. Suppliers should seek their own legal counsel on how to comply with all laws applicable to their product. For information on Product Safety & Compliance, please visit the following web sites: Consumer Product Safety Improvement Act http://www.cpsc.gov/about/cpsia/cpsia.html California Air Resource Board Formaldehyde in Composite Wood Products http://www.arb.ca.gov/toxics/compwood/compwood.htm Lacey Act http://www.aphis.usda.gov/plant_health/lacey_act/index.shtml Questions gmcomply@wal-mart.com 10

3. Testing Process for Apparel The purpose of this section of the Apparel Testing Manual is to outline the responsibilities of Suppliers and the Designated Testing Laboratory as it relates to the testing process itself. It also defines testing processes for National Brands and Private Brands Suppliers. For Private Brands it details the Tiering system that looks at past testing history of suppliers and tiers suppliers by that performance. The remainder of this section outlines other commitments required of Suppliers and the Testing Laboratory. Please refer to Appendix G for the information on the designated testing facility for all apparel products for the USA Retail Division of Walmart Stores, Inc. 3.1 National Brands Testing Process This section identifies testing process for Walmart National Brands and their testing protocols. Note: The following testing process also applies to Licensed Merchandise. No Color Testing unless there is a Walmart CSI Color used Pre-Production Testing for Children s Critical Regulatory and Critical Walmart criteria Production Testing for all styles In-Store Quality Audits performed quarterly National Brands Suppliers performance will be reviewed bi-annually and additional testing requirements may be applied to below average suppliers. National Brands Production Test failures are sent to the appropriate Department Buyer or DMM for resolution. In-Store Critical Regulatory and Critical Walmart failures are sent to the Buyer or DMM who will notify the Walmart Compliance Team. In-Store Critical Regulatory High Sampling Retest (HSR) Failures will be sent to Walmart Compliance. In-Store Critical Walmart High Sampling Retest Failures will be sent to the Buyer/DMM who will notify Compliance Department for Product withdrawal from stores. Note: A second Production level test is required for all Children s items which remain in stores longer than 6 months. 3.2 Private Brands Testing Process This section identifies a Tiering system for Private Brands testing that is reward based. It tiers suppliers based on their past testing performance and rewards better performing suppliers with less testing while focusing on average and poorer performing suppliers. Poor performing suppliers risk cancellation or elimination of future orders. Tier I - Less than 5% Failure Rate, No Critical Regulatory Failures - Production Testing for all styles (Critical Regulatory and Critical Walmart criteria only) - Two (2) day testing turnaround at no extra cost 11

Tier II - Between 5% and 10% Failure Rate, no more than 1 Critical Regulatory Failure - Full Production Testing for all styles - Four (4) day testing turnaround Tier III Greater than 10% failure rate or more than 1 Critical Regulatory Failure - Full Pre-Production Testing for all styles - Full Production Testing for all styles - Five (5) day testing turnaround - Different Countries of Origin or newly introduced colors require additional separate testing. ** All performance criteria is based on a prior 12 month performance, but reviewed bi-annually. Note: Regardless of Tier, a second Production level test is required for all Children s items which remain in stores longer than 6 months. All Private Label items must receive Standard Fabric Testing (SFT) approval per the SFT process (see Appendix E). In-Store Quality Audits To insure consistency of quality of merchandise in the stores and on-going compliance with all Critical Regulatory and Critical Walmart requirements, all styles will undergo In-Store Quality Audits on a quarterly (seasonal) basis. Laboratory Report Distribution and Failure Resolution Critical Regulatory Failures 1. Production Failures and Production Retest Failures will be sent to the Supplier. Production Retest Failures will be sent to Walmart Compliance with a copy to the NY Apparel Office, Buyer/DMM. 2. In-Store Failures will be sent to the Supplier and Walmart Compliance with a copy to the NY Apparel Office, Buyer/DMM. 3. Production Corrective Action Plans (CAP s) will be requested and evaluated by the testing laboratory. Critical Walmart Failures 1. Production Failures will be sent to the Supplier and the NY Apparel Office. 2. In-Store failures will be sent to the Supplier and the NY Apparel Office. The NY Apparel Office will contact the Compliance Department. All Major (non-critical) failures will be sent to the Supplier and to the NY Apparel Office for resolution. 3.3 In-Store Quality Audit Process In order to insure that merchandise meets Federal and State requirements, Industry Standards, and our Customer s needs, the testing laboratory will test merchandise pulled directly from Walmart stores sales floors. This section identifies what will be pulled from stores and defines the testing protocol in place if this initial In-Store Quality Audit fails testing. For the initial In-Store Quality Audit all sizes and colorways representative of each style will be pulled from the stores with a minimum of 4 garments per style. Additional testing of failed In- Store goods (High Sampling Retest) will/may occur when the Initial In-Store Quality Audit 12

results in a Critical Regulatory or Critical Walmart Test Failure (see High Sampling Retest section below). High Sampling Retest for Major or Minor failures will be at the direction of the NY Apparel Office for Private Brands or the Buyer/DMM for National Brands. If the same style is packaged differently (i.e. different case packs), only 1 test of that style will be tested. Different Countries of Origin or newly introduced colors require additional separate testing. The Initial In-Store Quality Audit During the initial In-Store Quality Audit, all items will be pulled for testing as soon as garments are available in stores. Full testing will be conducted, including Critical Regulatory and Critical Walmart compliance reviews, performance and color match testing, as applicable. High Sampling Retest A High Sampling Retest is conducted when an initial In-Store Quality Audit fails. - Critical Regulatory In-Store failures will immediately generate a High Sampling Retest. - Critical Regulatory Failures have a zero tolerance level and any failure will result in a Product Recall from the stores. - Critical Walmart and Major In-Store Failures will generate a High Sampling Retest only at the direction of the NY Apparel Office for Private Brands; and at the direction of Buyer/DMM for National Brands. High Sampling Retests will be pulled from 5 regions of the country and subjected to retesting for the failure attribute only (not full testing) unless full testing is requested by Walmart. The High Sampling Retest piece count will be based on the chart on the next page. The total required piece count for the High Sampling Retest will be accomplished by pulling equal quantities of samples from 5 Walmart regions of the country. The decision to pass or fail the product will be determined by the number of defects per acceptance and rejection level shown in the chart below. For the purpose of High Sampling Retest, multiple defects within the same garment will represent one (1) rejection. The total number of samples required for testing will be based on the sampling plan procedures outlined in ANSI/ASQ Z1.4 - Sampling Procedures and Tables for Inspection by Attributes (known as Military Standard), Special Inspection Level S-4, Single Sampling Plan for Normal Inspection (Table II-A of the Standard). Order Size Sample size Number of Major and Critical Walmart defects: acceptance/rejection Up to 10,000 pieces 32 pieces 2 / 3 10,001 to 35,000 pieces 50 pieces 3 / 4 35,001 to 500,000 pieces 80 pieces 5 / 6 500,001 and up 125 pieces 7 / 8 13

Important Note: Critical Regulatory failures have a zero tolerance level and any failure will result in a Product Recall from the stores. 3.4 Walmart Exception Orders Flow of fashion-right product remains a key Walmart strategy, which requires certain orders to use very quick lead times. These fast orders require a different approach that streamlines the approval and testing process, while maintaining quality and consistency of product. Exception orders are buys made outside of the normal milestone deadlines in order to react to market direction or fashion trends. Note: It is the Suppliers responsibility to only accept orders that enable the proper approval process as defined below. Items must be clearly identified by the prefix code in the style # for the GDP/ SQ, purchase orders and testing applications for all exception orders. All test results must be satisfactory to ship. If not then Walmart approval must be given. 3.4.1 Exception Order Requirements Analysis Type of Order Fast Fashion- A normal size order where delivery is paramount and the buy is outside of the regular milestone meeting. Pick-Up Buy- An order where goods are already existing Test Order- An order where units are small to test future buys. Emerging Brand Brands new to Walmart VP/DMM Approval Needed Pre-Production Testing Color Testing Production Testing In-Store Testing Aesthetic Review Required Not needed If applicable Required Required Required Required Not needed Not needed Required Required Required Required Not needed Not needed Required Required Required Required Not needed Not needed Required Required Required Gold Seal Approval is not required for Pick Up Buy because the goods are already existing. Gold Seal Approval is not required for Fast Fashion and/or Test Order, but GDP s must be approved by NY Tech Designers to ensure grades are used and proper documentation exists to enable in-store quality audits being done effectively. It is the expectation that product will pass in-store testing for all attributes including specifications. This is inclusive of all Hot Spot items, Annual Event. For Emerging Brand Orders, approval must be given with a specific time frame defined to allow the Supplier to navigate the normal testing pipeline. 14

3.5 Test Report Ratings The completed test report which suppliers receive will be rated one of three ways: Pass, Marginal Pass or Fail. This section identifies defects that lead to these ratings and where a supplier will be tiered. It will also determine future testing requirements for those suppliers. PASS: The sample has no Critical Regulatory, Critical Walmart, Major, or Minor Defects as defined in section 3.6 and as listed in Appendix A. MARGINAL PASS: All products with Minor Defects (see Appendix A for minor defects classification) and minor deviations from standards, as decided by the laboratory, will be rated Marginal Pass. Marginal Pass rating is an approval for supplier to ship goods In situations where numerous violations of approved standards continue, these ratings could result in future test failure. Suppliers should insure that they adhere to the Walmart Apparel Standards and implement a running change in the manufacturing process for future orders improvement. Walmart reserves the right to cancel any order with a Marginal Pass rating. FAIL: The sample has Critical Regulatory, Critical Walmart, or Major Defects as defined in section 3.6 and as listed in Appendix A. 3.6 Defect Classification Defects are classified according to the nature and severity of the defect. Defect classification will determine the Pass, Marginal Pass or Fail rating received on the test report. Below is an explanation of defect classifications and the types of defects found in those classifications: Critical Regulatory Product that is non-compliant with government regulations Critical Walmart Walmart requirements that are not covered by law. Major Likely to result in customer complaint or return Minor Unlikely to result in customer complaint or return Refer to Appendix A for a list of defect classifications. 3.7 Quality College Quality College is critical to understanding the testing process and test results. Quality College puts the Supplier and the CTL Technical Support Group together in an effort to clarify and resolve supplier s questions and/or address supplier quality issues. New Walmart Suppliers will automatically be invited to Quality College as part of an on boarding process. 15

The Process The Test Lab identifies suppliers that have quality issues, are not complying with the Walmart testing program or are having inconsistent test results The Test Lab invites suppliers to meet with Technical Support group The Test Lab identifies to the supplier those issues to be resolved (i.e. quality issue, inconsistent test results) Supplier meets with The Test Lab Technical group to discuss the Quality issues After the meeting supplier is requested to provide The Test Lab with a written plan of action identifying how and when the quality issues will be resolved Post meeting tracking of supplier performance will be completed by The Test Lab. Ongoing detailed reporting will be provided to Walmart identifying results of the Quality College Plan submitted by the supplier All Tier II and Tier III Suppliers will be invited to Quality College Walmart Management may request a Quality College for any supplier or suppliers may request one themselves. These sessions with the CTL Technical Support Group will address any questions or concerns suppliers may have. 3.8 Laboratories Commitment to Suppliers - Testing Turn-Around Time Standard Testing Turn-Around Time See section 3.2 Private Brands Testing Process for Standard Testing Turn-Around times. Express Testing Services are available at extra cost. Express Testing is a two day (48 hours) turn-around excluding the day the product is received. Express Testing by Supplier Tier Tier 1 Suppliers Express testing is not needed as standard turn-around time is 2 days, at no extra charge to suppliers. Tier II and Tier III Suppliers Express Testing is available at two times the regular testing charge. Certain products may require specialized testing protocol, and therefore may result in extended time for testing. The test lab will not be able to conduct Express Testing for these samples. Please refer to Appendix B for a list of products that cannot be express tested. 3.9 The Supplier s Commitment - What to Submit Pre-Production - For each body style the supplier must submit two prototype garments with all production quality trims, hardware, and attachments, along with 2 yards of production quality fabrics in each additional color to be shipped to Walmart stores. A product is considered to have the same body style if the following criteria are identical: Country of origin Garment construction Fiber content and fabric construction Size specs Trims Rib construction 16

Pre-Production Retest Pre-Production failures require the supplier to make corrections to the fabric or garment to address the failure attribute. The supplier can then submit a new set of garments / fabrics for retesting of the original failure attribute. The supplier must receive a passing Pre-Production Test report before proceeding with garment production or submission of Production Testing set. Production When 10% of garment production is complete, the supplier must submit garments representing all sizes and colorways for Production testing. For each body style, the supplier must submit two garments of each colorway. The entire submission must include at least one garment of each size. Note: Critical Regulatory failures require the supplier to submit a Corrective Action Plan (CAP) for the failure. (refer to the CAP process as outlined in Appendix C Corrective Action Plan (CAP) Process). Production Retest - will require the supplier to re-submit samples to be tested only for the failure attribute found during Production Testing. Only one (1) Production Retest is allowed for Critical Regulatory Failures. Premium Gift with Purchase Program A premium gift with purchase is defined as an item/gift offered as a bonus with the purchase of a primary item. The supplier of the gift will submit the product for Pre-Production testing. Once the premium gift product receives a passing test, the supplier of the primary item will then submit the primary item, the gift with the passing test report, and the packaging as a final product for Production testing to the primary item testing laboratory. Additional Supplier s Documentation The following documentation must be submitted with each Pre-Production or Production sample as applicable: - Certificate of Compliance (COC) as required by Walmart Regulatory Standards and per Toxics in Packaging Regulations (TIP). - Supporting documentation for labeled claims, such as chemical free. - Organic Cotton Certificate from a Walmart approved certifier for organic cotton Please review the appropriate testing protocol for your product prior to sample submission to determine documentation to submit with your product. Note: All independent laboratory reports must be dated within one (1) year of sample submission to the testing lab. An exception to this is Toxicological Risk Assessment (TRA) reports, which have a two (2) year period. 3.10 When to Submit Pre-Production and Production Samples Suppliers are responsible for passing all required testing and should not wait for the Test Lab notification forms in order to submit samples to the laboratory for testing. As per direction from Walmart, the Testing Laboratory monitors the testing process by reviewing all Purchase Orders to ensure all orders are tested in compliance with the Walmart testing requirements. This monitoring is accomplished by reviewing the testing status of all Purchase Orders, and if testing is not complete, the applicable Testing Notification Forms will be issued as follows: 17

Pre-Production Testing Notification Forms will be forwarded to the supplier 60 days prior to the shipping date. Production Testing Notification Forms will be forwarded to the supplier 30 days prior to the shipping date. If the supplier fails to submit Pre-Production or any required Production samples for testing 15 days prior to the shipping date, the Test Lab will issue a Non-Compliance Testing Notification Form. 3.11 Where to Submit Pre-Production and Production Samples Suppliers are responsible for submitting samples to the testing laboratory. All suppliers, both Domestic and Direct Import, have a choice to submit Color swatches (Lab Dips, Shade Bands, etc.) and Apparel items to any designated laboratory. However, once a location is chosen for Color Approval, all subsequent testing for that item and coordinating items, Pre-Production, Production and Retest, must occur in the same facility. For the designated laboratory locations, please refer to Appendix G. 3.12 Flammability Testing Process for Children s Sleepwear (16 CFR 1615/1616) This testing process applies to all children s sleepwear items such as nightgowns, pajamas, or similar related items such as robes and loungewear, which are intended to be worn primarily for sleeping or activities related to sleeping. All fabric production units (FPU), all prototype trim and seams and all garment production units (GPU) must be tested prior to shipment. Note: No GPU will be tested unless the FPU and prototype trims and seams tests have passed testing. No exceptions are allowed. Retest of Samples that Failed Flammability Testing Only one (1) retest will be allowed on a fabric or garment production unit and any prototype seams or trim that fails the children s sleepwear flammability test. Submitting Samples for Children s Sleepwear Flammability Program Suppliers are responsible for submitting all samples to the designated testing laboratory for flammability testing. For testing locations, please refer to Appendix G. Required Sampling for Flammability Testing following a Normal Plan Fabric Production Units (FPU) When submitting fabric for flammability testing, send at least two (2) yards of the production quality fabric; At least one (1) yard should be cut from the beginning of the first piece and the end of the last piece in the 5,000 yard unit. If the unit is made up of only one piece, at least one (1) yard should be cut from the beginning and the end of that piece. Label each piece accordingly (beginning or end). 18

Note: If the 50x wash requirement applies, send a total of four (4) yards from the FPU. Two (2) yards cut from the beginning and two (2) yards cut from the end. Prototype Seam when submitting prototype seams for flammability testing, make a sufficient number of prototype seams to obtain up to six (6) sample sets of five (5) specimens (30 individual specimens) from each seam to be tested. The seam(s) should be constructed using the longest seam type and any other seam types ten (10) inches or longer to be included in the garment. Prototype Trim when submitting prototype trim for flammability testing, provide enough to obtain up to six (6) sample sets of five (5) specimens (30 individual specimens) from each type of trim to be included in the garment.. Note: Prints (screen or sublistatic) are considered trim for flammability testing purposes. The trim should be constructed using the criteria described below: - Garments with Horizontal Trim Configurations - prepare the specimens by sewing or attaching the trim horizontally to the bottom edge of an appropriate section of untrimmed fabric. If more than one row of trim is used on the garment, the specimens must be prepared with the same configuration as the garment. - Garments with Other Trim Configurations prepare the specimens by sewing or attaching the trim to the center of the vertical axis of an appropriate section of untrimmed fabric. Be sure to begin the sewing or attaching at the lower edge of each specimen. Note: For either configuration the sewing or attachment must be made in the manner in which the trim is attached to the garment. The sewing and attaching must be done with thread or fastening material of the same composition and size to be used in the garment, using the same stitching or seam type. Production Testing for Flammability when submitting production garments for flammability testing, randomly select a sufficient number of garments from each garment production unit (GPU) for the laboratory to obtain three (3) samples (15 individual specimens) from the longest seam type. Testing Application Form for Flammability a completed Testing Application Form must be included with each fabric and garment production unit submitted for testing. Reference must be made on the application form of all previous lab report numbers. Please refer to Appendix G of this manual regarding the on-line application process. Note: If any In-Store product is found without passing Production Flammability testing, the Supplier will be put on notice which may result in loss of order for a season (minimum). If you have any questions about the procedures for submitting samples please contact the appropriate laboratory directly at the telephone and address as listed in Appendix G. 19

4. CHILDREN S APPAREL Walmart Compliance Department manages regulatory requirements for apparel and provides direction for associated failures. Walmart Compliance Department regulatory requirements can be accessed on retail link using the following address. https://retaillink.wal-mart.com/rl_posting/view_review.aspx?docid=2868&ukey=w4116 4.1 Private Brand Garments All press fasteners, zippers, dungaree clips (hasps) and sliders must be from an approved Walmart trim supplier. If during the testing process it is not possible to determine whether a component is from an approved supplier, the testing laboratory will require documentation (i.e. invoice) to substantiate the component used is from an approved supplier. For the approved list of trim suppliers, please refer to Appendix F. 4.2 Children s Apparel Mechanical Hazards Components used on children s apparel, such as zippers, drawstrings, fasteners, and decorative attachments must not present any hazards to children during normal use, or as a result of reasonably foreseeable damage or abuse. For the purpose of this document the following correlation has been established to relate the age of a child to the appropriate apparel size. Size Age 0-9M Under 1 yr 12M-5T 12M to Under 3 yrs Girls 4-6X / Boys 4-7 3 years to 8 yrs Girls 7-20 / Boys 8-20 9 yrs & up Note: For clarity, the remainder of this section will refer to size (not children s ages) when specifying requirements. Small Parts Small components that become detached from children s apparel through normal use, or reasonably foreseeable damage or abuse can present choking, aspiration, or ingestion hazards to young children. If the component can fit entirely within the small parts cylinder shown below, without being compressed, it is considered a potential choking hazard. 20

Examples of small parts found on children s apparel include, but are not limited to: Snaps/Rivets Zipper Components Dungaree Clip (Hasps) & Slider Toggles Decorative labels Pom-poms & Fringe Appliqués Eyelets & Grommets Aglets (plastic sleeves) Buttons Belt fastenings Bows and Rosettes Stud Buttons Hook & Loop Tape Decorative & Functional Loops It is Walmart s intention to minimize the risk of small part hazards on children s clothing. Children s apparel sizes 0 to 5T shall not exhibit any hazardous small parts as received, and after being subjected to normal use and reasonably foreseeable damage and abuse testing, including the 15 lb tensile test. Small Parts Labeling Products with certain small part decorative trims and embellishments may need to have an additional hangtag attached to the garment. For children s apparel sizes 4 6x (girls) / 4 7 (boys), the following hangtag must be attached to the garment if the garment contains: - Small part embellishments such as rhinestones, beads, jewels, sequins, etc. OR - Cords/ties/belts made from metal chain. Garments with functional hardware only (such as buttons, snaps, etc.), must not provide this hangtag. THE CHOKING HAZARD WARNING MUST NOT BE USED ON CHILDREN S APPAREL SIZES 0-5T. THE CHOKING HAZARD WARNING MUST NOT BE USED ON GARMENTS WITHOUT DECORATIVE EMBELLISHMENTS OR METAL CHAIN. FUNCTIONAL COMPONENTS (such as snaps, buttons) ARE NOT DECORATIVE EMBELLISHMENTS. Sharp Points Non-Functional (e.g. needles, pins, staples, exposed fastener prongs) Apparel for all sizes shall not exhibit non-functional sharp points as received. Functional Sharp Points (e.g. fastening pin on a decorative brooch) For apparel sizes Girls 0-6X / Boys 0-7 functional sharp points are not permitted. For apparel sizes Girls 7-20 / Boys 8-20, functional sharp points are permitted. Components used on children s apparel shall not break or become detached through normal use, or reasonably foreseeable damage or abuse, in such a way that a sharp point is created. Packaging for garments must not contain staples or pins. 21

Sharp Edges All children s apparel sizes shall not exhibit sharp edges as received (e.g. rough edges on metal fasteners). Components used on children s apparel shall not break or become detached through normal use, or reasonably foreseeable damage or abuse in such a way that a sharp edge is created. Abuse Testing The torque and tension tests described below are used to simulate exposure of decorative and functional components of the garment to actions likely to be performed by a child, which are characterized as reasonably foreseeable abuse. After abuse testing the components and garments shall be examined for mechanical hazards, such as hazardous sharp edges and points, and aspiration / choking hazards. Examples of decorative components include, but are not limited to: appliqués, pom-poms, fringe, beads, jewels, sequins, rhinestones, plastic or textile flowers, fixed bows, light up components, liquid filled components. Examples of functional components include, but are not limited to: D-rings, toggles, buttons, snaps, rivets, dungaree clips and sliders, zippers, hook and loop tape. Torque Testing Torque test is applied to functional or decorative components which are rigidly assembled or attached (e.g. zipper pull, or similar decorations) and that the child can grasp with at least the thumb and forefinger, or the teeth. The amount of torque allowed is determined by the size range of the garment, as shown in the table below. Apparel Size Range Torque Value Applied 0 to 9M 2 +/- 0.2 in-lbs 12M-5T 3 +/- 0.2 in-lbs Girls 4-6x / Boys 4-7 4 +/- 0.2 in-lbs Upon completion the component is examined for small parts, and sharp edges and points. Tension Testing Tension test is applied to functional or decorative components. Any decorative or functional component that a child can grasp with at least the thumb and forefinger, or the teeth shall be subjected to this test. The amount of tensile force is 15 lbs for all components requiring the test. 4.3 Apparel Trim/Hardware Where the term non-ferrous is used in the following sections, it means material must comply with all Laws and Regulations including Consumer Product Safety Improvement Act (CPSIA). 4.3.1 Press Fasteners Press fasteners used on children s apparel can be constructed of metal or plastic. All metal fasteners used on children s apparel must be non-ferrous to ensure garments can pass through a metal detector. This includes metallic finishes. Plastic press fasteners for all children s apparel sizes must be pre-applied to twill tape from an approved trim supplier, as listed in appendix F. Exception: Vinyl like wearing apparel (e.g. raincoats) may have plastic press fasteners that are not pre-applied to twill tape for sizes 4 and up. This exception does not apply to sizes 0-5T. 22

Press fasteners used on children s apparel sizes 0-5T shall not be positioned at the knee area, or any other area that could cause injury or discomfort. Press Fastener Examples POST FASTENER PRONG FASTENER RIVETED RHINESTONE STUD BUTTON RIVET GROMMETS / EYELETS Approved Press Fastener Suppliers All press fasteners must be from an approved source, as listed in Appendix F. Use of an unapproved trim supplier on Private Label garments will result in a failure from CTL. Press fasteners from any other sources are not permitted. Exception: National Brands may source from non-approved trim as long as all product requirements are met as stated in the manual, or as required by law. 4.3.2 Zippers All metal zippers used on children s apparel must be non-ferrous to ensure garments can pass through a metal detector. This includes metallic finishes. Pin Lock zippers are not acceptable for children s apparel. Closed ended zippers (such as zippers that run into a waistband) must always have a bottom stop for children s apparel sizes 0-5T. Open-ended zippers must have a top and bottom stop for children s apparel sizes 0-5T. Top stops must be designed to prevent the zipper slider from pulling off. Zipper stops specifically designed so that the zipper slider can be removed (as in the examples below) are not permitted for children s apparel sizes 0-5T. 23

Zippers which include any metal components require a zipper guard or facing to prevent the zipper from coming in direct contact with the skin (not required for metal zipper components which do not come in direct contact with skin). Plastic top and bottom stops are recommended for all zipper types. If metal stops are used, prongs must face away from the child s body or be covered with fabric to prevent scratching. All top / bottom stops must be securely attached. Invisible Concealed Zippers Invisible/concealed zippers are not permitted for children s apparel sizes 0 5T. INVISIBLE / CONCEALED ZIPPER Zipper Pulls A zipper pull is the component used to open and close a zipper. It can be attached through either the main body of the zipper slider or through the eye of the zipper pull. All metal zipper pulls used on children s apparel must be non-ferrous to ensure garments can pass through a metal detector. This includes metallic finishes. Indirect attachment pulls (2-piece zipper pulls) are NOT permitted for children s apparel sizes 0 5T. Indirect attachment pulls (2-piece zipper pulls), is where there is an intermediate connection ring between the pull and body the pull is clamped onto the ring. Direct attachment pulls (one-piece zipper pull) is where the pull inserts directly into the slider body. 24

Ring pulls or other open type designs are not permitted for children s apparel sizes 0 5T. Ring Pull Open Design Pulls One piece ring pulls or other open type designs can be used on children s apparel sizes 4 and up, providing the inside diameter of the ring (measured at widest point) does not exceed 1 inch. Zipper Pull Attachments All metal zipper pull attachments used on children s apparel must be non-ferrous to ensure garments can pass through a metal detector. This includes metallic finishes. Fabric zipper pull attachments must be secured through the eye of the zipper pull with a bar tack or similar secure attachment method. Elastic pulls are not acceptable on children's apparel sizes 0-6x (girls), and 0-7 (boys). For sizes where they are allowed, elastic pulls must be no longer than 1 inch in the relaxed state. Wadded/filled zipper pull attachments are not allowed on children s apparel sizes 0 5T. Plastic and rubber zipper pull attachments are not allowed on children s apparel sizes 0 5T. Looped zipper pull attachments are not allowed on children s apparel sizes 0-6X (girls) or 0-7 (boys). Zipper pull attachments used on children s apparel (all sizes) must meet the maximum length requirement indicated below. 25

Position of Zipper Pull Attachment At the ends of long skirts or trousers At the ends of long sleeves At center plackets All other locations Maximum Length 1 in 1 in 1½ in 2 in Approved Zipper Suppliers All zippers must be from an approved source, as listed in Appendix F. Zippers from any other sources are not permitted. Zippers must be sourced from an approved supplier as a complete unit with all of the components shown below. Zipper components (e.g. top stops and zipper tape) must not be individually purchased and self-assembled. Exception: National Brands may source from non-approved trim suppliers as long as all product requirements are met as stated in the manual, or as required by law. 4.3.3 Dungaree Clips (Hasps) and Sliders There must be no visible joins on either the dungaree clip (hasp) or slider. This is to prevent potential injury during wear, as visible joins on metal components can be very sharp. All joins must be securely covered with fabric. For children s apparel sizes 0-5T the dungaree clip (hasp) unit and construction of the strap and slider must be designed so that they cannot become detached from the garment. Dungaree clips may be constructed of ferrous metal and, therefore must be attached after metal detection. Approved Dungaree Clips (Hasps) and Slider Suppliers All dungaree clips (hasps) and sliders must be from an approved source, as listed in Appendix F. Exception: National Brands may source from non-approved trim suppliers as long as all product requirements are met as stated in the manual, or as required by law. 26

4.3.4 D-Rings (attached on garments) D-Rings are not permitted on children s garments sizes 0-5T. D-rings are not permitted at the end of ties with free ends for children s apparel. All metal D-Rings used on children s apparel or on items included with children s apparel must be non-ferrous to ensure garments can pass through a metal detector. This includes metallic finishes. There must be no visible joins in a D-Ring. This is to prevent potential injury during wear as visible joins on metal components can be very sharp. All joins must be securely covered with fabric. The D-Ring must be designed so that it cannot become detached from the garment. D-Rings 4.4 Drawstrings, Cords and Ties (Functional and Decorative) Definitions Drawstring - Cord, chain, ribbon, string or tape of any textile or non-textile material which passes through a channel, casing, loops, eyelets, or similar, has 2 loose hanging ends and is used to adjust the size of the opening, or part of the garment or to fasten the garment itself. Continuous drawstring - Cord, chain, ribbon, string or tape of any textile or non-textile material which passes through a channel around the total circumference of a garment, has no loose hanging ends and is used to adjust the size of the opening. Two loose hanging ends cannot be knotted together to form a continuous drawstring. Cords & / Ties (functional) - Cord, chain, ribbon, string or tape of any textile or non-textile material, which is attached to the outside of the garment and is used to adjust the size of the opening, or part of the garment or to fasten the garment itself. 27

Cords & Ties (decorative) Cord, chain, ribbon, string or tape of textile or non-textile material which is attached to the garment and has no functional attributes. Drawstrings / Cords / Ties General Requirements: For children s apparel of all sizes, the free ends of all drawstrings, cords and ties must not be secured with a knot or equivalent (i.e. bead, toggle, pom-pom, ring, etc.). The ends of drawstrings, cords and ties must be properly finished to inhibit fraying. (e.g. double turn secured with lockstitch, a heat seal, laser cut or a plastic sleeve / aglet). Beads must not be used at any location on functional or decorative drawstrings, cords and ties for children s apparel sizes 0-5T. Lace up ties must be securely attached at exit points for children's s sizes 0-5T, and at mid-point for all others. Drawstrings must be secured with a bartack to prevent the drawstring from being pulled out of the garment. This also prevents one end of the drawstring from ending up longer than the other and thus becoming an entrapment/catch hazard. The most common place to secure the drawstring is at the center back waist. Cords and ties must be securely attached to prevent the cord/tie from being pulled out of the garment. This also prevents one end of the cord/tie from ending up longer than the other and thus becoming an entrapment/catch hazard. Metal Chain Cords / Ties Cords/ties made from metal chain must not be used for children s apparel sizes 0-5T. For children s apparel sizes 4 and up, cords/ties/belts made from metal chain must breakaway under the weight of the child (for applicable testing weights please reference Appendix D). For children s apparel sizes 4-6X (girls) and 4-7 (boys), which includes cords/ties/belts made from metal chain the Small Part Warning tag is required (see page 21). Maximum Length Requirements Drawstrings, cords, and ties can be used on some areas of a garment and are not permitted on others; there are also maximum length restrictions to consider when using drawstrings and cords/ties on children s apparel. The following tables explain the maximum lengths permitted for certain areas. Neck Area and Hood Elastic cords/ties are not permitted in the hood and neck area of children s apparel. Decorative drawstrings, cords and ties when allowed, can only be located on the hood at the base of the front opening. 28

The table below indicates the maximum length and use restrictions for drawstrings, cords, and ties used on hoods or in the neck area. Neck area 0 9 M 12 24 M 2T 5T Girls: 4 6X Boys: 4 7 Girls: 7 20 Boys: 8 20 Drawstrings (Continuous loops or with free ends) No No No No No Cords or Ties No No No No No Decorative Cords or Ties No No No No 3 Below the Ankle & Below the Elbow Drawstrings, cords and ties of any type are NOT allowed at the hems of children s apparel that finish at or below the ankle, or at the ends of sleeves that finish below the elbow. Chest, Leg, Waist, Hip, and Above the Elbow Areas 29

The table below indicates the maximum length and use restrictions for drawstrings, cords and ties. These requirements are for drawstrings, cords and ties used in the following areas: Chest Area, Leg Area, Waist Area, Hip Area, and the area Above the Elbow (including shoulder). Chest Area, Leg Area, Waist Area, Hip Area, and the area Above the Elbow (including shoulder) 0 9M 12 24M 2T 5T Girls: 4 6X Boys: 4 7 Girls: 7 20 Boys: 8 20 Drawstrings No No 3 3 3 Continuous Drawstrings No No No No No Cords or Ties 3 3 3 5½ 5½ Drawstring Measurement Criteria: Drawstring measurements are taken with the garment fully extended, as flat to pattern (not over extended). Drawstrings are measured from where the drawstring first exits the 'channel' to the end. Internal Drawstring / Functional Cord An internal functional drawstring, cord, ribbon, tape, or elastic bungee used to cinch in a garment top at waist or sweep area must not have free ends. An internal functional drawstring cord with safety loop is allowed only for sizes 4-20. The cord must be securely attached at center-back (this will help limit cord length / entanglement risk). The cord must sit flush to the garment, and must not be longer than 2 in distance between exit point and safety loop. (Refer to photo for details) 30

SAFETY LOOP MAX 2" EXIT MAX 1" EXIT 4.5 Adjustable Waistbands Adjustable waistband elastic must be secured to the garment with a bartack at the center back to prevent the band from being pulled out. 31

4.6 Sashes & Thin Ties Tied at Waist Area (Dresses and Tops) Definitions Sashes / Ties- A textile band permanently sewn in the side seams at the waist area of a dress or a top, which is intended to be tied in the back. Sizes 0-5T Sash Requirements Sashes measure at least 1 ¼ inch in width. Sashes must not hang below the hem of the garment when untied. It is recommended that tops and dresses include loops near the center back so if ties or sashes are untied they do not hang below the hem of the garment. Sashes must be permanently and securely attached at the waist area so that they cannot be removed. The length of all sashes when untied must be no more than 14 inches. (measured from the point where they are to be tied). 32

Size 4 and up Sash & Thin Tie Requirements Sashes and thin ties must be permanently and securely attached at the waist area so that they cannot be removed. The length of all sashes when untied must be no more than 14 inches. (measured from the point where they are to be tied). It is recommended that tops and dresses include loops near the center back so if ties or sashes are untied they do not hang below the hem of the garment. 4.7 Belts Belts - General Requirements Belts without buckles for sizes 0-5T must be permanently and securely attached at the waist area so they cannot be removed. Belts for sizes 0-5T must not hang below the hem of the garment when untied. Buckles / D-rings are not permitted on belts which are permanently attached to garments intended for sizes 0-5T. Belts with buckles / D-rings are permitted on unattached fabric belts intended for sizes 0-5T, provided that the strap end of the belt does not exceed 3 inches in length. Garments with non-attached belts must have belt loops at both side seams, at a minimum, to prevent the belt from being a trip hazard when untied. 33

Belts Strap End Length Restrictions (Based on measurement criteria below) Belt Type Belts with Buckles / D-Rings - Attached to Garment Belts with Buckles / D-Rings - Not Attached to Garment Belts without Buckles (tied belts) Attached or not attached to garment Garment Size 0-5T 4-20 Not Permitted 5½ inches 3 inches 14 inches 14 inches Measurement Criteria All belts measurements are taken while fastened to the intended garment. Belts without buckles (tied belts) are measured from the point where they are intended to be tied. Belts with buckles are measured from where the belt strap exits the buckle to the strap end. Belts with buckles and punched holes are fastened to the intended garment and buckled at the center hole. For belts which have an even number of punched holes the belt is fastened one hole past the center point (e.g. a belt with 6 punched holes is buckled at the 4 th hole from the strap end). Belts without punched holes (e.g. braided belts, belts with D-ring buckles) or for belts with punched holes around the entire belt; the belt is fastened to the intended garment and closed with the garment and belt lying flat. The measurement is taken where the belt strap exits the buckle to the strap end. 34

4.8 Bath Robes Belts used on bath robes must be permanently attached and meet the requirements for belts. 4.9 Fixed Bows Bows must be securely attached at or near the center. The tail ends of the bow must be secured with either a double turn secured with a lockstitch, a heat seal or laser cut. The table below indicates the maximum lengths for fixed bow tail ends and loop lengths. Fixed Bows (in all areas other than below) Fixed Bows (located at the Hood, Neck, Ankle or Below the Elbow) Girls: 4 20 / 0 5T Boys: 4 20 Loops Tails Loops Tails 3 3 3 5½ 1½ 1 1½ 1 The total loop length and tail length of a bow are measured from the bartack, or from the exit point as shown below: Bartacks No visible bartack, loops are measured from exit points. Bartack at both sides of bow, loops are measured from bartacks. 4.10 Functional and Decorative Loops Fixed loops that protrude from the garment also have length restrictions that must be considered when designing garments with either functional or decorative loops. The loop length must not exceed 3 inches in total circumference when measured end to end, the end being the point at which the loop is attached to the garment. 35

Belt Loops Belt loops must be attached so that they lie flat against the garment. Belt loops are securely attached and reinforced with bartacks. Back Neck (locker) Loops Back neck (locker) loops must be located in the center back neck and positioned at the inside of a garment only. Hanger Loops Hanger loops are not permitted on children s apparel sizes 0-5T. Hanger loops for sizes 4 and up should be constructed of clear elastic tape which must break away under the weight of the child (for applicable testing weights please reference Appendix D). Hammer Loops Hammer loops are allowed on children s apparel; however they must be designed in such a way that the hammer loop does not exhibit any loops which exceed 3" in length. 3 x3 maximum with center bartack 4.11 Hats / Caps Hat / Caps with Under-Chin Ties Under-chin ties are only allowed on occasion wear (e.g. religious clothing). INSERTED PICTURE OF OCCASION WEAR HAT Under-chin ties must meet the following requirements: Ties are not continuous. Ties do not exceed 8 inches in length, when measured from the point of securement. 36

Ties are not constructed of elastic. Ties exhibit no trims attached to the ends. Pom-poms, tassels or similar types of decorative trims are not permitted on the crowns of hats with under chin ties. Hats / Caps with Chinstraps Chinstraps are allowed on all children s hats / caps. Chinstraps must meet the following requirements: Chinstraps must fit snugly against the chin. The chinstrap must not be a continuous loop which is permanently attached to each side of the hat / cap. Exception is elastic chin straps that fit snugly against the chin. Hats / Caps with no Securement Means Pom-poms, tassels and other types of decorative trim are permitted on hats with no means of securement. (e.g. chinstraps, ties) Decorative trim, when allowed, must meet all requirements for decorative trim and embellishments as outlined in section 4.18 of the manual. Hats with Decorative Tassels or Non-Functional Tassels Tassels used on hats for children, must not be of a length that is capable of being knotted or tied into a bow under the chin. (Tassels are tested in an un-stretched state with hat placed upon head form as intended to be worn). PERMITTED 37

NOT PERMITTED Decorative trim, when allowed, must meet all requirements for decorative trim and embellishments as outlined in section 4.18 of the manual. 4.12 Halter Neck Style Garments and Baby Bibs Halter neck style garments and baby bibs must not be constructed with free ends in the hood and neck area. The use of hook and loop tape, self fabric, snap fasteners and buttons are recommended as alternative fastening methods for halter neck style garments and baby bibs. 4.13 Neck Ties Neck ties are allowed for all sizes. 38

For sizes 0-5T, the tie must be designed in such a way that it detaches or breaks away under the weight of the child (for applicable testing weights please reference Appendix D). 4.14 Toggles & Toggle Buttons Toggles Toggles used on children s apparel sizes 0-5T, must not be constructed of wood, cork, leather, mother of pearl (shell), glass or other non-durable material. All metal toggles used on children s apparel must be non-ferrous to ensure garments can pass through a metal detector. This includes metallic finishes. Toggles must only be used on drawstrings, cords or ties that have no free ends. In addition, free ends cannot be knotted together to form a continuous loop. Toggles must not be positioned where they could cause injury or discomfort. Toggles in the knee area are not allowed. Toggle Buttons Loops used to attach a toggle button to a garment must be securely bartacked as close to the toggle button as possible, while still being functional. Loops used to secure a toggle button must not exceed 3 inches in total circumference. Pig Nose Toggles (Cord Lock) / Spring Loaded Toggles Pig nose and spring loaded toggles can be used on a garment and have either a decorative or functional application. However, below are the guidelines pertaining to the size groups that these trims can be used for, and also the method of attachment. Decorative Application Pig nose and spring loaded toggles can be used on children s apparel as a decorative application. The following factors must be considered when attaching pig nose and spring loaded toggles to rigid and elastic cords: Decorative pig nose or spring loaded toggles are NOT allowed in the Hood, or Neck area. 39

The cord must be securely attached to the garment. Elastic cords can only be used on children s apparel sizes 12M and above. The pig nose/spring loaded toggle must be securely contained within the loop of the cord so it cannot be removed from the garment. The cord and toggle must sit flush to the garment. The cord must be securely bartacked no more than 3/8 from the eyelet or buttonhole. 3/8 Functional Application Pig nose and spring-loaded toggles can sometimes be used on children s apparel as a functional application. The following requirements apply when attaching pig nose and spring loaded toggles to rigid and elastic cords: - Functional pig nose or spring loaded toggles are NOT allowed in the Hood, or Neck area. - The pig nose (cord lock)/spring loaded toggle must be securely contained within the loop of the cord so it cannot be removed. - The cord must be secured with a bartack to prevent it from being pulled completely out of the garment. - The loop circumference cannot extend more than 3 when the cord is cinched to the body and must fully retract inside the waistband when the garment is fully extended. - The toggle cannot be attached to a continuous drawstring, 4.15 Buttons and Buttonsew Buttons Buttons used on children s apparel sizes 0-5T, must not be constructed of wood, cork, leather, mother of pearl (shell), glass or other non-durable material. Two-piece multi-component buttons must not be used for children s apparel sizes 0 5T. Fabric covered buttons must not be used on children s apparel sizes 0 5T. Spare buttons are not permitted for children s apparel sizes 0-5T. Buttonsew All buttons must be attached using a lockstitch button attach machine for children s apparel sizes 0-5T. 40

4.16 Hook and Loop Fastener Tape A low profile high tech hook is recommended for use on all children s apparel sizes 0-5T. Hook and loop tape must be positioned on the garment so only the loop part of the fastener tape is in direct contact with the skin. The corners of hook and loop fasteners must be die cut or rounded to avoid sharp edges and prevent potential irritation to the skin. 4.17 Thread Ends and Float Threads Thread Ends Toe seaming threads or other thread ends on socks or footed garments for children s apparel sizes 0-6M must be trimmed to a maximum of ¾ inch. Thread ends in the hand/finger area of mittens/gloves must not be over ¾ inch for sizes 0-6M. For footed garments, socks, or booties intended for sizes 0-6M, with a seam around the sole, the start / stop position must be in the ankle area to prevent seaming thread ends in the toe area. Float Threads The table below indicates the maximum length and use restrictions for float threads used on apparel and accessories intended for sizes 0-6M. Float Threads (0-6M) Socks, Booties, or Footed Garments Foot Area Non-Foot Area Mittens Hand / Finger Area Other Areas (other than foot or hand area) Not permitted ½ inch maximum length Not permitted ½ inch maximum length 4.18 Decorative Trims and Embellishments Beads and Jewels Beads and jewels are not permitted for children s apparel sizes 0-5T. Beads or jewels used on other children s apparel sizes must not be constructed of metal, glass, or wood. Sequins For children s apparel sizes 0-5T sequins must exhibit stitching on at least 5 points around each sequin, as shown below. 41

Sequins must not be constructed of metal. Garments intended for sizes 4-6X (girls) / 4-7 (boys) which exhibit sequins that are tacked at 5 points, do not require the small part choking hazard hangtag. Diamante (Rhinestones) and Metal Studs Diamante (Rhinestones) and metal studs are not permitted for children s apparel sizes 0-5T. For sizes 4 and up, riveted items are considered Press Fasteners, and must follow requirements listed in section 4.3.1 Note: Garments intended for sizes 4-6X (girls) / 4-7 (boys) which exhibit sequins, beads and jewels, rhinestones and metal studs, must include the small part choking hazard hangtag, as outlined in section 4.2. Appliqués & Embroidery Appliqués and embroidery must be backed with interlining if the reverse is scratchy, and in direct contact with the skin. Interlinings used on children s apparel sizes 0-5T must be securely attached so as not to create a small parts hazard. Pom-Poms & Fringe Traditional Pom-Poms or fringe made from hand knitting / sweater yarns are not permitted on children s apparel sizes 0-5T. Stuffed pom-poms made from fabric must be new and completely enclosed inside a lining. Pom-Poms and fringe must not be constructed with metal components. Pom-Poms must not be attached to the end of a drawstring, cord or tie with free ends. Fake (Faux) Fur Fake (faux) fur used on children s apparel sizes 0-5T must be securely attached so as not to easily pull out. Natural Feathers Natural feathers are not permitted for use in any part of the exposed make-up of children's wearing apparel or accessories. Note: Caps and hats are exempt from the requirement. Boas constructed of natural feathers are not permitted. Note: Feathers contained within fabric, or filled, as in outerwear, are acceptable. 4.19 Miscellaneous Requirements Abrasive metallic yarns, or any other abrasive materials are not permitted for use in garments designed for children 0 9M. 42

Monofilament thread is not permitted for use on children s apparel unless it is properly covered with a backing. Boys swim short liners must be constructed of micromesh fabric with a minimum of 225 holes per square inch. Pairing clips as shown below are not permitted on socks or mittens designed for children s apparel sizes 0-5T. Thread packaging tacks are not permitted on socks or mittens designed for children s apparel sizes 0-5T. 4.20 General Wearing Apparel Flammability Requirements All children s textile wearing apparel must comply with any and all State and/or Federal guidelines, regulations, and laws, including but not limited to reasonable and representative testing as required under CFR Title 16, Part 1610, and must be classified as Class 1: Normal Flammability. 4.21 Children s Sleepwear / Loungewear Flammability Requirements All children s sleepwear sized 0 20 must comply with any and all State and/or Federal guidelines, regulations, and laws, including but not limited to CFR Title 16, Part 1615 and 1616. Notes: If the packaging or any printed design on a children s garment suggests sleeping, it will be considered sleepwear, and must pass testing to comply with the requirements set forth in CFR Title 16, Part 1615 and 1616. Loungewear is considered sleepwear, and therefore must follow the same requirements as sleepwear. Some examples of loungewear are provided below. These examples are for reference only and are not intended to depict all apparel which may be regulated as loungewear. CPSC is the final authority for determining what loungewear is. 43

Federal Flammability requirements for children s sleepwear are outlined as follows: Sleepwear for infants 9M and younger are exempt from the Children s Sleepwear Flammability Requirements if the following two conditions are true: 1. The sleepwear is a one piece garment that is not longer than 64.8 centimeters (25 3/4 inches), or a two piece garment with no piece longer than 40 centimeters (15 3/4 inches). AND 2. The sleepwear includes a label stating the age (in months) of the children for whom it is intended. Note: Even though the sleepwear for infants under 9M is exempt from the children s sleepwear regulations, the sleepwear must still meet the general wearing apparel flammability requirements outlined in section 4.21. Children s Sleepwear sized above 9M and up to 6X and size 7 to 20 must meet the flammability requirements of 16 CFR 1615, Standard for the Flammability of Children s Sleepwear Sizes 0-6X (FF3-71) or 16 CFR 1616, Standard for the Flammability of Children s Sleepwear Sizes 7 through 14 (FF 5-74) respectively, or be classified as tight fitting as defined in the applicable regulations. Note: Although tight fitting garments are exempt from the flammability requirements of 16 CFR 1615 &1616 they must meet the sizing and labeling requirements specified in 16 CFR 1615 &1616 and meet Class I Normal Flammability under 16 CFR 1610 for General Wearing Apparel. In addition to flammability requirements for finished products, Federal regulations require certain record-keeping procedures and testing protocols at specific stages in the manufacturing process. 4.22 Polyvinyl Chloride in Children s Bibs It is a Walmart requirement that all children s plastic bibs are manufactured from material that does not contain PVC. 44