GRS v3 Implementation Manual
GRS v3 Implementation Manual
2014
The Global Recycled Standard (GRS) is a product standard for tracking and
verifying the content of recycled materials in a final product, while ensuring
strict production requirements.
English is the official language of the Global Recycled Standard. In any case of inconsistency between versions, reference
shall be made to the English version.
Copyright: 2014 Textile Exchange
Table of Contents
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Global Recycled Standard Interpretations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
A3 Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
A4 Recycled Material Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
A5 Production Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
B1 Social Policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
B2 Social Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
B3 Verification of Social Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
C1 Environmental Management System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
C2 Environmental Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
C3 Verification of Environmental Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Section D: Chemical Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
D1 Chemical Management System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
D2 Chemicals used in GRS products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
D3 Verification of Chemicals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
GRS Logo Use and Labeling Guide Interpretations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
B1.2 Requirements for all GRS Labeled Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
B1.3 Optional Additional Language for Labeling GRS Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
GRS Frequently Asked Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Introduction
The GRS Implementation Manual provides interpretations and clarifications for the Global Recycled
Standard (GRS) and its supporting documents. All guidance given in this manual is to be considered
binding to Certification Bodies (CB) working with, and Organizations certified to, the Global Recycled
Standard v3.
This manual will be updated regularly to address areas of uncertainty or to give further detail in the
application of the standard. It is up to all users of the standard to regularly check for the most current
version of the manual found at http://globalrecycled.org. The manual does not change or alter any of
the criteria of the standard, but rather is intended to support correct and consistent application of the
standard.
CBs are to use the guidance and assessment requirements found in the current version of the GRS
Implementation Manual for their clients at the time of their certification. Whenever there is an update
to the manual, TE will inform all CBs and organizations will be assessed against the new version of the
manual during their next annual certification. If it is a significant change, TE will communicate to CBs that
they must communicate to all Certified Organizations that changes should be made as soon as possible,
but will not require compliance with the newly added requirements until their next annual certification.
The Content Claim Standard (CCS) is an integral part of the GRS; therefore the CCS Implementation
Manual is to be followed as well where references to CCS are considered to be referencing the GRS.
Guidance: Proof of legal authorization to operate is for example, a government-issued business license
number or non-profit registration document. This ensures that there is a valid organization behind the
declaration form, and to give an added measure of protection against the possible trading of stolen goods.
Where legal authorization is required to process waste, there must be proof that this is in place.
Pre-Consumer Material: Material diverted from the waste stream during the manufacturing process. Excluded
is the reutilization of materials such as rework, regrind or scrap generated in a process and capable of being
reclaimed within the same process that generated it.1
By-products may be considered pre-consumer material when the following criteria are met:
a)
b)
c)
Guidance: UL has released a document titled: Interpreting Pre-Consumer Recycled Content Claims that
provides helpful interpretation of pre-consumer recycled content. The FTC Green Guides2 also includes helpful
guidelines for understanding claims.
Pre-consumer may sometimes be referred to as post-industrial.
Reclaimed Material: Material that would have otherwise been disposed of as waste or used for energy recovery,
but has instead been collected and reclaimed as a material input, in lieu of new primary material, for a recycling
process.3
Guidance: The expressions recovered material and reclaimed material are treated as synonyms; however,
it is recognized that, in some countries, one or other of these expressions may be preferred for this application.
If your industry or your country uses different terminology, please contact [email protected] for
further clarification.
We also recognize that it is difficult to substantiate that a material would have otherwise been disposed of as
1
2
3
This excerpt is taken from ISO 14021:1999, section 7.8.1.1, subsection a.1 on page 14, with the permission of ANSI on behalf of
ISO. ISO 2013 All rights reserved.
Guides for the Use of Environmental Marketing Claims (Green Guides); Federal Trade Commission; October 12, 2012. http://
www.ftc.gov.
This excerpt is taken from ISO 14021:1999, section 7.8.1.1, subsection c on page 14, with the permission of ANSI on behalf of
ISO. ISO 2013 All rights reserved.
waste or used for energy recovery, as once a recycling process is established, the material is no longer being
directed into a waste stream. See Pre-Consumer Material for further clarification.
Recycled content: Proportion, by mass, of recycled material in goods or packaging. Only pre-consumer and postconsumer materials shall be considered as recycled content.
Guidance: Packaging is exempted from the requirements of the standard, unless the recycled material being
claimed is part of the packaging.
Recycled Material: Material that has been reprocessed from reclaimed material by means of a manufacturing
process and made into a final product or into a component for incorporation into a product.1
Guidance: A recycled content claim may be made only for materials that have been recovered or otherwise
diverted from the solid waste stream, either during the manufacturing process (pre-consumer), or after
consumer use (post-consumer). To the extent the source of recycled content includes pre-consumer material,
the manufacturer or advertiser must be able to justify that the pre-consumer material would otherwise have
entered the solid waste stream and/or meets the qualification for by-products listed in the definition for preconsumer material.
In the US, the Federal Trade Commission, Recycled content includes recycled raw material, as well as used,
reconditioned, and re-manufactured components. (FTC 2012 Green Guide, 260.13.a) While materials that
meet this definition may be considered as recycled in the US, the narrower definition of recycled material
listed above is used for the Global Recycled Standard.
This excerpt is taken from ISO 14021:1999, section 7.8.1.1, subsection b on page 14, with the permission of ANSI on behalf of
ISO. ISO 2013 All rights reserved.
in documentation. CBs should make an effort to avoid inspection of the same sites from one year to
the next, if possible.
Direct verification of Material Collectors and Material Concentrators should seek to verify the
authenticity of the Reclaimed Material Declaration Form as well as the following information:
1. That all claimed material meets the definition of Reclaimed Material (A3).
2. That all claimed material is properly identified as Pre-Consumer or Post-Consumer Material (A3).
3. That the source of all claimed material is reviewed.
Textile Exchange will not collect fees from inspections of Material Collectors or Material Concentrators.
A4.3b In addition, entities involved in Material Recycling must:
i.
Hold valid Reclaimed Material Declaration Forms for all GRS input materials, or proof of
verification to an accepted standard (see TE Accepted Equivalent Standards), available
online (http://globalrecycled.org).
Guidance: If the reclaimed materials have been verified through an approved equivalent
standard, then those reclaimed materials will be accepted for the GRS, as long as all related
documentation is submitted to the Material Recycling facility and the Certification Body.
Accepted equivalent standards are those that have been approved by Textile Exchange and
meet or exceed the requirements of the GRS for verification of reclaimed materials (i.e.:
verification that they would have otherwise gone in to the waste stream). To be considered
for equivalency, standards may be submitted to Textile Exchange by contacting Integrity@
TextileExhange.org.
ii.
Verify that all sources of reclaimed material have legal authorization to operate for the
relevant function, and hold copies of the relevant documents.
Guidance: Prior to the initial inspection, the Material Recycled should submit a list of all
sources of reclaimed material to their CB. This allows the CBs time to verify legal authorization
of the entities involved in Material Collection and Concentration to operate (A4.1 and A4.2) as
well as to assess any areas of risk.
The reference to all sources of reclaimed material does not include Material Collection from
individuals.
iii.
Inspect all incoming shipments of reclaimed material to confirm that they are not virgin
material. In the case that virgin material is identified, the supplier of the material and
the certified shall be notified, and there shall be increased control established over
incoming goods from the supplier involved.
Guidance: Virgin material shall be defined as any material that does not meet the definition
of recycled material given in A4. Staff receiving reclaimed materials must be trained and
directed to identify any material that is or could be virgin material. If virgin material is
suspected or identified, it must be immediately removed from the reclaimed materials stock
until further investigation confirms its identity. It is understood that it will not be possible in
every case to confirm whether input materials are reclaimed or virgin.
In all cases of virgin material, the certification body must be informed, and it will be at their
If recycled cotton is being used as an input, and the staple length is shorter than the virgin
fiber, then during the combing process it is likely that most of the shorter fibers that are
combed out will be the recycled cotton. This would mean that the percentage of recycled fiber
in the output is less than the amount used in the input, and for low ratio claims, this can lead
to inaccurate product claims. To address this, companies shall:
o
Add more recycled fiber to their inputs, to account for the expected loss (e.g.: use 55kg
of recycled cotton fiber and 45 kg of virgin cotton fiber to create a 50% recycled yarn)
or
o
Adjust the final amount being claimed to reflect the actual amount of recycled
material in the output.
A5.2e Buyers of the GRS product will be responsible to set any further requirements on the specific
standards or requirements to which the input material must be certified. These additional
requirements are separate from the GRS and its certification process.
Guidance: Any additional requirements set by a buyer do not fall under the GRS certification.
However, it may be advantageous to have the additional requirements checked during the
GRS inspection process. All such arrangements will be strictly between the buyer and the
certification body.
Some brands may wish to identify the original source material prior to recycling. This is outside
the scope of certification to the GRS, but may be added to the Transaction Certificates if
requested by the brand. The arrangements should be made through the Certification Body.
B1 - Social Policy
B1.1b Worker awareness of policies regarding the social principles listed in Section B2.
Guidance: Worker awareness may be demonstrated through training records or procedures
around worker access to updated social policies.
B2 - Social Requirements
B2.5a Certified Organizations shall provide safe and clean conditions in all work and residential facilities
and shall establish and follow a clear set of procedures regulating occupational health and safety.
Emergency procedures must be clearly displayed and understandable to all workers, and hazards
must be clearly marked.
Guidance: A safe and hygienic working environment shall be provided, bearing in mind the
prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be
taken to prevent accidents and injury to health arising out of, associated with, or occurring in
the course of work, by minimizing, so far as is reasonably practicable, the causes of hazards
inherent in the working environment.
B2.5b Certified Organizations must take adequate steps to prevent accidents and injury to health arising
out of, associated with, or occurring in the course of work, by minimizing, so far as is reasonably
practicable, the causes of hazards inherent in the working environment. Appropriate and
effective personal protective equipment shall be provided as needed.
Guidance: Appropriate protective equipment shall include adequate clothing, footwear, and
eyewear where necessary.
The audit must have been conducted against GRS recognized social principles, see TE
Accepted Equivalent Standards, (http://globalrecycled.org).
The full audit report must be made available to the GRS inspector.
The audit must have been conducted by a qualified auditor.
The audit must not be older than 12 months at the time of the GRS audit.
The audit report must be accompanied by proof that any identified corrective actions
have been implemented as indicated in the corrective action plan.
Implementation of identified corrective actions will be confirmed during the GRS audit, and
random checks will be made on the information in the audit reports.
Guidance: The auditing body must be a third party (i.e.: not the Certified Organization, one
of its customers or suppliers) and be authorized by the standard owner of the equivalency
standard to conduct the inspection and issue the report.
Other detailed Social Audit reports may be assessed by the GRS certification body to verify
that the GRS Social Principles (Section B2) have been covered, and that the applied audit
methodology is equivalent to the methodology outlined in Appendix 3. These criteria for the
audits must be submitted to Textile Exchange for approval at least 3 months prior to any GRS
audits or certification.
Certified Organizations must have an environmental management system (EMS) in place. The
environmental management system must include the following:
Guidance: See Global Social Compliance Program Environmental Implementation Guidelines, for
further guidance in meeting the environmental requirements of the GRS.1
C2 - Environmental Requirements
C2.1d The Certified Organization must set and meet targets for meaningful improvements in energy
use and review progress annually.
Guidance: When assessing whether the targets set for improvements are meaningful,
Certification Bodies shall consider how advanced the Certified Organizations current energy
usage is and how much improvement is adequate and/or realistic.
For example, new machines to reduce water used per kg of fabric dyed and processed, an
energy reduction plan to turn machines off when not in use. The Natural Resources Defense
Council (NRDC)s Clean by Design initiative has helpful guides for this approach.2
C2.2d The Certified Organization must set and meet targets for meaningful improvements in water use
and review progress annually.
Guidance: When assessing whether the targets set for improvements are meaningful,
Certification Bodies shall consider how advanced the Certified Organizations current water
usage is and how much improvement is adequate and/or realistic.
C2.3e There must be a system in place to ensure that wastewater receives proper treatment, either
on or off-site, to meet minimum requirements before entering the water stream, see Appendix
4. Where national and local requirements are more stringent, these limit values supersede the
requirements listed in Appendix 4. This system shall also ensure that sludge receives proper
treatment and disposal. Test reports must be made available for the certification body and meet
the requirements below.
i.
ii.
iii.
Guidance: If there is doubt, the CB may take samples and carry out tests.
following requirements:
i.
ii.
iii.
iv.
v.
The audit must have been conducted against GRS recognized environmental principles,
see TE Accepted Equivalent Standards, (http://globalrecycled.org).
The full audit report must be made available to the GRS inspector
The audit must have been conducted by a qualified auditor
The audit must not be older than 12 months at the time of the GRS audit
The audit report must be accompanied by proof that any identified corrective actions
have been implemented as indicated in the corrective action plan
Implementation of identified corrective actions will be confirmed during the GRS audit, and
random checks will be made on the information in the audit reports.
Guidance: Other detailed Environmental Audit reports may be assessed by the GRS
certification body to verify that the GRS Environmental Principles (Section B2) have been
covered. These criteria for the audits must be submitted to Textile Exchange for approval at
least 3 months prior to any GRS audits or certification.
Substances of Very High Concern (SVHC)2 as referred to in Article 57 of European Regulation (EC) No
1
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1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)1,
and included in Annex XIV of the Regulation.
Guidance: Substances still under review by REACH, and not yet listed on the SVHC list may be used in
GRS products. These substances must meet the requirements of D2.2 and D2.3a if applicable.
D2.2 Exclusion of substances and mixtures classified with particular hazard codes or risk phrases
No use is allowed of substances and mixture that are assigned (or may be assigned by the time of the
application) any of the hazard statement codes and/or risk phrases (or a combination of them) listed in
Table A.
Guidance: The GRS does not apply the complete list of Hazard codes or Risk phrases; it includes those
that represent the highest risk of environmental and human health hazards.
D2.3a Chemical groups identified in the GRS Prohibited Substance List (available online) must not
be used and must not be part of any preparations or formulations used in manufacturing GRS
certified textile products.
Guidance: Chemical groups listed in the GRS Prohibited Substance List have been identified as
chemicals of concern due to known and potential environmental and human health hazards.
ZDHC (Zero Discharge of Hazardous Chemicals) has released a MRSL, intended to assist
brands, their supply chains and the broader industry to adopt a harmonized approach to the
control of hazardous substances used to process textile and trim materials in apparel and
footwear. It is intended that when producing GRS certified products, the products will also
meet the ZDHC MRSL requirements.2
D3 - Verification of Chemicals
D3.1d Further information and testing may be required by the Certification Body to further verify that
chemicals or substances used in GRS products are not prohibited by Section D2.
Guidance: Based on risk assessment, the Certification Body may request additional testing
or document requests. Random testing of chemicals used may also be conducted by the
Certification Body.
Additional documents that may be requested by a CB include, but are not limited to: analytical
test reports (from chemical suppliers), invoices (to verify the dye stuff has been bought from an
approved supplier), and the recipes used in GRS products.
D3.2a Chemicals or additives which have met the criteria set out in Section D2 may be added to the
GRS Allowed Substance List, to be maintained by Textile Exchange and available online (http://
globalrecycled.org/). Any chemicals on this list may be used in the processing of GRS certified
products. This is not a comprehensive list and only represents chemicals which have been
screened.
Guidance: Certification Bodies are required to submit substances (basic chemicals or complex
mixtures) found to comply with all GRS Chemical Requirements to Textile Exchange. The list of
1
2
Regulation (EC) No 1907/2006 of the European Parliament and of the Council. http://eur-lex.europa.eu/LexUriServ/LexUriServ.
do?uri=OJ:L:2006:396:0001:0849:EN:PDF.
You can find the ZDHC MRSL online: http://www.roadmaptozero.com/.
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substances approved for use in GRS products will be maintained by Textile Exchange.
Chemical suppliers may also request that a chemical be added to the list of approved
substances. To request a chemical or additive be added to the TE GRS Allowed Substance List,
please send an email to [email protected].
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X% shall represent the final percentage of Recycled Material by appropriate unit of measure in
the finished product.
Guidance: In most cases the unit of measure will be weight, but in some cases (such as paint
recycling), volume will be more appropriate. Percentage must be calculated exclusive of trims.
The minimum percentage of recycled content has been set at 20% for GRS v3. As increased
technology and innovation allows for higher percentages of recycled content in products, the
minimum required recycled content percentage will also likely increase in future versions of the
GRS.
Material refers to the raw material created as the output of the recycling process. In the case
of products with multiple Recycled Material types, each material must be separately listed with
each percentage:
Guidance: Examples of Recycled Materials are:
Input: plastic bottles
Output: PET chips
Recycled Claim: Recycled Polyester
Input: wool clothing
Output: wool fiber
Recycled Claim: Recycled Wool
Some brands may wish to identify the original source material prior to recycling. This is outside
the scope of certification to the GRS, but may be added to the Transaction Certificates if
requested by the brand. The arrangements should be made through the Certification Body.
B1.2b The labeling must reference the Certification Body (e.g.: Certification Bodys name and/or logo)
and a reference to the Certified Organization (e.g.: Certified Organizations name and/or license
number).
Guidance: The Certified Organizations reference number is given by the CB so that the Certified
Organization that produced the product can be tracked by the CB.
B1.3
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Guidance: Equivalent terms may also be used, such as post-consumer recycled (PCR) or
post-industrial recycled (PIR).
B1.3b Companies may use the language below for on- or off-product communication, at the discretion
of the brand.
Factories involved in the production of GRS certified products meet the fair labor and
environmental impact requirements of the GRS.
or
Virtually all products impact the environment. For details on the issues covered by the GRS, go
to http://globalrecycled.org.
Guidance: Companies may reference the GRS website which will provide the consumer with
additional information about the requirements of the standard.
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