Product Safety Manual-Apparel.09.05.2017

GAP INC.
SAFETY REQUIREMENTS
APPAREL AND APPAREL-TYPE ACCESSORIES
Contents
Contents.................................................................................................................................................................... 1
List of Tables ............................................................................................................................................................. 6
REGULATORY AND CHEMICAL SAFETY REQUIREMENTS .............................................................................................. 7
1 Compliance with U.S. Product Safety Rules ......................................................................................................... 7
1.1 Consumer Product Safety Act and Amendments Summary....................................................................................... 7
1.2 Gap Inc.’s CPSC Testing and Certification Program .................................................................................................... 7
1.3 Gap Inc. CPSC Certification Folder on GapSource Library .......................................................................................... 8
1.4 Responsibility as a Certifier ........................................................................................................................................ 8
1.5 Gap Inc. Due Care Requirements ............................................................................................................................... 8
1.6 Certificates of Compliance (COC) ............................................................................................................................... 9
1.7 How to Certify Compliance ........................................................................................................................................ 9
2 Restricted Substances ....................................................................................................................................... 10
2.1 Restricted Substances List (RSL) – EU REACH ........................................................................................................... 10
2.2 Gap Inc. RSL Testing Program...................................................................................................................................10
2.2.1 Critical “REACH” Testing Failures.......................................................................................................................... 10
2.2.2 Non-Critical Advisory RSL Component Failures ....................................................................................................11
2.2.3 Result Tracking ..................................................................................................................................................... 11
3 Chemicals of Concern – Selected Substances ..................................................................................................... 11
3.1 Antimicrobial Treatments ........................................................................................................................................ 11
3.1.1 North America Requirements ............................................................................................................................... 11
3.1.2 European Union Requirements ............................................................................................................................ 11
3.1.3 Marketing Claims .................................................................................................................................................. 11
3.2 Azo Dyes ...................................................................................................................................................................12
3.2.1 Testing ..................................................................................................................................................................12
3.3 BPA (Bisphenol-A) .................................................................................................................................................... 13
3.4 Cadmium ..................................................................................................................................................................13
3.5 Chemical Finishes ..................................................................................................................................................... 13
3.6 Chromium VI (Hexavalent Chromium) ..................................................................................................................... 13
3.6.1 Testing ..................................................................................................................................................................13
3.7 Colorfastness of Dyes ............................................................................................................................................... 14
3.7.1 ColorFastness to Saliva in Infant products............................................................................................................ 14
3.7.2 Pigment ban for Baby 0-24 months and Maternity .............................................................................................. 14
3.8 DMFu (Dimethyl Fumarate) .....................................................................................................................................14
3.9 Formaldehyde .......................................................................................................................................................... 14
3.9.1 Testing ..................................................................................................................................................................14
3.9.2 Formaldehyde Emission from Composite Wood Products ................................................................................... 15
3.10 Heavy Metals (Soluble) ............................................................................................................................................ 15
3.10.1 Testing ..................................................................................................................................................................15
3.11 Heavy Metals (Total) – Packaging ............................................................................................................................ 16
3.12 Lead .......................................................................................................................................................................... 16
3.12.1 General Requirements .......................................................................................................................................... 16
3.12.2 Children’s Products ............................................................................................................................................... 16
Gap Inc. Safety Requirements

Apparel And Apparel-Type Accessories Page 1 of 63
3.12.3 Adult Products ...................................................................................................................................................... 18
3.12.4 Canada ..................................................................................................................................................................18
3.13 Liquid Filled Products (Jewelry, Accessories, and Apparel)...................................................................................... 19
3.13.1 All products........................................................................................................................................................... 19
3.13.2 Liquid Fill ............................................................................................................................................................... 19
3.13.3 Evaluation ............................................................................................................................................................. 19
3.14 Mercury ....................................................................................................................................................................19
3.14.1 All Products ........................................................................................................................................................... 19
3.14.2 Batteries ............................................................................................................................................................... 19
3.15 Nickel ........................................................................................................................................................................ 19
3.16 PAHs (Polycyclic Aromatic Hydrocarbons) ............................................................................................................... 20
3.16.1 Testing ..................................................................................................................................................................20
3.17 Phthalates ................................................................................................................................................................ 20
3.17.1 Apparel and Accessories ....................................................................................................................................... 20
3.17.2 Toys and Childcare Articles ...................................................................................................................................21
3.17.3 Testing in Regular Testing Program ...................................................................................................................... 21
4 Jewelry ............................................................................................................................................................. 21
4.1 Jewelry Definition..................................................................................................................................................... 21
4.2 Physical and Mechanical Requirements ................................................................................................................... 22
4.3 Jewelry Chemical Limits ........................................................................................................................................... 22
4.3.1 Cadmium............................................................................................................................................................... 22
4.3.2 Heavy Metals (Soluble) ......................................................................................................................................... 22
4.3.3 Lead ......................................................................................................................................................................22
4.3.4 Nickel ....................................................................................................................................................................23
4.4 Age Definition and Labeling .....................................................................................................................................23
4.4.1 Age Labeling.......................................................................................................................................................... 23
4.5 California (CA) Jewelry Limits and Certification ....................................................................................................... 25
5 Electronics in Apparel and Apparel Accessories ................................................................................................. 26
5.1 EU Restrictions – WEEE / RoHS ................................................................................................................................ 26
6 Flammability ..................................................................................................................................................... 26
7 California Proposition 65 ................................................................................................................................... 26
7.1 Duties and Requirements ......................................................................................................................................... 27
7.2 Gap Inc. Prop 65 Policy............................................................................................................................................. 27
8 Trim Imitating Food .......................................................................................................................................... 27
8.1 EU Restrictions ......................................................................................................................................................... 28
8.2 US and Non-EU Markets........................................................................................................................................... 28
PHYSICAL & MECHANICAL SAFETY RESTRICTIONS..................................................................................................... 29
9 Small Parts (Choking Hazards) ........................................................................................................................... 29
9.1 Baby ≤ 36 Months – All Markets .............................................................................................................................. 29
9.2 Small Parts Cylinder.................................................................................................................................................. 29
9.3 Safety Standard ........................................................................................................................................................ 29
10 Graspable Components ..................................................................................................................................... 29
10.1 Attachment Strength (Tension, Torque and Drop) ..................................................................................................29
11 Trim Supplier Sourcing & Qualification .............................................................................................................. 30
11.1 Adult Trim Supplier Requirements ........................................................................................................................... 30
11.2 Kids & Baby Trim Supplier Qualification Process .....................................................................................................30
11.3 Gap Inc. Component Pre-Certification Program ......................................................................................................31
12 Buttons and Toggles.......................................................................................................................................... 31
12.1 Poly and Nylon Buttons (Except Toggles) ................................................................................................................. 31
12.2 Button Attachment Requirements ........................................................................................................................... 32
12.2.1 general requirements ........................................................................................................................................... 32
12.2.2 Shank Button attachment.....................................................................................................................................32

12.2.3 Four-Hole Button attachment .............................................................................................................................. 32
12.3 Fabric-Covered Buttons............................................................................................................................................ 32
12.3.1 Children 3 years and younger ............................................................................................................................... 32
12.3.2 Children 4 years and over .....................................................................................................................................33
12.4 Toggle Buttons (Baby 0-5T) ......................................................................................................................................33
12.4.1 Material & Design Requirements ......................................................................................................................... 33
12.4.2 Test requirements ................................................................................................................................................ 33
13 Fragile Trims ..................................................................................................................................................... 33
13.1 Beads Strung on Shoulder Straps ............................................................................................................................. 33
13.2 Sequins for Toddler Apparel and Apparel Accessories*........................................................................................... 34
13.3 Rhinestones for Toddler Apparel and Apparel Accessories* ................................................................................... 35
13.4 Thread Test Specification ......................................................................................................................................... 37
13.5 Extra Trim .................................................................................................................................................................37
13.5.1 Children Age 3 and under .....................................................................................................................................37
13.5.2 Children Age 4 and over ....................................................................................................................................... 37
13.6 Fur and Faux Fur ....................................................................................................................................................... 37
13.6.1 Baby (Size 12 Months and under)......................................................................................................................... 37
13.6.2 Baby and Children (Sizes over 12 Months) ........................................................................................................... 37
13.7 Glitter ....................................................................................................................................................................... 37
13.7.1 Children Age 3 and Under.....................................................................................................................................37
13.7.2 Children Age 4 and Over ....................................................................................................................................... 37
13.8 Heat Transfers for Baby & Toddler........................................................................................................................... 37
13.8.1 Development and Testing of Heat Transfers ........................................................................................................ 38
14 Labels ............................................................................................................................................................... 38
14.1 Adhesive or Pressure-Sensitive Stickers ................................................................................................................... 38
14.1.1 Children 3 Years and Younger (Sizes 0 – 3T) ......................................................................................................... 38
14.1.2 Children 4 Years and Over (Sizes 4T and Above) ..................................................................................................38
14.2 Heat Transfer Labels................................................................................................................................................. 38
14.2.1 Baby (0-5t) ............................................................................................................................................................ 38
14.2.2 Children 4 Years and Over ....................................................................................................................................39
14.3 Tear-away Labels ...................................................................................................................................................... 39
14.3.1 Children 3 Years and Younger (Sizes 0 – 3T) ......................................................................................................... 39
14.3.2 Children 4 Years and Over (Sizes 4T and Above) ..................................................................................................39
15 Machine-Attached Hardware Trims ................................................................................................................... 39
15.1 Safety Requirements ................................................................................................................................................ 39
15.2 Application Requirements ........................................................................................................................................ 40
15.3 Grommets & Eyelets ................................................................................................................................................ 40
15.3.1 Baby (0-5T)............................................................................................................................................................ 40
15.3.2 Children (All Ages) ................................................................................................................................................ 40
15.4 Hooks & Bars ............................................................................................................................................................ 40
15.5 Snap Fasteners ......................................................................................................................................................... 41
15.5.1 Light-Duty Snap Fasteners (12-16 Ligne) .............................................................................................................. 41
15.5.2 Medium-Duty & Heavy-Duty Snap Fasteners (20-24 Ligne) ................................................................................. 41
15.6 Tack/Jean Buttons .................................................................................................................................................... 41
16 Other Metal Trims (Excludes Zippers) ................................................................................................................ 42
16.2 Hasps & Sliders ......................................................................................................................................................... 42
16.3 Hook & Eyes (Hand-Sewn or Stitched-On) ............................................................................................................... 43
16.3.1 Children 3 Years and Under ..................................................................................................................................43
16.3.2 Children 4 Years and Over ....................................................................................................................................43
17 Zippers ............................................................................................................................................................. 43

17.2 Baby Zipper Design & Test Requirements (0-5T) .....................................................................................................43
17.2.1 Design Requirements............................................................................................................................................ 43
17.2.2 Test Requirements................................................................................................................................................ 44
18 Pompoms, Tassels and Decorative Extensions ................................................................................................... 45
18.1 Pompoms .................................................................................................................................................................45
18.2 Tassels ......................................................................................................................................................................46
18.3 Decorative Extensions .............................................................................................................................................. 46
19 Jewelry (Including Hair Accessories, Headbands & Watches) ............................................................................. 47
19.1 Scope: Gap Inc. Jewelry Standards Apply to All Jewelry as Defined by Gap Inc. ..................................................... 47
19.2 Regulatory and Chemical Requirements .................................................................................................................. 47
19.3 Mechanical Hazards (Children’s) .............................................................................................................................. 47
19.3.1 Children 3 Years and Younger............................................................................................................................... 47
19.3.2 Children 4 Years and Older ...................................................................................................................................47
19.4 Breakaway Features (Children Only) ........................................................................................................................ 47
19.5 Jewelry Containing Batteries ....................................................................................................................................47
19.5.1 Children’s Jewelry ................................................................................................................................................. 47
19.5.2 Adult Jewelry ........................................................................................................................................................ 48
19.6 Jewelry Containing Magnets ....................................................................................................................................48
19.6.1 Children’s Jewelry ................................................................................................................................................. 48
19.6.2 Adult Jewelry ........................................................................................................................................................ 48
19.7 Liquid-Filled Jewelry ................................................................................................................................................. 48
19.8 Suction Tongue Studs ............................................................................................................................................... 48
19.9 Watches ...................................................................................................................................................................48
19.10 Hair Accessories ....................................................................................................................................................... 48
19.10.1 Children Under 36 Months ...................................................................................................................................49
19.10.2 Children 36 Months and Older ............................................................................................................................. 49
19.11 Headbands ............................................................................................................................................................... 49
19.11.1 Soft Fabric Headbands .......................................................................................................................................... 49
19.11.2 Hard Headbands ................................................................................................................................................... 49
20 Loop Hazards on Accessories for Infants, Toddlers and Children ........................................................................ 50
20.1 Bags for Toddlers and Infants...................................................................................................................................51
20.1.1 Loop Hazards ........................................................................................................................................................ 51
20.1.2 Bags for Toddlers and Infants Younger than 24 Months of Age ........................................................................... 51
20.1.3 Bags for Toddlers and Infants 24 Months and Older ............................................................................................ 51
20.2 Bungee Cords on Children’s Bags ............................................................................................................................. 51
20.3 Suspenders for Toddlers & Infants ........................................................................................................................... 51
20.3.1 Suspenders for Toddlers and Infants Younger Than 24 Months of Age ............................................................... 51
20.3.2 Suspenders for Toddlers and Infants 24 Months and Older................................................................................. 51
20.4 Visors for Toddlers and Infants ................................................................................................................................ 51
20.4.1 Visors for Toddlers and Infants Younger Than 24 Months of Age ........................................................................ 51
20.4.2 Visors for Toddlers and Infants 24 Months and Older ......................................................................................... 52
20.5 Scarves for Infants, Toddlers and Children .............................................................................................................. 52
20.5.1 Scarves for Toddlers and Infants Younger Than 24 Months of Age......................................................................52
20.5.2 Scarves for Toddlers and Infants 24 Months and Older ....................................................................................... 52
20.5.3 Scarves for Children Ages 4 – 18........................................................................................................................... 52
20.6 Blanket Stitch/Continuous Yarn Stitching ................................................................................................................ 52
20.6.1 Baby (0 – 36 Months) ........................................................................................................................................... 52
20.6.2 Kids (Over 36 Months) .......................................................................................................................................... 53
21 Drawstring, Tie and Decorative Tie/Bow ........................................................................................................... 53
21.1 Requirements and Guidelines ..................................................................................................................................53
21.2 Halter Neck Garments .............................................................................................................................................. 53
21.2.1 Design Restrictions for Baby and Toddler 0 – 24 Months .................................................................................... 53
21.2.2 Additional Halter Policy for Kids and Baby ........................................................................................................... 53

21.3 Hats with Chinstraps ................................................................................................................................................ 53
21.4 Neck Opening on Apparel ........................................................................................................................................ 54
22 Thread Ends/ Yarn Floats .................................................................................................................................. 54
22.1 Socks and Footed Apparel for Baby (0 – 36 Months) ............................................................................................... 54
22.2 Sweater Floats on Baby Apparel .............................................................................................................................. 55
23 Caped Apparel – Restrictions for Baby and Toddler ........................................................................................... 55
24 Laceration......................................................................................................................................................... 56
24.1 Sharp Points and Edges ............................................................................................................................................ 56
24.2 Hook & Loop Fastenings........................................................................................................................................... 56
24.3 Monofilament Thread .............................................................................................................................................. 56
24.4 Metallic Fiber and Yarns ........................................................................................................................................... 57
24.5 Needles & Foreign Metal Contamination................................................................................................................. 57
24.6 Zipper Guards ........................................................................................................................................................... 57
24.6.1 Baby and Toddler (0 – 36 Months) ....................................................................................................................... 57
24.6.2 Kids (4 years and older) ........................................................................................................................................ 57
24.7 Infant One-piece Garments with Center Front Zippers............................................................................................ 58
24.7.1 Construction Requirements..................................................................................................................................58
24.8 Pumice Stone Washed Garments............................................................................................................................. 59
24.9 Sandblasting Abrasives............................................................................................................................................. 59
24.10 Minimum Plant Safety Equipment ........................................................................................................................... 59
25 Footwear .......................................................................................................................................................... 59
25.1 Footwear Safety for All Age Groups ......................................................................................................................... 59
25.2 Additional Footwear Safety for Infants, Toddlers and Children ............................................................................... 60
26 Sunglasses ........................................................................................................................................................ 60
26.1 Requirements (All Age Groups) ................................................................................................................................ 60
26.2 Ultraviolet Protection (UVA & UVB) ......................................................................................................................... 60
26.3 US FDA Lens Testing ................................................................................................................................................. 60
26.4 European Requirements .......................................................................................................................................... 60
26.5 Japan Requirements ................................................................................................................................................. 60
27 Tacky Residue on Screen Printed Garments ....................................................................................................... 61
27.1 Requirements ........................................................................................................................................................... 61
27.2 Action Steps ............................................................................................................................................................. 61
28 Pigments Used as Garment Colorants................................................................................................................ 61
28.1 Prohibition of Pigments............................................................................................................................................ 61
29 Promotional Items ............................................................................................................................................ 61
29.1 Product Safety and Regulatory Requirements ......................................................................................................... 61
Notes and References .............................................................................................................................................. 62

List of Tables
Table 1 – Safety Rules for Certification ................................................................................................................................ 9
Table 2 – Azo Restrictions .................................................................................................................................................. 12
Table 3 – Cadmium Restrictions ........................................................................................................................................ 13
Table 4 – Formaldehyde Limits .......................................................................................................................................... 14
Table 5 – Formaldehyde: Japan Sampling Plan .................................................................................................................. 15
Table 6 – Heavy Metals ...................................................................................................................................................... 16
Table 7 – Lead Limits: Exclusion from Testing ................................................................................................................... 17
Table 8 – Lead limits: Apparel ............................................................................................................................................ 18
Table 9 – Lead Limits: Other Accessories ........................................................................................................................... 18
Table 10 – Nickel: Components Subject to Testing ............................................................................................................ 20
Table 11 – PAH Limits: Rubber and Plastic Components ................................................................................................... 20
Table 12 – Phthalate Requirements................................................................................................................................... 21
Table 13 – Cadmium Limits: Jewelry .................................................................................................................................. 22
Table 14 – Heavy Metals: Jewelry ...................................................................................................................................... 22
Table 15 – Lead limits: Jewelry .......................................................................................................................................... 23
Table 16 – Jewelry Age Labeling Requirements ................................................................................................................. 24
Table 17 – Gap Inc. Branded California Jewelry Certificate ............................................................................................... 25
Table 18 – In-Scope Kids & Baby Trim & Packaging Categories ......................................................................................... 30
Table 19 – Out-of-Scope Kids & Baby Trim & Packaging Categories.................................................................................. 31
Table 20 – Button Minimum Safety Requirements............................................................................................................ 31
Table 21 – S-2 Sampling Plan ............................................................................................................................................. 32
Table 22 – Toggle Button Test Requirements .................................................................................................................... 33
Table 23 – Toddler Sequin Requirements .......................................................................................................................... 34
Table 24 – Toddler Rhinestone Requirements................................................................................................................... 35
Table 25 – Thread Test Specification ................................................................................................................................. 37
Table 26 – Open Top Tack/Jean Button Restrictions by Age of Child ................................................................................ 42
Table 27 – Approved Hasp & Slider Designs ...................................................................................................................... 42
Table 28 – Zipper Pull/Zipper Type Requirements (Baby 0 – 5T)....................................................................................... 43
Table 29 – Baby Zipper Increased Testing Requirements & Sampling ............................................................................... 44
Table 30 – Production Testing Sampling Plan .................................................................................................................... 45
Table 31 – Pompom Requirements by Age ........................................................................................................................ 45
Table 32 – Tassel Requirements by Age............................................................................................................................. 46
Table 33 – Decorative Extension Requirements by Age .................................................................................................... 46
Table 34 – Children’s Headband Design Requirements by Retail Market ......................................................................... 49
Table 35 – Neck Opening Measurements .......................................................................................................................... 54
Table 36 – Sock Internal Yarn and Thread Ends ................................................................................................................. 54
Table 37 – Internal Toe Closure Threads ........................................................................................................................... 54
Table 38 – Internal Yarn Floats .......................................................................................................................................... 55
Table 39 – Cape Allowance by Market............................................................................................................................... 55
Table 40 – Maximum Cape Lengths Allowed by Size ......................................................................................................... 55
Table 41 – Cape Warning Labels ........................................................................................................................................ 56
Table 42 – Metallic Yarns/Fibers Design Requirements .................................................................................................... 57
Table 43 – Zipper Guard Requirements ............................................................................................................................. 58

REGULATORY AND CHEMICAL SAFETY REQUIREMENTS
To ensure a high level of safety for the products offered to our customers, Gap Inc. has established the standards,
requirements, and restrictions below, covering the United States, Canada, Europe, and Japan. Emerging markets (China,
Taiwan and Mexico) requirements are not included in the scope of this document. For China-specific requirements,
please refer to Technical Bulletins 173 series and 174 series. For Taiwan-specific requirements, please refer to
Technical Bulletin 208 series. For Mexico-specific requirements, please refer to Technical Bulletin 212 series. All
technical bulletins are posted to GapSource Library on GapWeb.
We expect suppliers to:

 Be accountable for compliance whether or not Gap Inc. chooses to enforce compliance through testing.
 Know the chemical composition and physical properties of the products they offer.
 Provide products that comply with all applicable Gap Inc. standards across all our markets.
Gap Inc. reserves the right to monitor supplier compliance with product safety requirements through audits and/or
other means in addition to the regular Testing Program.
The requirements stated in this manual apply to products that are:
 Gap Inc.-branded – Product or packaging bears Gap Inc. brand name/logo.
 Co-branded – Product or packaging bears Gap Inc. brand name/logo in conjunction with vendor's name/logo/brand.
 Un-branded – Product or packaging has no identifiable brand name/logo. By absence of branding, these products
are managed as Gap Inc.-branded.
For 3rd-party branded product, please refer to Technical Bulletin 203 series PSR Handbook for 3rd Party Vendor Brands.
1 Compliance with U.S. Product Safety Rules

1.1 Consumer Product Safety Act and Amendments1 Summary
 Gap Inc. and all US importers/US manufacturers of a consumer product subject to a Consumer Product Safety
Commission (CPSC) safety rule have been required to certify product compliance since the 2008 passing of the
Consumer Product Safety Improvement Act (CPSIA) and the subsequent amendments in 2011.
 Certification is the issuance of formal documentation stating that a product complies with all applicable CPSC rules,
standards, bans and regulations. This document is known as a Certificate of Compliance (COC), Children’s Product
Certificate (CPC) or General Certificate of Conformity (GCC) for non-children’s products.
 Certificates must be available to CPSC or US Customs and Border Protection (CBP) upon request. At US port of entry,
shipments found to have missing or invalid certificates face potential entry denial and/or destruction at the
importer’s expense. CPSC is authorized to impose civil fines or even criminal penalties against responsible parties
for products found in market to be non-compliant.
 Knowing and willful issuance of a fraudulent certificate or misrepresentation of product compliance on the
certificate is a US federal crime.
1.2 Gap Inc.’s CPSC Testing and Certification Program

 Substantive changes were made to Gap Inc.’s CPSC Testing and Certification program to address the final rule, 16
CFR 11072, which defined the requirements on how to test and certify compliance (effective Feb 8, 2013), and an
already effective companion rule, 16 CFR 11093 which allows certifiers to rely on another party’s test reports and
certificates.
 Non-children’s products: CPSC’s decision not to finalize “reasonable testing program” requirements for non-
children’s products allowed Gap Inc.’s existing adult testing and certification program to continue without
substantive change. Certification of adult products compliance is required for any applicable rule (e.g., flammability).
 Children’s products: The infrastructure of Gap’s CPSC Testing and Certification program is based on a Gap/vendor
co-certification of compliance. Gap Inc. and the vendor share in the responsibility to meet compliance requirements.

 Vendors certify finished product compliance based on sufficient and representative 3rd party testing, manufacturing
process controls, exercise of due care4 in accepting component certifications and component handling, record
keeping and undue influence policy and training.
 Gap uses the vendor’s finished product documentation as the basis for importer certification with the exercise of
due care as allowed in 16 CFR 1109.
 Co-certification allows vendors to take ownership of the certification requirements as the manufacturing experts
and Gap Inc. to achieve efficiencies by eliminating the need for duplicative testing while still ensuring compliance.
1.3 Gap Inc. CPSC Certification Folder on GapSource Library

 Gap Inc. maintains a folder of CPSC related documentation on GapSource Library in the following
location: >>GapSource Library>> Product Guidelines >> CPSC Certification
 User guides and forms include Gap Inc.’s certification policy, background and requirements along with vendor SOPs,
blank forms (COC and Test Failure Corrective Action), and PSR Authorized Trim Supplier list.
1.4 Responsibility as a Certifier5

 Duties as a certifier to establish compliance are the same for all certifiers (component, finished product and
importer). General requirements include:
o 3rd party testing to establish compliance, including:
 Sufficient sample size and sampling plan to provide high degree of assurance of compliance throughout
production lot
 Representative sampling to prevent selection of “golden samples”
 Periodic testing for continuing product
 New certification testing if material changes in design, materials, or manufacturing that could affect
compliance
o Corrective action and new testing:
 Testing failures investigated and root causes addressed
o Manufacturing controls to ensure:
 Process controls and documentation to ensure safe, compliant product
 Factory Production Testing Plans with procedures and controls to manage compliance
 Traceability along supply chain (for trim suppliers, this means ensuring that any sub-components obtained
from other suppliers meets testing requirements and is identifiable in the finished trim product)
 Exercise of due care to control conditions that could affect compliance, as well as due care in accepting
another party’s certificates of compliance
o Undue Influence:
 Policy and training of staff to safeguard against “undue influence” on labs to undermine test results
o Record Retention:
 Retention of records for minimum of 5 years documenting all of above
1.5 Gap Inc. Due Care Requirements

 CPSC puts special emphasis on the exercise of due care in relying on certification supplied by upstream partners in
the supply chain. Due care means reviewing the parties’ documentation before acceptance and their process
controls while the product or component is in their possession.
 Gap’s CPSC Testing and Certification program establishes due care by setting conditions for accepting certifications
as well as auditing and verification of testing, process, and documentation. Requirements include:
o Minimum sampling plans for vendor’s 3rd party testing to support CPSC certification
o Qualifications for parties authorized to supply CPSC documentation to Gap Inc. These include:
 Vendors with contractual relationship with Gap Inc. and signed VCA
 Kids and Baby Qualified Trim Suppliers who have met the qualification requirements (see section 11.2).
o Vendors required to collect and provide to Gap Inc. all documentation specified in 16 CFR 1109.5.g, including:
 Compliance Worksheet to identify component parts and establish traceability of parts to final product
 Vendor test reports from 3rd party labs

 Kids and Baby Qualified Trim Supplier’s component part certifications and test reports
 Vendor attestation of due care in accepting component supplier’s certification and controlling conditions
that could affect compliance
 Material change documentation and test reports
 Root cause analysis and corrective action plan to address testing failures
 Vendor facility audit by Gap Inc. QA or 3rd party auditor including: certification testing correlation through
verification sampling and testing of in-facility production and review of manufacturing process and documentation
1.6 Certificates of Compliance (COC)

 Gap Inc. created new COC forms as part of the 2012 CPSC Testing and Certification program revision.
o Adult and Kids/Baby COC forms are now separate documents.
o Adult COC form: Gap Inc. remains the sole certifier for adult product.
o Kids/Baby COC form: Vendor is required to co-certify with Gap Inc.
 Blank Gap Inc. COC forms are available in the CPSC Certification Folder on GapSource Library.
 Gap Inc. COC forms may only be used when Gap Inc. is the importer of record (IOR).
 For orders where the vendor is the IOR or from US domestic manufacturers, vendors must use their own forms as
the sole certifier. Refer to Technical Bulletin 206 series, Certification and Testing Responsibilities of US Importers
and Domestic Manufacturers in the CPSC Certification Folder on GapSource Library.
 16 CFR 1110, the rule that governs the certificate issuer, form, content and availability to CPSC and/or CBP is
currently under review by CPSC. Gap Inc. anticipates updating the COC form after the final rule is published. Based
on industry feedback, CPSC has moved 16 CFR 1110 rule review status to data analysis and is unlikely to publish a
final rule in 2015.
1.7 How to Certify Compliance

 Certifiers are responsible for knowing applicable safety rules for their products. Key Safety rules are in Table 1.
 Vendor SOP C101, workflow and instructions for certificate issuance when Gap Inc. is the IOR, is available in the
CPSC Certification Folder on GapSource Library.
Table 1 – Safety Rules for Certification
Key* Mandatory Safety Rules for Certification
Safety Rules Products / Limits / Comments
Lead in Substrates of Children’s Products Limit: 100 ppm total lead per component
(15 USC 1278a)
Lead in Surface Coatings, Paint, Furniture Limit: 90 ppm
(16 CFR 1303)
Lead in Metal Components of Children’s Jewelry Limit: 100 ppm
(15 USC 1278a)
Phthalates (15 USC 2057c) Limits:
Phthalates and scope of products will be impacted ≤0.1% (1000 ppm) of DEHP, DBP, or BBP in any toy or childcare article
by Proposed Rule Change (cited in Endnote 21) ≤0.1% (1000 ppm) of DINP, DIDP or DnOP in toy or childcare article that are mouthable
Flammability of Wearing Apparel Adult and children’s products subject to time-of-flame spread testing, if not exempt or
(16 CFR 1610, 1611) excluded
Sleepwear Flammability - Children’s Scope is flame resistant sleepwear subject to testing for length of charring. No certificate for
(16 CFR 1615/1616) snug fit sleepwear.
ASTM F963 Standard Consumer Safety Certification of compliance for properties that involve actual testing
Specifications for Toy Safety (15 USC 2056b)
Small Parts Choking Hazard Accessories, foodware and articles for children under 3 years
(16 CFR 1501) Apparel and footwear must comply but are exempt from certification (16 CFR 1501.3)
Mechanical Hazards - Specified Children’s Articles Bans and/or restrictions on products including dive sticks, clacker balls, noisemaking toys,
(16 CFR 1500.18(a)(9) toys with electrical hazards, lawn darts, caps, baby bouncers, small balls, etc.
(16 CFR 1500.86(a)(5), (a)(7), (a)(8)
Bicycle Helmets (16 CFR 1203) Design, construction, performance testing, and labeling requirements for all ages
Pacifiers (16 CFR 1511) Restrictions on shield, flexibility, small parts with testing and labeling requirements
Rattles (16 CFR 1510, 1500.18, 1500.86) Restrictions on mechanical hazards causing choking, laceration, or suffocation, with testing.
Carpet/Rug Flammability (16 CFR 1630-31) Ignition testing with restrictions on charring. Labeling option for non-passing small rugs.
Electrically Operated Toys (16 CFR 1505; 1500.18) Toys, intended for use by children, powered by 120 volt electrical current from circuits

*Not all-inclusive but covers most products relevant to Gap Inc. Brands. Other very specific safety rules exist for matchbooks,
cigarette lighters, refrigerators, garage-door openers, lawn mowers, and other consumer products over which CPSC has jurisdiction.
2 Restricted Substances
2.1 Restricted Substances List (RSL) – EU REACH
 Gap Inc.’s regular Testing Program limits selected hazardous chemicals. With rapid expansion of chemical legislation
across markets, Gap Inc. created a more comprehensive Restricted Substances List (RSL) and associated special
testing program in 2008. The RSL, initially created to address Europe’s REACH6 Regulation, also facilitates
compliance with new chemical reporting laws7 in states like California, Washington, and Maine as well as chemical
restrictions in new markets.
 REACH is chemical regulation that ensures EU manufacturers and importers control chemical hazards in their
products. EU regularly updates its list of Substances of Very High Concern (SVHC).
o SVHC are chemicals categorized by scientific and governmental authorities as carcinogenic, mutagenic, or toxic
to reproduction (CMRs). Also included are other persistent, bio-accumulative, and toxic substances (PBTs) as
well as substances of equivalent concern.
o SVHCs are regulated at a concentration ≥0.1% by weight of the entire product. A much stricter standard of
limiting the SVHC concentration to ≥0.1% by component weight is expected to eventually become the standard.
o Consumers and governments may inquire about presence of SVHC in products above 0.1% and must be
answered accurately within 45 days.
o If a product contains an SVHC >0.1%, importers/manufacturers must calculate and report annually the total
aggregated amount of the SVHC above 1 ton in all their products in the EU market.
o All SVHC are slated to be eventually banned from use in the EU unless authorized for a specific use by a specific
company that petitions for and justifies the SVHC’s use. SVHC will gradually be restricted to strict limits in
imported articles over time.
 Gap Inc. RSL sets limits for hazardous chemicals in finished products components, based on a combination of
legislative requirements, industry best practice, and scientific evidence.
 For any product offered in Europe, Gap Inc. prohibits presence of SVHCs above 0.1% by weight of the product.
 Most current RSL and Standard Operating Procedure (SOP) are available on GapSource Library on Gap Web.
 Gap Inc.’s RSL applies to all Gap, Banana Republic, Outlet, Old Navy, and Athleta styles. Intermix styles will be
phased in at a later date.
2.2 Gap Inc. RSL Testing Program

 RSL testing program is a separate program currently paid for by Gap Inc. that is in addition to, not in place of, Gap
Inc.’s regular Testing Program.
 Testing is performed on selective sampling of styles based on product risk and vendor characteristics and
performance. Sampling is taken at higher rates from riskier products, higher volume vendors, and poorly
performing vendors.
 RSL testing uses advanced chemical screening technique to minimize costly and time-consuming quantification tests.
 RSL testing may only be performed by Gap Inc. approved RSL Labs with advanced, reliable analytical capabilities.
Currently approved labs are exclusively Modern Testing Service (MTS) in Hong Kong and Germany.
2.2.1 CRITICAL “REACH” TESTING FAILURES

 No product may be sold in the EU that fails the SVHC limit (>0.1% by wt. of product).
 Vendors must correct REACH failures before shipping.
 EU shipments are rejected if failure cannot be corrected. UK-Product Integrity (PI) and UK Legal have final authority.
 Shared styles that fail may ship to the non-EU markets if Gap Inc. legal and safety requirements for those markets
are not compromised. San Francisco Corporate Product Safety and Regulations with Legal exercises final authority.
 Critical failures result in increased monitoring of vendor and testing of additional styles at vendor’s expense. A
record of passing tests leads to reduced testing and increased trust in that vendor’s compliance.
 Consistent failure without improvement may result in reduced business and eventual termination of relationship
with vendor.

2.2.2 NON-CRITICAL ADVISORY RSL COMPONENT FAILURES
 Test reports show failures to Gap Inc. RSL limits by component weight, in addition to critical REACh failures by
product weight. Non-regulated RSL component failures currently do not stop shipments unless they pose safety
risks.
 Gap Inc. provides this advisory information to vendors to facilitate reduction or elimination of violating chemicals
before bans and restrictions take effect at the stricter component level.
2.2.3 RESULT TRACKING

 Test results are tracked to build metrics for vendor risk ratings. Better results will result in reduced testing.
 Product risk ratings are also tracked to ensure sufficient testing coverage by product.
3 Chemicals of Concern – Selected Substances

Gap Inc.’s RSL is a comprehensive statement of “chemicals of concern” to be controlled. The following is a smaller
subset of chemicals that have special significance due to legal restriction, hazard, and/or history of usage in apparel
and apparel accessories. Chemical groups are listed alphabetically.
Use this link for more information regarding where chemicals of concern can be found in manufacturing processes and
how to manage them. http://www.afirm-group.com/supplierrsltool.htm
3.1 Antimicrobial Treatments

 Antimicrobial finishes on garments and apparel accessories inhibit odor-producing bacterial growth associated with
perspiration. Antimicrobials include chemicals like Triclosan and silver formulations, among others. Because these
chemicals function as pesticides and must be safe for human exposure, antimicrobial treatments are regulated in
many markets.
 SF Product Safety & Regulations (PSR) must be informed of any antimicrobial treatment to ensure chemical safety is
documented and its use complies with market regulations.
o Chemical composition of any such potentially hazardous treatment must be fully disclosed in documentation
from vendor or mill.
3.1.1 NORTH AMERICA REQUIREMENTS

 Regulations of the U.S. Environmental Protection Agency require that the antimicrobial finish be formally registered
as a pesticide and that the EPA-approved registration label on the chemical product specifically reference the
product category it will be applied to (e.g. socks, undergarments, leggings, etc.).
 Vendor must provide its EPA registration number for verification by PSR.
3.1.2 EUROPEAN UNION REQUIREMENTS

 Regulations in the EU require that an antimicrobial finish be approved for use in the specific product category or
have been previously used in the same or similar Gap Inc. product available for sale in the EU before Sept. 1, 2013.
 The product or packaging must contain a clearly visible, legible, and durable label in languages of the EU member
countries where product will be sold, with the following:
o a statement that the product incorporates an antimicrobial product
o the antimicrobial property attributed to the treated product, e.g., resistance to odors
o names of active substances
o names of any nanomaterials contained in the antimicrobial product followed by the word “nano” in brackets
o relevant instructions for use including any necessary precautions
 Upon customer request, information on the antimicrobial substance(s) must be provided within 45 days, cost free.
3.1.3 MARKETING CLAIMS

 Marketing claims and label statements concerning the antimicrobial must be approved by Product Regulations to
ensure compliance with government regulations, which strictly limit claims to protecting the product, such as:
“This product contains an antimicrobial agent to control odors.” It is not permitted to:
o Make public health claims
o Claim the antimicrobial treatment provides protection against disease
o Imply normal laundering/hygienic measures are not needed
 Claims must be located together, printed in font of the same size, style, and color, and should be given equal
prominence to other described product features.
 To justify marketing claims, Gap Inc. requires antimicrobial-treated products to be tested for performance in either
the fabric or garment stage. For testing requirements, see the Apparel & Apparel Accessories PSR Protocol GP100
under the Product Guidelines & Testing >> Softlines Manual, Testing Protocols, and
Product Testing Specifications link on GapSource Library.
3.2 Azo Dyes8

 Azo colorants (dyes) that produce prohibited amines are banned from use.
 Dyestuff must not contain detectable amounts (less than 20 ppm) of the following amines.
Table 2 – Azo Restrictions

Restricted Amines CAS # Restricted Amines CAS# Limit
1 4-Amino-azobenzene 60-09-3 13 3,3'-Dimethoxybenzidine 119-90-4
(o-Dianisidine)
2 o-Aminoazotoluene 97-56-3 14 3,3'-Dimethylbenzidine (o-Tolidine) 119-93-7
3 4-Aminodiphenyl 92-67-1 15 3,3'-Dimethyl-4,4'-diamino- 838-88-0
diphenylmethane
4 2-Amino-4-nitrotoluene 99-55-8 16 4,4'-Methylene-bis-(2-chloroaniline) 101-14-4
Not
5 o-Anisidine 90-04-0 17 2-Naphthylamine 91-59-8
Detected
6 Benzidine 92-87-5 18 4,4'-Oxydianiline 101-80-4
(20 mg/kg)
7 p-Chloroaniline 106-47-8 19 4,4'-Thiodianiline 139-65-1
8 4-Chloro-o-toluidine 95-69-2 20 2,4-Toluenediamine 95-80-7
9 p-Cresidine 120-71-8 21 o-Toluidine 95-53-4
10 2,4-Diaminoanisole 615-05-4 22 2,4,5-Trimethylaniline 137-17-7
11 4,4'-Diamino-diphenylmethane 101-77-9 23 2,4-Xylidine 95-68-1
12 3,3'-Dichlorobenzidine 91-94-1 24 2,6-Xylidine 87-62-7
25 Benzene-1,4-diamine dihydrochloride; 624-18-0 1000
p-phenylenediamine dihydrochloride mg/kg
 Benzene-1,4-diamine dihydrochloride; p-phenylenediamine dihydrochloride: tested by the Restricted Substances List Testing
Program and not the regular Testing Program.
3.2.1 TESTING
 The regular Testing Program limits testing of Azo amines to the following high-risk fabrics and materials: hand dyed
cotton, silk, wool, animal hair and leather. However, RSL testing looks for prohibited amines in all materials.
3.2.1.1 Greece and Turkey Franchise Markets Special Testing

 Greece and Turkey separate Azo testing was discontinued in January, 2013.
 Both of these franchise markets now follow Gap Inc.’s normal testing protocol for the EU.

3.3 BPA (Bisphenol-A)
 Any children’s product sold by Gap Inc. must be manufactured without BPA and have no detectable BPA if audited.
 Heat-sensitive dyes used to produce so-called “hypercolor” effects in textiles may intentionally contain BPA, e.g., T-
shirts that change color when heat is applied, and are not permitted.
3.3.1.1 Testing
 The Restricted Substances List Testing Program, where styles are selectively sampled for testing, screens for BPA in
all materials of children’s products. (See Restricted Substances List (RSL) – EU REACH in Section 2).
3.4 Cadmium9
 Across all markets, Gap Inc. bans cadmium from use except where a product cannot function without it, such as in
certain electronic components not in the scope of apparel and apparel accessories.
 Cadmium limit of 0.01% by weight (100 ppm) in non-jewelry is verified through testing of EU and EU franchise non-
jewelry orders. The scope of testing is limited to manufactured materials such as metal, plastic, and coatings.
Although mandatory testing is not required in other markets, cadmium is still banned.
 Jewelry for all ages: Cadmium restrictions and testing are required for jewelry. All regulatory and chemical
requirements for jewelry are consolidated in Section 4 below but Table 3 here summarizes the cadmium limits.
Table 3 – Cadmium Restrictions

Gap Inc. Cadmium limits* – All Ages
(by weight of accessible component)
Non-Jewelry (Test EU & EU Franchise Only)
Metal, plastic, coatings, topical treatments 0.01% (100 ppm)
Jewelry (Test all markets)
Metal, plastic, glass, surface coatings, topical treatments 0.0075% (75 ppm)
* Natural substrate materials, with coatings/finishes removed, are not expected to contain cadmium, e.g., wood, horn, glass,
stainless steel, and more (See lead exclusions in Table 7). Suppliers are responsible for knowing whether their materials result in
excessive cadmium levels.
3.5 Chemical Finishes

 Product Safety & Regulations Standard Operating Procedure (SOP) C001 on GapSource Library/Product Guidelines
and Testing sets out development procedures for new textile chemical finishes to ensure they meet environmental,
health and safety standards.
o Finish developers and the Gap Inc. business partner must compile a Compliance Review File with basic
information (type of chemical, purpose of finish, MSDS, toxicological assessments if any, and more).
o Product Safety and Regulations must review file along with Environmental Affairs Department (Social
Responsibility). Review can take 2-4 weeks.
3.6 Chromium VI (Hexavalent Chromium)

 CrVI must not be present above the detection limit (3 mg/kg) in all leather components of products supplied to
Gap Inc.
3.6.1 TESTING
 Leather substrates of all baby products as well as kids’ footwear and accessories are routinely tested for CrVI in the
regular Testing Program. Leather substrates in adult handbags intended for the EU market are also routinely tested
for CrVI. The RSL Testing Program, where styles are selectively sampled for testing, tests all leather substrates of
components in baby, child and adult products for CrVI (See Gap Inc. RSL Testing Program in Section 2).

3.7 Colorfastness of Dyes
3.7.1 COLORFASTNESS TO SALIVA IN INFANT PRODUCTS
Although not specifically a chemical prohibition in most markets, dye transfer onto infants caused by mouthing or
sucking is restricted. (Note China restricts it in its mandatory China Textile Safety Standard GB 18401.)
 All baby apparel and apparel accessories must be tested and meet the minimum requirement of Class 4.0 for
colorfastness to saliva AATCC multifiber test strip staining, color change and self staining, following China method:
GB/T 18886-2002 (mod).
 Baby accessories not already covered by the rule for textiles (e.g., shoes, straw bags, hats) will transition to the new
standard in Spring 2016 production.
3.7.2 PIGMENT BAN FOR BABY 0-24 MONTHS AND MATERNITY

Pigment colorants as a class vary widely in color retention and bleeding. Because dye transfer is highly undesirable in
baby and maternity styles, pigment colorants are not permitted to be used for maternity apparel and apparel/apparel
accessories for baby 0-24 months. Please see Section 28.
3.8 DMFu (Dimethyl Fumarate)

 DMFu is used to prevent mold formation during storage and transit. DMFu in silica gel packets and similar “drying
agents” in packaging or as a spray applied directly to product are prohibited as toxic chemicals. With or without
DMFu, silica packets are known to be ineffective as a drying agent in high-humidity conditions at factories.
3.9 Formaldehyde
 Gap Inc. restricts formaldehyde in textiles (including leather), textile trim (including linings, ribs, cuffs, non-woven
interlinings, labels, etc.), and accessories with skin contact such as footwear and textile/leather jewelry components.
Please note: Japan law requires any textile accessory sized for Baby to meet the strict limit for Baby, whether or not
it has direct skin contact.
Table 4 – Formaldehyde Limits
Formaldehyde Limits: Apparel and Apparel Accessories
Product Type / Test Method Baby (0-36 months) Children and Adults
Apparel, Apparel Accessories, Af < 0.05  75.0 (parts per million)
Jewelry and Home Textiles Japan Market: Results between 0.03 and 0.05 require
 JIS Method 1041 GIS PI to verify that units tested by color meet S2
sampling plan for each color’s quantity on Japan PO.
Footwear:
Leather 30 ppm 150 ppm
 ISO TS 17226
Textile 20 ppm 75 ppm
 ISO 14184-1
Outerwear Af < 0.05 Children Adults
(Coats, jackets for wear over Japan Market: Results between 0.03 and 0.05 require 75 ppm 300 ppm
other garments) GIS PI to verify that units tested by color meet S2
 JIS Method 1041 sampling plan for each color’s quantity on Japan PO.
3.9.1 TESTING
 Textiles are tested following Japanese Test Method (J.I.S. 1041, Law 112). Footwear and related accessories are
tested to EU ISO methods noted in Table 4.
3.9.1.1 Japan market

 A legal agreement with Japan requires Gap Inc. baby product to be tested for formaldehyde in Japan and the
number of units tested must meet a statistical sampling plan. This applies to any Gap Inc. Brand selling in Japan, for
apparel and apparel-type accessories (e.g., shoes, hats) with size ranges that include baby (i.e., 0 – 3 yrs.)

 Gap Inc. uses the Japan Synthetic Textile Inspection Institute Foundation (JSTIIF)’s Tokyo lab, affiliated with Bureau
Veritas, one of Gap Inc.’s approved laboratory networks. Vendor is responsible for sending required number of
samples to JSTIIF.
o Japan contact information: JSTIIF, 1-7-22 Saiwai-cho, Kawaguchi-shi, Saitama Pre., 332-0016, Japan, Tel: +81-48-
258-3277, Fax: +81-48-258-3288.
o Number of units for Japan formaldehyde testing is required to follow the S2 sampling plan shown in Table 5,
based on Japan purchase order quantities. Sampling at this level improves the reliability of test results when the
limit is as close to the limit of detection as Japan’s. Samples for testing must be drawn randomly from
production.
o If a style number is offered in more than one color, at least one unit of every color must be represented in the
sample group for testing, which may increase the same size.
Table 5 – Formaldehyde: Japan Sampling Plan
S2 Sampling Plan for Testing Japan POs
Japan Baby Program Units Minimum Samples for Testing
(Unit: Garment) (Unit: Garment)
26 – 150 3
151 – 1,200 5
1,201 – 35,000 8
35,000 – 500,000 13
o Formaldehyde testing for orders for other Gap Inc. markets may rely on the Japan testing if it fits with shipping
schedules for the other markets.
3.9.2 FORMALDEHYDE EMISSION FROM COMPOSITE WOOD PRODUCTS

 To protect air quality, some US states and the federal government restrict emission of formaldehyde from
composite wood products. Although most composite wood products are not in scope of this document, apparel and
accessories could contain composite wood components, e.g., handbags with “wooden” handles and
garments/footwear with “wooden” trim parts like buttons.
 Please refer to Technical Bulletin 178, Composite Wood Products: Formaldehyde Restrictions and Labeling (August
3, 2010) on GapSource Library for complete details on the following:
o Composite wood is particle board, fiberboard, and plywood under various specifications.
o Gap Inc. vendors and their suppliers must ensure composite wood is sourced from certified mills that meet
required emission standards, must maintain certain documentation, and attach specified labels to products with
composite wood.
o Products in store are subject to government inspection and testing. Importers and retailers must provide
documentation as requested.
o Solid wood is not subject to composite wood requirements. Because the complex composite wood requirements
apply even to very minor components, solid wood is preferred for components of apparel and apparel
accessories.
3.10 Heavy Metals (Soluble)

 All baby products must not exceed limits in Table 6 below.
 Heavy metals restrictions and testing are required for children’s jewelry. Regulatory and chemical requirements for
jewelry are consolidated into Section 4 below.
 Any product found to have “play value” by Gap Inc. or approved laboratories must comply with the soluble heavy
metal limits of ASTM F 963 Standard Consumer Specifications for Toy Safety10 using test method BS EN 71-3 (mod)
as applied to both surface coating and substrate materials.
3.10.1 TESTING
 All accessible components of baby products and children’s jewelry are subject to testing following BS EN 71-3 (mod).
 For leather and suede substrates, which typically are chromium-tanned, the chromium value is reference only.
However, presence of chromium triggers additional testing for chromium VI, which must be non-detectable
(see Section 3.6 above).

Table 6 – Heavy Metals
Soluble Heavy Metal Limits
Baby Products and Jewelry for Children (per accessible component)
Antimony (Sb) ≤60 ppm
Arsenic (As) ≤25 ppm
Barium (Ba) ≤1000 ppm
Cadmium (Cd)* ≤75 ppm
Chromium (Cr) ≤60 ppm
Lead (Pb)* ≤90 ppm
Mercury (Hg) ≤60 ppm
Selenium (Ae) ≤500 ppm
*Because total cadmium in jewelry is limited to 75 ppm, Cd cannot exceed the identical soluble limit. Similarly, total lead in surface
coatings of children’s products is limited to 90 ppm, so Pb cannot exceed soluble limit.
3.11 Heavy Metals (Total) – Packaging

 Intentionally added lead, mercury, cadmium or chromium VI are prohibited in packaging or packaging components
that include inks, dyes, pigments, adhesives, stabilizers or additives.
o Total sum concentration of the metals may not exceed 100 parts per million (0.01% by weight).
o Suppliers must maintain documentation of compliance for their packaging materials.
o Refer to Toxics In Packaging Clearinghouse website for additional details.
3.12 Lead
Gap Inc. and the laws in many markets impose severe limits on lead in children’s products. Increasingly, lead is
restricted in products for adults as well, including by Gap Inc.
3.12.1 GENERAL REQUIREMENTS

3.12.1.1 Testing
Following Gap Inc.’s lead limits in the tables below, all accessible, non-exempted components require testing.
Exempted materials require documentation supplied by vendor and are subject to verification.
3.12.1.2 Jewelry for All Ages

Lead restrictions, testing and certifications are required for jewelry. Regulatory and chemical requirements for jewelry
are consolidated into Section 4 below.
3.12.1.3 Certifications
 Children’s products: Under US law, Children’s products require testing and certification. (See “Certification of
Compliance” in Section 1.6 above.)
3.12.2 CHILDREN’S PRODUCTS

The U.S. Consumer Product Safety Improvement Act (CPSIA) reduced total lead content to levels in the tables below.
In general, total lead content must not exceed 0.009% by weight (90 ppm) in surface coatings and 0.01% by weight
(100 ppm) in substrates of accessible components. Products must meet these limits to be certified compliant.
 “Children’s Product” is defined under US law as designed and intended primarily for children 12 years and under.
However, Canada and Europe consider children to be 14 years and under. Gap Inc. policy requires all Kids and Baby
products, regardless of age range, to meet the lead restrictions.
3.12.2.1 Accessible Components

Accessibility is determined by CPSC use and abuse tests. Coatings and electroplating do not make parts inaccessible.
However, fabric that covers or encloses a part and passes use and abuse testing makes the part inaccessible, provided
the product or part is not small enough to be placed in the mouth (less than 5 cm in any one dimension).

3.12.2.2 Exception Process
The law sets high hurdles to obtaining exemptions11 from lead limits when lead is present. After notice and a hearing,
CPSC may grant a “functional” exception for a specific product, class of product, material, or component under these
conditions:
 It is not practicable or technologically feasible to remove the lead or make it inaccessible during manufacture; and
 Part is not likely to be placed in the mouth or ingested, under foreseeable use and abuse; and
 Lead concentration will have no measurable adverse effect on public health, measured currently by no increase in
blood lead levels. (CPSC may come up with a different measure in future.)
3.12.2.3 Electronics Exception

While not common, some Gap Inc. apparel and accessories contain electronic components. CPSC allows specified
components12 to exceed normal lead limits when it is not technologically feasible for these parts to function without
lead. An example is a copper alloy connector prong at the end of a cord that plugs into an electronic device.
3.12.2.4 Exclusions from Testing 13

 Specified materials: Table 7 below shows materials CPSC excludes from testing, provided the materials are not
treated in any way that could exceed the lead limits.
 Product categories: Ordinary books and paper products without play value.
o Exclusion from testing does not cover metal and plastic components that are not part of conventional binding
and finishing methods.
Table 7 – Lead Limits: Exclusion from Testing
Materials Excluded from Children’s Lead Limits
(by Exclusion From Testing)
Precious gemstones: diamond, ruby, sapphire, emerald
Semiprecious gemstones and other minerals if not based on lead or lead compounds and not associated in nature with any
mineral based on lead or lead compounds. Not exempt from testing: aragonite, bayldonite, boleite, cerussite, crocoite,
galena, linarite, mimetite, phosgenite, vanadinite, and wulfenite
 Natural or cultured pearls
 Wood
Paper and similar materials made from wood or other cellulosic fiber, including, but not limited to paperboard, linerboard
and medium, and coatings on such paper which become part of the substrate
Product Category of books and paper products, including sub-materials used in conventional finishes and binding only. Does
not include added plastic or metal components. Does not include products with play value.
CMYK process printing inks (excluding spot colors, other inks that are not used in CMYK process, inks that do not become
part of the substrate, and inks used in after-treatment applications, including screen prints, transfers, decals, or other prints)
Textiles (excluding after-treatments, such as screen prints, transfers, decals, or other prints):
 Natural fibers (dyed or undyed) including, but not limited to, cotton, kapok, flax, linen, jute, ramie, hemp, kenaf, bamboo,
coir, sisal, silk, wool (sheep), alpaca, llama, goat (mohair, cashmere), rabbit (angora), camel, horse, yak, vicuna, qiviut,
guanaco;
 Manufactured fibers (dyed or undyed) including, but not limited to, rayon, azlon, lyocell, acetate, triacetate, rubber,
polyester, olefin, nylon, acrylic, modacrylic, aramid, spandex.
Other plant-derived and animal derived materials including, but not limited to, animal glue, bee’s wax, seeds, nut shells,
flowers, bone, sea shell, coral, amber, feathers, fur, leather
Specified metals, alloys if no lead or lead-containing metal is intentionally added. Does not include non-steel or non-
precious metal parts, such as solder or base metals in electroplate, clad, or fill applications:
 Surgical steel and other stainless steel within the designations of Unified Numbering System, UNS S13800–S66286, not
including the stainless steel designated as 303Pb (UNS S30360);
 Precious metals: Gold (at least 10 karat); sterling silver (at least 925/1000); platinum; palladium; rhodium; osmium;
iridium; ruthenium, titanium
3.12.2.5 Illinois
 Illinois law14 requires special lead warning labels for certain children’s products with components exceeding 40 ppm
lead. The following products with accessible components whose lead test results exceed 40 ppm must not be
distributed in Illinois. Lead warnings are not an option.
o Paint/surface coatings on children’s toys
o Children’s Jewelry

o Childcare articles, defined as “…designed or intended by the manufacturer to facilitate the sleep, relaxation, or
feeding of children under the age of 6 or to help with children under the age of 6 who are sucking or teething.”
3.12.3 ADULT PRODUCTS

 To ensure non-children’s apparel and apparel accessories do not expose consumers to lead, Gap Inc. has set the
limits shown in Table 8 and Table 9 below. The general default limit is 300 ppm in accessible surface coatings and
substrates for most materials that are not otherwise exempted. Plastic requires a lower limit of 200 ppm per
accessible component.
Table 8 – Lead limits: Apparel
Apparel and Soft Accessories (Textile And Leather)
Gap Inc. Lead limits
Accessible Components Adult Kids and Baby
Surface Coatings
Fabrics & Leather: Topical after-treatments when mechanically ≤0.03% by weight (300 ≤0.009% by weight (90ppm)
separable from substrates (e.g., potentially paint, coatings, screen ppm) of each surface of each surface coating
prints, transfers, decals, flocking, and others) coating
Trim Components: Buttons, snaps, zippers, etc.
Substrates
Fabrics & Leather: Topical after-treatments when not mechanically Metallic: ≤300 ppm ≤0.01% by weight
separable from substrates (e.g., some screen prints, transfers, decals, Plastic: ≤200 ppm (100 ppm)
flocking, laminates, plastic-coated fabrics)
Trim Components: Buttons, snaps, zippers, etc.
Table 9 – Lead Limits: Other Accessories
Other Accessories: Footwear, Bags, Belts, Sunglasses*
Gap Inc. Lead limits
CA Prop 65 / Gap Inc. Requirements CPSC Requirements
Metallic Components
Exempt materials, if documented by supplier All other metals All other metals
following definitions in Excluded Materials Table 7: ≤0.03% by wt (300 ppm) Surface Coatings
 Surgical and stainless steel alloys ≤0.009% by wt (90 ppm)
 Precious metals: Karat gold, sterling silver, Substrates
platinum metals ≤0.01% by wt (100 ppm)
Non-Metallic Components
Exempt materials, if documented by supplier Surface coatings Surface coatings
following definitions in Excluded Materials Table 7: ≤0.03% by wt (300 ppm) ≤0.009% by wt (90 ppm)
 Natural & cultured pearls
 Gemstones Plastic, rubber substrates Substrates
 Elastic, fabric, ribbon, rope, string with no ≤0.02% by wt (200 ppm) ≤0.01% by wt (100 ppm)
intentionally-added lead
 Natural materials: amber, bone, coral, feathers,
fur, horn, leather, shell, wood in natural state or
treated without added lead
Ceramic, Glass & Crystal These substrate materials are exempt in
(e.g., cat’s eye, CZ, rhinestones, cloisonné) adult products. Surface Coatings
 Metallic backings on rhinestones fall ≤0.009% by wt (90ppm)
under metallic limit
All other separable surface coatings fall Substrates
under non-metallic limit ≤0.01% by wt (100 ppm)
All Other Materials ≤0.03% by wt (300 ppm) ≤0.01% by wt (100 ppm)
*Handbags, small leather goods, wallets, backpacks, luggage; belts and suspenders; footwear; sunglasses; earmuffs; umbrellas
3.12.4 CANADA
 Canada lead limits for most apparel and apparel accessories are covered by Gap Inc. lead limits in the tables above.
However, any apparel or apparel accessory with a component that qualifies as one of the following must comply
with the more stringent lead limit of 90 mg/kg in the Canada market:
o Toys and articles for learning for children under 3 years, e.g. crayons.
o Products intended to be brought to mouth for any age, e.g., musical instruments.
3.13 Liquid Filled Products (Jewelry, Accessories, and Apparel)

3.13.1 ALL PRODUCTS
All products must not contain liquid filled components containing chemicals or materials that:
 Pose safety hazards15 from ingestion, aspiration, and skin contact if exposed.
o Prohibited chemicals include mercury, diethylene glycol, ethylene glycol, methanol, methylene chloride,
petroleum distillates, toluene, xylene, turpentine, kerosene, liquid paraffin, and related substances as described
by CPSC in 16 CFR 1500.231.
 Require special labeling as described by CPSC in 16 CFR 1500.14
o Examples of such labeling: “HARMFUL IF SWALLOWED,” “VAPOR HARMFUL,” “MAY BE FATAL OR CAUSE
BLINDNESS IF SWALLOWED,” “CALL PHYSICIAN IMMEDIATELY,” and more
 Have a flashpoint less than 150° F (65.6 C)
3.13.2 LIQUID FILL

Liquid fill must be clean.
 Microbial limits16
o Prohibited: Staphylococcus aureus, Pseudomonas aeruginosa, Salmonella, and fecal coliform17 bacteria such as
Escherichia Coli
o Total viable count (equal to total aerobic microbial count + total combined mold and yeast) is not to exceed
500 cfu/g or cfu/mL (for baby products) and 5000 cfu/g or cfu/mL (all others).
3.13.3 EVALUATION
A Gap Inc. approved lab must review chemical formulation of filling. Documentary assessment is usually sufficient to
pass the product. If questions arise, lab may require testing under the GP 8003 protocol (Liquid Based Solutions).
 Vendors submit product sample along with fill formulation detailed on special form provided by lab.
 Lab notifies vendor and Gap Inc. if it determines testing is necessary.
3.14 Mercury
3.14.1 ALL PRODUCTS
 Intentionally added mercury is prohibited in all components, including surface coatings. Mercury occurs in nature
and can be an unavoidable contaminant; hence only trace amounts less than 1 ppm (0.0001% by weight) are
permitted.
3.14.2 BATTERIES
 Mercury is prohibited above trace amounts (less than 1 ppm) in all button cell batteries (removable or non-
removable). Even though mercury had a functional purpose in button cells, it has now been banned in our markets.
Suppliers must provide documentation of mercury content in products with button cell batteries.
 Mercury-compliant button cell batteries are available from multiple foreign and domestic sources, including New
Leader, an approved supplier in China.
 Note: Alkaline (cylinder) batteries generally are not manufactured with mercury.
3.15 Nickel
 Nickel is a potential skin sensitizer. For all markets, Gap Inc. restricts nickel migration (leaching) in jewelry and
apparel trims in direct and prolonged contact with skin. Nickel migration is restricted by law18 in the EU for items in
direct and prolonged contact with skin.

 Jewelry: Nickel restrictions and testing are required for jewelry. Regulatory and chemical requirements for jewelry
are consolidated into Section 4 below.
 Apparel trims (metal substrates): Nickel migration is limited to ≤0.28 micrograms/cm2/week.
 Testing: EU orders (including Franchise) of jewelry and specified apparel trims with direct and prolonged skin
contact are required to be tested, following EU methods for wear (BS EN 12472) and release (BS EN 1811).
Table 10 – Nickel: Components Subject to Testing
SUBJECT TO TESTING ON EU ORDERS IN REGULAR TESTING PROGRAM
Belt Buckles Rivets & Burrs
D-Rings Shank Buttons (not 2 or 4-hole buttons)
Eyelets Snaps (all four parts of snap)
Hasps & Sliders Suspender Clips
Hooks & Eyes Zipper parts: only metal slider and pull-tab if
Jewelry slider is non-standard construction (i.e., where
Rings and Sliders pull is not directly connected to slider).
 Sunglasses (metal substrates): Nickel migration is limited to ≤0.28 micrograms/cm2/week.
o Testing: EU orders (including Franchise) of sunglasses (metal parts) with direct and prolonged skin contact are
required to be tested, following EU methods EN 16128:2011 and BS EN 1811.
3.16 PAHs (Polycyclic Aromatic Hydrocarbons)

 Oils contaminated with PAHs may be used as softeners or extenders in rubber and plastic materials. PAHs may also
be formed during thermal decomposition of recycled materials during reprocessing and can be present as
impurities in carbon black pigments and dyestuff.
 Important note on EU: Effective December, 2015 in-store, all accessible plastic and rubber components for EU-EU
Franchise orders must meet the limits in Table 11 for 8 PAHs.19
Table 11 – PAH Limits: Rubber and Plastic Components
PAH Limits – All Ages
(By weight of accessible rubber and plastic component)
Adult Kids and Baby
Benzo[a]pyrene 1ppm 0.5 ppm
Benzo[e]pyrene 1ppm 0.5 ppm
Benzo[a]anthracene 1ppm 0.5 ppm
Chrysene 1ppm 0.5 ppm
Benzo[b]fluoranthene 1ppm 0.5 ppm
Benzo[j]fluoranthene 1ppm 0.5 ppm
Benzo[k]fluoranthene 1ppm 0.5 ppm
Dibenzo[a,h]anthracene 1ppm 0.5 ppm
3.16.1 TESTING
 The RSL Testing Program, where styles are selectively sampled for testing, restricts and tests for 18 PAHs, including
PAHs in Table 11. (See Restricted Substances List (RSL) – EU REACH in Section 2 and List on GapSource Library.)
3.17 Phthalates
Phthalates are substances that perform “plasticizing” functions such as softening and dispersion in certain plastic
substrates and surface coatings.
3.17.1 APPAREL AND ACCESSORIES

 Gap Inc. restricts and tests in the regular Testing Program the designated phthalates in Table 12 below. The
Restricted Substances Testing Program, where styles are selectively sampled for testing, restricts and tests all
orthophthalates. (See Restricted Substances List (RSL) – EU REACH in Section 2 above and current RS List on
GapSource Library.)

3.17.2 TOYS AND CHILDCARE ARTICLES
Six phthalates from the orthophthalate family have long been restricted by law20 and the list is growing*. Toy and
childcare articles are not in scope of this safety chapter. However, apparel and apparel accessories with components
determined to be toys or childcare articles must meet the requirements for toys/childcare articles in the chart below.
Note children’s sleepwear is considered a “childcare article” in the US.
Table 12 – Phthalate Requirements
Gap Inc. Phthalate Requirements
Products / Definitions Limits by Accessible Component
APPAREL and ACCESSORIES  Each of following ≤ 0.1% by wt (1000 ppm)
Clothing, footwear, belts, bags, hair items, jewelry, key rings and all  DEHP, BBP, DBP, DIDP, DNHP, DINP
others not defined below
CHILDCARE ARTICLES  Sum DEHP+BBP+ DBP+DINP+DIDP+DNOP = ≤ 0.1%
Products intended to facilitate sleep, relaxation, hygiene, feeding, and by wt (1000 ppm)
sucking or teething by children. All Kids and Baby size/age ranges, e.g.  No substitution for above with other
Plasticized parts of children’s sleepwear, including gripper dots or orthophthalates
treads and screen prints; plastic laminated bibs
TOYS  Sum DEHP+BBP+DBP+DINP+DIDP+DNOP = ≤0.1%
As a component of apparel and apparel accessories: Trim or by wt (1000 ppm)
components determined to be toys or have play value. Examples:  No substitution for above with other
Slipper with squeaker attachment, Pajama with doll sewn into pocket orthophthalates
*The phthalates and scope of products covered by the requirements are likely to change under a proposed rule change by CPSC21
3.17.3 TESTING IN REGULAR TESTING PROGRAM

 Only accessible plastic materials/components are subject to testing in the regular Testing Program (as contrasted
with RSL program) including:
o PVCs, soft plastics, natural and synthetic leather, scrapable surface coatings, decals, polymeric coated materials
(unscrapable), screenprint or plasticized/rubber print, and textiles containing PVC or related polymers.
 Exempt “plastic-like” materials: polyolefins, silicone rubber, natural latex.
 Materials Identification Form must be submitted at time of testing to enable labs to filter components by material
for testing or testing exclusion. Form is found in Lab Memo 108b.
 Labs utilize composite testing as appropriate and detailed in Gap Inc. Lab Memo 108b.
 Apparel and accessories which do not qualify as toys or childcare articles are tested for listed phthalates in US
orders only, subject to change. Gap Inc. requires that all markets should receive products in compliance with these
restrictions.
4 Jewelry
4.1 Jewelry Definition22
 Anklet, arm cuff, bracelet, brooch, chain, crown (tiara), cuff link, tie clip, hair accessory, earring, necklace, pin, ring,
and any bead, chain, link, pendant, or other component of such ornament.
 Any charm, bead, chain, link, pendant or other attachment to shoes or clothing that can be removed and used as a
component of jewelry.
 Watch in which a timepiece is a component of an ornament, excluding the timepiece itself if the timepiece can be
removed from the ornament
 Key Rings
 “Body piercing jewelry” for immediate use in new piercing of a body part or mucous membrane23. This type of
jewelry, not currently sold by Gap Inc. has additional material restrictions.
 Jewelry components in craft kits where the final assembled jewelry product is principally designed and intended as
an ornament worn by a person.

4.2 Physical and Mechanical Requirements
 Refer to Section 19 for Physical and Mechanical Safety Restrictions.
4.3 Jewelry Chemical Limits

4.3.1 CADMIUM
 Gap Inc. restricts cadmium in jewelry more tightly than other products with a limit of 0.0075% (75 ppm) per
component.
 This limit supports, and is in-fact stricter, than the California legal settlement24 in which Gap Inc. participated. The
settlement notably restricts cadmium in both adult and children’s jewelry. This cadmium limit also meets other
states’ limits on cadmium in children’s jewelry.
Table 13 – Cadmium Limits: Jewelry
Gap Inc. Jewelry Cadmium Limits – All Ages
(by weight of accessible component)
Jewelry (Test all markets)
Metal, plastic, glass, surface 0.0075% (75 ppm)
coatings, topical treatments
* Natural substrate materials, with coatings/finishes removed, are not expected to contain cadmium, e.g., wood, horn, glass,
stainless steel, and more (See lead exclusions in Table 7). Suppliers are responsible for knowing whether their materials result in
excessive cadmium levels.
4.3.2 HEAVY METALS (SOLUBLE)

 All children’s jewelry must not exceed limits in chart below.
 Testing: All children’s jewelry is subject to testing following EU Standard BS EN 71-3(mod).
Table 14 – Heavy Metals: Jewelry
Soluble Heavy Metal Limits
Baby Products and Jewelry for Children (per accessible component)
Antimony(Sb) ≤60 ppm
Arsenic (As) ≤25 ppm
Barium (Ba) ≤1000 ppm
Cadmium(Cd)* ≤75 ppm
Chromium(Cr) ≤60 ppm
Lead(Pb)* ≤90 ppm
Mercury(Hg) ≤60 ppm
Selenium(Se) ≤500 ppm
*Because total cadmium in jewelry is limited to 75 ppm, Cd cannot exceed the identical soluble limit. Similarly, total lead in surface
coatings of children’s products is limited to 90 ppm, so Pb cannot exceed soluble limit.
4.3.3 LEAD
 Adult jewelry metallic components have different lead limits compared to other accessories, following California
law and legal settlements25. Non-metallic component limits are the same for all adult products.
 Kids and baby jewelry lead limits follow CPSIA requirements applicable to all children’s products.
 Important note on EU: Effective October, 2013 in-store, all jewelry components for EU-EU Franchise orders were
required to meet 0.05% (500ppm) for all ages26.
o Established Gap Inc. requirements for non-metallic components of adult jewelry and all components of kids’
jewelry already comply with the requirement.
o For adult metallic components, testing to the new lead limit was implemented in July, 2013, to ensure
compliance.

Table 15 – Lead limits: Jewelry
Gap Inc. Jewelry Lead Limits (by weight of accessible component)
California Prop 65 and
CPSC Requirements
Gap Inc. Requirements
Metallic Components
Exempt Class 1 materials, if documented by supplier  Electroplated metal (with plating All other metals
following definitions in Excluded Materials Table 7: documentation): 6.0% by wt Surface Coatings
 Surgical and stainless steel alloys (60,000 ppm) ≤0.009% by wt (90 ppm)
 Precious metals: Karat gold, sterling silver, platinum  Unplated metal: 1.5% by wt
metals (15,000 ppm) Substrates
 EU-EU Franchise orders only: As of ≤0.01% by wt (100 ppm)
October, 2013: ≤0.05% (500 ppm)
Non-Metallic Components
Exempt Class 1 materials, if documented by supplier Surface coatings Surface Coatings
following definitions in Excluded Materials Table 7: ≤0.03% by wt (300 ppm) ≤0.009% by wt (90ppm)
 Natural & cultured pearls
 Gemstones Plastic, rubber substrates Substrates
 Elastic, fabric, ribbon, rope, string with no ≤0.02% by wt (200 ppm) ≤0.01% by wt (100 ppm)
intentionally-added lead
 Natural materials: amber, bone, coral, feathers, fur,
horn, leather, shell, wood in natural state or treated
without added lead
Ceramic, Glass & Crystal (e.g., cat’s eye, CZ, rhinestones, These substrate materials are exempt in
cloisonné) adult jewelry. Surface Coatings
 Metallic backings on rhinestones fall ≤0.009% by wt (90ppm)
under metallic limit
 All other separable surface coatings fall Substrates
under non-metallic limit ≤0.01% by wt (100 ppm)
All Other Materials ≤0.03% by wt (300 ppm) ≤0.01% by wt (100 ppm)
4.3.4 NICKEL
 Nickel migration is restricted by law27 in the EU in jewelry items.
 Nickel content in posts and assemblies for pierced earrings or other jewelry intended to penetrate a body is
restricted to a migration limit of 0.11 micrograms/cm2/week. (Assembly components hold the piercing post or wire
in place, e.g., back, butterfly). Other jewelry (non-penetrating) is restricted to the migration limit of ≤0.28
micrograms/cm2/week.
 Testing: EU orders (including franchise) of Jewelry and specified apparel trims with direct and prolonged skin
contact are required to be tested, following BS EU methods for wear (BS EN 12472) and release(BS EN 1811).
4.4 Age Definition and Labeling

 “Children’s Product,” including jewelry, is defined under US law as designed and intended primarily for children 12
years and under. However, Canada and Europe consider children to be 14 years and under.
 In order to harmonize global requirements, Gap Inc. sets adult jewelry age to be 15 years and older.
 Gap Inc. policy requires all Kids and Baby jewelry, regardless of intended age range, to meet the chemical and safety
restrictions.
4.4.1 AGE LABELING

Consumers must be able to distinguish between jewelry that meets strict children’s lead limits and adult jewelry that is
not required to meet the same limits.
 Adult exclusive brands: Banana Republic, Athleta, and Intermix currently exclusive to adults, are not required to age
label their jewelry.
 Mixed-age brands not exclusive to adults:
o Gap, Gap Outlet and Old Navy: Age labeling is required on all adult jewelry.

o Adult Jewelry Labeling: Required labeling for jewelry not meeting the children’s lead limits in brands for mixed-
age group brands: “INTENDED FOR AGES 15 YEARS AND OLDER.” This age accommodates various global
requirements of children as 14 years and under.
o Children’s Jewelry Labeling: Mixed age brands require appropriate age labeling and, if applicable, small parts
choking hazard warnings.
 In general, jewelry is not permitted for children 3 years and younger. Exceptions must be pre-approved by
Product Safety. See details in Section 19.
 Hair accessories, headbands, and watches fall under the scope of jewelry and, therefore, age labeling and
safety warnings apply. Refer to Table 16 for age labeling requirements by product type, retail market, and
age of user.
Table 16 – Jewelry Age Labeling Requirements
Types Adult Kids (4 – 15 Years) Baby (0-5T)
AGE LABELING
Jewelry Mixed-Age Group Brands:  Tested, age labeled, and appropriate for Not allowed unless specifically pre-
Jewelry not meeting the strict children 4 years and older. approved by PSR.
children’s limits must be tested,  All retail markets require age labeling.
and age labeled appropriate for
ages 15 years and over.
Adult Exclusive Brands: No age
labeling required.
Watches Same as Adult Jewelry  Must be tested, age labeled, and Not allowed unless specifically pre-
appropriate for children 6 years and older. approved by PSR.
 All retail markets require age labeling.
Hair Accessories Same as Adult Jewelry  Tested, age labeled, and appropriate for children 36 months and older (3 Years
(Pins, Ponies, Clips) and Older).
Headbands Same as Adult Jewelry  Testing, age labeling, and appropriateness dependent on retail market.
(HARD) o US, Canada, Japan – Children 24 months and older (2 Years and Older). Design
restrictions apply (See Table 34).
o EU, China – Children 36 months and older (3 Years and Older). Design
restrictions apply (See Table 34).
Headbands Same as Adult Jewelry  Testing, age labeling, and appropriateness dependent on retail market.
(SOFT FABRIC) o US, Canada, Japan – All Ages (Birth & older).
o EU, China – All Ages but certain design restrictions apply. (See Table 34).
CHOKING HAZARD WARNING STATEMENT
All Jewelry, Not Applicable Choking Hazard Warning statement required if finished product or any of its
Watch, and Hair components create small parts before or after use/abuse testing. Choking Hazard
Accessory Types Warning is a separate warning statement. Both age grade label and choking hazard
warning label are required.
LABEL LANGUAGE, PLACEMENT, EXAMPLES
Language Labeled age grade can be stated Labeled age grade can be stated in a variety of Labeled age grade can be stated in
in a variety of ways on product ways on product or packaging. a variety of ways on product or
on packaging. EXAMPLE: “4 and up”;“4 years and older ”; packaging.
EXAMPLE: “Intended for Ages “4+”, etc. EXAMPLE: “3 and up”; “3 years
15 Years and Over ”; “Intended and older”; “3+”, etc.
for Ages 15 and Older,”etc.
Placement Age label should be placed on packaging in a location likely to be seen by consumers. In almost all cases, this is the
(Jewelry sold in front of the packaging. No special formatting or labeling method is required.
package form)
Placement Age label may appear on price tickets, or may be presented in the form of retail shelf cards in a size or form likely to be
(Jewelry sold in seen by consumers.
unpackaged form)

Examples
4.5 California (CA) Jewelry Limits and Certification

 CA Jewelry Certification: Law28 in California requires suppliers to certify that jewelry is in compliance with California
lead and cadmium limits.
 All items within the jewelry definition must comply, with the exception of conventional watches and keychains.
o The California Jewelry Law does not define all watches to be jewelry. For watches to be considered jewelry, the
timepiece must be part of a decorative ornament. If the timepiece itself is removable, it is excluded.
Conventional watches that are primarily functional are excluded.
o However, accessible parts of all watches (including removable timepieces) must be tested and meet the
following chemical limits:
 Adult: Gap Inc. standard for lead and cadmium standards.
 Children’s: CPSC limits for lead and Gap Inc. standard for cadmium
 For children’s jewelry, California law sets cadmium limits and lead limits in jewelry for all ages.
 The CA Jewelry Certificate is a separate certificate and cannot be combined with the CPSC Certificate of Compliance.
 Suppliers must provide CA Jewelry Certificates to retailers under the law.
o For all US orders, Gap Inc. must receive CA Jewelry Certificates from all vendors of all jewelry it offers for sale.
“All vendors” means both GIS vendors and 3rd party vendors, regardless of branding and importer status.
o Certificates must reference the California law in a statement of compliance, identify the applicable jewelry, and
provide name and signature of a company officer. Required Information is shown on the model CA Jewelry
Certificate (Error! Reference source not found.).
 Gap Inc. branded Jewelry: Refer to Table 17 for summary of CA Jewelry Certificate requirements.
 Vendor-branded Jewelry: Refer to the PSR Handbook for 3rd Party Vendor Brands under the General
Information >> Vendor Handbook for Third-Party Branded (Non-Gap Branded) Product link on
GapSource Library.
Table 17 – Gap Inc. Branded California Jewelry Certificate
Gap Inc. Branded (GIB) Jewelry
California Jewelry Certificate Requirements
Applies To:  Children’s and Adult Jewelry offered for sale in US market
 Branding includes any Gap Inc. brand: Gap, Banana Republic, Old Navy, Gap Outlet, Athleta and Intermix.
 Includes Gap Inc. branded, Gap Inc. co-branded with external vendor brand, and unbranded (no
identifiable brand, Gap Inc. or other).
Testing Requirements:  Jewelry must be submitted for testing at Gap Inc. approved labs and meet Gap Inc. requirements.
 By meeting Gap Inc. standards under test protocol GP 2104 (Jewelry, Keychain/Cardholder/Lanyard, Hair
Accessories and Watches), styles are assured of compliance with the CA Jewelry Certificate requirement.
 Lead (Table 15), Cadmium (Table 13)

Gap Inc. Branded (GIB) Jewelry
California Jewelry Certificate Requirements cont’d
CA Jewelry Certificate For efficient retention and retrieval of the CA Jewelry Certificate with its supporting test report, this
Requirements: Certificate must be incorporated in the Gap Inc. test report document, following the same process the testing
lab uses to append the Test Request Form (TRF) to the report PDF. (See model certificate in Error! Reference
source not found..)
1. Vendor completes and submits CA Jewelry Certificate along with TRF at time of sample submission for
compliance testing. Compliance testing should not commence until the vendor is confident the product
can pass. Prior raw material, development, or screening tests, as well as other means of control, can
provide confidence.
2. When results are passing, the testing lab appends both CA Jewelry Certificate and TRF to the Test
Report PDF. Lab emails Test Report, including appended form, to the appropriate Gap Inc. Testing
Mailbox as usual, for storage and retrieval.
3. If a style or component fails testing, the submitted CA Jewelry Certificate is void and documentation of
compliance must be re-established. Correction of the failed item, a new submission with new
certificate, and re-testing are required for the item to go forward.
4. If any passing components or styles are on the same test report with a failure, vendor must submit a
new CA Jewelry Certificate listing only passing items and request lab to re-issue a passing test report
for the passing components/styles with the new CA Jewelry Certificate included.
5 Electronics in Apparel and Apparel Accessories

Although not common in apparel/apparel accessory programs, electronic components are found in battery-operated
watches and footwear with button cell batteries that power flashing lights. More rarely, a garment may be wired for
attachment to electronic players or have concealed batteries producing light or sound effects.
5.1 EU Restrictions – WEEE / RoHS

 Legislation in the EU imposes significant requirements on electronic products. WEEE, the Waste Electrical and
Electronic Equipment Directive 29 mandates that EEE (Electrical and Electronic Equipment) must be designed to
enable recycling/reuse and display special labeling. There are also obligations for take-back of EEE at end of life and
their collection and transport to facilities for recycling/re-use. Once an importer like Gap Inc. offers any electronic
product in scope of WEEE, it incurs significant registration, reporting, and financial responsibilities.
 Gap Inc. only offers electronics exempted or excluded from the WEEE Directive, such as plush toys with button-cell
batteries producing sounds. For example, such plush toys with sound, musical greeting cards, and footwear with
battery-powered lights or sound have electronic components that are not necessary to fulfill the product’s primary
function. Only products that are dependent on electrical current or electromagnetic fields for their basic function
are in scope of WEEE. Product scope may change under the Directive after 2018.
 RoHS, the Restrictions on Hazardous Substances in Electrical and Electronic Equipment Directive30 imposes
maximum concentration values in homogenous materials in EEE: lead (0.1%), mercury (0.1%), hexavalent chromium
(0.1%), cadmium (0.01%), and flame retardants PBB (0.1%) and PBDE (0.1%).
 Batteries—and the chemicals within—do not come under the scope of RoHS and WEEE. Separate directives31 cover
batteries and restricts the use of certain materials, requires specific markings, mandates easy removal, and
establishes treatment and recycling obligations.
6 Flammability
Gap Inc. imposes flammability restrictions on textile apparel and accessories, with certain exceptions. Special
requirements apply to children’s sleepwear. Please refer to Gap Inc. Flammability Safety Requirements in the
Softlines Manual on GapSource Library.

7 California Proposition 6532
This complex California law requires businesses to warn consumers of exposure to a list of chemicals that cause cancer
or reproductive harm (birth defects). Prop 65 permits private parties and their attorneys to enforce the law and extract
monetary settlements for violations from the retailer and manufacturer.
7.1 Duties and Requirements

 Manufacturers must be able to determine whether their products expose consumers above the State’s ‘‘safe
harbor” level for each listed chemical, stated in micrograms per day. These levels are different for chemicals that
cause cancer compared to reproductive harm. For carcinogens the “no significant risk level” is the exposure
calculated to result in one excess cancer in a population of 100,000 over a lifetime. For reproductive harm
chemicals, the “maximum allowable dose level” takes the dose in animal studies where there is “no observable
effect” and divides it by a safety factor of 1000. Lead, for example, has a safe harbor level of 15 ug/day for cancer
but 0.5 ug/day for reproductive harm.
 Determining whether a product exposes consumers above the safe harbor level requires a risk assessment and
calculation of how much of a listed chemical in a specific product creates exposure above the daily threshold. For
example, over 20 years ago, California set the exposure level (safe harbor level) for lead as a cause of reproductive
harm at 0.5 micrograms/day. Since then, limits for the concentration of lead in the product that triggers this
exposure level were gradually settled for different product types. Limits vary by product. In one of the earliest cases,
ceramic foodware was restricted to a leachable lead limit of 0.1 ug/ml (ppm). In contrast, for apparel accessories,
recent settlements have set concentration limits based on total lead in components, e.g., 300 ppm or even lower in
some cases.
 Importantly, in a Prop 65 lawsuit, the defendant businesses carry the burden of proof and any associated costs, to
show that the chemical(s) in their products have not exceeded safe harbor levels. If the business is a retailer, the
retailer has the right to rely on the manufacturer’s duty to inform it of the presence of the chemical in the product.
 The State has not yet set safe harbor (exposure) levels for some recently-listed Prop 65 chemicals. Therefore, if such
a chemical is in a product, the manufacturer and/or retailer have a double task to protect themselves against Prop
65 claims of consumer exposure: First they must obtain a toxicologist’s assessment of the likely safe exposure level
for the chemical with respect to cancer or reproductive harm. Then they must determine if the amount of chemical
in the product causes exposure above this safe daily exposure level.
 To gauge the appropriate Prop 65 limit or concentration in a product, businesses should review existing settlements
for the chemical in question. These settlements can become limit guidelines to follow to avoid lawsuits. However,
settlements may be driven to stricter limits over time and may bear no actual relation to exposure. If conflicting
settlements raise doubts about the limit or if a safe harbor exposure level has not yet been set for a recently listed
chemical, then consultation with a lab or toxicologist may be necessary.
 Warnings: When used to comply with Prop 65, warnings must be specific to the chemical and include mandatory
text set by the State. For example, a proper warning for lead is: “THIS PRODUCT CONTAINS LEAD, A CHEMICAL
KNOWN TO THE STATE OF CALIFORNIA TO CAUSE BIRTH DEFECTS OR OTHER REPRODUCTIVE HARM.”
o Warnings for specific products may also carry instructions on how to avoid exposure to the chemical, such as the
direction to “wash hands after handling.” Businesses that use warnings which do meet legal requirements may
be subject to sanctions by the CA Attorney General.
 Complete information on Prop 65 may be found on the website of California’s Office of Environmental Health
Hazards Assessment: http://www.oehha.ca.gov/prop65.html. Please note that the Agency is in the process of
amending its regulations on warnings and related requirements.
7.2 Gap Inc. Prop 65 Policy

 Gap Inc. requires its suppliers to comply with Prop 65 by ensuring their products do not contain levels of listed
chemicals that expose customers over safe harbor levels. Providing Prop 65 warnings is not an option except in
special cases approved in advance by Gap Inc. Legal and Product Regulations.
 Gap Inc. adopts concentration limits in products for chemicals it knows could present a Prop 65 exposure risk above
safe harbor levels. Vendors are responsible for knowing the chemical composition of their products and for
informing Gap Inc. if the concentration of a listed chemical is at risk of causing a Prop 65 exposure.

8 Trim Imitating Food
Europe restricts sale of products that imitate food and could injure children if mistaken for food33.
8.1 EU Restrictions
 Prohibited products include apparel with three-dimensional appliqués, embroideries, charms, or other trim that
looks like food. Gap Inc.’s policy is to not offer in the EU any product that represents a food, if any of the following
apply:
o Product or trim replicates the food’s 3-dimensional shape and form, even if not true to size or color.
o It could be detached or has detachable parts if mouthed.
o It could be mistaken by a child for a sweet or candy.
 Examples: Socks with a round protruding cherry appliqué on the ankle are not permitted, but a tee shirt with a
printed cherry design is allowed.
 Given the broad scope of the laws in the EU, any accessory or apparel with trim whose shape mimics a food, even if
not completely realistic, should be avoided. These restrictions are effective for product destined for the EU market.
Please note, although outside the scope of this chapter, toys representing fruit that have met the safety
requirements for all ages of the European Toy Safety Standard (EN 71) are not prohibited.
8.2 US and Non-EU Markets

 In the US and our other non-EU markets, apparel with trim that imitates food is not prohibited unless it poses
identifiable hazards to children, such as failing attachment strength and posing a small parts choking hazard.
o In addition, if a children’s accessory bears a resemblance to food, such as a fruit-shaped pony tail holder, it is not
prohibited in non-EU markets unless it is so life-like that a child can mistake it for food or candy. This risk must
be assessed on a case-by-case basis.

PHYSICAL & MECHANICAL SAFETY RESTRICTIONS
In addition to basic safety standards applicable to all Gap Inc. products, the following requirements apply to apparel
and accessories specifically intended for infants and children. Footwear requirements apply to all ages as specified. The
majority of standards in this section are intended to apply to USA, Canada and Japan markets. Note: toys, including
toys affixed to apparel or accessories, are required to meet more stringent attachment requirements (consult Toys &
Sporting Goods Manual for requirements for toys).
9 Small Parts (Choking Hazards)

9.1 Baby ≤ 36 Months – All Markets
 For all Gap Inc. markets, articles for use by children under 36 months must not present a risk of choking, aspiration
or ingestion injury from small parts.
9.2 Small Parts Cylinder

 A small part is any component that fits inside the truncated cylinder (also known as the “small parts choking tube”,
pictured below) in any orientation. Small parts may include, but are not limited to buttons, snaps, buckles, zipper
pulls and sliders, flexible textile components such as bows and appliqués, rigid components, flexible plastic sheeting,
textile components, glitter flakes and powder.
9.3 Safety Standard

 Gap Inc. has adopted the Canadian toy safety laws as a corporate standard, under which small parts include objects
that fit entirely within the test cylinder with the added compression of 1 lb. of weight.
Figure 1 – Small Parts Choking Tube (1.25 in. diameter x 2.25 in. interior depth & 1.0 in. interior depth)
10 Graspable Components
10.1 Attachment Strength (Tension, Torque and Drop)
 Small parts and/or graspable components, functional and decorative, are subjected to attachment strength tests.
The component is expected to withstand a tension force of 17 lbs., applied evenly within a period of 5 seconds and
maintained for an additional 10 seconds. In addition, the component should withstand torque forces of no less than
4 in. lb., applied evenly within a period of 5 seconds in a clockwise direction, as well as a counter-clockwise
direction. The torque requirements for certain zippers vary depending on size – see test protocols for details.
 An attachment strength failure is defined as a complete or partial detachment and/or tearing or rupturing of the
base to which the component was attached. A risk assessment performed by an approved test lab or by Product
Integrity is necessary to determine whether the attachment strength failure constitutes a potential hazard, such as
a small part or sharp edge/point, to the expected user.
 A drop test may also be required in lab tests to certain trims and products that are made from rigid materials, with
potential to break into small or sharp pieces (for example rhinestones, toggle buttons, jewelry or sunglasses).

11 Trim Supplier Sourcing & Qualification
This section applies to trim suppliers providing and vendors purchasing trims for kids, baby, and adult apparel and
apparel accessories intended for sale in all retail markets.
11.1 Adult Trim Supplier Requirements

 All metal trims and labels must be sourced from trim suppliers on the Gap Inc. Approved Trim Supplier List under
Trim & Packaging on GapSource Library. This list applies exclusively to apparel and apparel accessories.
 All metal trims used on adult apparel, apparel accessories, and intimate apparel sold in Japan must be Kensin.
Kensin trims contain metal components that can pass through needle detectors without setting off alarms. Refer to
the Gap Inc. Needle & Foreign Metal Contamination (FMC) Policy under the Quality Assurance link on
GapSource Library for more information.
11.2 Kids & Baby Trim Supplier Qualification Process

 Certain types of trims intended for use in Kids & Baby products must be sourced from Kids & Baby Qualified Trim
Suppliers. Refer to Table 18 and Table 19 for trims in-scope and out-of-scope to this policy. Refer to PSR SOP 001:
Kids & Baby Trim Supplier Qualification Process under the Product Guidelines and Testing >> Product
Safety and Regulations Standard Operating Procedures link on GapSource Library for more
information.
 Qualification requirements include but are not limited to:
o 3rd Party Facility Audits: Nominated trim suppliers must have their own and finished trim contractor facilities
audited under a 3rd-party, industry-based audit program to certify that they have sufficient product safety,
regulatory and quality controls in place. Facilities must be re-certified biannually in order to maintain their Kids
and/or Baby qualification status..
 Qualified trim supplier facilities are designated on the Gap Inc. Kids & Baby Qualified Trim Supplier List under the
Product Guidelines >> CPSC Certification or Trim & Packaging links on GapSource Library.
Table 18 – In-Scope Kids & Baby Trim & Packaging Categories

In-Scope Kids & Baby Trim & Packaging Categories
Applicable Trims: Types/Examples Including But Not Limited To:
Buttons  All types (2-hole, 4-hole, shank, toggles, fabric-covered, etc.)
 All materials (polyester, nylon, metal, etc.)
Labels (All interior & exterior  All types (heat transfer, screen print, paper, fabric, tear-away/rippable, etc.,
labels permanently attached to care/content labels, logo labels, main/fit labels, size/COO labels, KAFF labels, traceability
the product) labels, Remove Before Sleep labels, etc.)
Machine-Attached Hardware  All types of machine-attached hardware trims (snap fasteners, grommets/eyelets,
Trims hook/eyes, hook/bars, rivets, burrs, tack buttons, jean buttons, studs, etc.)
 All materials (plastic, metal, etc.)
Other Metal Trims  Other metal trims (buckles, d-rings, hasps & sliders, etc.)
Packaging or packaging  These items are typically not discarded after purchase and may be re-used by a
components Intended to be consumer. They include reusable or multi-functional fabric/mesh bags, polybags,
Re-used, Multi-functional, or ribbons with hook/loop fasteners, boxes, hangtags, play tent sacks, etc.
Have Play Value
Zippers  All zipper types and zipper components (plastic, metal, invisible, zipper pulls, etc.)

Table 19 – Out-of-Scope Kids & Baby Trim & Packaging Categories
Out-of-Scope Kids & Baby Trim & Packaging Catagories
Bindings Packaging [Sock bands, underwear bands, sleep set bands, sock riders,
accessory hangers, shoe hangers, polybag packaging (including price stickers
& hanger), ribbon with velcro (PJ & blanket sets), vinyl bags with hooks, gift
boxes, etc.]
Clips Piping
Collar Stays Pocketing
Cords Ribbons & Lace
Drawstrings/Draw Cords Rib Knits
Labels or Packaging Intended to be Removed & Discarded Seam Tapes
(Matchbooks, size strips, call out stickers, hangtags, etc. attached via
adhesives, pressure sensitivity, swift-tacks, etc.)
Elastics Screen Print Inks (Regular screen print inks, glow-in-the-dark inks,
plastisols, etc.)
Embroidery & Applique Patches Shoulder Pads
Fragile Trims (Sequins, rhinestones, beads, studs, crystals, etc.) Suspenders
Heat Transferred Embellishments (Photo real, foil, flocking, Thread
welds, crystallina, patches, sugar glitter, etc.)
Hook & Loop (Velcro) Webbings
Interlinings
11.3 Gap Inc. Component Pre-Certification Program

 Under this program, eligible trim supplier facilities can pre-certify all types of trims, as applicable, for lead and
phthalates prior to shipment to vendors for use in Kids and Baby products. Trim orders must be accompanied by a
Certificate of Compliance that attests to the trim components’ chemical compliance to applicable US Consumer
Product Safety Commission (CPSC) rules, bans and standards. Both the certificate and its supporting test reports
must be provided to the vendor at the time of trim purchase.
 For more information, refer to the FAQ’s – Gap Inc. Component Pre-Certification Program under the Product
Guidelines and Testing >> CPSC Certification.
 Trims must still be tested for other PSR requirements as per the regular Gap Inc. testing program.
 Trim Certifier facilities are identified with “Yes” under the Component Pre-Certification column on the Gap Inc. Kids
& Baby Qualified Trim Supplier List. Only designated owned and finished trim sub-contractor facilities may pre-
certify their trims. Facilities designated with “No”, “Not K/B Qualified” or not referenced at all on the List are not
eligible to pre-certify trims.
12 Buttons and Toggles

12.1 Poly and Nylon Buttons (Except Toggles)
 All poly and nylon buttons for kids & baby must meet the following minimum requirements.
Table 20 – Button Minimum Safety Requirements
Button Minimum Safety Requirements
Two Hole Two or Four Hole Two or Four Hole
For Ligne Size: < 14 14 - 21 ≥ 22
Center Thickness 1.65 mm/0.0625 in. 1.65 mm/0.0625 in. 2.0 mm/0.0750 in.
Center/Breaking Strength 7.7 kg/17 lbs. 7.7 kg/17 lbs. 10 kg/22 lbs.

12.2 Button Attachment Requirements
12.2.1 GENERAL REQUIREMENTS
 All Children:
o Buttons are to be attached using polyester core spun thread on a lock stitch machine. 100% cotton thread is
NOT allowed to attach buttons.
o Buttons are to be attached with a minimum of 16 needle passes (i.e. 8 needle passes 2 times for total of 16
needle passes).
 Children 3 Years and Younger:
o All buttons must pass the standard attachment strength test of 17 lbs. for 10 seconds. Vendors may need to
apply adequate backing as reinforcement if necessary in order to meet this requirement.
o Hand-sewn buttons are prohibited for this age range.
12.2.2 SHANK BUTTON ATTACHMENT

 All Children
o All shank buttons should be attached using a lock stitch machine with appropriate attachments for supporting
the shank button at 90 degrees for button attachment.
o It is recommended that a minimum of 16 needle passes is used to attach shank buttons, unless there is a
technical limitation on accommodating this many needle passes, in which case the appropriate number of
needle passes should be used for shank buttons to consistently pass attachment strength.
 Children 3 Years and Younger
o Newly developed shank buttons for children 3 and under must be reviewed with Product Safety during the
development stages (i.e. prior to adoption into the product line).
o New shank buttons must be tested for attachment strength by S-2 sampling plan (Table 21).
Table 21 – S-2 Sampling Plan
S-2 Sampling Plan
Program Units Minimum Samples for Testing
26-150 3
151 – 1200 5
1201 – 35,000 8
35,000 – 500,000 13
12.2.3 FOUR-HOLE BUTTON ATTACHMENT

 Four-hole configuration buttons must be sewn with a lock stitch machine through all four holes in a cross-stitch
pattern. Refer to Figure 2 below.
 A successful lockstitch button will be double knotted with two pieces of thread in a “V” like shape (rabbit ears).
These threads should not be cut and the acceptable maximum length of thread (rabbit ears) is 1/4”, which are
critical for button security. Refer to Figure 2 below.
Figure 2 – Lockstitch Button Sewing Requirements
12.3 Fabric-Covered Buttons

12.3.1 CHILDREN 3 YEARS AND YOUNGER
 Fabric-covered buttons are prohibited for this age range.

12.3.2 CHILDREN 4 YEARS AND OVER
 Fabric-covered shank buttons and fabric-covered flat (2-hole or 4-hole) buttons with grommets are permitted for
Kids apparel and apparel accessories provided they are made from nylon or other plastic-like material.
 Fabric-covered metal shank buttons are prohibited due to the risk of sharp points and edges.
12.4 Toggle Buttons (Baby 0-5T)

12.4.1 MATERIAL & DESIGN REQUIREMENTS
 Toggle buttons for baby and toddler are restricted to molded nylon material only.
 Toggle buttons made from other materials and drilled toggles may not be used for this age group.
12.4.2 TEST REQUIREMENTS

 Development testing needs to be met only one time. Toggles that have already passed development testing are not
required to go through development testing every season, unless a change is made to the toggle that can
potentially affect the toggles ability to comply, such as new toggle factory, change in material, color or shape. Refer
to Table 22 for development test requirements.
 Production trim testing must be done seasonally per the normal Gap Inc. testing program for every color way. Any
failures at this point suggest a change in the toggle integrity. Refer to Table 22 for production trim and garment test
requirements.
 If at any stage of testing there are cracks, breakage or damage that threatens the integrity of the toggle, the testing
results will be considered “critical failures” and unacceptable for baby/toddler programs. Critical failures during
bulk trim production and/or garment production on baby programs must be reviewed with SF Product Safety.
Table 22 – Toggle Button Test Requirements
Drop Test Repeated Laundering
Test Stage
(ASTM F963, 8.731 (mod): 10 drops @ 4.5 ft. (Dry Cleaning Not Permitted for Testing)
Development Trim Testing Sample Size = 10 toggles 30 wash cycles
Production Trim Testing Sample Size = 10 toggles 20 wash cycles
Production Garment Testing Not Required 20 wash cycles
 Sample Size = 1 set of toggles, mocked up to simulate attachment on garment.
 The fabric used for mock-up does not have to be production-quality, however it is recommended.
 The number of toggles on mock-up samples must be equal to or greater than the number that will be used per garment. If
garment construction is unknown, then a minimum of 5 toggles must be submitted on mock-up samples.
13 Fragile Trims
Trims that cannot be appropriately measured for attachment strength through conventional test equipment due to
size or delicacy are considered fragile trim.
 Examples include but are not limited to beads, studs sequins and rhinestones.
 Fragile trims that are accessible or graspable are prohibited on garments and accessories designed for children aged
3 and under (up to sizes XXS and/or 3T).
If a style encompasses both baby and toddler sizes, fragile trim is prohibited for that style.
13.1 Beads Strung on Shoulder Straps

Beads strung on shoulder straps are permitted for children age 12 months and over provided the beads cannot be
liberated from the strap and therefore not accessible to the child wearing the garment. To ensure that beads cannot
detach the following parameters must be met:
 Fixed straps must meet minimum attachment strength of 17 lbs/10 seconds. Garments with fixed straps that do not
meet the 17 lbs requirement and may liberate small parts are not permitted.
 Beads on unfixed straps (straps not anchored on both ends such as adjustable straps) must be secured with a knot
that is stitched down so it cannot be unknotted.
 Beads must be plastic. Glass, ceramic and wooden beads are not permitted.

 Garments with beads must pass extended laundering test during development (30 cycles) and production
(20 cycles). Beads are acceptable if they meeting laundering test with no cracks, breakage or damage.
Figure 3 – Examples of non-accessible beads on fixed shoulder straps
13.2 Sequins for Toddler Apparel and Apparel Accessories*

*Not applicable to accessories that cannot be laundered or sized according to safety policy outlined below. Accessories are to be
reviewed with Product Safety on an item by item basis to determine acceptability.
Table 23 – Toddler Sequin Requirements

Exposed Sequins Encased Sequins
Definition &  Sequin trims that are not protected or shielded  A textile fabric overlay is used to enclose sequins
Example completely within a casing so they are not accessible.
Age Restriction  Not permitted for baby and toddler apparel sizes 0 to 24  Not permitted for babies less than 12 months.
months.  Permitted on toddler apparel sized 12 months and over
 Permitted on toddler apparel sized 2T and over, provided that provided that design, manufacturing and test
design, manufacturing and test requirements are met requirements are met
Design &  Maximum diameter permitted is 3mm.  Must be machine attached, lockstitch sewn & secured.
Manufacturing  Must be machine attached, lockstitch sewn & secured.  Must have a minimum attachment of 2 points (edge to
Requirements  Individual sequins minimum attachment at 4 points center, center to edge).
 4 passes x 2 required = 8 passes total  2 passes x 2 required = 4 passes total
 Must be attached using polyester core with polyester outer  Must be attached using polyester core with polyester
wrap or continuous filament trilobal polyester thread, outer wrap or continuous filament trilobal polyester
minimum Tex 30 thread, minimum Tex 30
 Thread must meet test specifications as listed in Table 25  Thread must meet test specifications as listed in
 Sequins must be round, flat, with smooth edges and have a Table 25
center hole.  Sequins must be round, flat, with smooth edges and
 Sequins must not have sharp, rough edges or burrs by visual have a center hole.
assessment.  Sequins must not have sharp, rough edges or burrs by
 Interlining reinforcement is required behind embellishment visual assessment.
to ensure secure attachment.  Interlining reinforcement is required behind
 Hand attachment, monofilament thread attachment and glue embellishment to ensure secure attachment.
attachment are not permitted.  Hand attachment, monofilament thread attachment and
glue attachments are not permitted.

Table 23 – Toddler Sequin Requirements
Test Exposed Sequins Encased Sequins
Requirements  Exposed sequins cannot be graspable.  Overlay fabric must be subject to strength testing
 Laboratory must use a 0.030 inch feeler gauge at the time of requirements as follows: knit fabrics must pass bursting
testing to confirm sequins are not graspable. A photo is strength (ASTM D3786); woven fabrics must pass tensile
included below for reference. strength (ASTM D5034) and tear strength (ASTM D1424).
 Must pass extended laundering test during development (30 Test results must meet or exceed the requirements
cycles) and production (20 cycles). Hand Wash and Dry outlined in Gap Inc. performance protocols and
Cleaning are not acceptable laundering test method to specifications.
evaluate encased sequin attachment for safety.  Tension test for all seams must be done according to
 Feeler Gauge for Graspability: ASTM F963 – 08 part 8.9.1 Tension Test for Seams. The
overlay fabric must be pulled separately from the base
fabric. A round clamp must be used to grasp overlay
fabric while a square clamp can be used to hold the base
fabric (see example above). Test procedure and
equipment is fully described in the standard, and tension
values must meet or exceed 15 lbs. applied over 5 secs
and held in place for 10 secs.
 Must pass extended laundering test during development
(30 cycles) and production (20 cycles). Hand Wash and
Dry Cleaning are not acceptable laundering test method
to evaluate encased sequin attachment for Toddler
safety.
13.3 Rhinestones for Toddler Apparel and Apparel Accessories*

*Not applicable to accessories that cannot be laundered or sized according to safety policy outlined below. Accessories are to be
reviewed with Product Safety on an item by item basis to determine acceptability.
Table 24 – Toddler Rhinestone Requirements

Encased Rhinestones Exposed Oversized Rhinestones
Definition & “Encased” refers to a technique where a textile overlay is used to Exposed rhinestones on toddler apparel are
Example enclose rhinestones completely within a casing so they are not required to be oversized, meaning larger than
accessible. Encased rhinestones may or may not fit completely 1.25 inches (32 mm) in at least one dimension
within the small parts cylinder. and too large to fit completely within the small
parts cylinder in any orientation.
Age Not permitted for baby & toddler apparel sized 0 - 36 months Not permitted for baby & toddler apparel sized 0 -
Restrictions Permitted on toddler apparel sized 3T and over, provided that design, 36 months
manufacturing and test requirements are met. Permitted on toddler apparel sized 3T and over,
provided that design, manufacturing and test
requirements are met.

Table 24 – Toddler Rhinestone Requirements
Encased Rhinestones Exposed Oversized Rhinestones
Design & Thread Thread
Manufacturing  2 passes x 4 required = 8 passes total  4 passes x 4 attachment points = 16 passes total
Requirements  Hand sewn attachment is permitted  Hand sewn attachment is permitted.
 Must be attached using polyester core with polyester outer wrap or  Thread at each hole must be individually
continuous filament trilobal polyester thread, minimum Tex 30 knotted without cutting thread
 Thread must meet test specifications as listed in Table 25  Must be attached using polyester core with
 Monofilament thread and glue attachments are not permitted polyester outer wrap or continuous filament
Encased Rhinestones trilobal polyester thread, minimum Tex 30
 Must be sized 11mm or larger in any one direction.  Thread must meet test specifications as listed in
 Must be made of plastic material; all other materials including glass Table 25
are not permitted  Monofilament thread and glue attachments are
 Must have at least 4 points for attachment, with machine pre-drilled not permitted
holes Exposed, Oversized Rhinestones
 Must not have sharp, rough edges, points or burrs by visual or tactile  Must meet the ‘oversized’ dimensions, unable
assessment to fit inside the small parts cylinder
 Must consist of a single component (multi-piece components, such  Must be made of plastic material; all other
as rhinestones with underlying metal cup, are not permitted) materials including glass are not permitted
Interlining Reinforcement  Must have at least 4 points for attachment, with
 Required behind embellishment to ensure secure attachment machine pre-drilled holes
Note: Recommend a mesh/tulle overlay fabric weight of 58g/m2 sewn  Must not have sharp, rough edges, points or
in bias direction. burrs by visual assessment or tactile
assessment.
 Must consist of a single component (multi-piece
components, such as rhinestones with
underlying metal cup, are not permitted)
Interlining Reinforcement
 Required behind embellishment to ensure
secure attachment
Test Drop Test Drop Test
Requirements  Rhinestones are required to pass the Drop Test prior to placement  Rhinestones are required to pass the Drop Test
on garment (ASTM F963) 10 drops, 4.5 feet. No Accessible Sharp prior to placement on garment (ASTM F963) 10
Edges or Points. No Small Parts. drops, 4.5 feet. No Accessible Sharp Edges or
Tension Test Points. No Small Parts.
 Rhinestones must withstand a direct pull force of 17 lbs. for 10 Tension Test
seconds, without detachment or breakage in development stage.  Rhinestones must withstand a direct pull force
Pull test to be completed directly on rhinestone (attached to of 17 lbs. for 10 seconds, without detachment
production quality base fabric), without mesh overlay. or breakage in development stage on actual
Extended Laundering production quality base fabric.
 Encased rhinestone design must pass extended laundering “machine Extended Laundering
wash cold ‐ tumble dry low” during development testing at 30 cycles  Exposed rhinestone design must pass extended
and production testing at 20 cycles. No other laundering method is laundering “machine wash cold ‐ tumble dry
permitted to evaluate rhinestone attachment for Toddler safety. low” during development testing at 30 cycles
Fabric Strength and production testing at 20 cycles. No other
 Overlay fabric must be subject to and pass strength testing laundering method is permitted to evaluate
requirements outlined in Gap Inc. performance protocols and rhinestone attachment for Toddler safety.
specifications as follows: knit fabrics must pass bursting strength
(ASTM D3786); woven fabrics must pass tensile strength (ASTM D
5034) and tear strength (ASTM D 1424).
Seam Tension
 Tension test for all seams must be done according to ASTM F 963,
part 8.9.1 Tension Test for Seams. In this test the overlay fabric must
be pulled separately from the base fabric. A round clamp must be
used to grasp overlay fabric while a square clamp can be used to
hold the base fabric. Test procedure and equipment is fully
described in the standard, and tension values must meet or exceed
15 lb. applied over 5 seconds and held in place for 10 seconds.

13.4 Thread Test Specification
Thread used to attach sequins and rhinestones for baby & toddler must meet the minimum requirements outlined in
below chart.
Table 25 – Thread Test Specification
Yarn Type Tex Ply Test Method Breaking Strength Breaking Strength Elongation
No. Grams Requirement Lbs. Requirement
Continuous filament polyester core Tex 24 2 ASTM D 2256 1020 2.25 14-19%
with polyester outer wrap
Continuous filament polyester core Tex 30 2 ASTM D 2256 1530 3.37 14-19%
with polyester outer wrap
Continuous filament trilobal polyester Tex 27 2 ASTM D 2256 1200 2.65 19-26%
Continuous filament trilobal polyester Tex 40 2 ASTM D 2256 1200 2.65 19-26%
13.5 Extra Trim

Extra Trim includes, but is not limited to buttons, snaps, bows, appliqués, etc.
13.5.1 CHILDREN AGE 3 AND UNDER

 No extra trim either in small bags or attached to the inside of the garment is permitted.
13.5.2 CHILDREN AGE 4 AND OVER

 No additional safety restrictions for extra trim.
13.6 Fur and Faux Fur

13.6.1 BABY (SIZE 12 MONTHS AND UNDER)
 Not recommended for use anywhere, especially around the head and face areas due to potential asphyxiation
hazard. If fur/faux fur is used then the pile must not exceed ½" in length.
13.6.2 BABY AND CHILDREN (SIZES OVER 12 MONTHS)

 Fur/faux fur is permitted, however, the pile must not exceed 2½" in length.
 Fur/faux fur for baby (age 3 and under) must pass pile retention testing as outlined in Protocol GP PSR 100 Apparel
and Apparel Accessories.
13.7 Glitter
13.7.1 CHILDREN AGE 3 AND UNDER
 Loose glitter is prohibited. Glitter must be completely contained in gel/print or sealed in a way so that individual
glitter flakes cannot detach.
13.7.2 CHILDREN AGE 4 AND OVER

 No special safety restrictions.
13.8 Heat Transfers for Baby & Toddler

 Heat transfers that detach can be considered small parts and a potential choking hazard for children aged 3 and
under.
 Heat transferred embellishments which include but are not limited to photo real, foil, flocking, welds, crystalline
and patches smaller than 1.5 inches in diameter, can be considered small parts.
 Additional testing requirements have been created to ensure safety for heat transfers intended for baby products.

Figure 4 – Heat transfers in excess of 1.5 inches in diameter
 Alternative trims such as direct embroidery, screen-printing or permanently sewing/tacking the embellishment to
the base of the fabric, if possible, are encouraged.
13.8.1 DEVELOPMENT AND TESTING OF HEAT TRANSFERS

 All new heat transfers developed are required to undergo increased sampling for safety-related properties.
13.8.1.1 Development
 All styles using Heat Transfers must be developed and sampled with a GIS office and undergo development testing.
Thirty (30) repeated home laundering cycles or five (5) dry clean cycles (according to care label instruction) required.
An alternative test method should be used where laundering is inappropriate such as on footwear or backpacks.
Consult Product Safety or Product Integrity manager for details.
13.8.1.2 Production
 Enhanced Production testing is required to ensure durability for the life of the garment. Twenty (20) repeated home
laundering cycles or one (1) dry clean cycle (according to care label instruction) required. An alternative test
method should be used where laundering is inappropriate.
o Any part (including the edge) of the heat transfer lifting or detaching during testing will be considered a failure
and will not be allowed for baby product.
14 Labels
This section outlines safety requirements for various types of labels (adhesive, pressure-sensitive, heat transfers, and
tear away labels) attached to children’s apparel and apparel accessories.
14.1 Adhesive or Pressure-Sensitive Stickers

14.1.1 CHILDREN 3 YEARS AND YOUNGER (SIZES 0 – 3T)
 The potential exists for young children to remove, mouth, ingest or choke on stickers.
 To ensure that Gap Inc. footwear, apparel, and apparel-type accessories do not present safety hazards for infants
and toddlers, all adhesive or pressure-sensitive stickers/labels smaller than 1.5 inches in diameter are prohibited on
products intended for children age 3 and under. For example, dime stickers are not allowed since they are
considered to be small parts.
 Permanently affixed markings such as sewn labels or direct imprinting are acceptable alternatives.
14.1.2 CHILDREN 4 YEARS AND OVER (SIZES 4T AND ABOVE)

 No additional safety restrictions
14.2 Heat Transfer Labels

14.2.1 BABY (0-5T)
 Detached heat transfers are small parts and a potential choking hazard for children age 3 and under. Heat transfers
smaller than 1.5 inches in diameter can be considered small parts.

 Additional test requirements have been created to ensure safety for heat transfer labels used on baby products.
Refer to Section 13.8.1 for development and production testing requirements.

 No additional safety restrictions.
14.3 Tear-away Labels

14.3.1 CHILDREN 3 YEARS AND YOUNGER (SIZES 0 – 3T)
 All apparel and accessories intended for children age 3 and under are prohibited from bearing tear-away or
“rippable” labels. Rippable labels are paper-like, usually a coated acetate fabric, with or without perforation holes
that can be ripped off a product with very little force.
 Any label attached to an infant style must be made of a non-rippable substrate and must meet the attachment
strength standard of 17 lbs. for 10 seconds (tension) and 4 in-lbs. (torque).
 To convey that a non-rippable label may be removed, a cutaway label stock with the “scissor” icon is available
(Refer to Figure 5).
14.3.2 CHILDREN 4 YEARS AND OVER (SIZES 4T AND ABOVE)

 No additional safety restrictions.
Figure 5 – Cutaway label with scissor icon
15 Machine-Attached Hardware Trims

This section applies to all machine-attached hardware trims used on kids & baby apparel and apparel accessories
including but not limited to:
 Burrs/Rivets
 Grommets/Eyelets
 Hooks/Bars
 Snap Fasteners
 Tack/Jean Buttons
Machine-attached hardware trims are made of all materials (metal, plastic, etc.) and cover all ligne sizes, shapes, post
types, and prong types.
15.1 Safety Requirements

 All Kids & Baby machine-attached hardware trims must be sourced from qualified trim supplier facilities (owned
and finished trim subcontractors) as designated on the Gap Inc. Kids & Baby Qualified Trim Supplier List. Light-Duty
Snap Fasteners and Hasps & Sliders have additional sourcing restrictions as indicated in Sections 15.5.1 and 16.2.
 PSR test requirements for machine-attached hardware trims are outlined in the following documents available on
GapSource Library:
o Apparel & Apparel Accessories PSR Protocol GP100
o Trim Component PSR Protocol GP110
 All machine-attached hardware trims for kids & baby are required to withstand an attachment strength force of 17
lbs. for a minimum of 10 seconds.

 No exposed sharp points, sharp edges, or exposed prongs from machine-attached hardware trims are allowed on
kids & baby apparel and apparel accessories in accordance with ASTM F963/16 CFR 1500.
 All Kids & baby machine-attached hardware trims used in all retail markets must be Kensin. Kensin trims contain
metal components that can pass through needle detectors without setting off alarms. Refer to the Gap Inc. Needle
& Foreign Metal Contamination (FMC) Policy under the Quality Assurance link on GapSource Library for more
information.
15.2 Application Requirements

 All trim suppliers supplying and garment vendors using machine-attached hardware trims on kids & baby apparel
and apparel accessories are subject to the technical support, testing, application, and inspection procedures
outlined in the Gap Inc. Machine-Attached Hardware Trims Standard Operating Procedures (SOP).
o The Gap Inc. Machine-Attached Hardware Trim SOP may be found on GapSource Library under Product
Guidelines and Testing >> Product Safety and Regulations Standard Operating
Procedures.
o Previously known as the Snap SOP, this document will be updated in 2015 to include all types of machine-
attached hardware trims.
 Only semi-automated or fully-automated pneumatic or electric presses with brand-compatible attaching dies,
recommended by the trim supplier, may be used to attach hardware trims. Manually-operated hand, foot, or
flywheel presses are strictly prohibited. For additional details, please contact your Product Safety or Product
Integrity contact or refer to the Gap Inc. Machine-Attached Hardware Trims SOP.
 If application standards are not followed, machine-attached hardware trims can be prone to detachment, thereby
creating a choking hazard for babies. Improper application can also damage or deform the hardware trim
components, causing a laceration hazard for all ages of children.
15.3 Grommets & Eyelets

15.3.1 BABY (0-5T)
 Metal grommets and eyelets must always have a lining or backing to prevent the grommet/eyelet from being in
direct contact with the baby’s skin (Figure 6). This policy does not apply to other types of machine-attached
hardware trims (Burrs/Rivets, Hook/Bars, Snap Fasteners, Tack/Jean Buttons, etc.).
15.3.2 CHILDREN (ALL AGES)

 Prior to production, garment vendors must consult with the designated hardware trim supplier to determine the
appropriate type of grommet/eyelet required based on garment design, function, fabrication used, fabric thickness,
attaching equipment, etc. Refer to the Gap Inc. Machine-Attached Hardware Trims SOP for details.
Figure 6 – Grommet/Eyelet
15.4 Hooks & Bars

 Machine-attached hooks & bars are allowed on kids & baby apparel and apparel accessories, provided they meet
use and abuse testing and do not have sharp points and edges once attached (Figure 7).
 Hooks & bars may be post-type or prong-type as recommended and specified by the hardware trim supplier.

appropriate type of hook & bar required based on garment design, function, fabrication used, fabric thickness,
attaching equipment, etc. Refer to the Gap Inc. Machine-Attached Hardware Trims SOP for details.
 Hook & bar requirements for kids & baby products are currently under review by SF Product Safety. Additional
guidelines will be provided in 2015. In the interim, please contact the regional GIS Product Integrity Manager with
questions.
 Refer to Section 16.3 for hand-sewn or stitched-on hook & eye requirements.
Figure 7 – Hooks & Bars
15.5 Snap Fasteners

15.5.1 LIGHT-DUTY SNAP FASTENERS (12-16 LIGNE)
 All Kids & Baby light-duty snap fasteners must be sourced from YKK, Prym, Morito, or Scovill facilities as designated
on the Gap Inc. Kids & Baby Qualified Trim Supplier List.
 All apparel and apparel accessories with light-duty snap fasteners must be tested at an independent laboratory in
accordance with the 24-Hour Attachment Strength Testing Process as outlined in the Gap Inc. Machine-Attached
Hardware Trims SOP.
 Light-duty snap fasteners are typically used on baby knitwear and intimate apparel. Light-duty snap fasteners
include post/stud, cap prong socket, ring prong socket, including Gripper®, Snapet®, Kipper®, etc.
15.5.2 MEDIUM-DUTY & HEAVY-DUTY SNAP FASTENERS (20-24 LIGNE)

 Medium-duty and heavy-duty snap fasteners may be post-type or prong-type as recommended and specified by the
hardware trim supplier. Prior to production, garment vendors must consult with the designated hardware trim
supplier to determine the appropriate type of snap fastener required based on garment design, function,
fabrication used, fabric thickness, attaching equipment, etc. Refer to the Gap Inc. Machine-Attached Hardware
Trims SOP for details.
 Medium-duty and heavy-duty snap fastener design requirements for kids & baby products are currently under
review by SF Product Safety. Additional guidelines will be provided in 2015. In the interim, please contact the
regional GIS Product Integrity Manager with questions.
 Different sizes and types of medium-duty and heavy-duty snap fasteners may be used on pants, outerwear, jeans,
and other accessories as determined appropriate by the hardware trim supplier. They are typically available in ring-
spring (post), parallel-spring (s-spring), and ring-spring (2-prong) configurations.
15.6 Tack/Jean Buttons

 Tack/jean buttons are allowed on kids & baby apparel and apparel accessories provided they meet use and abuse
testing and do not have sharp points and edges once attached.
 Certain types of tack buttons are currently restricted by age of child (Refer to Table 26). In 2015, SF Product Safety
may revise these requirements as needed. In the interim, please contact the regional GIS Product Integrity Manager
with questions.
appropriate type of open top tack/jean button required based on garment design, function, fabrication used, fabric
thickness, attaching equipment, etc. Refer to the Gap Inc. Machine-Attached Hardware Trims SOP for details.

Table 26 – Open Top Tack/Jean Button Restrictions by Age of Child
Open Top Tack/Jean Button Restrictions by Age of Child
Baby (0-5T) Kids (4 Years and Over)
Post-Type Allowed as specified by Allowed as specified by
trim supplier trim supplier
Prong-Type Not Allowed Allowed as specified by

trim supplier
16 Other Metal Trims (Excludes Zippers)

 PSR test requirements for other metal trims are outlined in the following documents available on GapSource Library:
o Apparel & Apparel Accessories PSR Protocol GP100
o Trim Component PSR Protocol GP110
 All kids & baby metal trims are required to withstand an attachment strength force of 17 lbs. for a minimum of
10 seconds.
 No exposed sharp points, sharp edges, or exposed prongs are allowed on kids & baby metal trims in accordance
with ASTM F963/16 CFR 1500.
 All kids & baby metal trims in all retail markets must be Kensin. Kensin trims contain metal components that can
pass through needle detectors without setting off alarms. Refer to the Gap Inc. Needle & Foreign Metal
Contamination (FMC) Policy under the Quality Assurance link on GapSource Library for more information.
16.2 Hasps & Sliders

 Hasps and sliders on children’s apparel and apparel accessories must be specifically designed to pass through
needle detectors without setting off alarms.
 All Kids & Baby hasp and sliders must be sourced from Luk’s Brothers’ facilities as indicated on the Gap Inc. Kids &
Baby Qualified Trim Supplier List. Refer to Table 27 for approved hasp and slider designs.
Table 27 – Approved Hasp & Slider Designs
Approved Hasp & Slider Designs
Approved Hasps Approved Sliders

16.3 Hook & Eyes (Hand-Sewn or Stitched-On)
16.3.1 CHILDREN 3 YEARS AND UNDER
 Hand-sewn hook & eyes are not allowed due to their inability to consistently meet attachment strength
requirements.

 Hand-sewn hook & eyes are allowed for this age group provided they are sourced from qualified suppliers, meet
use and abuse testing requirements, and do not have sharp points and edges.
17 Zippers
 Metal, coil and plastic zippers may be used on kids & baby apparel and apparel accessories. Aluminum zippers are
not allowed. Additional design and testing requirements may apply for zippers used on baby products (Refer to
Section 17.2 for details)
 PSR test requirements for zippers are outlined in the following documents on GapSource Library:
o GP 100 - Apparel & Apparel Accessories PSR Protocol
o GP110 - Trim Component PSR Protocol
o Zipper Specification #4000 in the Performance Protocols & Specifications also contains additional zipper strength
specifications that impact safety.
 No exposed sharp points or edges are allowed on kids & baby zippers in accordance with ASTM F963/16 CFR 1500.
 All kids & baby zippers in all retail markets must be Kensin. Kensin trims contain metal components that can pass
through needle detectors without setting off alarms. Refer to the Gap Inc. Needle & Foreign Metal Contamination
(FMC) Policy under the Quality Assurance link on GapSource Library for more information.
17.2 Baby Zipper Design & Test Requirements (0-5T)

17.2.1 DESIGN REQUIREMENTS
 Due to potential small part choking hazards, design and test requirements vary depending on zipper pull type. Refer
to Table 28 and Section 17.2.2 for details. Contact Product Safety if there are questions about what is considered a
standard pull versus a decorative pull.
Table 28 – Zipper Pull/Zipper Type Requirements (Baby 0 – 5T)
Zipper Pull / Zipper Type Requirement (Baby 0-5T)
Definition Requirement
Standard Pulls  Standard pulls are rectangular or oblong in  Standard pulls are permitted with no style restrictions.
shape with no play value for children.
Decorative Pulls  Decorative pulls come in a large variety of  Decorative pulls are only permitted on zipper sizes 5 and
shapes, sizes and materials including but above and must be sourced from YKK.
not limited to: plastic, rubber, PVC, metal  Increased testing is required to ensure sufficient
or other rigid or semi-rigid materials. attachment strength and guard against choking hazards
 They may have an increased degree of (See Section 17.2.2).
interest/”play value” for young children
due to shape, and/or movement of pull.

Zipper Pull / Zipper Type Requirement (Baby 0-5T) - Table 28 cont’d
Definition Requirement
Textile Pull-Tabs  Zipper pulls may include cords, ribbon, twill  Textile pull-tabs attached to standard zipper pulls are
tape, etc. permitted provided the pull tab can pass required testing.
Increased testing is required to ensure sufficient
attachment strength and guard against choking hazards
(See Section 17.2.2).
 Zipper pulls including any embellishment must not exceed
3.0 inches from top of zipper slider.
 Textile pull-tabs must be permanently secured through the
eye of the zipper pull and tabs that form a loop must be
bar-tacked at the center of the loop.
 Textile pull-tabs that have a rubber tip must be produced
by a supplier who can apply the rubber piece consistently
throughout production. The rubber tip should not be
applied by the sewing factory.
Invisible Zippers and  Invisible zippers are only used when the  Due to the limited attachment/torque strength of invisible
Pulls design intent is for the zipper to be hidden. zippers, invisible zipper placement is restricted to the
 Invisible zips are available in 2 sizes (2CC or product’s back or side, thus restricting the baby’s
3CC) and depending on the pull’s design accessibility to the zipper. They are not allowed on front
may or may not be able to meet the closures or pockets.
children’s 4 lb. torque requirement (ASTM  Invisible zipper pulls are not subject to increased testing
F-963). If the pull cannot meet children’s requirements because of reduced accessibility.
torque requirements, it may become a  Contact SF Product Safety to review placement or for
choking hazard to babies if detached. more info.
 Hinged zipper pulls on other zippers are
considered decorative pulls since other
zipper types have standard pull options
available.
17.2.2 TEST REQUIREMENTS

The additional testing requirements in this section do not apply to baby zippers with standard pulls or invisible zippers.
 Product Safety Review
New decorative pulls and textile pull tabs for baby must be reviewed with Product Safety during the development
stages (i.e. prior to adoption into the line) to determine if appropriate for use on baby products. In order for a
complete and accurate assessment to be made, a sample or detailed picture/drawing must be provided in addition
to the zipper type it will be attached to. The potential use and/or placement on garment must also be provided.
 Test Requirements
o Development testing is conducted to prove the combination of materials used is workable. Testing will include
increased sampling for safety-related properties for all new decorative pulls and textile pull-tabs. Refer to
Table 29 to determine which safety tests must be performed and required number of units needed for testing.
o Production testing is conducted to confirm production execution of concept and evaluate consistency of
product. Testing will include increased sampling for safety-related properties of both decorative zipper pulls
(zipper size 5 and above) and textile pull-tabs.
 Refer to Table 29 to identify the correct sampling plan column (S-3 or S-4) for either decorative pulls or
textile pull tabs.
 Refer to Table 30 to determine required number of units needed for testing based on style order quantity.
Table 29 – Baby Zipper Increased Testing Requirements & Sampling
Baby Zipper Increased Testing Requirements & Sampling
Test Property Decorative Pull Textile Pull Tab
Development Testing: Number of Units Selected for Testing
Attachment Strength 50 units 50 units
Torque 50 units Metal Puller - 50 units1
Textile Pull Tab - Not Applicable
Extended laundering (30 HL) 50 units 30 units1
(Test attachment strength & torque after laundering)

Baby Zipper Increased Testing Requirements & Sampling - Table 29 cont’d
Test Property Decorative Pull Textile Pull Tab
Production Testing:
Attachment Strength S-4 Sampling Plan S-3 Sampling Plan
Torque S-4 Sampling Plan Metal Puller – S-3 Sampling Plan1
Textile Pull Tab - Not Applicable
Extended laundering (20 HL) S-4 Sampling Plan S-3 Sampling Plan1
(Test attachment strength & torque after laundering)
1While the zipper puller’s textile pull tab is not subject to torque testing, the metal puller must be tested and meet torque
requirements outlined in the Gap Inc. PSR protocols in the trim and apparel stages.
Table 30 – Production Testing Sampling Plan
Production Test Sampling Plans
(Based on Military Standard 105E)
Lot/Batch Size S-3 Sampling Plan S-4 Sampling Plan
151 – 500 8 13
501 – 1200 13 20
1201 – 3200 13 32
3201 – 10000 20 32
10001 – 35000 20 50
35001 – 500000 32 80
18 Pompoms, Tassels and Decorative Extensions

18.1 Pompoms
The term Pompom applies to lengths of strands of fiber, yarn or threads clamped, secured or tied at the center and
brushed up to form a spherical shape. Fabric filled and fleece pompoms are included within the definition of pompom.
Figure 8: Pompoms
Table 31 – Pompom Requirements by Age
Age Pompom Requirements
Not permitted on free ends of ties, cords, drawstrings, etc.
Not permitted on hoods or on back of garments.
No glue or metal brads are permitted in construction or attachment.
All Ages Fleece pompoms are permitted for all age. They should be constructed of one piece of fabric folded in half so that
the individual cut ends are exposed.
Fabric-filled pompoms are permitted for all ages. They should be constructed from one piece of fabric and stuffed
with polyfill to create desired effect.
Loops must not exceed 3 inches in circumference.
Traditional yarn and thread pompoms are not permitted for children 36 months and under.
Pompom should measure 2 inches or greater in diameter to ensure a compliance.
Baby 0 – 36 Individual yarn strands are required to measure less than 12 inches.
months For apparel, apparel accessories and home textiles, minimum attachment strength is specified at 17 lb., for 10 secs,
for both whole unit and individual strands.
For toys, min attachment strength is specified at 21 lbs., for 10 secs, for both whole unit & individual strands.

18.2 Tassels
The Term Tassels are defined as components comprised of lengths of string, yarn, fiber or thread laid parallel and
bound together at the end.
Figure 9: Tassel Examples

Table 32 – Tassel Requirements by Age
Age Tassel Requirements
No unsecured material/yarns are permitted to be inserted to create a fuller appearance or increase bulkiness.
Not permitted on hoods or on the back of garments.
All Ages Must not exceed 3 inches in length.
No glue or metal brads are permitted in construction or attachment.
Tassels at the end of ties on apparel must be constructed in a way that they do not create a catching hazard.
Yarn and thread tassels are not permitted for children 36 months and under.
Baby 0 – 36 For apparel, apparel accessories and home textiles, minimum attachment strength is specified at 17 lb., for 10 secs,
months for both whole unit and individual strands.
For toys, min attachment strength is specified at 21 lbs., for 10 secs, for both whole unit & individual strands.
18.3 Decorative Extensions

The Term Decorative Extensions applies to textile attachments that protrude from a base fabric. Decorative extensions
may be 2D or 3D attachments and include but are not limited to tails, ears and antennas.
 2D Attachments are flat attachments that do not have any volume.
 3D Attachments have volume and are typically stuffed or filled.
Figure 10: Decorative Extensions

Table 33 – Decorative Extension Requirements by Age
Age Decorative Extension Requirements
Baby 0 – 36 For apparel, apparel accessories & home textiles, minimum attachment strength is specified at 17 lbs., for 10 secs.
months For toys, minimum attachment strength is specified at 21 lbs., for 10 secs.
3D attachments are not permitted on free ends of ties, cords, drawstrings, etc.
All Ages 3D attachments are not permitted on hoods or on back of garments.
2D and 3D attachments must not exceed 3 inches in length.

19 Jewelry (Including Hair Accessories, Headbands &
Watches)
Gap Inc. requires all children’s jewelry to meet or exceed the requirements of ASTM F2923 Standard Specification for
Consumer Product Safety for Children’s Jewelry. For adult jewelry, selected requirements in the ASTM F2999 Consumer
Specification for Adult Jewelry have been adopted by Gap Inc.
19.1 Scope: Gap Inc. Jewelry Standards Apply to All Jewelry as Defined by Gap
Inc.
 Refer to Section 4 for Gap Inc. Jewelry Definition.
19.2 Regulatory and Chemical Requirements

 Refer to Section 4 for Regulatory and Chemical requirements including:
o California Jewelry Certificates
o Age Labeling
19.3 Mechanical Hazards (Children’s)

19.3.1 CHILDREN 3 YEARS AND YOUNGER
 Gap Inc. does not permit jewelry to be marketed or sold to children 3 years of age or younger, unless specifically
approved by Product Safety.
19.3.2 CHILDREN 4 YEARS AND OLDER

 Gap Inc. sets the children’s jewelry age definition at 15 years or younger.
 As a standard, children’s jewelry must be tested, labeled and appropriate for children 4 years and older, unless a
different age is approved by Product Safety. See Table 16 for jewelry age labeling requirements.
 Depending on jewelry design, play value, marketing and in-store placement, certain types of children’s jewelry may
be subject to children’s toys requirements. Contact Product Safety to review jewelry.
 Hair accessories, headbands and watches, although included in the scope of ‘Jewelry’, have different age grade
rules (See 19.9, 19.10, and 19.11).
19.4 Breakaway Features (Children Only)

 Children’s jewelry intended to be worn around the neck must release, either by designed breakaway feature,
attachment design or physical properties of the material, when tested to the Breakaway Tension Test outlined in
ASTM F2923, Sec.13.1 to 15 lbs.
19.5 Jewelry Containing Batteries

19.5.1 CHILDREN’S JEWELRY
 Children’s jewelry that utilizes button cell or other type of batteries requires approval by Product Safety. Special
safety labeling and design requirements apply.
 Children’s jewelry or jewelry components containing batteries that can become small parts are prohibited.
 EU Market: Children’s jewelry with batteries is not allowed in the EU market due to WEEE restrictions. Refer to
Section 5 for more details.

19.5.2 ADULT JEWELRY
 For all adult jewelry with batteries, batteries that can be swalloed or small parts shall not be accessible without the
use of a coin, screwdriver, or other common house hold tool. Testing is performed using the recommended
batteries installed.
 EU Market: Adult jewelry with batteries is not allowed in the EU market due to WEEE restrictions. Refer to Section 5
for more details.
19.6 Jewelry Containing Magnets

All children’s and adult jewelry containing magnets require approval by Product Safety. This requirement applies to all
brands and all markets.
19.6.1 CHILDREN’S JEWELRY

 Hazardous magnets that are small parts or can create small parts and have a flux index > 50 are prohibited in
children’s products (jewelry, toys, etc.) due to potential ingestion, inhalation, and attachment hazards.
 Children’s products must not contain loose as-received hazardous magnets or magnetic components.
 Children’s products must not liberate hazardous magnets or magnetic component before or after magnet testing as
outlined in ASTM F963 and F2923.
19.6.2 ADULT JEWELRY

 Jewelry containing hazardous magnets (small parts and have a flux index > 50) must contain a warning statement:
WARNING: Contains magnets. Prolonged wearing can form a hole in body tissue. Swallowed or inhaled magnets
can attract through and squeeze intestines or other body tissue, causing serious injury or death. Seek immediate
medical attention if swallowed or inhaled.
 Consideration of additional warnings should be given addressing the hazard of magnetic fields affecting the function
of pacemakers or other implanted electronic medical devices.
19.7 Liquid-Filled Jewelry

 Children’s Jewelry: Must not contain any materials listed in 16 CFR 1500.231 or materials which would require
special labeling under 16 CFR 1500.14. See Section 3.13.
 Adult Jewelry: Must not contain materials which would require special labeling under 16 CFR 1500.14. See
Section 3.13.
 EU Market: Jewelry for all ages must comply with Reach regulations. For more details, refer to Section 2.1.
19.8 Suction Tongue Studs

 Children’s Jewelry: Prohibited as a jewelry item for all ages of children.
 Adult Jewelry: Adult suction tongue studs require approval from Product Safety.
19.9 Watches
 All Markets except EU: Watches for all ages fall within the scope of jewelry and therefore additional testing, age
labeling, and safety warning requirements apply. Refer to Table 16 for age labeling requirements.
 EU Market: Watches for all ages are not allowed in the EU market due to WEEE restrictions. Refer to Section 5 for
more details.
19.10 Hair Accessories

Hair accessories fall within the scope of jewelry and therefore additional testing, age labeling and safety warnings
requirements apply. Refer to Table 16 for age labeling requirements.

19.10.1 CHILDREN UNDER 36 MONTHS
 Hair accessories (clips, ponies, pins, etc.) that are small parts or can become a small part after use and abuse testing
are potential choking hazards for children under 36 months and are prohibited for baby.
19.10.2 CHILDREN 36 MONTHS AND OLDER

 Hair accessories may be marketed to baby 36 months and older, provided each of the following standards or
restrictions is met:
o Hair accessories that are small parts or may become small parts must be labeled with the choking hazard
warning statement.
o Marketing artwork and merchandising strategy for hair accessories should be directed to children 36 months
and older.
o Hair accessories intended for the EU market require additional wording of “remove before sleep” to be on the
swing ticket.
19.11 Headbands
 Headbands fall within the scope of jewelry and therefore additional testing, age labeling and safety warnings
requirements apply. Refer to Table 16 for age labeling requirements.
 Baby and Toddler (0-5T):
o Decorative features that have the potential to become small parts (beads, rhinestones, crystals, studs, heat
transfers, etc.) are not permitted.
o All textile attachments must be machine-sewn. Hand sewing of attachments is not permitted.
o Glue is not permitted for use in textile attachments.
 Kids (4 Years & Older):
o Glue is allowed as a secondary means of reinforcing textile attachments for added strength.
19.11.1 SOFT FABRIC HEADBANDS

 May be allowed for all ages in certain retail markets as per specific design requirements outlined in Table 34.
19.11.2 HARD HEADBANDS

 US, Canada, Japan:
o Not permitted for children younger than 24 months and should not be marketed to ages 0-24 months.
o May be allowed for children over 24 months in certain retail markets as per specific design requirements
outlined in Table 34
o Table 34.
 EU, China:
o Not permitted for children younger than 36 months and should not be marketed to ages 0-36 months.
o May be allowed for children over 36 months in all retail markets as outlined in Table 34
Table 34 – Children’s Headband Design Requirements by Retail Market
Children’s Headband Design Requirements by Retail Market
Examples US, CDA, Japan EU, China
BABY & TODDLER HEADBANDS (0-5T) (0-24 Months) (2T-5T) (0-3 Years)
SOFT FABRIC Headbands
(Continuous Loop With or
Not
Without Elastic) Allowed Allowed
Allowed
SOFT FABRIC Headbands

(With Hook/Loop Closure that
Allowed Allowed Allowed
Separates at Center Back)

Children’s Headband Design Requirements by Retail Market
Examples US, CDA, Japan EU, China
BABY & TODDLER HEADBANDS (0-5T) (0-24 Months) (2T-5T) (0-3 Years)
SOFT FABRIC Headbands with
Large Textile Attachments
Not
Measuring Approximately 1 ½ Allowed Allowed
Allowed
Inches or Larger
(Fabric Rosettes, Bows, etc.)
HARD Headbands
(With or Without Fabric
Covering)
Not Not
Allowed
Allowed Allowed
HARD Headbands with Large

Textile Attachments Measuring
Approximately 1 ½ Inches or
Not Not
Larger Allowed
Allowed Allowed
(Fabric Rosettes, Bows, etc.)
SOFT FABRIC or HARD

Headbands with Decorative
Features with Potential to
Become Small Parts
(Beads, Rhinestones, Crystals, Not Not Not
etc.) Allowed Allowed Allowed
KIDS HEADBANDS (4 YEARS & OLDER)

SOFT FABRIC Headbands Allowed with no design restrictions in all retail markets.
HARD Headbands Allowed with no design restrictions in all retail markets.
Note: All KIDS and BABY/TODDLER headbands require age labeling in all retail markets. See Table 16 for requirements.
20 Loop Hazards on Accessories for Infants, Toddlers and

Children
 Accessories, such as bags, intended for toddlers and infants must be designed so that handles, cords, straps, etc., do
not create strangulation or entanglement hazards, also referred to as “loop hazards”.
 A loop hazard exists when a flexible cord can form a loop with a circumference of 14 inches or greater, either alone
or in connection with an accessory.
o Additionally, the strap or cord, when in a loop configuration, must not permit the passage of the head probe
when tested in accordance to ASTM F963-section 8.22.
o Cords or elastics included with or attached to accessories intended for toddlers and infants less than 24 months
shall be less than 12" (300 mm) long when measured to the maximum length in a free state and under a load of
5 lb (2.25 kg).
 Drawstrings are not the same as straps, ties and cords but pose similar hazards in accessories worn on the body.
Refer to Drawstrings and Ties in Children’s Toddler and Infant Wearing Apparel and Accessories (Error! Reference
source not found.) for additional details.

20.1 Bags for Toddlers and Infants
20.1.1 LOOP HAZARDS
Most bags, by design, have straps that can form loops, including loops that can become hazardous for small children
and babies. For measurement techniques to determine the presence of loop hazards, refer to the following Guidelines
for Loop Measurement – Bags. Keep in mind that specialized test equipment (head probe) is used to make a final
determination of a loop hazard.
20.1.2 BAGS FOR TODDLERS AND INFANTS YOUNGER THAN 24 MONTHS OF AGE
 Bags with straps or handles that present a potential loop hazard are prohibited.
20.1.3 BAGS FOR TODDLERS AND INFANTS 24 MONTHS AND OLDER

 Bags with straps or cords that create a loop circumference in excess of 14" are permitted for children 24 months
and older, provided each of the following standards or restrictions is met.
o Marketing artwork and merchandising strategy should be directed to children 24 months and older.
o Bags are labeled or tagged with the following statement: “Not Recommended for Children under 2 Years of
Age.” There is no required font or label size, but text must be legible, easy to read and conspicuous at the point
of purchase.
 Refer to Error! Reference source not found. for Guidelines for Loop Measurement – Bags
20.2 Bungee Cords on Children’s Bags

 Bungee cords can retract unexpectedly and with significant force. For this reason, the following restrictions apply to
bungee cords on the exterior of children’s bags (including fashion bags, backpacks, lunch kits, etc.):
 Bungee cord must be continuous without dangling free ends. In order to keep bungee cord in place and maintain
function, ends of bungee cord must be sewn together and bungee cord must be tacked down at each channel.
Please refer to the following examples for details.
20.3 Suspenders for Toddlers & Infants

All suspenders are assumed to present a loop potential by way of the design and function.
20.3.1 SUSPENDERS FOR TODDLERS AND INFANTS YOUNGER THAN 24 MONTHS OF AGE
 Sales or marketing of suspenders to children younger than 24 months of age is specifically prohibited as a matter of
Gap Inc. policy.
20.3.2 SUSPENDERS FOR TODDLERS AND INFANTS 24 MONTHS AND OLDER

 Suspenders are permitted for children 24 months and older, provided all the following standards and restrictions
are met:
o Marketing artwork and merchandising strategy is directed to children 24 months and older.
o Suspenders are labeled or tagged with the following statement: “Not Recommended for Children Under 2 Years
of Age”. There is no required font or label size, but text must be legible, easy to read and conspicuous at the
point of purchase.
o This policy does not apply to suspenders for kids or adults. It also excludes suspenders that are permanently
attached to garments.
20.4 Visors for Toddlers and Infants

All visors are presumed to present a loop hazard potential by way of the design and intended function.
20.4.1 VISORS FOR TODDLERS AND INFANTS YOUNGER THAN 24 MONTHS OF AGE
 The manufacturing of any visor for use by children less than 24 months is prohibited as a matter of Gap Inc. policy

20.4.2 VISORS FOR TODDLERS AND INFANTS 24 MONTHS AND OLDER
 Visors are permitted for children 24 months and older, provided all the following standards and restrictions are met:
o Marketing artwork and merchandising strategy is directed to children 24 months and older.
o Visors are labeled or tagged with the following statement: “Not Recommended for Children Under 2 Years of
Age”. There is no required font or label size, but text must be legible, easy to read and conspicuous at the point
of purchase.
20.5 Scarves for Infants, Toddlers and Children

All scarves are presumed to present a loop hazard potential by way of the design and intended function.
20.5.1 SCARVES FOR TODDLERS AND INFANTS YOUNGER THAN 24 MONTHS OF AGE
o Sales or marketing of scarves to children younger than 24 months of age is specifically prohibited as a matter of
Gap Inc. policy.
20.5.2 SCARVES FOR TODDLERS AND INFANTS 24 MONTHS AND OLDER

 Scarves are permitted for children 24 months and older, provided all the following standards and restrictions are
met:
o Scarves are labeled or tagged with the following statement: “Not Recommended for Children under 2 Years of
Age”.
o Maximum scarf length permitted is 28.0 inches from edge to edge including any fringe or tassels.
o Must be constructed with a hook and loop tape closure so scarf lies around the neck.
o Must not loop or tie around the neck (Infinity fashion scarves and neck warmers included).
Figure 11 – Approved Construction with Hook & Loop Closure
20.5.3 SCARVES FOR CHILDREN AGES 4 – 18

 Scarves designed to loop around the neck (Infinity fashion scarves ) must be constructed with a hook and loop tape
closure and have a maximum circumference of 30.0 inches.
 Neck warmers are allowed with a maximum circumference of 20.5 inches. Must fit snug to neck.
 Traditional scarves are allowed with maximum length of 60.0 inches from edge to edge including fringe, tassels and
pompoms.
20.6 Blanket Stitch/Continuous Yarn Stitching

20.6.1 BABY (0 – 36 MONTHS)
 Blanket stitching and decorative continuous stitching (done with heavy sewing thread or embroidery yarn) that can
unravel in a continuous length must be cut & knotted for every 8.0 inches of thread/yarn.
 The cut and knot requirement does not apply to functional stitches done with standard sewing thread.
 As unraveling can vary depending on the stitch technique and the garment fabrication, exceptions may be made on
a case-by-case review and approval by Product Safety.

20.6.1.1 Automatic Exceptions
Automatic exceptions include:
 Machine Pick Stitching around pockets and on side seams.
 Embroidery stitches are not required to be cut and knotted.
 For all other exemption requests, Product Safety in conjunction with GIS PI, must review production quality
garments to determine if the proposed technique will be a potential hazard and will advise cut and knot
instructions accordingly.
20.6.2 KIDS (OVER 36 MONTHS)

 Exempt from the blanket stitch/decorative continuous stitch “cut and knot every 8.0 inches” requirement.
 Ends of all blanket stitch/decorative continuous stitches must be secure.
21 Drawstring, Tie and Decorative Tie/Bow

21.1 Requirements and Guidelines
 Regulations apply to kids and baby apparel and apparel accessories.
 Implementing these specifications enables compliance for global brands selling children’s wear in the global
marketplace (USA, Canada, EU, Japan and China).
 Drawstrings in the hood and neck area on all children’s apparel are strictly prohibited.
 As drawstring, tie and decorative tie/bow requirements are detailed and lengthy, refer to Drawstrings and Ties in
Children’s Toddler and Infant Wearing Apparel and Accessories (Error! Reference source not found.) for detailed
requirements and images.
21.2 Halter Neck Garments

21.2.1 DESIGN RESTRICTIONS FOR BABY AND TODDLER 0 – 24 MONTHS
 Halter necklines that begin at center front and encircle (intentionally wrap around) the neck are prohibited.
Figure 12 – Halterneck Design Restrictions
21.2.2 ADDITIONAL HALTER POLICY FOR KIDS AND BABY

 Functional halter ties are prohibited for kids and baby. Halter necklines are permitted if constructed with no free
ends in conjunction with a hook or button closure (Error! Reference source not found.).
21.3 Hats with Chinstraps

 Continuous chinstraps are prohibited.
 Chinstraps must be used with a break away closure on Kids/Baby Hats. Hook and loop fasteners are the preferred
method of closure.

 Chinstrap length should be graded according to size range. Technical Design will determine the appropriate
chinstrap size to allow proper functioning.
21.4 Neck Opening on Apparel

 Neck stretch gauges should be used to measure neck stretch on applicable products.
 Gauges can only be obtained from SDL Atlas. These gauges may not be copied or reproduced.
Table 35 – Neck Opening Measurements
Minimum Neck Stretch Specifications
Baby Preemie Preemie 17"
Baby 0-3 months Newborn -XS 18"
Baby 3-6 months S 19"
Baby 6-12 months M 20"
Baby 1-4 years L-4XL 21"
Kids 2-4 years XXS-XS 21"
Kids 5-9 years S-M 22"
Kids 10-14 years L - XXL 23"
 Pass: gauge goes through neck opening smoothly without distorting the gauge or causing seam failure
 Fail: gauge goes through neck opening with gauge distortion or garment seam failure; or gauge unable to go
through neck opening.
22 Thread Ends/ Yarn Floats

22.1 Socks and Footed Apparel for Baby (0 – 36 Months)
 Infant’s toes/toe nails can become trapped in interior yarn floats and excessive thread lengths of socks and footed
apparel resulting in entrapment and blood circulation issues.
 The following guidelines apply to socks, footed apparel and footwear for babies (0-36 months).
 Internal Yarn and Thread Ends: Must be trimmed to a maximum length of 1 inch above and below the heel.
Table 36 – Sock Internal Yarn and Thread Ends
Acceptable Unacceptable
Acceptable: Yarns trimmed to max Unacceptable: Yarns not trimmed to

length of 1 inch. max length of 1 inch.
 Internal Toe Closure Threads: Must be trimmed to a maximum of ½ inch. No loops are allowed in this area
Table 37 – Internal Toe Closure Threads
Acceptable: Toe closure Unacceptable: Toe closure Unacceptable: Untrimmed Unacceptable: Toe finish with
threads trimmed to max threads not trimmed to max sewing thread in footed loops (no loops allowed).
length of ½ inch. length of ½ inch. apparel.

 Internal Yarn Floats:
o If yarn floats cannot be avoided in certain patterns or repeats such patterns can only be used in areas above the
heel.
o There is no limit on yarn floats above the heel; however, excessive floats should be avoided if possible.
Table 38 – Internal Yarn Floats
Acceptable: No yarn floats below Unacceptable: Yarn floats below the

the heel. heel.
22.2 Sweater Floats on Baby Apparel

 The following are recommended yarn float lengths in sweaters for baby younger than 36 months.
o Body Floats recommend not to exceed 1 inch maximum
o Sleeve Floats recommend not to exceed ⅜ inch maximum
 Please refer to Technical Design for further details and/or yarn float measurement guidelines for a product design,
which cannot be achieved using these recommended lengths.
23 Caped Apparel – Restrictions for Baby and Toddler

Table 39 – Cape Allowance by Market
US, Canada, Japan Markets European Union Markets
Daywear & Sleepwear Daywear Sleepwear
18-24 Months Actual capes are not permitted. Screen- Actual capes are not permitted. Screen- Actual capes are not
or Younger printed images of capes are permitted. printed images of capes are permitted. permitted. Screen-
2 Years / 2T Permitted. See Cape Design & Actual capes are not permitted. Screen- printed images of
Manufacturing Requirements below. printed images of capes are permitted. capes are permitted.
3 Years / 3T Permitted. See Cape Design & Permitted. See Cape Design &
4 Years / 4T Manufacturing Requirements below. Manufacturing Requirements below.
5 Years / 5T
 Cape Design & Manufacturing Requirements:
o Cape Attachment:
 Cape must be detachable and must be attached to back location only.
 Cape must be attached using hook/loop fastener. Any other trim or attachment type must be approved by
Product Safety as a deviation to policy.
 Testing
o Hook/loop fasteners must have a shear strength of 5 lbs or less (ASTM D5169).
o Hook/loop fasteners must have a peel strength of 5 lbs or less (ASTM D5170).
o Testing may be performed at either the development or garment production stage as long as the tested caped
apparel has the same hook/loop fastener quality and dimensions as that which is used on actual production.
 Hook/loop must have rounded corners and be sewn so that edges are set back from edge of fabric.
Table 40 – Maximum Cape Lengths Allowed by Size
Cape Length is Measured from Cape’s Highest Point
to Cape’s Bottom Edge
2 Years / 2T 14 Inches
5 Years / 5T 17 inches

 Sleepwear with Capes:
o A cape offered in a sleepwear set or on one-piece sleepwear must pass flame resistant sleepwear testing and
bear its own main label. (See Table 41 – Cape Warning Labels below.) The matching sleepwear garment may be
either snug-fitting or flame resistant, in compliance with Gap Inc.’s sleepwear requirements and must bear the
appropriate sleepwear labeling.
 Warning Labels:
o Sleepwear: A special warning label on the cape main label and a hangtag on the matching sleep garment are
required on the sleepwear sizes with capes, advising the adult to remove the cape before sleep.
Table 41 – Cape Warning Labels
Permanent Cape Label Garment Hangtag
(May be Used with Either Sewn-In or Tagless Labels)
 Statement: “FLAME RESISTANT”.  Must at least repeat the warning text “REMOVE CAPE
 Warning statement “REMOVE CAPE BEFORE SLEEP” in capital BEFORE SLEEP” on hangtag.
letters on the front of the label.  Other marketing text may be used as long as the key
 Warning must be in equal or larger prominence of other fonts safety warning from the permanent cape label is
used on the label. repeated.
 Cape label must also include all other legally required labeling  Warning must be in equal or larger prominence of
information as on the garment label (logo, fiber content, other fonts used on the hang tag.
country of origin, RN number, CA number, FPU, GPU, etc.).
 Statements must be translated for Canada and Japan.
 Daywear: The cape removal warning on the cape main label and hangtag must not be used for daywear.
24 Laceration
24.1 Sharp Points and Edges
 Sharp points and edges, whether functional or not, are never permitted for products intended for infants and
toddlers under 4 years of age, under any circumstance.
 Accessible sharp points or edges, as defined by 16 CFR 1500.48 (points) and 1500.49 (edges), are not permitted on
any apparel or accessory product for children, with the exception of products having a sharp edge or point that is
essential to the function of the product.
o For example: An earring with a thin, rigid post necessary for insertion into earlobes would be permitted.
 However, for most apparel, accessories and footwear, an exposed sharp edge or point is not necessary to the
function, and is prohibited in the as is condition and as a result of use and abuse testing.
24.2 Hook & Loop Fastenings

 Hook and loop fastening tape with sharp corners is prohibited. Corners must be rounded (die-cut or hand trimmed)
to prevent scratching.
Figure 13 – Rounded corners on hook and loop fastening
24.3 Monofilament Thread

 As a general policy, monofilament thread is prohibited in the assembly of any children’s product due to the
potential for sharp points (from thread ends) and hazardous loops.

 Core spun polyester threads (spun polyester/cotton wrapped threads) are preferred, when an enhanced
attachment strength is required.
 Where it can be confirmed that no alternative thread exists to provide the needed attachment strength, and no
hazardous conditions are created by the use of the monofilament thread, Product Safety may be consulted for a
style-specific exemption.
24.4 Metallic Fiber and Yarns

 Metallic fiber and yarns (such as Lurex) pose a risk of skin irritation for infants and toddlers 0 – 5T.
Table 42 – Metallic Yarns/Fibers Design Requirements
Apparel & Apparel Accessories Apparel & Apparel Accessories
(0 – 12 months) (Over 12 months)
Fabrics and sweater yarns Skin contact not permitted Lining not required by PSR
incorporating metallic (Garments must be lined)
yarns/fibers
Embroidery with metallic Embroidery must have lining or backing Embroidery must have lining or backing
yarns/fibers
(example: graphic t-shirts)
 All baby and toddler apparel and apparel accessories incorporating metallic yarns/fibers must be reviewed per
established PSR line review process.
24.5 Needles & Foreign Metal Contamination

 Gap Inc. will not accept any product containing foreign metal contaminants such as needles, needle fragments or
other sharp metal objects (metal staples, pins, prongs, accidental/extra footwear nails / screws, mechanical tools,
scissors, clippers, etc.). In addition, no metal clips, pins, wires or staples may be used in any part of the production
process for bundling, tacking or securing components.
o When foreign metal contaminants are found in Gap Inc. product, the safety of the entire shipment is questioned.
Vendors found in violation of Gap Inc.’s Needle & Foreign Metal Contamination policy are subject to financial
penalty or termination as a Gap Inc. approved factory.
 Gap Inc. requires that all factories producing product in the following product, market and age divisions utilize a
needle detector in metal-free detection packing zones:
o Baby (All Gap Inc. Brands)
o Kids (All Gap Inc. Brands)
o Japan Market (All Gap Inc. Brands; Adult, Kids, Baby)
o Intimate Apparel (All Gap Inc. Brands; Adult, Kids, Baby)
 Refer to the Quality Assurance Manual under the Quality Assurance link on GapSource Library for more
detailed procedures on needle control, needle detection, and metal-free detection and packing zones.
24.6 Zipper Guards

 Zipper guards must be attached to the garment between the zipper and the body (facing the body) to prevent injury.
Zipper guard design can vary (see chart below) but the top of the zipper guard must extend at least ¼” beyond the
top edge of the zipper head and set flush with the bottom of the zipper.
24.6.1 BABY AND TODDLER (0 – 36 MONTHS)

o Zipper guards are required for all baby garments with zippers (regardless of zipper type - including metal, plastic
and coil zippers)
 Baby and toddler boy bottoms with a zip fly must have a zipper guard at least 20 mm wide (3/4”), secured by
stitching across the fly opening at the bottom, to provide protection against accidental entrapment.
24.6.2 KIDS (4 YEARS AND OLDER)

o Zipper guards are required for all children’s garments with a metal zipper. Zipper guards are recommended for
all other zippers.

Table 43 – Zipper Guard Requirements
Zipper Guard Approved Garment Approved Zipper
Examples
Type Type & Location Type
Plastic
Triangular Outerwear Only
Coil
Plastic
All apparel
Gusset Coil
(where feasible)
Metal
Plastic
One Flap All apparel Coil
Metal
Plastic
Kissing Two-Flap All apparel Coil
Metal
24.7 Infant One-piece Garments with Center Front Zippers

Exposed zipper pulls around the face and neck area can easily flip up and pose a potential laceration hazard for infants
who do not yet have the neck strength to hold up their heads. Additionally, exposed pulls on these styles are perceived
by some customers as a potential choking hazard, even when pulls are firmly attached.
Figure 14: Examples of zip one-piece garments
24.7.1 CONSTRUCTION REQUIREMENTS

 This requirement applies to all one-piece garments intended for infants, including footed or non-footed and
daywear or sleepwear styles.
 Infant one-piece garments with a center front zipper must be designed so the zipper pull does not come in contact
with the wearer’s neck or chin.

 Acceptable construction options are pictured below in Figure 15.
 Alternative designs must be reviewed and approved by Product Safety.
Triangle Zipper Guard Tab with snap or Velcro Offset Zipper Reverse Zip
(Zipper set to side) (Zips from neck to foot)
Figure 15: Front zipper acceptable construction for Infant one-piece garments
24.8 Pumice Stone Washed Garments

 Children age 3 and under: Stone and sand washing is prohibited on all products.
 Children age 4 and over: No safety restrictions.
24.9 Sandblasting Abrasives

 Sandblasting banned on all products as per Social Responsibility requirement.
24.10 Minimum Plant Safety Equipment

 All garment manufacturers producing Gap Inc. kids & baby products are required to purchase and maintain the
following equipment, where applicable:
o Attachment strength gauge/appropriate clamping devices (e.g., SafQ snap attachment tester for light weight
duty snap application)
o Lock stitch buttoning machine
o Minimum neck stretch gauges (sweaters/knits)
o Needle detection machines – Refer to the Quality Assurance Manual under the Quality Assurance link on
GapSource Library for machine requirements
25 Footwear
25.1 Footwear Safety for All Age Groups
 Gap Inc. requires footwear for all age groups to meet certain safety and durability standards to ensure the safety of
its customers. Footwear failing to meet these standards may constitute a critical hazard, and be considered unfit for
sale. Refer to PSR footwear protocol GP2102 for specific details regarding these tests.
o Slip Resistance
o Bond Durability
o Strap Attachment (including special strap tests for flip flops)
o Heel Attachment
o Heel Impact
 Restrictions or prohibitions apply to outsoles with textile surfaces, depending on shoe type and location of textile
application. Such styles should be reviewed with a Product Safety or GIS Product Integrity manager to determine if
a restriction applies.
 Note: Footed Sleepwear and Socks, while not within the scope of “Footwear” are required to meet slip-resistance
requirements for sizes 12 months and over.

25.2 Additional Footwear Safety for Infants, Toddlers and Children
 In addition to the above, footwear for Infants, Toddlers and Children have the following special restrictions:
o Slip-on footwear styles (slides, clogs, flip flops, etc.) for infants and toddlers must have back straps.
o Heels are prohibited for baby and heel height may not exceed 5 cm for children.
o Footwear for babies under 12 months are exempt from Slip Resistance requirements
26 Sunglasses
26.1 Requirements (All Age Groups)
 Laboratory testing of sunglasses is restricted to specific approved labs capable and certified to execute highly
specialized and regulated testing of sunglasses. Please consult Product Integrity to obtain information regarding
qualified lab contacts.
 Labeling requirements, which vary significantly across markets, are detailed in the Footwear and Accessories
Manual under Product Guidelines and Testing on GapSource Library.
26.2 Ultraviolet Protection (UVA & UVB)

 All sunglasses and eyewear are required to meet the European standard for UVA and UVB protection per EN ISO
12312-1:2013, with a minimum standard of 100% UVA and UVB protection.
26.3 US FDA Lens Testing

 All sunglasses are required to meet the U.S. Food and Drug Administration requirement for lens impact resistance
described in 21 CFR 801.410. Sunglass production batches must be statistically sampled and pass a designated
impact resistance test.
 For importation in the U.S., vendors must prepare a Sunglass Lens Impact Resistance Certificate to accompany each
production batch shipped. The vendor certifies compliance with the test and regulations by providing specified
information, including a certification statement, the Sampling Plan applied and description of the batch, the Test
Method, Lab identification, and Test Results Summary, among other details.
 Refer to TB 215 series FDA Sunglasses Lens Impact for details in the Technical Bulletins folder under Product
Guidelines and Testing on GSL. This includes the GAP INC SUNGLASS LENS IMPACT RESISTANCE CERTIFICATE form.
26.4 European Requirements

 Sunglasses intended for distribution in Europe must meet the test requirements of EN ISO 12312-1:2013 and EN ISO
12311:2013 and must comply with special marking and labeling requirements as specified in the Footwear and
Accessories Manual (FAM) under Product Guidelines and Testing on GSL.
 For detailed information regarding test requirements, refer to test protocol GP PSR 2105 on GSL within FAM; Error!
Reference source not found.; and/or consult Product Integrity or Product Safety and Regulations.
26.5 Japan Requirements

 Sunglasses intended for distribution in Japan must be submitted for verification of compliance to Japanese market
requirements, and for detailed directions on labeling and product marking in accordance with the Household Goods
Labeling Law.

27 Tacky Residue on Screen Printed Garments
27.1 Requirements
 Gap Inc. requires that no sticky substance be found on screen-printed garments for kids and baby.
 It is the responsibility of the vendor to prevent sticky residue on the garment.
 In addition, the vendor is expected to develop appropriate internal controls to ensure that a quality product is
delivered to Gap Inc.
27.2 Action Steps

 Perform 100% inspection of screen-printed garments of all baby and kids products. The inspection process should
involve a visual check and feel to verify that sticky residue is not present anywhere on the garment.
 Products found to have a sticky residue must be removed from the production line or from the shipment and
corrected.
 If the sticky product cannot be corrected it must be destroyed. It cannot be treated or labeled as second or overrun.
 Evaluate and pre-test all screen-print products so that any sticky residue is detected up front and addressed.
28 Pigments Used as Garment Colorants

 Pigments are variable in terms of color retention. Crocking and bleeding performance are extremely unreliable.
 As a class of colorants, pigments and their associated auxiliary chemicals are difficult to ‘qualify’ as non‐toxic. There
is no standardized formula, so the chemical make‐up is likely to differ from pigment to pigment.
 Even if a pigment is determined to be ‘safe’, the potential for a perceived scare (due to dye transfer onto the mouth
or skin) is very high for baby and maternity.
28.1 Prohibition of Pigments

 Pigments used as garment colorants (including spray pigment) are prohibited for:
o Baby 0‐24 months: All apparel and apparel accessories
o Maternity: All apparel
 Exclusions: Pigment prints applied in fabric form (such as sleepwear prints) will not be prohibited due to their
application process and chemistry.
29 Promotional Items
29.1 Product Safety and Regulatory Requirements
 Promotional products intended for distribution to customers are required to meet the same safety and regulatory
requirements as merchandise intended for sale.
 Promotional concepts must be reviewed and approved by Product Safety & Regulations (PSR), prior to the
promotional event.
 Use of the term “promotional item” includes the following types of customer-facing items:
o Bonus item
o Gift with purchase (GWP)
o Gift or prize in association with a promotional event
o Store giveaway
To learn about the policy, please see the latest version of Technical Bulletin 76 series – Product Safety and Regulatory
Requirements for Promotional Items for full details.

Notes and References
Page 7
1 Consumer Product Safety Improvement Act of 2008 or CPSIA (Public Law 110-314), as amended by H.R. 2715, August 12, 2011.
Both laws amended sections of the Consumer Product Safety Act (15 USC §§2051-2089)
2 US Federal Register -16 CFR 1107 Testing and Labeling Pertaining to Product Certification Final Rule (link)
3 US Federal Register-16 CFR 1109 Conditions and Requirements for Relying on Component Part Testing or Certification, or Another
Party’s Finished Product Testing or Certification, to Meet Testing and Certification Requirements Final Rule (link)
Page 8
4 16 CFR 1109.4(g) Definition of Due Care: Due care means the degree of care that a prudent and competent person engaged in the
same line of business or endeavor would exercise under similar circumstances. Due care does not permit willful ignorance.
5 16 CFR 1107.20-26, Subpart C- Certification of Children’s Products
Page 10
6 Regulation (EC) No. 1907/2006 (REACH)
7 Washington State’s Children’s Safe Products Act (CSPA), chapter 70.240 RCW, Rules in WAC 173-334-110 forward; California’s Safer
Consumer Product Alternatives, Statutes of 2008, Chapter 559, AB 1879 Health & Safety Code §25252 and Chapter 560, SB 509,
Health & Safety Code §25251; Maine’s An Act to Protect Children’s Health and the Environment from Toxic Chemicals in Toys and
Children’s Products, Laws of 2007, Chapter 643, (2008), 38 Maine Rev. Stat. Ann. §1691
Page 12
8 REACH, Annex XVII, entry 43, (EC) No. 1907/2006
Page 13
9 Restricted widely but in different applications by market, e.g., EU REACH, Annex XVII, point 23, (EC) No. 1907/2006; RoHS
2002/95/EC; various US States restrict Cd in children’s Jewelry, and under CA Prop 65 settlements, cadmium is also restricted in
adult jewelry.
Page 15
10 ASTM F963 Standard Consumer Product Specifications for Toy Safety is a mandatory US Consumer Safety Standard
Page 17
11Requirements in 16 CFR 1500.90 were modified under H.R. 2715 in 2011. This amendment provides for a functional purpose
exception to the children’s lead limits. But the conditions imposed severely restrict the use of this exception.
12 See 16 CFR 1500.88
13 Children’s Products Containing Lead; Determinations Regarding Lead Content; see 16 CFR 1500.91.
14 Illinois Lead Poisoning Prevention Act (410 ILCS 45/6(a)), specifically prohibits sale of painted toys, child care articles, and
children’s jewelry with total lead content above 40 ppm unless the product bears this warning statement: “WARNING: CONTAINS
LEAD. MAY BE HARMFUL IF EATEN OR CHEWED. MAY GENERATE DUST CONTAINING LEAD”
Page 19
15 Federal Hazardous Substances Act (FHSA): A product that is not intended for children, but that creates a risk of substantial injury
or illness because it contains hazardous chemicals, requires precautionary labeling under the Act [15 U.S.C. 1261(p)]. CPSC Guidance
on hazardous liquids in children’s products is found in 16 CFR 1500.231. See also ASTM F2923-11 “Standard Specification for
Consumer Product Safety for Children’s Jewelry,” section 11.
16 Cleanliness is determined by methods in USP 24<61> Microbial Limits Tests or the most current edition of the U.S. Pharmacopeia.
These requirements are applied to liquid filled toys. See ASTM F963-11, section 8.4.1.
17 Coliform: Fecal Coliform (Escherichia); other common types: Citrobacter, Enterobacter, Hafnia, Kliebsella, Serratia
18 See REACH, Annex XVII entry 27, Regulation (EC) No. 1907/2006
Page 20
19 EU Commission Regulation (EU) No 1272/2013
Page 21
20 For example, California Toxic Toys Act 2007 (Assembly Bill 1108); EU REACH Regulation Annex XVII, entry 51, 52
21 Notice of Proposed Rule Making, Federal Register Vol. 29, No. 249, December 30, 2014: 16 CFR 1307, Prohibition of Children’s
Toys and Childcare Articles Containing Specified Phthalates

22 California Jewelry Law, CA Health & Safety Code §25214.3.1
23 California Health and Safety Code § 25214.1-25214.4.2
Page 22
24 Center for Environmental Health v. Aeropostale et al, Case No. RG 10-514803 (September 2011)
25 CA Health & Safety Code § 25214.1-.2; County of Alameda Case No.RG-04-162075
26
Commission Regulation (EU) No 836/2012, amending Annex XVII to Regulation No 1907/2006 as regards lead
Page 23
27 See REACH, Annex XVII entry 27, Regulation (EC) No. 1907/2006
Page 25
28 California Jewelry Law, CA Health & Safety Code §25214.3.1
Page 26
29 Directive 2012/19/EC – WEEE of 13 August 2013 (repealed former 2002/96/EC of 27 January 2003). See Frequently Asked
Questions http://ec.europa.eu/environment/waste/weee/pdf/faq.pdf
30 Directive 2002/95/EC – RoHS of 27 January 2003; RoHS Recast Directive 2011/65/EU, effective January 2, 2013
31 Batteries and Accumulators and Waste Batteries and Accumulators Directive (Directive 2006/66/EC of 6 September 2006) as
amended by Directive 2013/56/EC
32 Safe Drinking Water and Toxic Enforcement Act of 1986, found in California Health and Safety Code Section 25249.5 and in
regulations in Title 27, California Code of Regulations

Page 27
33 EU Dangerous Imitations Directive 87/357/EEC


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GAP INC.

Gap Inc. Safety Requirements

Gap Inc. Safety Requirements

Gap Inc. Safety Requirements

Gap Inc. Safety Requirements

Gap Inc. Safety Requirements

Gap Inc. Safety Requirements

We expect suppliers to:

1 Compliance with U.S. Product Safety Rules

1.2 Gap Inc.’s CPSC Testing and Certification Program

Gap Inc. Safety Requirements

1.3 Gap Inc. CPSC Certification Folder on GapSource Library

1.4 Responsibility as a Certifier5

1.5 Gap Inc. Due Care Requirements

Gap Inc. Safety Requirements

1.6 Certificates of Compliance (COC)

1.7 How to Certify Compliance

Gap Inc. Safety Requirements

2.2 Gap Inc. RSL Testing Program

2.2.1 CRITICAL “REACH” TESTING FAILURES

Gap Inc. Safety Requirements

2.2.3 RESULT TRACKING

3 Chemicals of Concern – Selected Substances

3.1 Antimicrobial Treatments

3.1.1 NORTH AMERICA REQUIREMENTS

3.1.2 EUROPEAN UNION REQUIREMENTS

3.1.3 MARKETING CLAIMS

3.2 Azo Dyes8

Table 2 – Azo Restrictions

3.2.1.1 Greece and Turkey Franchise Markets Special Testing

Gap Inc. Safety Requirements

Table 3 – Cadmium Restrictions

3.5 Chemical Finishes

3.6 Chromium VI (Hexavalent Chromium)

Gap Inc. Safety Requirements

3.7.2 PIGMENT BAN FOR BABY 0-24 MONTHS AND MATERNITY

3.8 DMFu (Dimethyl Fumarate)

3.9.1.1 Japan market

Gap Inc. Safety Requirements

3.9.2 FORMALDEHYDE EMISSION FROM COMPOSITE WOOD PRODUCTS

3.10 Heavy Metals (Soluble)

Gap Inc. Safety Requirements

3.11 Heavy Metals (Total) – Packaging

3.12.1 GENERAL REQUIREMENTS

3.12.1.2 Jewelry for All Ages

3.12.2 CHILDREN’S PRODUCTS

3.12.2.1 Accessible Components

Gap Inc. Safety Requirements

3.12.2.3 Electronics Exception

3.12.2.4 Exclusions from Testing 13

Gap Inc. Safety Requirements

3.12.3 ADULT PRODUCTS

3.13 Liquid Filled Products (Jewelry, Accessories, and Apparel)

3.13.2 LIQUID FILL

Gap Inc. Safety Requirements

3.16 PAHs (Polycyclic Aromatic Hydrocarbons)

3.17.1 APPAREL AND ACCESSORIES

Gap Inc. Safety Requirements