SUPPLIER HANDBOOK ( Addition )
Against Animal Testing (AAT) - Annual Renewal Declarations
Overview
The Body Shop is opposed to the use of animals in testing products or ingredients for the cosmetics and toiletries industry.
We believe that sufficient ingredients are currently available for use by the sector, in order to produce innovative, effective and safe products, without the need for animal testing.
Customer safety is of paramount importance to The Body Shop, and upholding policies and practices Against Animal Testing does not jeopardise the safety of our products or the customers that use them.
The Body Shop will only accept finished products and the individual ingredients thereof, that Manufacturers have not tested or re-tested on animals, for cosmetic purposes, since December 31st 1990.
Humane Cosmetics Standard
The Body Shop subscribes to the internationally recognised standard for cosmetics and toiletries that are Not Tested On Animals, as defined by the British Union for the Abolition of Vivisection (BUAV).
The Standard requires :-
- Companies do not conduct or commission animal testing.
- Finished products are not tested on animals.
- Implementation of a fixed cut-off date for the animal testing of products and ingredients.
- Each product or ingredient supplier must not have conducted or commissioned animal testing for the specific products/ingredients, since the Company’s fixed cut–off date.
- Purchasing policies and supplier monitoring systems ensure that ingredients, formulations and products meet the Standard’s criteria.
What is covered under The Body Shop AAT Rule ?
This rule applies to cosmetics products, their component parts and/or additives, as defined by the European Union Cosmetics Directive 76/768 EC (as amended).
The ingredient Raw Materials are defined as any single substance or mixture of substances, system or compound intended for use in Cosmetics products, as listed on the finished product label.
Specifically excluded are non-cosmetic formulated products, e.g home fragrance oils; candles; eye masks.
Please contact our Technical Information Manager at The Body Shop, should you be in any doubt about the need to procure an AAT declaration for any specific Finished Product and /or Raw Material.
Supply Monitoring System
We select finished product manufacturers according to defined criteria. This includes compliance to The Body Shop Purchasing Rule, which means that we will only purchase finished products and their ingredients that manufacturers have not tested or retested on animals, for cosmetic purposes, since our fixed cut-off date of 31st December 1990.
Finished product manufacturers are required to:
- Ensure that each finished product they develop is not tested on animals.
- Obtain and maintain on file, annual AAT Declarations from the manufacturers, for each raw material in the finished product.
(Template TI/9/8 sent to raw material suppliers)
The list below summarises the most critical steps of the AAT monitoring process, in order to define the division of responsibility between The Body Shop and its supply base, and to assist accountability and compliance.
AGAINST ANIMAL TESTINGSUPPLY MONITORING SYSTEM (SMS)
Process for obtaining Annual Declarations
Setting up of Master records/ Database systemsContacting Raw Material manufacturers
Responses & Time limits
Targets
Monitoring for Compliance
BSI site visits/audits
Non-compliance
Sub-contracting to a third party
BSI support/contact points
Best practices and Continuous Improvement
Setting up of Master Records/Database systems
It is vital that a comprehensive and accurate master record system be in place to ensure traceability and compliance to the process.
It is expected that the choice of system be such that secure and up-to-date status is maintained, required measurements can be made, and regular audits can be readily carried out.
Contacting Raw Material Suppliers/Manufacturers
We require that you contact each Raw Materials supplier/manufacturer on an annual basis, for all of the ingredients used in the finished products that you develop/manufacture for The Body Shop.
You will need to obtain from them, signed Declarations of Raw Material Compliance in order to avoid the use of ingredients that may have been animal tested for cosmetic purposes.
If many raw materials are purchased from the same supplier/manufacturer, a single declaration is acceptable, providing that each individual Raw Material is identified, using its Trade Name.
Each contact must be done in writing using the supplied Template TI/9/8, or equivalent version as approved by The Body Shop. It is essential that the Body Shop fixed cut-off date of 31st December 1990 is stated.
Fax, e-mail or hard copy versions are acceptable provided that the returned declaration has an original/ scanned original signatory from a named responsible person, and is dated.
Responses & Time Limits
In order to effectively measure and monitor on-going compliance, The Body Shop recommends a time limit of 1-month for Raw Material suppliers/manufacturers to sign and return their annual declarations.
It is expected that each finished product manufacturer will have a system in place to track this process and send out reminders as required.
Failure to obtain a signed declaration after a three month period has elapsed from the date of the initial request, will mean that the listed Raw Materials from that manufacturer will become non-compliant, and The Body Shop must benotified ( by e-mail/fax ).
All returned declarations must be checked for compliance by a ‘responsible person’ from the finished product manufacturers site, and the record signed-off as compliant and dated.
Any comments received from Raw Materials suppliers/manufacturers that indicate that animal testing has or may have occurred, or any incomplete or inconclusive information, must be treated as a non-compliance, and
The Body Shop immediately notified ( by e-mail/fax ).
The Body Shop will review all non- compliance issues, and inform you, in writing, of our required action.
Targets
Against Animal Testing is one of the principle core values of The Body Shop, and therefore we consider it essential to set targets and to play a part in monitoring the compliance of the overall process against these targets.
You will therefore be expected to continually measure your level of compliance, and make results available (on an annual basis) to The Body Shop as part of your self-audit process.
TARGETS & KEY PERFORMACE INDICATORSKPI
/Set Target
Raw Material AAT Declarations requested as % of those in use in BSI products (over year-to-date period). / 100%AAT declarations received as % of those sent out. / 100%
Non-Compliances reported to The Body Shop -
at any given date ( to be individually specified ) / 100%
Monitoring for Compliance.
Finished Product manufacturers will be required to complete an annual spreadsheet of AAT compliance data , and make this information available to The Body Shop.
This will enable us to :
- Identify levels of SMS compliance for each Finished Product manufacturer
- Satisfy BUAV Standard criteria.
- Provide timely support and input should problems arise
Your compliance with this AAT monitoring process is a vital aspect of your relationship with The Body Shop, and we will be regarding this as one of the key performance indicators (Quality Assured Status) in our Supply Chain Management System.
BSI site visits/audits
The Body Shop reserves the right to visit your site(s) to audit the AAT systems in place, in accordance with usual protocol agreements.
Non-compliance & communication
It is essential that all non-compliance issues or queries be immediately notified to The Body Shop (e-mail/fax). We reserve the right to make a final decision on compliance, and you will be notified of this in writing.
Examples of non–compliance are listed, but not restricted to :-
- Comments appearing on returned declarations relating to animal testing.
- Comments appearing on returned declarations relating to environmental testing.
- Incomplete or undated declarations (only original signatures are valid)
- Unsuitable ‘responsible person’ as Raw Material manufacturers’ signatory
- No response to an AAT declaration request after a 3-month time period has elapsed.
Sub-contracting to a third party
The Body Shop will need to pre-approve the use of any third-party Final Product manufacturing. As our approved contractual finished product manufacturer you will remain responsible for ensuring that all Raw Materials used in our finished products conform to the AAT standards and enter into your monitoring system.
BSI support/contact points
Non-compliance issues :
Ian Prendergast, Technical Information Manager
e-mail :
Fax : 01903-844064
Tel : 01903-731500
Site visits/audits :
Mike Taggart, Quality Assurance Manager
e-mail :
Fax : 01903-844134
Tel : 01903-731500
Supporting documents :
Process Flow Chart AAT Supply Monitoring Systems
Template TI/9/8 Annual Renewal AAT Declaration for Raw Materials
Details of the BUAV Standard may be obtained from :
British Union for the Abolition of Vivisection.
Fax : 020 7700 0252
Tel : 020 7700 4888
Best practice and continuous improvement
We are always interested in sharing and promoting Best Practice, so if you have suggestions for improvement to this AAT monitoring process, please share this with us.
PAS- 28/06/05 Updated 07-06-07 PDW
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