A. General feedback

1. How do the criteria in draft standard V1.1 affect your organization and your primary stakeholders?

2. Does the draft standard include all key topic sections and criteria that should be included as scoped for the draft 1 release?

3. Are there sections or criteria that feel irrelevant or out of touch with industry improvements?

4. More specifically,

   a.     do the conformance-related criteria set clear expectations? 

   b.     do you agree with the type of criteria as set (conformance-related or leadership)? Are there any criteria labeled as “conformance-related” (required) that should be “leadership” (recommendation) at this time, or, conversely, leadership criteria that should be set as conformance-related and required for certification?

5. Do you foresee criteria to be auditable, generally speaking or specific to a geographic region you’re familiar with?

6. We have introduced a new feature called Performance Determination that allows information to supplement each criterion. In the first draft this has been used mostly for the Human Rights & Livelihoods section to indicate applicability of the criteria based on size and scale of the site. Do you think this should be expanded upon to support all sections of criteria and potentially replace the separate user manuals?

B. Animal materials

1. We are aiming to deliver on the Five Domains of animal welfare and provide more positive outcomes for animals through the unified standard. Is there anything you think we are missing, or you would like to see strengthened?

2. In our last revision of the Responsible Animal Fiber standards we introduced criteria that when painful husbandry procedures like castration are necessary, pain relief must be used when suitable pain-relieving drugs are available. Currently this is only the case in Australia and NZ. For the unified standard we discussed removing the pain relief requirement until more pain relief is available, or strengthening the criteria so that when available, both short- and long-term pain relief is used. In the end we kept the requirement as it currently is. Do you agree with this? If not, what would you recommend be required for pain relief?

3. We have proposed changes to strengthen our biodiversity section for animal fibers to cover all wildlife species instead of only predators. But we have included the possibility for poison to be used to control invasive predator species when no other methods are suitable. Do you agree with this? If not, how else would you recommend  this challenge be addressed?

4. We’ve expanded the scope of the standard to include yak fiber. Do you agree that this is a good idea? Do you think we covered the key aspects of yak welfare?

C. Fiber crops (cotton)

1. Fiber crop production systems and farm management decisions are based upon local contexts. We aimed to write the fiber crops criteria so that it may adapt to local contexts and provide desired outcomes where applicable, guided by the user manual. Are there criteria that feel out of reach within your locality? Based on geographical context, are there criteria that could be rewritten or reconsidered? What specific guidance would you request in the user manual?

2. Another layer of complexity is related to farm type and scale. Performance determinations have been introduced to the draft standard to define conformance expectations based on organizational characteristics such as size and scale. This has been done primarily for human rights & livelihoods in the first draft, and applicability for fiber crops (e.g., farm size) will be considered for the second public consultation. From a scale lens, are there any criteria you believe would be challenging to implement at the smallholder-, medium-, and large-scale levels?

3. Do you believe we have covered all important topics related to fiber crop production for cotton?

D. Recycled materials

1. By leaving out the ZDHC MRSL criteria and re-designating Hazard codes as a leadership criterion, the Unified Standard addresses the difficulties with the chemical requirements in the GRS that are unique to Tier 3.5 (initial production). Moreover, we attempt to recognize additional industry standards and certifications that apply to the initial production. Do you agree with this modification? Do you believe there are any further possibilities to consider meeting the chemical requirements?

2. We plan to add a criterion in the second draft of the standard specific to man-made cellulosic fiber (MMCF) chemical management that will require following the latest version of the ZDHC Guidelines for MMCF, as well as their implementation timelines. Do you agree with this approach?

3. We introduced a new RSL criterion to the Unified Standard for assessing intermediate goods such pellets, flakes, filaments, and fibers. Do you agree with the new criterion? What factors should determine the test parameters and the testing schedule? What should the test methods and limit values be? Can you suggest any external parties to refer to, such as an AFIRM?

4. Do you encounter difficulties with any other criterion in the Unified Standard's Environmental/Facility section? Please bring any additional factors that may have been overlooked to our attention.