Vendor Compliance Manual

1. Product Safety

Any product or component vendors sell to us must be safe for the consumer to use

Vendor acknowledges and agrees that any and all products sold or shipped in relation to or on behalf of Solar Holdco Group will comply with all applicable product safety laws and standards, such as but not limited to product flammability, the US Consumer Product Safety Improvement Act of 2008 (“CPSIA”), the California Safe Drinking Water and Toxic Enforcement Act of 1986 (“California Proposition 65”), Washington’s Children’s Safe Product Act (“CSPA”), laws regulating the usage of PFAS in products. 

European Union Regulation No 2023/988 of the European Parliament  and of the Council of 10 May, 2023 on General product safety, Directive No 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment (“RoHS”), and European Union Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (“REACH”). It is Vendor’s responsibility to be aware of and to ensure that Vendor’s business practices and products comply with all applicable product safety standards and regulations.

Upon request, Vendor will provide or cooperate in providing Solar Holdco Group with any appropriate and valid product certification and/or lab test reports in a form acceptable to Solar Holdco Group. Any lab test report must not be older than 12 months, should be resubmitted annually via email to [email protected] and wherever applicable should explicitly refer to the end product (not its components) Vendor sells to Solar Holdco Group. Vendor agrees that in case it fails to send annual lab test reports to the email [email protected], Solar Holdco Group may perform the necessary lab test at its own discretion and charge the costs associated with the test to the Vendor.

All Vendors supplying the below listed goods to Solar Holdco Group are obligated to provide a General Conformity Certificate (“GCC”):

• general wearing apparel for adults conforming to 16 CFR Part 1610;
• shower curtains made of vinyl plastic films;
• rugs and carpets;
• magnets conforming to 16 CFR 1262;
• metal-cored candlewicks;
• button cells and coin batteries;
• cloth masks for adults conforming to FFA.

Furthermore, all Vendors supplying children’s products to Solar Holdco Group are obligated to provide a Children’s Product Certificate (“CPC”). Such certificates shall be substantiated by test results obtained from a CPSC-accepted laboratory, and shall be submitted on an annual basis via email to [email protected].

Learn more about types of product certification and lab test reports Solar Holdco Group requires and accepts for various product categories below. Some specific product categories might not be mentioned herein, and in order to understand applicable requirements for those, Vendors must reach out to their point of contact at Solar Holdco Group.

a) General Wearing Apparel for Adults (including swimwear/underwear)

Requirements for Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf to North America locations (US, Canada and Mexico) 

While clothing items aren’t typically considered “high risk” products, flammability issues are one of the main risks for this product category, thus, for all adult use apparel products and fabrics intended for use in apparel we require Flammability test to show the compliance with USA 16 CFR Part 1610. Any product or fabric tested according to this requirement must have Class 1 flammability rating. Products that consist of (i) plain surface fabrics, regardless of fiber content, weighing 2.6 oz. or more per square yard; or (ii) plain and raised surface fabrics made 100% of acrylic, modacrylic, nylon, olefin, polyester, wool, or any combination of these aforementioned fibers, regardless of weight; can be exempt from this requirement, meaning that Vendor can submit a written statement signed by authorized representative of the Vendor that the product is exempt from flammability testing and provide a reference to the relevant type of the exemption. 

In addition to the aforementioned, if the product or fabric is made of PVC, PU, neoprene or other plastic materials, then we also require testing for lead (permitted max. limit: 90ppm) and phthalates  (DEHP, BBP, DBP, DINP, DnHP and DIDP) (permitted max. limit: 1000ppm) to show the compliance with California Proposition 65 regulations. 

If the product fabric is treated with flame retardant, we require testing for deca-BDE and phenol PIP, as it is prohibited to use both of the chemicals in the production of the product.

Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf to European locations only can submit a valid OEKO-TEX® Standard 100 Certification issued for this product. If no OEKO-TEX® Standard 100 Certification is available then Vendor should show the product compliance with the following REACH or EU standards:

• Dyes content – to comply with REACH standards EN 14362-1 (Textiles) and EN 14362-2 (Polyester) which require that azo dyes in a product shall not exceed 30 ppm; and
• Formaldehyde in Textiles – to comply with (EU)2018/1513 BS EN ISO 14184-1:2011 which requires that if the product has a formaldehyde content, the limit should not exceed 300 mg/kg.

Products classified as Personal Protective Equipment (PPE) under EU Regulation 2016/425 must comply with specific requirements. This includes products with Ultraviolet Protection Factor (UPF) ratings, such as UPF 50+ apparel, which are considered Category I PPE. For such products supplied to the Solar Holdco Group, the Vendor must provide the following as evidence of compliance before they can be offered for sale in the EU:

• CE Marking on labels (See additional information in Section “Labelling requirements” below);
• Signed Declaration of Conformity (DoC) for Regulation (EU) 2016/425;
• Valid CE Certificate issued by a notified body;
• Relevant test reports according to the applicable European standards for the PPE category; For UPF-rated products (e.g., UPF 50+ rash guards), this includes, but is not limited to, testing according to EN 13758-1 and EN 13758-2.

The Vendor is solely responsible for determining if their products are classified as EU PPE and for providing Solar Holdro Group all necessary compliance documentation.

See additional information that might apply to products from this category in Section “California Proposition 65” below.

b) Apparel Intended for Children 12 years of age or younger

Requirements for Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf to North America locations (US, Canada and Mexico)

Children’s products, including apparel, accessories, etc. require third party test reports from an accredited U.S. Consumer Product Safety Commission (“CPSC”) lab (list of CPSC accredited labs is available here: https://www.cpsc.gov/cgi-bin/labsearch/) including but not limited to:

• testing for flammability (must have Class 1 flammability rating);
• testing for lead in substrate and coating (must not contain more than 90 ppm of lead in in paint or any similar surface coatings to comply with US 16 CFR §1303 and 100 ppm of total lead content in accessible parts to comply with US CPSIA Section 101); 
• testing for total cadmium content (must not contain more than 40ppm cadmium); and
• testing for phthalates (must not contain more than 0.1% concentration of each of these phthalates  DEHP, DBP, BBP, DINP, DIBP, DPENP, DHEXP and DCHP per CPSIA/16 CFR 1307.  Relevant for such child care articles as children’s sleepwear, infant and toddler bottles, sippy cups, utensils, bibs, pacifiers, and teethers. Testing is not necessary for materials that are known not to contain phthalates, for example, untreated/unfinished wood; metal; natural fibers (cotton, wool, etc.); paper; and natural latex and mineral products).

In addition to aforementioned, Vendors must ensure that all products intended for children comply with US 16 CFR §1500 and shall not exhibit non-functional sharp points, sharp edges, and small parts.

If the upper outerwear apparel item (e.g. jacket, hoodie or sweatshirt) has drawstrings in their hood or neck, then it might be considered as a substantial product hazard that might present a strangulation risk to the children according to US 16 CFR Part 1120, thus the Vendor should submit a testing that shows such product complies with the requirements of ASTM F 1816 Drawstrings on Children’s Upper Outerwear².

In case the apparel item might be considered as a sleepwear or loungewear (e.g. onesies, bodysuits, pajamas, etc.), then the Vendor must provide testing that shows compliance with:

• US 16 CFR Part 1615 for children’s sleepwear sized above 9 months and up to 6X, or
• 16 CFR Part 1616 for children’s sleepwear sized 7 through 14.

Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf to European locations only should show the product compliance with the following EU standards:

• Formaldehyde in Textiles – to comply with (EU)2018/1513 BS EN ISO 14184-1:2011 which requires that if the baby product (children of 3 years or younger) has a formaldehyde content, the limit should not exceed 20 ppm; for other children products the limit for direct skin-contact products should not exceed 75 ppm, whereas for non-direct skin contact products the limit is up to 120 ppm;
• Cords and Drawstrings on Children’s Clothing – any product that contains a drawstring must comply with EN 14682 requirement³;
• Flammability – children’s clothing must comply with BS EN 14878:2007 which requires Class A flammability for general children’s clothing and Class B flammability for children’s pajamas.
• Security of attached components – if the children’s clothing contains any attached components, Vendor must show compliance with the following standards: CEN/TS 17394-1 for attached components to infants’ clothing; CEN/TS 17394-2 for buttons; CEN/TS 17394-3 for metal mechanically applied press fasteners; and CEN/TS 17394-4 for components except buttons and metal mechanically applied press fasteners.

For Children’s apparel classified as EU PPE (e.g., UPF 50+) the Vendors must provide CE marking (see Section “Labeling requirements” below), a signed Declaration of Conformity for Regulation (EU) 2016/425, a valid CE Certificate, and relevant test reports (including EN 13758-1 & EN 13758-2 for UPF). Vendors are responsible for PPE classification and providing all compliance documents to Solar Holdo Group.

c) Accessories (bags, hats, socks, phone cases, jewelry, etc.)

Requirements for Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf to North America locations (US, Canada and Mexico)

Accessories made of textile (e.g. bags, socks, etc.) should either have a Flammability test to show the compliance with US 16 CFR Part 1610⁴, or the Vendor can submit a written statement signed by an authorized representative that the product is exempt from flammability testing and provide a reference to the relevant type of the exemption (specific flammability requirements to baby hats and diaper bags described below).

For all adult hats the Vendor must be able to prove the product’s compliance⁵ with (for more information see Section “California Proposition 65” below):

• California Proposition 65 For Hats Consent Judgment No. RG-641740-Total Lead (Pb) Content;
• California Proposition 65 For Hats Consent Judgment No.CIV-1103513 – Phthalate Content.

If the hat contains foam or other flame retardant materials, then Vendor must also prove that the product complies with polybrominated diphenyl ethers (PBDEs) chemical content limits⁶.

Baby hats made primarily of knitted or crocheted fabric (≥80%, e.g., Cotton, polyester) are classified as textile products and must comply with the Federal Hazardous Substances Act (FHSA) and the Consumer Product Safety Act (CPSIA). Therefore, for these baby hats the Vendor must ensure compliance with: 

• Flammability of Clothing test (16 CFR 1610, testing non-exempt fabrics only).
• Class 1 hats (only for hats that provide a covering for the neck, face, or shoulders when worn by an individual): It is recommended to avoid using cords that can be wound around the neck or head⁷.

Hats for children under 7 years old must not have drawstrings, functional, or decorative straps allowed (including shoulder straps, neck straps), and the length of any fixed decoration (like a bow) and the circumference of any loop must be ≤75mm.

For diaper bags the Vendor must provide solids flammability tests to show compliance with 16 CFR 1500.3(c)(6)(vi) and 16 CFR 1500.44 (testing shall not exceed the maximum allowable limit of no greater than 0.1 inches per second).

For travel accessories (such as suitcases, mirrors, umbrellas, etc.) the Vendor must ensure compliance with general goods requirements. If a travel accessory contains textile material(s), textile requirements are applicable (excluding requirements for wearable/apparels). If a travel accessories contain electronic components, in addition to the above, the Vendor must ensure electronic requirement compliance (for more information see Section “Electronic devices” below).

For accessories made of or containing composite wood (including hardwood plywood with combination or veneer cores, particleboard, and medium-density fiberboard) the Vendor must provide testing for 40 CFR 770.45 for EPA formaldehyde emission.

Accessories made of plastic (including phone cases) must not contain any Bisphenol A (BPA) and Bisphenol S (BPS). Vendors must provide testing demonstrating no detection of BPA and BPS, or that any detected amounts fall below the maximum allowable dosage levels stated in the testing document.

For all phone cases (whether made of plastic or other materials) the Vendor must ensure General goods compliance, and that the product does not contain harmful substances such as lead, mercury, or phthalates as per the Toxic Substances Control Act (TSCA).

In addition to the above, biodegradable and silicone phone cases must comply with California Proposition 65  (see Section “California Proposition 65” below), If the target audience is children, the product must also comply with chemical requirements as per ASTM F963 standard. Furthermore, if the material claims biodegradability, manufacturers must ensure it meets specific environmental claims criteria as per Federal Trade Commission (FTC) Green Guides.

All adult jewelry sold by Vendor to Solar Holdco must be made from only one or more of the specified materials⁸, and must comply with California Proposition 65 (for more information see Section “California Proposition 65” below). No jewelry or its parts can contain any restricted heavy metals/substances (e.g. lead, nickel, cadmium, mercury and phthalates) above permitted limits⁹. 

In case the Vendor provides any jewelry designed or intended primarily for use by children 12 and under (e.g. a bracelet, brooch, tiara, hair accessories, etc.), Vendor must ensure that its products are compliant with all applicable and mandatory total lead and cadmium content requirements for children jewelry, as well as all ASTM substance restrictions and standards, for example, by providing a product testing for ASTM Standard F2923 that is deemed as passed.

Requirements for Vendors that supply Solar Holdco Group in or fulfill orders on Solar Holdco Group’s behalf to European (EU) locations

Vendors supplying goods to or on behalf of Solar Holdco in European locations must comply with the following key regulations: 1907/2006/EC (REACH) and its amendments, the General Product Safety Regulation (GPSR) (EU) 2023/988, and Regulation (EU) 2019/1021 (POPs) (specific requirements apply to baby hats and diaper bags described below).

Baby hats made primarily of textile (≥80%) are classified as textiles and the Vendor must ensure compliance with both the Special safety Standards for baby products and the General Textile Regulations. It is recommended to avoid using cords on baby hats that can be wound around the neck or head¹⁰.

Hats for children under 7 years old must not have drawstrings, functional, or decorative straps, and the length of any fixed decoration and the circumference of any loop must be ≤75mm.

Diaper bags are classified as textile if it’s made of textile fibers accounting for ≥80% of its weight or contains indivisible textile components. In such a case, the Vendor must ensure compliance with EU Textile Labelling Regulation (EU) No 1007/2011 (for more information see Section “Labelling requirements” below).

For travel accessories (suitcases, mirrors, umbrellas, etc.) the Vendor must ensure compliance with  general goods requirements. Furthermore, if a travel accessory contains textile materials, the relevant textile requirements apply, excluding those specific to wearable apparels.

For accessories containing wood, the Vendor must ensure compliance with EN 717-3 for formaldehyde release, with a recommended release limit of 80 ppm max.

For accessories made of plastic (such as phone cases) and biodegradable and silicone phone cases, the Vendor must ensure compliance with the EU general requirements as mentioned above.

All adult jewelry sold by Vendor to Solar Holdco must be made from only one or more of the specified materials¹¹.  For jewelry including materials like wood, textile, and/or leather components, the following formaldehyde standards must be complied with: 

• EN 717-3 for wood, 
• ISO 14184-1 for textiles, and 
• ISO 17226 for leather.

d) Food contact products (bottles, tumblers, mugs, etc.)

Requirements for Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf to North America locations (US, Canada and Mexico)

Food contact materials, such as stainless steel bottles, cups/mugs, baby bottles, and other drinkware/foodware items (including lids, cups, etc.) are subject to compliance with FDA Title 21 Code of Federal Regulations on Food contact materials. Vendor understands and agrees that:

• For plastic products the Vendor must ensure compliance with the applicable sections of FDA Title 21 Code of Federal Regulations (CFR) Part 177, such as FDA 21 CFR § 177.1520¹² for olefin polymers or other relevant provisions based on the specific plastic used. Furthermore, none of the product’s components should contain a detectable level of Bisphenol A (BPA) and Bisphenol S (BPS). Therefore, if any plastic components or materials are included in the product, the Vendor must provide testing where no BPA and BPS has been detected, or if detected, the amount falls below the maximum allowable dosage level quoted in the testing document. All product components, including base polymers, additives, and colorants, must be authorized for food contact use under the appropriate CFR sections, a Food Contact Notification (FCN), or be Generally Recognized As Safe (GRAS). Materials must also be suitable for the intended food types and conditions of use as defined by FDA guidelines.

• For stainless steel products the Vendor must ensure that stainless steel used in food contact materials complies with FDA regulations, including 21 CFR§174.5, which requires that substances used in food contact articles be of suitable purity. Furthermore, the Vendor must provide testing that shows compliance with FDA GRAS stainless steel composition (chromium content must be 16% or more). If the chromium content is between 11.5% to 16%, then the Vendor must provide a Leachable heavy metal test¹³ to confirm that no harmful substances migrate into food under intended use conditions.

• In case any part of the product is made of silicone – Vendor must provide testing to show compliance with FDA 21 CFR § 177.1210¹⁴, whereas if any part of the product is made of rubber, then the Vendor must provide testing showing compliance with FDA 21 CFR § 177.2600¹⁵. In addition, if the vendor must provide proof of compliance with any listed chemicals under Proposition 65, such as formaldehyde, benzene, toluene, styrene, or 1,3-butadiene, the vendor must ensure that exposure levels are below Safe Harbor limits (NSRL/MADL) that are applicable to the product, or provide a clear and reasonable warning in accordance with California Health & Safety Code § 25249.6.

• For glass, ceramic, or enamel products (e.g., mugs, glasses, cutting boards, etc.), the Vendor must provide testing demonstrating compliance with the extractable lead and cadmium limits set forth by the FDA and California Proposition 65. More specifically:
  • The ceramic materials used for the body or internal parts of the product must not contain lead or cadmium exceeding 0.5 ppm.
  • If the product has a decorated 20 mm lip and rim area (e.g., with silver, gold, or other material), the limit for leachable lead in this area is 4 ppm, and for cadmium is 0.4 ppm, to demonstrate compliance with ASTM C927-99 standards.

For mugs (or other glass, ceramic, or enamel products) with heat-reactive designs, the vendor must ensure compliance with FDA food contact regulations (21 CFR Parts 175-178) if the coating is intended to, or may, touch food. If a mug is designed or intended primarily for children’s use, testing for total lead content (≤100 ppm) and total phthalate content (≤1000 ppm) is required under the CPSIA. Furthermore, the Vendor must ensure compliance with Proposition 65, and provide testing with the applicable substances known to cause cancer or reproductive harm and provide clear and reasonable warnings if the exposure levels exceed the established safe harbor limits.

For Glass Cutting Boards in addition to the above prescribed requirements, depending on the design and the intended use, mechanical and thermal shock testing may be applicable and thus required from the vendor. Furthermore, the Vendor must ensure that cookware or a cookware component does not contain lead or lead compounds at a level of more than 5 ppm, as established by US State Law, Revised Code of Washington (RCW), Chapter 70A.565.020 (HB 1551), and complies with the applicable labelling requirements (for more information see Section “Labelling requirements” below).

• For products made of wood (e.g., wood cutting boards) the Vendor must provide testing that shows that the product complies with Formaldehyde limit requirements set in 40 CFR 770.10, 40 CFR 770.17, and 40 CFR 770.18 – (i) for hardwood plywood made with a veneer  core or a composite core, 0.05 ppm; (ii) for medium-density fiberboard, 0.11 ppm; (iii) for thin  medium-density fiberboard, 0.13 ppm; (iv) for particleboard, 0.09 ppm.). If composite wood is used, the vendor must provide documentation of certification by an EPA-approved Third-Party Certifier in accordance with 40 CFR § 770.15. If the product is treated with preservatives, it must comply with 21 CFR § 178.3800, ensuring pentachlorophenol (PCP) content does not exceed 50 ppm. Additionally, wood and wood wicker may only be used as food contact surfaces if sealed and finished to be smooth, nonabsorbent, and easily cleanable, in accordance with FDA Food Code 2022, Section 4-101.19.

• For products made out of Acrylic (e.g., acrylic serving trays) the vendor must provide  testing to ensure compliance with FDA 21 CFR § 177.1010 for acrylic and modified acrylic plastics intended for food contact use. If the product includes any printed, painted, or coated surfaces that come into contact with food, the materials used must also comply with applicable FDA regulations under 21 CFR Parts 175–178.
• For products like ice buckets the vendor must provide testing to demonstrate compliance with FDA 21 CFR § 177.1640 for use in food contact applications. If the product includes any printed, painted, or decorated food-contact surfaces, those components must also comply with applicable FDA regulations under 21 CFR Parts 175–178.

• For bottle openers, if the opener is designed to or may come into direct contact with the bottle or cork, the vendor must confirm that it is made of food-grade stainless steel (such as 304 or 316) and provide test reports demonstrating that any coated or painted areas comply with 16 CFR Part 1303, not exceeding 90 ppm lead.

• For oven mitts (classified as kitchenware) the Vendor must provide testing for thermal insulation and heat resistance to show compliance with ASTM F1060-21. Additionally, oven mitts must comply with CPSIA requirements for lead (≤ 100 ppm) and phthalates (≤ 1000 ppm). If the mitts are printed, scented, or treated with flame retardants, testing for California Proposition 65-listed substances is also required.

Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf with food contact products to European locations should show the product compliance with the EU requirements, including Regulation (EC) No. 1935/2004 on materials and articles intended to come into contact with food, Regulation (EU) No. 10/2011 for plastic food contact materials, Directive 84/500/EEC and Commission Directive 2005/31/EC for ceramic and glass materials, the General Product Safety Directive (GPSD) 2001/95/EC, and the REACH Regulation (EC) No. 1907/2006. Vendors must also adhere to Regulation (EU) 2024/3190, which prohibits the use of BPA and its salts in all food contact materials.

• For food contact plastic the Vendor must ensure compliance with applicable legislation, including Regulation (EC) No. 1935/2004, Commission Regulation (EU) No. 10/2011, and Commission Regulation (EU) 2024/3190. Products must be tested for the following heavy metals with specified migration limits:  i) Aluminum (max. limit allowed – 1mg/kg); ii) Antimony (max. limit allowed – 0.04 mg/kg); iii) Arsenic (should not be detected); iv) Barium (max. limit allowed – 1 mg/kg); v) Cadmium (should not be detected); vi) Chromium (should not be detected); vii) Cobalt (max. limit allowed – 0.05 mg/kg); viii) Copper (max. limit allowed – 5 mg/kg); ix) Iron (max. limit allowed – 48 mg/kg); x) Lead (should not be detected); xi) Lithium (max. limit allowed – 0.6 mg/kg); xii) Manganese (max. limit allowed – 0.6 mg/kg); xiii) Mercury (should not be detected); xiv) Nickel (max. limit allowed – 0.02 mg/kg); xv) Zinc (max. limit allowed – 5 mg/kg); and xvi) Europium/Gadolinium/Lanthanum/Terbium (max. limit allowed for sum of all these 4 elements – 0.05 mg/kg).

If the product is made of or contains PVC, the Vendor must demonstrate that DEHCH (di(2-ethylhexyl) cyclohexane-1,4-dicarboxylate) migration does not exceed 0.05 mg/kg, in accordance with the Union List under EU 10/2011. Additionally, phthalate content must comply with the latest restrictions under the same regulation: DBP (dibutyl phthalate) ≤ 0.05% and BBP (benzyl butyl phthalate) ≤ 0.1%. As mandated by Regulation (EU) 2024/3190, the use of Bisphenol A (BPA) and its salts is fully prohibited in all food contact materials as of December 31, 2024; therefore, products placed on the EU market from this date must not contain BPA, and the previous migration limit of 0.01 mg/kg (10 ppb) no longer applies. Vendors must also provide and ensure that a valid Declaration of Compliance (DoC) is available in accordance with Article 15 of EU 10/2011, and that migration testing is carried out under the latest conditions as specified in Commission Regulation (EU) 2023/1442.

• For food contact glass and ceramic products (e.g., mugs, glasses, etc.) the Vendor must ensure compliance Directive 84/500/EEC (for ceramic and glass articles intended to come into contact with foodstuffs) and Regulation (EC) No 1935/2004 (on materials and articles intended to come into contact with food). Testing for extractable lead and cadmium limits as per ISO 6486-2 standards (Lead: 4 mg/L and Cadmium: 0.3 mg/L).

For mugs (or other glass, ceramic or enamel products) with heat-reactive designs the Vendor must ensure compliance with EU food contact material regulations. This specifically involves considering the requirements of REACH (Regulation (EC) No 1907/2006) Annex XVII (restrictions on certain dangerous substances) and Substances of Very High Concern (SVHC). Furthermore, The Vendor must provide a valid Declaration of Compliance (DoC) for food contact materials, including the mugs.

For Glass Cutting Boards, the Vendor must ensure that the glass boards comply with the General Product Safety Regulation (GPSR) (EU) 2023/988). This includes ensuring the product is safe for its intended use and reasonably foreseeable misuse. Compliance with specific standards such as EN 12983-1 (cutting boards for domestic use) is also required. Furthermore, the Vendor must provide testing for specific migration of heavy metals (e.g., lead, cadmium, and arsenic) in accordance with Directive 84/500/EEC and the related ISO 6486-2 standards.

• For products made of wood (e.g., wood cutting boards) the Vendor must ensure that the product complies with EN 717-3 standard, and EC Regulation No.1935/2004 regarding i) Formaldehyde content (for wooden articles, formaldehyde released should not exceed 80 ppm, for food contact bamboo formaldehyde must not exceed 15 mg/kg, and ii) Pentachlorophenol (PCP) content in food contact bamboo and wood cannot exceed 5 ppm.

• Plastic food contact materials containing bamboo or other plant-based additives, must only use substances authorized under Regulation (EU) No. 10/2011. The use of unauthorized additives renders the product non-compliant and illegal in the EU. Products made of 100% natural bamboo are not covered by EU 10/2011 but must comply with Regulation (EC) No. 1935/2004 and relevant chemical limits under REACH.

e) Home textiles and products (blankets, pillow cases, coasters, etc.)

Requirements for Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf to North America locations (US, Canada and Mexico)

For general-use bed products (e.g., blankets, pillowcases, etc.) the Vendor must ensure compliance with mandatory regulations and confirm that the products do not contain restricted substances. At a minimum, vendors must provide testing to verify that the products meet the following limits: lead content must not exceed 100 ppm in accordance with the Consumer Product Safety Improvement Act (CPSIA), cadmium content must not exceed 75 ppm in line with CPSC guidelines, and azo dyes must not release banned amines, as outlined in 16 CFR Part 1500. Additionally, formaldehyde content must not exceed 75 ppm, in compliance with AATCC TM112. For synthetic fabrics (e.g. polyester, nylon and spandex), the Vendor must ensure that the products contain no detectable levels of bisphenol A (BPA) or bisphenol S (BPS). The Vendor must also ensure that the products comply with California Proposition 65 if sold in California, ensuring proper testing for chemicals and providing appropriate warnings if any listed chemicals are present.

For bed products categorized as baby products (e.g., baby swaddle blankets, toddler blankets, soft fleece baby blankets, baby bibs, and baby changing pad covers) the Vendor must ensure compliance with the Consumer Product Safety Improvement Act (CPSIA). This includes ensuring the products meet mandatory requirements such as lead content not exceeding 100 ppm, phthalates content not exceeding 1000 ppm, and adherence to Federal Flammability Standards for children’s sleepwear (16 CFR Part 1615/1616). Additionally, any synthetic fabrics (e.g., polyester, nylon, and spandex) must be free of detectable levels of bisphenol A (BPA) and bisphenol S (BPS). Vendors must provide testing results to confirm compliance with these regulations and ensure that the products do not contain any restricted substances.

Infant cushions and pillows which meet all of the following criteria are banned in accordance with 16 CFR 1500.18 – i) has a flexible fabric covering; ii) is loosely filled with a granular material, including but not limited to, polystyrene beads or pellets; iii) is easily flattened; iv) is capable of conforming to the body or face of an infant and v) is intended or promoted for the use by children under one year of age.

For other home products (coasters, hanging posters, etc.) that are made of composite wood (e.g. hardwood plywood, particleboard, medium-density fiberboard, etc.), Vendors must prove that:

• the wood is not sourced from China (or if it is, that the Vendor can be found on the list of Approved Wooden Handicraft Manufacturers available at: Chinese Wood Handicraft Industry); and 
• the products are compliant with Formaldehyde Standards (ASTM E1333-14 and ASTM E 1333-96) for Composite Wood Products (US 40 CFR Section 770)¹⁶.

If such other home products (coasters, hanging posters, etc.) are made of solid wood, Vendors must prove that the moisture content of solid wood is within 8% – 12%.

For any home products that contain magnet components the Vendor must ensure compliance with US 16 CFR §1262 that requires magnets to have a flux index of 50 kG2 mm2 or less.

For pens the Vendor must ensure that the product complies with BS 7272-1 and BS 7272-2 requirements for pen cap safety. For pens containing ink, Vendor must provide Toxicological Risk Assessment (TRA) for the ink and chemical formulation to process evaluation to comply with 16 CFR 1500.3 requirements. 

Inks must comply with the chemical limits set in 16 CFR 1500.14(b)(1) to (5)¹⁷. Pens must comply with art material requirements set forth in 16 CFR 1500.14(b)(8) and ASTM D4236. Pen physical safety testing must be performed in accordance with 16 CFR 1500. 48 and 16 CFR 1500. 49 standards. Pen flammability shall not exceed the maximum allowable limit of no greater than 0.1 inches per second. 

If the pen is intended or marketed for use by children, the Vendor must ensure that the product does not contain more than 90 ppm of lead in in paint or any similar surface coatings to comply with US 16 CFR §1303 and 100 ppm of total lead content in accessible parts to comply with US CPSIA Section 101).

Paper and cardboard products (e.g. greeting cards and standees) are generally excluded from third-party testing for lead content if they are printed on paper or cardboard, with inks or toners, and bound and finished using a conventional method. However, if the product is intended or marketed for use by children, it must comply with lead content testing to ensure it meets CPSIA requirements.

For all shower curtains the Vendor must ensure compliance with mandatory regulations, including CPSC regulations for lead (16 CFR Part 1303), cadmium (16 CFR Part 1303), phthalates (CPSIA – 16 CFR Part 1307), mercury (40 CFR Part 745), and PFAS testing (based on state and federal guidelines). PVC shower curtains are prohibited due to their toxicity under the Toxic Substances Control Act (TSCA).

In addition to the above, for vinyl plastic film shower curtains the Vendor must ensure compliance with 16 CFR 1611 for flammability. The average burn rates from the five specimens in either direction cannot exceed a burn rate of 1.2 inches per second. 

For rugs, carpets and mats (inside and outside use) the Vendors must ensure compliance with CPSIA regulations for lead (16 CFR Part 1303) and phthalates (16 CFR Part 1307), as well as flammability standards under Flammable Fabrics Act (FFA) – 15 U.S.C. 1191.16 CFR Parts 1630 and 1631. Furthermore, products must meet formaldehyde limits per CPSIA Section 108. If the product is intended or marketed for use by children, additional lead and phthalate testing is required. If treated with chemicals or containing PVC, the Venodor must ensure compliance with EPA chemical safety standards.

For car accessories (e.g., car magnets, bumper stickers, metal license plate frames, vanity plates, soapstone car coasters, car air fresheners, car mats, car seat covers, and car sun shades) the Vendor must ensure compliance with these requirements:

For all candles the Vendor must ensure that the product does not contain metal cored wick exceeding 0.06% (600 ppm) and total lead as per 16 CFR 1500.17(a)(13) requirements. Wicks used in candles must be safe and prevent excessive flame height or fire hazards as per ASTM F2417. Candles shall not be marketed or to be used as Pesticidal products. 

For aluminium ornaments the Vendor must ensure compliance with jewelry requirements (non-precious metals) described in the section “ c) Accessories”.

For wall clocks (containing batteries) the Vendor must ensure compliance with these requirements:

Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf to European locations 

For general-use bed products (e.g., blankets, pillowcases, etc.) the Vendor must ensure compliance with Regulation (EC) No. 1907/2006 (REACH), Regulation (EC) No. 1935/2004, and EU Regulation No. 10/2011. This includes providing test reports to confirm that the products do not exceed the following limits: lead (max. 0.1%), cadmium (max. 0.01%), azo dyes (banned amines), and formaldehyde (max. 30 ppm). 

For bed products categorized as baby products (e.g., baby swaddle blankets, toddler blankets, soft fleece baby blankets, baby bibs, and baby changing pad covers) the Vendor must comply with EU Regulation No. 1907/2006 (REACH), Regulation (EC) No. 1935/2004, and EN 71-3 (Toy Safety) standards. This includes providing testing reports that confirm the products meet the limits for lead (max. 40 ppm), phthalates (max. 0.1%), and any other (applicable) restricted chemicals. 

For shower curtains the Vendor must ensure compliance with REACH Regulation (EC) No. 1907/2006, including testing for Formaldehyde, Phthalates, Flame Retardants, Titanium Dioxide (TiO2), Total Lead, Nickel Release, and VOC Emissions according to Annex XVII requirements. PVC shower curtains are prohibited due to toxicity under REACH. 

For rugs, carpets and mats (inside and outside use) the Vendor must ensure compliance with EU REACH Regulation (1907/2006) and Directive 76/769/EEC for restricted substances, including testing for lead, cadmium, phthalates, and formaldehyde. Furthermore, the products must be tested for fire resistance to prevent quick ignition when exposed to fire as per EN 1307 standard.

For infant cushions and pillows the Vendor must ensure compliance with EU Regulation (EC) No. 1907/2006 (REACH) and Directive 2001/95/EC (GPSD). This includes providing test reports to confirm that infant cushions and pillows are in compliance with the relevant restrictions. Products that meet all of the following criteria are banned: i) flexible fabric covering, ii) loosely filled with granular material (e.g., polystyrene beads), iii) easily flattened, iv) capable of conforming to the body or face of an infant, and v) intended for children under one year of age.

For metal products – due to Council Decision (CFSP) 2022/2478 of 16 December 2022 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, any home products that contain metal components (e.g., metal signs) Vendors must assure that the products made of iron or steel are not originated from Russia by submitting the following documents: 

• mill test certificate (including name and address of facility where production took place, name of the country corresponding to the heat number, classification at subheading level of the product (six-digit code CN code), OR 
• statement or declaration by the exporter or manufacturer confirming that, after exercising due diligence, the imported product does not contain any Russian steel or iron;  other documents – invoices, delivery notes, supplier’s declarations, etc.

For pens the Vendor must provide: REACH compliant Safety data sheet (SDS), Toxicological Risk Assessment (TRA), and chemical formulation. The Vendor must also ensure compliance with requirements stated in BS 7272-1 and BS 7272-2.

For car accessories (e.g., car magnets, bumper stickers, metal license plate frames, vanity plates, soapstone car coasters, car air fresheners, car mats, car seat covers, and car sun shades) the Vendor must ensure compliance with these requirements:

For scented candles the Vendor must ensure that the chemical substances, mixtures and certain specific articles used meet all applicable requirements of classification specified in the Regulation (EC) No. 1272/2008 (CLP) and its amendments. All candles are prohibited from resembling foodstuff that can be likely to be confused with foodstuff due to its form, odour, colour, appearance, packaging, labelling, volume, size or other characteristics and might therefore be placed in the mouth, sucked or ingested by consumers, especially by children.

For aluminium ornaments the Vendor must ensure compliance with jewelry requirements (non-precious metals) described in the “c) Accessories (bags, hats, socks, phone cases, jewelry, etc.)”.

For wall clocks (containing batteries) the Vendor must ensure compliance with these requirements:

f) Cosmetic products (perfumes, toners, moisturizers, cleansers)

Requirements for Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf to North America locations (US, Canada and Mexico)

For cosmetic products, the Vendor must ensure that the product complies with the Federal Food, Drug, and Cosmetic Act (FD&C Act), the Modernization of Cosmetics Regulation Act (MoCRA) of 2022, FDA regulations and any other applicable US standards.

To ensure compliance, the product must have a safety report (MoCRA). A safety report can be obtained from experts qualified by scientific training and experience (any accredited laboratory). They must conclude from the available toxicological and other test data, chemical composition, and other pertinent information that the product is not injurious to consumers under conditions of customary use and reasonably foreseeable conditions of misuse.

No specific format is currently required; however, the final product and all ingredients must be cleared for safety for the specific application.

Even though neither the law nor FDA regulations require specific tests to demonstrate the safety of individual products or ingredients, the Vendor must show their compliance and confirm that there are no restricted substances found in the products. At minimum, Vendor must provide a safety report that shows the cosmetic products it sells do not contain more than permitted amounts:

• Controlled Substances (e-CFR, Title 21: Food and Drugs, PART 700—GENERAL, Subpart B – Requirements for Specific Cosmetic Products);
• Colorants (Title 21 of the Code of Federal Regulations Parts 73, 74, 81 and 82);
• Fragrance Allergens (MoCRA);
• Microbiological quality, Stability and Packaging (FD&C Act);
• Microbiological testing as per USP 61/62 and USP 51 for products containing water.
• California Proposition 65/California Safe Cosmetic Reporting.

Vendors that supply Solar Holdco Group in or fulfill orders on Solar Holdco Group’s behalf with products to European locations

For cosmetic products, the Vendor must ensure that the product (and its packaging ) complies with SVHC and other restricted substances under REACH Regulation (EC) No 1907/2006,  Regulation (EC) No 1223/2009 and any other applicable EU standards. To ensure compliance, the Vendor must provide a Cosmetic Product Safety Report (CPSR). The CPSR consists of a product safety assessment, which is done by the safety assessor (any accredited laboratory). The CPSR must include all applicable testing that applies to EU perfumes, such as:

• Microbiological Specifications and Preservative Challenge Testing – In some justified cases (e.g. alcohol content > 20%, products based on organic solvents, high/low-pH products), microbiological product testing is not necessary (ISO 29621).
• Separate microbiological testing for products containing water – Microbiological testing as per USP 61/62 and USP 51 is required for products containing water.
• Stability testing and Packaging material purity – Regulation (EC) No 1223/2009 requires Microbiological quality and Stability test results and information about packaging material to be included under Part A of CPSR.
• Heavy Metals – ‘technically avoidable levels’ (TALs) (Regulation (EC) No 1223/2009 of cosmetic products (European Commission 2009).
• Fragrance Allergens (Commission Regulation (EU) 2023/1545) – 81 Fragrance Allergens that must be listed in the Ingredient Listing in the following instances:
  • 0.01% for rinse-off products
  • 0.001% for leave-on products (perfumes are leave-on products).
• Cosmetic Ingredients, Prohibited and Restricted Substances – Regulation (EC) No 1223/2009 – ANNEX II to VI.

g) Toys (plush toys, electronic toys, collectibles, board games, etc.)

Requirements for Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf to North America locations (US, Canada and Mexico)

For all toys Vendor must provide testing reports for the following requirements:

For plush toys, Vendor must show compliance with all applicable 16 CFR 1250, ASTM F963 (ASTM F963-23, and ASTM F963-17), and CPSC requirements:

• Testing for flammability of textile fabric;
• Testing for stuffing cleanliness (Loose fillers for stuffed toys shall be free of objectionable matter when evaluated by visual inspection as specified in the standard);
• Testing for machine washable (Toys intended to be machine washable shall comply with all applicable requirements. If the toy is meant for spot cleaning only, this requirement does not apply).

For solid toys (e.g. action figures), Vendor must show compliance with flammability for solid toys (16 CFR Part 1500, ASTM F963, CPSC), lead (16 CFR Part 1303), soluble heavy metals (ASTM F963 § 4.3.5), phthalates, azo dyes, cadmium, nickel, polycylic aromatic hydrocarbons (PAHs) (California Proposition 65) requirements. 

For collectibles (with target audiences 12+ years) the Vendor must show compliance with general product safety and no unreasonable risk of injury (CPSA), lead in surface coatings (16 CFR Part 1303 – 90 ppm limit), and phthalates, azo dyes, cadmium, nickel, polycylic aromatic hydrocarbons (PAHs) (California Proposition 65) requirements. 

For toys that contain wood, Vendor must show compliance with physical safety hazards for wood products testing (16 CFR 1250; ASTM F963). Accessible surfaces and edges of wood used in toys shall be free of splinters before and after the use and abuse tests. If the toy contains composite wood must comply with 40 CFR 770.10 /17/18 for formaldehyde emission.

For toys and children’s products containing button or coin cell batteries, the Vendor must show compliance with 16 CFR part 1263 requirements for performance and labeling. A warning statement shall be included to notify consumers of the risk of injury and death of children 6 years old and younger from ingesting button cells. If the product contains zinc-air button cell or coin batteries then the product is exempt from the warning statement requirements. Moreover, all toys containing button cell or coin batteries shall comply with ANSI/UL 4200A, Standard for Safety for Products Incorporating Button Batteries or Coin Cell Batteries. Button cell batteries must not have Mercury content detected (detection limit: 1 ppm).

Any children’s products and toys containing batteries larger than button cell shall not contain intentionally added Mercury (The Mercury-Containing and Rechargeable Battery Management Act – Public Law 104-142 | US EPA). Furthermore, battery-operated toys shall meet the ASTM F963 section 4.25 requirements related to Battery-operated toys.

For electric toys, Vendor must show compliance with ASTM F963 and 16 CFR 1505. Electrical toys with an operating frequency greater than 9 kHz for AC, or battery-operated product toys with an operating frequency greater than 1.705 MHz shall have a valid FCC Report and meet all applicable FCC Marking and labeling requirements (47 CFR Part 15)  (see additional information in Section “Labelling requirements” below).

For board games, the Vendor must be able to show compliance with ASTM F963 standard requirements for sharp edges and small parts, flammability, soluble heavy metal, and lead (ASTM F963 and California Proposition 65) and phthalates (California Proposition 65).  

Balloons that are intended and marketed for use for children aged 12 and under, are classified as ‌toys; therefore, the Vendor must ensure compliance with toy safety standards (ASTM F963), chemical Limits (CPSIA), and warning label requirements (see additional information in Section “Labelling requirements” below).

For regular balloons that are intended for adult use, it must follow the applicable labelling requirements (see additional information in Section “Labelling requirements” below). If the balloon is likely to be in contact with children (such as in mixed-use scenarios), it must comply with the ‌CPSIA Act ‘s ban or restriction on phthalates (such as DEHP, DBP, etc.)

Vendors that supply Solar Holdco Group or fulfill orders on Solar Holdco Group’s behalf with toy products to European locations

All toys, that are: i) intended for children of the age of 14 and below; and ii) intended for selling in the European market, must carry a CE mark²¹. If the toy includes batteries, the CE marking shall be affixed visibly, legibly, and indelibly to the battery (for more information see Section “Labeling requirements” below).

For all toys Vendor must provide valid testing reports for the following requirements:

If a toy contains foam and is intended for use by children under 36 months or other toy products that contain foam are intended to be placed in the mouth, then the Vendor must prove that the product complies with Directive 2009/48/EC:

• Formamide – Cut-Off Limit testing (shall not contain formamide exceeding 200 mg/kg (cut-off limit based on content));
• Formamide Emission testing –  If the above formamide content testing exceeds 200 mg/kg, then the emission of formamide must be carried out (shall not exceed the emission limit of 20 μg/m3).

For children’s products with electronic components (e.g., electronic toys such as songbooks with sound functions, remote-controlled cars, toy computers, and electrical experimental sets), the Vendor must provide testing demonstrating compliance with RoHS Directive 2011/65 requirements. These requirements stipulate that the chemicals outlined below should not exceed the limit of ≤ 0.01%:

• Lead
• Mercury
• Cadmium
• Hexavalent Chromium
• Polybrominated biphenyls (PBB)
• Polybrominated diphenyl ethers (PBDE)
• Bis(2-ethylhexyl) phthalate (DEHP)
• Butyl benzyl phthalate (BBP)
• Dibutyl phthalate (DBP)
• Diisobutyl phthalate (DIBP) (RoHS Directive – 2011/65).

For battery-operated toys and electrical toys (B/O electronic toys, B/O motorized electronic toys, simple toys, transformer toys with or without electronic circuits), the Vendor must show compliance with EMC testing and all applicable requirements of the Electromagnetic Compatibility Directive (Directive – 2014/30). 

If the electronic toy contains batteries, then the Vendor must also prove that the product complies with all applicable requirements set out in Directive 2009/48/EC, EN IEC 62115. Furthermore, the Vendor must show the product’s compliance with Heavy metal content testing in batteries to comply with Regulation (EU) 2023/1542 which requires that if electronic toys contain batteries, the batteries must be tested for:  i) Mercury (limit ≤ 0.0005% by weight); ii) Cadmium (limit ≤ 0.002% by weight); and iii) Lead (limit ≤ 0.002% by weight) (EFFECTIVE DATE: Aug 18, 2024, effective date for portable zinc-air button cells: Aug 18, 2028).

If a toy product’s batteries contain more than 0.002% cadmium or more than 0.004% lead, the batteries shall comply with Chemical Symbol for Batteries (for more information see Section “Labeling requirements” below).

If a toy or a children’s product is intentionally emitting radio waves, Vendors must show compliance with R&TTE testing and follow all applicable Radio Equipment Directive (RED) – European Commission requirements.

For toys containing a Laser and Light-emitting Diode (LED), the Vendor must show compliance with all applicable requirements specified in Annex E of EN IEC 62115.

For solid toys (e.g. action figures²³) Vendor must show compliance with solid toy flammability (EN 71 Part 2), heavy metal (EN 71 Part 3), phthalates (REACH Annex XVII entries 51 and 52), azo dyes, cadmium, polycyclic aromatic hydrocarbons (PAHs) (REACH Annex XVII) requirements. 

For collectibles (with target audiences 12+ years), Vendor must show compliance with the General Product Safety Regulation (GPSR) (EU) 2023/988, and relevant restrictions under REACH (Regulation (EC) No 1907/2006) Annex XVII:  

• Phthalates (REACH Annex XVII, Entry 51 (expanded to all articles) restricts DEHP, DBP, BBP, and DIBP to 0.1% by weight in plasticized materials).
• Azo Dyes (REACH Annex XVII, Entry 43 restrictions for textiles and leather).
• Cadmium (REACH Annex XVII, Entry 23 restrictions (e.g., in plastics, pigments)).
• Polycyclic Aromatic Hydrocarbons (PAHs) (REACH Annex XVII, Entry 50 restrictions in rubber and plastic components with skin/oral contact).

For board games, according to Directive 2009/48/EC, the Vendor must show compliance with sharp edge and small part, flammability, and heavy metal testing requirements.

Balloons that are intended and marketed for use for children aged 12 and under, are classified as toys; therefore, the Vendor must ensure compliance with Toy safety directive 2009/48/EC, with reference EN71 requirement. 

For regular balloons that are intended for adults the Vendor must ensure compliance with EN71 chemical requirements (recommended for balloons designed to be put in the mouth (such as a mouth-blowing balloon).

All balloons containing latex should contain natural latex and be labeled “Natural Latex” to avoid allergy risk. ‌

h) Sporting goods (pickleball sets, yoga mats, golf balls, hockey pucks, ping pong balls, frisbees, etc.)

Requirements for Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf to North America locations (US, Canada and Mexico) 

For all sporting goods , the Vendor must ensure that the product does not pose an unreasonable risk of injury under the Consumer Product Safety Act (CPSA). If any of the sporting goods are marketed for children under 12, the Vendor must ensure compliance with CPSIA for lead (≤ 100 ppm) and phthalates (≤ 0.1%) content and include CPSIA tracking labels (for more information see Section “Labelling requirements” below)

For Pickleball Set compliance, the Vendor must ensure that the product complies with ASTM F2574 (Standard Specification for Pickleball Paddles) for performance and safety and that no sharp edges or detachable parts are present on paddles/balls as per CPSA. If the product contains any PVC or neoprene, then Propostition 65 lead and phthalates testing must also be conducted. If the pickleball set is intended for children under 3 years of age, testing for small parts (choking hazard) is required under the CPSIA.

For Hockey Puck compliance, the Vendor must ensure that no restricted substances are present in the plastic/rubber as per the Toxic Substances Control Act (TSCA). Furthermore, the Vendor must also ensure the product complies with ASTM F1085 (Standard Specification for Ice Hockey Pucks) for performance and safety and does not exhibit cracking/splintering under pressure (CPSA).

For Yoga Mat compliance, the Vendor must also ensure that the foam contains no lead/phthalates as per the Toxic Substances Control Act (TSCA). If the yoga mat is foam or textile-based, the Vendor must ensure compliance with the flammability requirements of the Flammable Fabrics Act (FFA) 16 CFR Part 1630. 

For Golf Ball compliance, the Vendor must also ensure that no restricted substances are present in the plastic/rubber as per the Toxic Substances Control Act (TSCA). 

If the Ping Pong Ball is intended for the use of children under 3 years of age, then the Vendor must ensure that the product complies with testing for small parts (choking hazard) under the U.S. CPSIA.

Vendors that supply Solar Holdco Group or fulfill orders on Solar Holdco Group’s behalf with products to European (EU) locations

For all sporting goods, the Vendor must ensure compliance with the General Product Safety Regulation (GPSR) (EU) 2023/988 and REACH Regulation (EC) No 1907/2006.

All sporting goods that are marketed as toys and are: i) intended for children of the age of 14 and below; and ii) intended for selling in the European market, must carry a CE mark²⁴, and must undergo conformity assessment²⁵ (for more information see Section “Labeling requirements” below). Furthermore, the Vendor must ensure compliance with the Toy Safety Directive 2009/48/EC, including mechanical/physical safety and chemical (EN 71-3) requirements.

For Pickleball Set compliance, the Vendor must ensure that if intended for children under 14, the product complies with the Toy Safety Directive (2009/48/EC). This includes testing for small parts (choking hazard), sharp edges, and chemical safety as per the EN 71 series (EN 71-1, EN 71-3).

For Yoga Mat compliance, the Vendor must ensure that the product complies with the REACH Regulation (EC) No 1907/2006 for chemical safety. Testing for restricted substances (heavy metals, phthalates, etc.) in mat materials is required. If the yoga mat is marketed as a toy for children, it must also comply with the flammability requirements of EN 71-2 (Toys).

For Ping Pong Ball compliance, the Vendor must ensure that if intended for children under 14, the product complies with the Toy Safety Directive (2009/48/EC). This includes testing for small parts (choking hazard) and chemical safety as per EN 71-3.

i) Electronic devices (smart watches, lamps, wireless speakers and chargers, power banks)

Requirements for Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf to North America locations (US, Canada and Mexico)

For all electronic/electrical products, Vendor must provide testing documents that show that the product does not include substances mentioned in California Proposition 65, according to actual product components. 

If the product contains external power supply units that are used to power electronics/electrical products, testing is required, showing compliance with US CPSC and FCC requirements.

For smart watches the Vendor must provide testing for the following CPSIA standards- UL 62368-1, IEC 60529, UL4200A – to ensure that the product does not cause safety hazards during normal use. All smart watches must have a reference to 47CFR Part 2.906 and Part 15.19 included on the product or in the user manual.

Wireless chargers must be Qi-Protocol certified, and must be listed on the Wireless Power Consortium (WTC) database https://wirelesspowerconsortium.atlassian.net/servicedesk/customer/portal/12/article/24018945. 

Vendor must provide testing report that shows compliance with CPSIA standards UL 62368-1 and IEC 62471. Product must comply with conducted emission and radiated emission regulated by FCC standard 47 CFR Part 15.201 ~ 15.258. All wireless chargers must have a reference to 47CFR Part 2.906 and Part 15.19 included on the product or in the user manual.

Power banks must comply with conducted emission and radiated emission regulated by FCC standard 47 CFR Part 15.201 ~ 15.258 and basic requirements for product safety under normal use, referenced in CPSIA UL 2056. All power banks must have a reference to 47CFR Part 2.906 and Part 15.19 included on the product or in the user manual.

For LED lamps the Vendor must ensure that the product complies with energy efficiency requirements set by California Energy Commission and Department Of Energy. Product must comply with conducted emission and radiated emission requirements set in 47 CFR Part 15.101 ~ 15.123 and basic requirements to ensure no safety hazards occur as per CPSIA UL153 and IEC 62471 standards.

For earbuds the Vendor must ensure that the product complies with conducted emission and radiated emission regulated by 47 CFR Part 15.201 ~ 15.258. To comply with CPSIA UL 62368-1, the product must be safe to use under normal usage, thus Vendor must provide evidence that proves the compliance. If earbuds have a Bluetooth connection, the product must have Bluetooth Qualification (BQB) and must be listed on Bluetooth website = https://launchstudio.bluetooth.com/Listings/Search. 

Vendors that supply Solar Holdco Group or fulfill orders on Solar Holdco Group’s behalf with electronic products to European locations

All electronic/electrical products must comply with chemical threshold requirements set in 2011/65/EC RoHS directive²⁶. If the product includes a power source unit (in-built or internal), then it must comply with EN 55032 standard. Products containing battery or external power source unit, shall comply with EN 55035 standard. 

For electronic/electrical products containing batteries (both rechargeable and non-rechargeable) Vendor must show compliance with minimum values for the electrochemical performance and durability parameters set out in Annex III of EU Regulation 2023/1542 concerning batteries and waste batteries.

From August 18th, 2025 Vendors whose businesses have an annual volume of no less than 40 million Euro must complete a supplier due diligence survey. From August 18th, 2026 the Vendor must ensure that the battery information label, with content requirements to be specified by relevant regulations, will be mandatory on the product or its packaging. From February 18th, 2027 the Vendor must ensure that a QR code placed on the battery may be used to provide labeling information, as permitted by updated regulations. From August 18th, 2028 the Vendor must ensure that the batteries within electronic products must meet minimum endurance and chemical-electric performance standards as defined by the regulations in force at that time.

If the product contains a USB port, it must be a Type C connector, and comply with relevant electrical and transmission rates set by EU Directive  2022/2380/EU and the standard EN 62680-1~3.

For smart watches Vendor must provide documentation (testing for standards EN 62368-1 and EN 60529) that proves that the product does not cause risk of electric shock, excess of heating, mechanical hazards, chemical and physical radiation hazards in accordance with General Product Safety Regulation (2023/988/EU). Smart watches must also comply with the Directive 2014/30/EU on Electromagnetic Compatibility, and must be tested in accordance with the standards EN 55032 and EN 55035. From August 1st, 2025, Smart Watches must also comply with the cybersecurity requirements per RED Directive 2014/53/EU Article 3.3 d/e/f, using the standards EN 18031-1/-2/-3.

For wireless chargers Vendor must ensure that the product complies with electrical safety standards set by EU Directive 2014/53/EU (RED Directive)²⁷. Product must be Qi-Protocol certified, and must be listed on the Wireless Power Consortium (WTC) database https://wirelesspowerconsortium.atlassian.net/servicedesk/customer/portal/12/article/24018945.

To ensure power bank compliance, Vendor must provide testing for standards EN 62368-1 and EN 62133-2, set by General Product Safety Regulation (2023/988/EU), to ensure product does not cause harm under normal use. Power banks must comply with electromagnetic compatibility standards EN 55032 and EN 55035, as per Directive 2014/30/EU.

For LED lamps Vendor has to provide testing for standards EN 60598-1 and IEC 62471 to ensure basic safety under normal use, and testing for standards EN 55015 and EN 61547, that prove that the product is compliant with electromagnetic compatibility requirements set in Directive 2014/30/EU. LED lamps must comply with eco design and energy efficiency requirements as per Directive 2009/125/EC. From December 31st, 2025, all LED lamps supplied must comply with the updated standard EN IEC 60598-1:2024, which will replace the previous version by December 31st, 2027.

Earbuds must comply with electrical safety standards set by EU Directive 2014/53/EU (RED Directive)²⁸. If earbuds have Bluetooth connectivity, they must be compliant with Bluetooth qualification program requirements, and must be listed on Bluetooth website https://launchstudio.bluetooth.com/Listings/Search.  

j) Pet products (food trays, leashes, collars)

Requirements for Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf to North America locations (US, Canada and Mexico)

• For pet food trays (e.g., bowls) – Vendor must provide testing for lead, phthalates (US CPSC 16 CFR Part 1303 and 1307), total cadmium content, Bisphenol A (BPA) content, Bisphenol S (BPS) content sharp point, small parts and sharp edge assessment, total chromium content (FDA (GRAS))
• For pet leashes and collars – Vendor must show compliance with California Proposition 65 requirements.

Requirements for Vendors that supply Solar Holdco Group or fulfill orders on Solar Holdco Group’s behalf with pet products to European locations.

For pet food trays (e.g., bowls) – Vendor must meet the organotin²⁹ and polycyclic aromatic hydrocarbons³⁰ content requirements and migration of metal requirements³¹.

k) Food supplements – (wellness, beauty, performance (protein, electrolyte, multivitamin etc.)

Requirements for Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf to North America locations (US, Canada and Mexico)

For all supplements, the Vendor must ensure that the product complies with all applicable regulations, such as the Dietary Supplement Health and Education Act (DSHEA) of 1994 and the Food and Drug Administration (FDA) regulations on good manufacturing practices (GMPs) for dietary supplements (21 CFR Part 111).  The Vendor must also comply with California Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986, which requires warnings for significant exposures to chemicals that cause cancer, birth defects, or other reproductive harm.

Specifically, the Vendor must meet the following requirements and provide testing for: 

• Adulterants and contaminants (such as pesticides, herbicides, heavy metals, mycotoxins, and microbiological contaminants. The FDA may sample and analyze imported food products to ensure they meet U.S. safety standards).
• Allergens, to verify the absence of undeclared allergens in food products.
• Identity & purity testing of raw materials (each dietary ingredient used in the supplement) to verify its identity & purity. 
• Finished Product Testing (each finished batch) of dietary supplements is tested to verify that it meets specifications for identity, purity, strength, and composition³².
• Permitted Ingredients – all products ingredients must adhere to with the following regulations:
  • Food additives must comply with 21 CFR Part 172 and 21 CFR Part 173 on food additives permitted for direct addition to food for human consumption;
  • Color additives must comply with 21 CFR Part 73 on listing of color additives exempt from certification, and 21 CFR Part 74 on listing of color additives subject to certification;
  • All substances must comply with 21 CFR Part 182, 21 CFR Part 184 and 21 CFR Part 186 on substances that are Generally Recognized as safe;
  • Flavoring substances must be  evaluated by Flavor Ingredient Library (FEMA)³³ and the The Joint FAO/WHO Expert Committee on Food Additives (JECFA)³⁴.
• Restricted substances or plants – all products ingredients must adhere to with the following regulations:
  • Food ingredients listed in 21 CFR Part 189³⁵ have been prohibited from use in human food by the FDA;
  • Color Additives listed in FDA regulations 21 CFR 81.10 and/or 81.30³⁶;
  • “Food Additive Status List”³⁷ gives a list of approved and prohibited additives in the US.

Requirements for Vendors that supply Solar Holdco Group or fulfill orders on Solar Holdco Group’s behalf with products to European locations.

For all supplements, the Vendor must guarantee compliance with the mandatory EU regulations,  including the Food Supplements Directive 2002/46/EC, Regulation (EC) No 1925/2006, and Regulation (EC) No 1170/2009. Furthermore, adherence to the General Food Law (Regulation (EC) No 178/2002), which establishes overarching food safety principles including traceability and labeling, is mandatory. If a supplement contains novel foods or ingredients, compliance with the Novel Food Regulation (EU) 2015/2283 is also required.

Specifically, the Vendor must meet the following requirements and provide testing for: 

• Composition – products can contain only the vitamins and minerals listed in Directive 2002/46/EC. 
• Permitted Ingredients – all products ingredients must adhere to with the following regulations:
  • Food additives must comply with Regulations (EC) No 1333/2008³⁸ and (EU) No 231/2012, which harmonize the use and specifications of permitted food additives.
  • Food enzymes must comply with with Regulation (EC) No 1332/2008³⁹ concerning the use of food enzymes added for technological purposes.
  • Food flavourings must comply with Regulation (EC) No 1334/2008⁴⁰ regarding the use of flavourings.
  • Extraction solvents must comply with Directive (EC) No 2009/32⁴¹ regulating the use of extraction solvents in production.
  • Restricted Substances listed under Regulation (EC) No 1925/2006⁴² on restricted substances at the EU level (Annex III, Parts A, B, and C) are prohibited.
  • Novel food must comply with Regulations (EU) No 2283/2015⁴³ and (EC) No 2470/2017⁴⁴ defining novel foods and their authorization procedures.
  • Genetically Modified Organisms (GMOs) must comply with Regulation (EC) No 1829/2003⁴⁵ setting conditions for their use, including traceability and labeling.
  • Pesticides must comply with Regulation (EC) No 396/2005⁴⁶ establishing maximum residue levels in food ingredients.
  • Pharmacologically active substances must comply with Regulation (EU) No 37/2010⁴⁷ setting maximum residue limits in animal-origin supplements.
  • Organic supplements must comply with Regulations (EU) No 2018/848⁴⁸ and (EC) No 834/2007, along with Regulation (EU) No 2021/1165⁴⁹, harmonizing organic production and authorizing specific substances.
• Safety and quality – all products must adhere to with the following regulations safety and quality requirements:
  • Microbiological standards must comply with Regulation (EC) No 2073/2005 setting microbiological standards for ingredients.
  • Contaminants must comply with Regulation (EU) No 2023/915 establishing maximum levels for certain contaminants.
• General hygiene requirements must comply with Regulations (EC) No 852/2004 and (EC) No 853/2004 outlining hygiene rules, including HACCP implementation and establishment registration/approval, with specific requirements for animal-origin products.

l) Food Products (coffee, tea, jams, chocolate, etc.)

Requirements for Vendors that supply Solar Holdco Group in or fulfill orders on Solar Holdco Group’s behalf to North America locations (US, Canada and Mexico) 

Vendors supplying or fulfilling orders for food products to Solar Holdco’s North American locations must ensure full compliance with all applicable United States regulations. This includes, but is not limited to, the Federal Food, Drug, and Cosmetic Act (FD&C Act) and the Food Safety Modernization Act (FSMA). Vendors are responsible for adhering to Current Good Manufacturing Practices (CGMPs)⁵⁰ for both Food and Dietary Supplements⁵¹, implementing Hazard Analysis Critical Control Point (HACCP) principles, following the Good Manufacturing Practices for the 21st Century for Food Processing (2004 Study) Section 1, which outlines current Food CGMPs, and California Proposition 65 regulation.

Specifically, the Vendor must ensure compliance with the following requirements and provide testing for: 

• Adulterants and contaminants (such as pesticides, herbicides, heavy metals, mycotoxins, and microbiological contaminants. The FDA may sample and analyze imported food products to ensure they meet U.S. safety standards).
• Allergens, to verify the absence of undeclared allergens in food products.
• Microbiological contaminants under 21 CFR Part 111 CGMPs to ensure product safety and quality. Commonly tested microorganisms include Total Aerobic Count, Yeast and Mold, E. coli, Salmonella, and sometimes Staphylococcus aureus or Listeria, depending on the product form and target population⁵².
• Permitted Ingredients – all products ingredients must adhere to with the following regulations:
  • Food additives must comply with 21 CFR Part 172 and 21 CFR Part 173 on food additives permitted for direct addition to food for human consumption;
  • Color additives must comply with 21 CFR Part 73 on listing of color additives exempt from certification, and 21 CFR Part 74 on listing of color additives subject to certification;
  • All substances must comply with 21 CFR Part 182, 21 CFR Part 184 and 21 CFR Part 186 on substances that are Generally Recognized as safe;
  • Flavoring substances must be  evaluated by Flavor Ingredient Library (FEMA)⁵³ and the The Joint FAO/WHO Expert Committee on Food Additives (JECFA)⁵⁴.
• Restricted substances or plants – all products ingredients must adhere to with the following regulations:
  • Food ingredients listed in 21 CFR Part 189⁵⁵ have been prohibited from use in human food by the FDA;
  • Color Additives listed in FDA regulations 21 CFR 81.10 and/or 81.30⁵⁶.
  • “Food Additive Status List”⁵⁷ gives a list of approved and prohibited additives in the US.

In addition to the above, for coffee, tea, jams and chocolate, the Vendor must ensure compliance with the following requirements and provide testing for:

• Coffee – must have mandatory testing for:
  • Ochratoxin A (OTA), 
  • acrylamide, 
  • various pesticides (organophosphate, organochlorine, pyrethroids, etc.), and  pesticide tolerances (21 CFR Part 180),
  • Defect Action Levels (DALs),
  • heavy metals (lead, cadmium, arsenic, mercury), 
  • microbiological contaminants (Salmonella, E. coli, molds), 
  • physical contaminants (glass, metal, stones). 
  • California Proposition 65 requirement testing for applicable substances (e.g., acrylamide). 
• Tea – similar to coffee, tea must undergo testing for:
  • various pesticides (organophosphate, organochlorine, pyrethroids, etc.), and  pesticide tolerances (21 CFR Part 180),
  • heavy metals (lead, cadmium, arsenic, mercury), 
  • California Proposition 65 requirement testing for applicable substances (e.g., acrylamide). 

Specific requirements may apply to different tea types (e.g., herbal teas), and thus may require testing for contaminants like:

• • pesticides, 
  • heavy metals, 
  • microbiological contaminants, and
  • other relevant/applicable contaminants. 

• Jams  – must have mandatory testing for:
  • heavy metals, 
  • pesticides, 
  • mycotoxins (if relevant), 
  • fruit content (for specific fruit claims), 
  • and preservatives,
  • California Proposition 65.
• Chocolate – all cacao products defined in 21 CFR Part 163—Cacao Products⁵⁸, must have mandatory testing such as:
  • heavy metals, 
  • microbiological organisms,
  • California Proposition 65. 

For food products that carry claims:

• about their nutrient content, the Vendor must ensure adherence to specific definitions and criteria outlined by the FDA⁵⁹.
• about health (health claims), which link a food or its components to a reduced risk of a disease, the Vendor must ensure adherence to the applicable FDA requirements, and have received authorization by the FDA, for the usage of such claims (for more information see Section “Labeling requirements” below). 

Requirements for Vendors that supply Solar Holdco Group or fulfill orders on Solar Holdco Group’s behalf with pet products to European locations.

Vendors must ensure that all CPG products comply with applicable EU regulations, including but not limited to Regulation (EC) No 178/2002 (General Food Law), Regulation (EC) No 396/2005 (Pesticides), Regulation (EC) No 1881/2006 (Contaminants), Regulation (EU) No 1169/2011 (Food Information to Consumers), and Regulation (EC) No 1935/2004 (Food Contact Materials).

Specifically, the Vendor must ensure compliance with the following requirements and provide testing for: 

• Permitted Ingredients – all products ingredients must adhere to with the following regulations:
  • Food additives must comply with Regulations (EC) No 1333/2008⁶⁰ and (EU) No 231/2012, which harmonize the use and specifications of permitted food additives.
  • Food enzymes must comply with with Regulation (EC) No 1332/2008⁶¹ concerning the use of food enzymes added for technological purposes.
  • Food flavourings must comply with Regulation (EC) No 1334/2008⁶² regarding the use of flavourings.
  • Extraction solvents must comply with Directive (EC) No 2009/32⁶³ regulating the use of extraction solvents in production.
  • Restricted Substances listed under Regulation (EC) No 1925/2006⁶⁴ on restricted substances at the EU level (Annex III, Parts A, B, and C) are prohibited.
  • Novel food must comply with Regulations  (EU) No 2283/2015⁶⁵ and (EC) No 2470/2017⁶⁶ defining novel foods and their authorization procedures.
  • Vitamins and minerals must comply with Regulation (EC) No 1925/2006 on the addition of vitamins and minerals to food.
  • Genetically Modified Organisms (GMOs) must comply with Regulation (EC) No 1829/2003⁶⁷ setting conditions for their use, including traceability and labeling.
  • Pesticides must comply with Regulation (EC) No 396/2005⁶⁸ establishing maximum residue levels in food ingredients.
  • Pharmacologically active substances must comply with Regulation (EU) No 37/2010⁶⁹ setting maximum residue limits in animal-origin supplements.
  • Organic food must comply with Regulations (EU) No 2018/848⁷⁰ and (EC) No 834/2007, along with Regulation (EU) No 2021/1165⁷¹, harmonizing organic production and authorizing specific substances.
• Specific food requirements:
  • Food for Specific Groups and Food for Special Medical Purposes must comply with Regulation (EU) No 609/2013 on the foundational legal framework for specific categories of foods intended for particular vulnerable groups.
  • Food for Special Medical Purposes must comply with Regulation (EU) No 2016/128 on the specific compositional and information requirements for food for special medical purposes.
  • Food for weight control or diet replacement must comply with Regulation (EU) No 2017/1798 on  the specific compositional and information requirements for total diet replacement for weight control
  • Infant formulas and follow-on formulas must comply with Regulation (EU) No 2016/127 on the specific compositional and information requirements for infant formula and follow-on formula and as regards requirements on information relating to infant and young child feeding.
• Safety and quality – all products must adhere to with the following regulations safety and quality requirements:
  • Microbiological standards must comply with Regulation (EC) No 2073/2005 setting microbiological standards for ingredients.
  • Contaminants must comply with Regulation (EU) No 2023/915 establishing maximum levels for certain contaminants.
• General hygiene requirements must comply with Regulations (EC) No 852/2004 and (EC) No 853/2004 outlining hygiene rules, including HACCP implementation and establishment registration/approval, with specific requirements for animal-origin products.

In addition to the above, for coffee, tea, jams and chocolate, the Vendor must ensure compliance with the following requirements:

• Sugar must comply with Directive 2001/111/EC.  
• Fruit Jams, Jellies, and Marmalades must comply with Directive 2001/113/EC. 
• Dehydrated Milk products must comply with Directive 2001/114/EC
• Agricultural products must comply with Regulation (EU) No 1308/2013
• Cocoa and chocolate products must comply with Directive 2000/36/EC

For food products that carry voluntary nutrition or health claims the Vendor must ensure compliance with the requirements set in Regulation (EC) No 1924/2006. Additionally, health claims must comply with Regulation (EU) No 432/2012 authorized health claims list.

m) California Proposition 65 

This Section applies to all the product categories listed above, as well as to the products not specifically mentioned herein (for example, shoes, etc.) that Vendors supply to Solar Holdco Group in or that are fulfilled by Vendors on Solar Holdco Group’s behalf to North America locations (US, Canada and Mexico). 

Vendors must assure that all products or components they provide comply with California’s Proposition 65 which prohibits a business from exposing individuals to chemicals known to cause cancer or reproductive toxicity without first giving “clear and reasonable warning,” unless the business can prove that the level of exposure is not significant. Solar Holdco Group strives to sell products that do not require a California Proposition 65 warning, therefore Vendor is responsible for ensuring that all products sold to Solar Holdco Group have been tested for California Proposition 65 compliance against existing industry standards (as applicable). At minimum, Vendor must provide testing that shows the products it sells do not contain or if detected – contain less than the maximum allowable dosage level of: i) lead; ii) cadmium; iii) mercury; and iv) phthalates⁷². In case of plastic products or synthetic fabrics (e.g. polyester, nylon and spandex), in order to show Vendor compliance with California Proposition 65, the Vendor must also prove that the product does not contain more than the maximum allowable dosage level of BPA (bisphenol A) and BPS (bisphenol S).

If the Vendor cannot provide the aforementioned testing, then the product may require a California Proposition 65 warning. Vendor is responsible for providing Solar Holdco Group with a written notice placed on Vendor company’s letterhead and signed/dated by an officer of the Vendor company that includes all of the following: i) statement that the particular product may result in an exposure to one or more listed chemicals; ii) the exact name or description of the product; and iii) all necessary warning language that satisfies California Proposition 65. This written notice must be renewed and resubmitted annually to email [email protected].

Furthermore, a short-form warning may be provided on the label pursuant to Section 25602(a)(4) if it includes:

• The symbol required in subsection (a)(1);
• The word “WARNING:” or the words “CA WARNING:” or “CALIFORNIA WARNING:” in all capital letters, in bold print; and
• One of the following:
  • For exposures to listed carcinogens, the words: “Cancer risk from exposure to [name of chemical]. See www.P65Warnings.ca.gov.”; or “Can expose you to [name of chemical], a carcinogen. See www.P65Warnings.ca.gov.”
  • For small products with limited space, warning sentence should be as below:

• • For products with enough space to put full labelling, warning sentence should be as below:

n) Dangerous Goods

This Section applies to all the product categories listed above that qualify as dangerous goods, as well as to the products not specifically mentioned herein (for example, shoes, etc.) that Vendors supply to Solar Holdco or that are fulfilled by Vendors on Solar Holdco Group’s behalf to North America locations (US, Canada and Mexico) and European locations.

A dangerous good (also known as hazardous material or hazmat) is any product capable of posing an unreasonable risk to health, safety, and property during shipping, storage, and handling due to flammable, corrosive, pressurized, or otherwise harmful substances. These goods require special handling and transportation measures, including specific marking, labeling, and packaging.

Vendors are responsible for identifying if their products qualify as dangerous goods and for ensuring compliant shipping and labeling according to all applicable laws and regulations in the relevant jurisdictions.

Examples of dangerous goods (non-exhaustive): 

• Lithium battery products (laptops, smartphones)
• Household cleaners that are toxic, corrosive, irritants, strong sensitizers, flammable/combustible, or generate pressure and may cause substantial injury/illness during foreseeable use.
• Cosmetic products classified as hazardous (aerosol cosmetic products using flammable propellants, nail polish and nail polish removers containing flammable solvents, perfumes and fragrances with high concentrations of flammable alcohol, hair dyes and bleaches containing strong oxidizing agents or flammable ingredients, chemical peels and exfoliants containing corrosive acids).

Requirements for Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf to North America locations (US, Canada and Mexico)

For any product containing lithium batteries⁷³ The Vendor must ensure compliance with Hazardous Materials Regulations (49 CFR Parts 171-180 and 173.185) and the UN Manual of Tests and Criteria (UN38.3) regarding classification, safety features, marking, and packaging. The Vendor must provide a test report demonstrating compliance with the UN Manual of Tests and Criteria (UN38.3), Part III, sub-section 38.3. A test summary must also be available.

Smaller cells/batteries meeting certain conditions may have exceptions from some labeling and packaging requirements (refer to regulations for specific size limits and conditions). Exceptions also apply to air transport for specific scenarios (packed with/in equipment, disposal/recycling, low production, damaged/defective/recalled, medical devices).

For any household cleaners classified as hazardous substances, the Vendor must ensure compliance with Federal Hazardous Substances Act (FHSA) for labeling, Toxic Substances Control Act (TSCA) for inventory and EPA registration (if applicable), proper labeling according to EPA, recordkeeping, Workplace Chemical Protection, and Volatile Organic Compounds (VOCs) regulations (federal and state). For transportation, compliance with Hazardous Materials Regulations (49 CFR Parts 171-180 and 173.185). The Vendor must provide test reports verifying compliance with specific hazardous properties standards (e.g., flammability, corrosivity) as requested by Solar Holdco. Safety Data Sheets (SDS) are required including transportation classification.

For any cosmetic product classified as hazardous, the Vendor must ensure compliance with the FDA’s list of prohibited and restricted ingredients (e-CFR, Title 21, Part 700, Subpart B), inclusion of appropriate warning statements (FDCA), provision of tamper-resistant packaging (FDCA), child-resistant packaging for certain products (PPPA), adherence to organic labeling regulations (USDA NOP), compliance with cruelty-free regulations (California), and adherence to state-specific regulations (e.g., Florida Drug and Cosmetic Act). The Vendor must provide test reports verifying compliance with specific hazardous properties standards (e.g., flammability for aerosols) as requested by Solar Holdco. Safety Data Sheets (SDS) required including transportation classification.

Requirements for Vendors that supply Solar Holdco Group or fulfill orders on Solar Holdco Group’s behalf with products to European locations

For any product containing lithium batteries the Vendor must ensure compliance with the Restriction of Substances under the EU Battery Regulation (2023/1542) and the Inland Transport of Dangerous Goods Directive (Directive 2008/68/EC) / ADR. The Vendor must provide a test report demonstrating compliance with the Inland Transport of Dangerous Goods Directive (Directive 2008/68/EC) and the ADR, specifically verifying compliance with sub-section 38.3 of the UN Manual.

For any household cleaners classified as hazardous substances, the Vendor must ensure compliance with the EU Detergents Regulation (EC) No 648/2004 (biodegradability, labeling), CLP Regulation (EC) No 1272/2008 (labeling), REACH Regulation (EC) No 1907/2006, Biocidal Products Regulation (EU) No 528/2012 (if applicable), and Packaging and Packaging Waste Regulation (PPWR). The Vendor must provide test reports verifying compliance with specific hazardous properties standards (e.g., flammability, corrosivity) as requested by Solar Holdco. Safety Data Sheets (SDS) are required.

For any cosmetic product classified as hazardous, the Vendor must ensure compliance with the Chemical requirement – REACH (Regulation (EC) No 1907/2006) and its amendments regarding safe transportation. The Vendor must provide test reports verifying compliance with specific hazardous properties standards (e.g., flammability for aerosols) as requested by Solar Holdco. Safety Data Sheets (SDS) required including transportation classification.

Vendors are solely responsible for identifying dangerous goods and ensuring full regulatory compliance in the relevant sales regions. Solar Holdco may request further compliance documentation and reserves the right to conduct its own verification.

o) Per-and polyfluoroalkyl substances (PFAS) compliance

In case the product has the following characteristics – i) water resistant, waterproof, ii) oil proof, iii) anti-fouling, iv) antibacterial, v) wear resistant, vi) rust resistant or vii) fire resistant, the Vendor must provide i) a laboratory test report (as mentioned below), where the product has been tested for PFAS, or ii) material safety data sheet (MSDS) that includes information about the PFAS usage in the product or its coating, or iii) letter of guarantee, where the vendor guarantees that the product does not contain any of the PFAS.

Based on the product characteristics, the following testing must be performed:

• PFOS/PFOSF – for all waterproof, oil  proof, anti-fouling, antibacterial, wear, rust and fire resistant products;
• PFOS/PFOA – for waterproof and oil proof food contact products made of paper, plastic, or products having a coating;
• FPCA and its salts – for all oil and water proof textile;
• PFOS – for coating materials used in textile or other products;
• PFHxS – for waterproof and oil proof food packaging products and materials, coated textile and paper products, and coating itself;
• PFBS – for fire resistant products.

p) Inks supplies used for product decorating 

Vendors fulfilling orders on behalf of Solar Holdco Group regardless of their country of origin must ensure compliance with ink safety requirements by either having a copy of a valid ECO PASSPORT by OEKO-TEX® certificate (applies to textile products) or a valid product safety certificate where the following testing has been performed on inks of all colors: i) cadmium content; ii) total lead in surface coating; and iii) phthalates. Solar Holdco Group has the right to request these documents to be provided at any time.

q) Packaging materials 

Requirements for Vendors that supply Solar Holdco Group with or fulfill orders on Solar Holdco Group’s behalf to North America locations (US, Canada and Mexico)

Vendors must ensure that all products are free of toxic elements. In order to be able to prove this, upon receiving request from Solar Holdco Group, and must submit to email [email protected]: (i) certificate of compliance⁷⁴ where they warrant compliance with Toxics in Packaging Clearinghouse (“TPCH”) Model legislation for products sold specifically to Solar Holdco Group, as well as (ii) testing results from laboratory showing the Vendor has tested the packaging to ensure that it meets the set Cadmium, Hexavalent Chromium, Lead and Mercury concentration limits⁷⁵. As an alternative, if the packaging Vendor uses is exempt from TPCH Model legislation, Vendor must provide an exemption certificate of compliance⁷⁶.

All cosmetic products (i.e. perfumes) the Vendor sells to Solar Holdco Group must follow Proposition 65 chemical requirements for packaging. The Vendor is responsible for ensuring that cosmetic products, such as perfume, packaging or other components (except the perfume liquid itself) comply with Proposition 65, and meet these chemical requirements:

• Lead: Paints or other surface coating ≤0.009 % (90ppm)
• PVC component ≤0.02 % (200ppm)
• All other materials other than cubic zirconia, crystal, glass or rhinestones (Excluding materials other than leather listed in 16 CFR 1500.91(d) & (e)) ≤0.03 % (300ppm)

Testing Method: By EPA 3050B/3051, ASTM F 2853-10

All children’s products (i.e. toys) the Vendor sells to Solar Holdco Group must follow all relevant 16 CFR 1250 and ASTM F963 packaging requirements: 

• Promotional Materials – Packaging, literature accompanying toys, and point-of-sale presentations shall not use words, statements, or graphic material that are inconsistent in any way with the safety labeling instructions for use assembly or age grading of the toy.
• Marking of producer – Either a principal component of the toy or the packaging of the toy shall be marked with the name and address of the producer or the distributor. In the case of toys sold in bulk, only the container is required to be marked.
• Instruction of use – Information and instructions provided for the safe use or assembly, or both, of toys, whether on the packaging or in leaflet form, shall be easy to read and understand by a person of the age level for whom the toy is intended and shall be in the English language at a minimum.

Vendors that supply Solar Holdco Group or fulfill orders on Solar Holdco Group’s behalf products to European locations acknowledge that the product packaging will comply with the Packaging and Packaging Waste Directive 94/62/EC⁷⁷, which prescribes packaging  sustainability and labeling requirements, including but not limited to ensuring it is minimized and recyclable with heavy metals content ≤ 100 ppm.