Feasibility Assessment of YESS: Yarn Ethically & Sustainably Sourced
I have been assisting the Responsible Sourcing Network (RSN) with drafting the YESS: Yarn Ethically & Sustainably Sourced (YESS) standard and creating accompanying assessment tools. You may also recall that the goal of YESS is to create an industry-wide approach to encourage yarn spinning mills to develop and implement risk-based due diligence management systems to avoid sourcing cotton produced with forced labor. The standard is based on the Organisation for Economic Co-Operation and Development’s (OECD’s) Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector.
Initial activities to develop the YESS standard and accompanying tools included a 2017 research trip to spinners in India, Bangladesh and Turkey and to gins in India and Turkey, and incorporating the initial findings from this trip into a draft standard that underwent public consultation in the spring of 2018. After addressing the thoughtful and helpful feedback we received through the public consultation, Patricia Jurewicz, Founder and Vice President of RSN, and I recently visited four spinners in Bangladesh and Turkey—with the much appreciated support from H&M and VF Corporation—to assess whether or not spinners would be able to conform to the draft YESS standard. We also sought feedback from spinners on the assessment tools (i.e. whether they are understandable, practical and appropriate).
Patricia and I learned a lot during the Feasibility Assessment. Here are just a few highlights, which I will go into more detail on below: where spinners can meet the YESS standard today, what is achievable with minimal adjustments, what requirements of the YESS standard will be challenging, and other considerations that should be addressed. I will also look at next steps and opportunities to learn more about YESS.
Requirements currently met by the industry
Some expectations outlined in the YESS standard for a due diligence management system (e.g. validating the origin of cotton lint, internal material controls) are already standard practices across the industry, and will require little or no change to operations. For example, a Country of Origin certificate and phytosanitary permit (to address agricultural pest concerns) must accompany all shipments of cotton exported from one country to another. Additional documents, such as a bill of lading, invoice, and description of cotton lint characteristics, accompany all transactions as an industry standard. The eight spinners that participated in YESS’s 2017 research and 2018 feasibility assessment confirmed that it is standard practice for all spinners to review the detailed information contained within the various transaction documents (e.g. weight, date, origin, destination, supplier) to validate the origin of cotton. Additionally, all spinners take appropriate care to weigh cotton lint upon receipt and account for all of that lint as it is processed into yarn or captured as wastage or byproduct.
What is achievable with minor adjustments
Some requirements of the YESS standard are not currently met but could be incorporated into a spinner’s operations with minimal changes, if industry standards are developed and widely adopted. These include developing a policy to avoid sourcing cotton that may have been produced with forced labor and communicating that policy to the public and to suppliers. Similarly, spinners currently conduct due diligence of suppliers through informal processes (e.g. evaluating a supplier’s reputation across the industry or through conversations with other spinners). The feedback we received from spinners indicates that formalizing a Know Your Supplier process (as required by the YESS standard) would be achievable with minor adjustments to their existing supplier due diligence and procurement processes.
Areas that pose significant challenges to meet
Unlike many other commodity supply chains, spinners do not have leverage over many of their suppliers—namely the large global merchants that often supply imported cotton lint. Spinners suggested that RSN could discuss the goals and expectations of YESS with global merchants to assess their willingness and ability to support the efforts of YESS.
One specific question Patricia and I sought to answer was whether or not spinners could require that all Better Cotton originating from high-risk countries as defined in the YESS standard[1] be “physical” Better Cotton rather than “substituted” Better Cotton. Here’s what that means. “Physical” Better Cotton refers to cotton that was actually produced by a Better Cotton Initiative (BCI) licensed farmer), as opposed to “substituted” Better Cotton, which refers to cotton that was produced in the same country of origin as an equivalent amount of Better Cotton, but the actual “substituted” cotton may or may not be produced by a BCI farmer. The preference for “physical” Better Cotton would only be relevant in the high-risk countries (where “substituted” Better Cotton may pose a risk of being produced with forced labor) that have BCI programs.
Other considerations
Our conversations with spinners left us with some other considerations that we should bear in mind. We learned that spinners would find it helpful if YESS created trainings, resources and tools to help them understand and implement specific requirements of the YESS standard. For example, spinners could use a checklist of what constitutes sufficient due diligence of suppliers, gins and farms in high-risk countries. Other helpful resources include a Know Your Supplier questionnaire or sample letter to send to global merchants asking them to conduct due diligence of the gins or farms from which they source.
Spinners feel that BCI has a good system—using a mass balance approach—that is easy for spinners to implement. The systems for organic and fair trade (which include segregating organic or fair trade cotton from other sources of cotton during spinning) are difficult for spinners to implement.
We also discovered that spinners see any efforts to align with BCI as beneficial and suggest that these efforts may lead to wider adoption of YESS and growing support of BCI. Another suggestion for wider industry adoption is to simplify the YESS standard and assessment workbook.
Next steps
In the coming months, I will incorporate the input and lessons from the recent Feasibility Assessment trip as I finalize the YESS standard and assessment tools. You can learn more about YESS, insight from our recent Feasibility Assessment, and planned next steps for YESS by participating in a November 5th webinar hosted by the American Apparel & Footwear Association (AAFA) (if you are a member of AAFA). There are several resources on the YESS website, including a recording of a webinar that Patricia and I gave for the Textile Exchange community earlier this year.
[1] The YESS standard defines high-risk countries as Benin, Burkina Faso, China, India, Kazakhstan, Pakistan, Tajikistan, Turkmenistan and Uzbekistan.