This document is the single source of truth for all supplier compliance obligations at Wahl Clipper Corporation. It defines what is required, under what circumstances, in what form, and at what frequency.
Compliance requirements do not live in the Supplier Handbook or the Quality Agreement. When a compliance regulation changes, only this document and its referenced forms need to be updated. No changes to the Handbook or Quality Agreement are required unless a section pointer becomes invalid.
§1.0 Scope
§1.1 Applicability
This document applies to all suppliers providing goods or services to Wahl Clipper Corporation, regardless of geography, unless a specific clause explicitly limits applicability to a defined supplier type.
§1.2 Priority
In any case of conflict between this document and the Supplier Handbook, this document governs for compliance subject matter. For commercial, delivery, or quality matters, refer to the relevant authoritative document.
§1.3 Updates and Revisions
This document is owned and maintained by the Compliance Department. Wahl reserves the right to update compliance requirements to reflect changes in applicable law, regulation, or corporate policy. Suppliers will be notified of material changes. Upon notification, suppliers have 30 days to submit any updated documentation required by the revision.
§2.0 Document Control
§2.1 Versioning
This document is versioned independently of all other supplier documents. A compliance update does not trigger a revision to the Supplier Handbook or Quality Agreement.
§2.2 How Forms Are Referenced
Each compliance obligation in this document references the specific form or procedure that satisfies it. Those forms are maintained by the Compliance Department under their own revision control. When a form is revised, this document is updated to reflect the new revision number.
§2.3 Supersession
This document supersedes all inline compliance content previously published within the Supplier Handbook (Rev 2, 2024) §Environmental, Regulatory and Ethical Requirements. The Handbook's compliance section is now a pointer to this document only.
§3.0 Required Compliance Documents by Supplier Type
The matrix below identifies which compliance documents are required based on supplier classification. For questions about your supplier classification, contact your Wahl Sourcing Buyer.
| Compliance Requirement | All Suppliers |
Foreign Suppliers |
Third-Party Finished Goods |
Direct Material / Component |
Risk-Based (Global Services) |
|---|---|---|---|---|---|
| Supplier Code of Conduct Certificate | ✓ | ✓ | ✓ | ✓ | ✓ |
| Social Responsibility Questionnaire | ✓ | ✓ | ✓ | ✓ | ✓ |
| Social Responsibility Audit | — | — | — | — | ✓ |
| Conflict Minerals Reporting Template (3TG) | If applicable | If applicable | If applicable | If applicable | — |
| Restricted Substances Declaration (RSD) | — | — | ✓ | ✓ | — |
| Safety Data Sheet (SDS) | If liquid/gel/ battery |
If liquid/gel/ battery |
If liquid/gel/ battery |
If liquid/gel/ battery |
— |
| CTPAT Security Assessment | — | ✓ | — | — | — |
| CTPAT Audit | — | ✓ | — | — | — |
| Supplier Security Assessment | — | — | — | — | ✓ |
| Certificate of Insurance (COI) | — | — | ✓ (liquid/ gel/battery) |
— | — |
| FDA Registration | If FDA-regulated | If FDA-regulated | If FDA-regulated | — | — |
Source: Supplier Document Requirements (COM-014), Rev 4, effective 2024-05-20.
§4.0 Compliance Submission Requirements
§4.1 Timing
| Trigger | Action Required |
|---|---|
| New supplier onboarding | Submit all required documents (per §3.0 matrix) before first purchase order is released |
| Annual renewal | Renew designated documents each calendar year — October/November unless otherwise specified |
| Regulatory or corporate policy change | Wahl will notify suppliers; updated documents due within 30 days of notification |
| Change in supplied product, material, or process | Re-evaluate applicability of all compliance requirements; submit updated documents where affected |
| Change in supplier's supply chain (sub-tier) | Notify Wahl Sourcing; update relevant declarations |
§4.2 Submission Method
Submit all compliance documents to your designated Wahl Sourcing Buyer unless otherwise specified. Electronic submission (PDF or as specified by the form) is preferred.
§4.3 Non-Compliance
Failure to submit required compliance documents on schedule will result in hold on new purchase orders until documentation is current. Chronic non-compliance is subject to financial penalties and supplier status review per the Supplier Performance Rating system. See Supplier Handbook Addendum A for cost recovery schedule.
§5.0 Code of Conduct and Social Responsibility
§5.1 Supplier Code of Conduct
Wahl's Supplier Code of Conduct establishes the ethical, labor, and environmental standards expected of all suppliers. It covers:
- Labor rights and working conditions
- Health and safety
- Environmental responsibility
- Anti-bribery and anti-corruption
- Human trafficking and forced labor (California Supply Chains Act compliance)
- Wahl's corporate disclosure obligations
- Required of
- All suppliers.
- Form
- Complete and sign the Supplier Certification (COM-002), acknowledging receipt of and compliance with the Supplier Code of Conduct (COM-001).
- Frequency
- At onboarding. Re-attestation required when Code of Conduct is revised.
- Reference Documents
- Supplier Code of Conduct V2 (COM-001); Supplier Certification Rev 03 (COM-002)
§5.2 Social Responsibility Assessment
Suppliers must complete Wahl's Social Responsibility Assessment questionnaire, which evaluates labor conditions, environmental management, health and safety systems, and business ethics practices.
§5.3 Social Responsibility Audit
Wahl reserves the right to conduct on-site social responsibility audits of any supplier based on risk assessment by Global Services. Suppliers must cooperate fully and provide access to relevant records, facilities, and personnel.
§6.0 Restricted Substances
§6.1 Restricted Substances Declaration (RSD)
Wahl Clipper Corporation maintains a Restricted Substance List (RSL) composed of substances governed by the following regulations:
- EU Directive 2011/65/EU (RoHS)
- EU Regulation 1907/2006 (REACH/SVHC)
- California Proposition 65
- Montreal Protocol
- EU Regulation 2019/1021 (POPs)
- California AB 1817 / EU PFAS requirements
- EU Council Directive 2013/51/Euratom (radioactive substances)
- EU Directive 94/62/EC and Model Toxics in Packaging
The current RSL is published at: Corporate Disclosures | wahl.com
- Required of
- Third-party finished goods suppliers; direct material/component suppliers; processors changing physical attributes of components used in finished goods.
- Form
- Restricted Substances Declaration RSD 001 Rev 05 (COM-007). See also: Instructions and Tips (COM-008) and Glossary (COM-009).
- Frequency
- At onboarding. Annually with updated effectivity date. Upon any change in materials or supply chain affecting substance compliance.
- Format
- PDF. Must list all applicable Wahl part numbers — generic or blanket documents are not accepted.
§6.2 Hexavalent Chromium
Wahl requires that hexavalent chromium (Cr VI) present in any purchased product not exceed 1,000 ppm. Alternatives to hexavalent chromium / chromic acid plating baths are strongly preferred where technically feasible. Suppliers using hexavalent chromium plating processes must disclose this in their Restricted Substances Declaration (COM-007).
§6.3 Safety Data Sheet (SDS)
Suppliers of products that are liquid, gel, paste, or that contain a battery, or products falling under applicable OSHA and UN GHS requirements, must provide a current Safety Data Sheet.
- Required of
- Products that are liquid, gel, paste, battery-containing, FDA-regulated, or chemically regulated.
- Form
- SDS in PDF format, per OSHA 1910.1200 / UN GHS.
- Frequency
- Annually with updated effectivity date. Must list all applicable Wahl part numbers — generic or blanket documents not accepted.
§7.0 Conflict Minerals
§7.1 Conflict Mineral Policy
Wahl Clipper Corporation requires suppliers to implement a policy committing to responsible sourcing of all minerals and materials in accordance with Wahl's Conflict Minerals Policy (COM-005). This requires conducting due diligence per OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including its supplements on tin, tantalum, tungsten, and gold (3TG).
Wahl's Conflict Mineral Policy is published at: Corporate Disclosures | wahl.com
§7.2 Conflict Minerals Reporting
Suppliers must certify in writing that their products, including those from their sub-contractors, use only Conflict-Free materials (DRC Conflict-Free). Suppliers must disclose updated smelter/refinery information for any 3TG mineral used in production.
- Required of
- Suppliers whose products contain tin, tantalum, tungsten, or gold (3TG).
- Form
- Conflict Minerals Reporting Template v6.5 (COM-006), aligned with CFSI format.
- Frequency
- At onboarding. Annually. Upon any change to supply chain affecting 3TG sourcing.
§8.0 Safety and Security
§8.1 CTPAT (Customs-Trade Partnership Against Terrorism)
Foreign suppliers exporting to Wahl are required to participate in Wahl's CTPAT program. This includes completing a security questionnaire and, where required, undergoing a CTPAT audit per Wahl's audit procedure.
- Required of
- Foreign suppliers exporting to Wahl Clipper Corporation.
- Form
- Supply Chain Security Assessment Questionnaire; CTPAT Audit (COM-011).
- Frequency
- At onboarding. Reassessment as required by Wahl's CTPAT program.
§8.2 Supplier Security Assessment
Wahl conducts risk-based supplier security assessments through Global Services. Suppliers selected for assessment must complete the Supplier Security Assessment questionnaire covering physical, personnel, cyber, and logistics security.
- Required of
- Determined by risk assessment conducted by Global Services.
- Selection Criteria
- Suppliers are assessed based on spend threshold, country risk, product category risk, supply chain visibility, and prior audit findings.
- Form
- Supplier Security Assessment Rev 03 (COM-012).
- Frequency
- Upon selection. Reassessment per subsequent risk evaluation.
§8.3 Certificate of Insurance (COI)
Suppliers of third-party finished goods that are liquid, gel, or paste, or that include a battery within the product, must provide a valid Certificate of Insurance demonstrating adequate liability coverage.
- Required of
- Third-party finished goods suppliers — liquid, gel, paste, or battery-containing products.
- Format & Coverage
- Refer to Certificate of Insurance Example (COM-013).
- Frequency
- At onboarding. Annually upon renewal. Immediately upon any change in insurer or coverage.
§9.0 Corporate Disclosure
Wahl Clipper Corporation maintains corporate disclosures related to restricted substances, conflict minerals, and the California Transparency in Supply Chains Act. Suppliers are expected to support these disclosures through accurate and timely submission of required compliance documentation.
Wahl's corporate disclosures are published at: Corporate Disclosures | wahl.com
- Reference Documents
- Corporate Disclosure Rev 03 (COM-010)
§10.0 Anti-Bribery and Anti-Corruption
Wahl Clipper Corporation takes a zero-tolerance approach to bribery and corruption. Suppliers are expected to conduct all business in an honest and ethical manner, and to extend these standards throughout their own supply chains.
Anti-bribery and anti-corruption obligations are governed by the Supplier Code of Conduct (COM-001). Acknowledgment of the Code of Conduct (COM-002) constitutes acceptance of these obligations.
§11.0 Regulatory Requirements
Regulatory compliance obligations are incorporated within the compliance documents maintained by the Compliance Department. The compliance forms referenced in §5.0–§8.0 satisfy Wahl's regulatory obligations as mapped below.
| Regulatory Area | Governing Regulation | Covered By | Section |
|---|---|---|---|
| California Proposition 65 | CA Safe Drinking Water and Toxic Enforcement Act 1986 | RSD (COM-007) | §6.1 |
| RoHS | EU Directive 2011/65/EU | RSD (COM-007) | §6.1 |
| REACH / SVHC | EU Regulation 1907/2006 | RSD (COM-007) | §6.1 |
| POPs | EU Regulation 2019/1021 | RSD (COM-007) | §6.1 |
| PFAS restrictions | CA AB 1817 / EU PFAS | RSD (COM-007) | §6.1 |
| Ozone-depleting substances | Montreal Protocol | RSD (COM-007) | §6.1 |
| Radioactive substances | EU Council Directive 2013/51/Euratom | RSD (COM-007) | §6.1 |
| Packaging toxics | EU Directive 94/62/EC; US Model Toxics in Packaging | RSD (COM-007) | §6.1 |
| Conflict Minerals (3TG) | Dodd-Frank Act §1502 | COM-005, COM-006 | §7.0 |
| California Supply Chains Act | CA Transparency in Supply Chains Act 2010 | COM-001 | §5.1 |
| Supply chain security | CTPAT program | COM-011 | §8.1 |
| Hazmat shipping | US OSHA 1910.1200; UN GHS | SDS requirement | §6.3 |
| FDA-regulated products | US Food and Drug Administration | FDA Registration | §3.0 matrix |
| Country of origin / USMCA | US Customs & Border Protection | Supplier Handbook §8.0 | — |
| GS1 / barcode standards | GS1 Sunrise 2027 | Supplier Handbook §3.8 | — |
| CPSC (grooming appliances) | US Consumer Product Safety Commission | Addressed at PPAP/onboarding per product type | — |
If a regulatory requirement arises not yet addressed by an existing compliance document, the Compliance Department will issue an updated version of this document.
Appendix A — Compliance Document Index
| Doc ID | Document Name | Format | Current Version | Owner | Purpose |
|---|---|---|---|---|---|
| COM-001 | Supplier Code of Conduct | HTML | V2 | Compliance | Ethical, labor, environmental, and business integrity standards |
| COM-002 | Supplier Certification | HTML Form | Rev 03 | Compliance | Supplier sign-off certifying compliance with Code of Conduct |
| COM-003 | Social Responsibility Assessment | HTML Form | Rev 03 | Compliance | Social responsibility questionnaire (Parts A & B) |
| COM-004 | Social Responsibility Audit Procedure | HTML | Rev 03 | Compliance | Wahl audit process, ratings A–F, and CAP timelines |
| COM-005 | Conflict Mineral Policy | HTML | Rev 02 | Compliance | 3TG responsible sourcing policy and OECD due diligence requirement |
| COM-006 | Conflict Minerals Reporting Template ↓ XLSX RMI Source ↗ |
XLSX | 6.5 | Compliance | Smelter/refinery disclosure (CFSI/RMI format) |
| COM-007 | Restricted Substances Declaration (RSD 001) | HTML Form | Rev 05 | Compliance | Multi-regulation restricted substance certification form |
| COM-008 | RSD Instructions and Tips | HTML | Rev 00 | Compliance | Guidance and risk table for completing COM-007 |
| COM-009 | Restricted Substances Glossary | HTML | Rev 00 | Compliance | Regulatory framework definitions for COM-007 |
| COM-010 | Corporate Disclosure | HTML | Rev 03 | Compliance | California Supply Chain Transparency Act (SB 657) disclosure |
| COM-011 | CTPAT Audit Procedure | HTML | Rev 01 | Compliance | Wahl's C-TPAT audit process and program overview |
| COM-012 | Supplier Security Assessment | HTML Form | Rev 03 | Compliance | C-TPAT supply chain security questionnaire for foreign suppliers |
| COM-013 | Certificate of Insurance — Requirements | HTML | v1 | Compliance | COI coverage minimums, additional insured language, and ACORD format |
| COM-014 | Supplier Document Requirements | HTML | Rev 4 | Compliance | Master matrix of required compliance docs by supplier type and regulation |