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California Transparency in Supply Chain Act of 2010

On September 30, 2010, the California Transparency in Supply Chain Act of 2010 was signed into law. This statute applies to all retail companies with gross global sales in excess of $100 million selling product in the State of California. It creates public reporting requirements for companies to verify that their Supply Chain evaluates and addresses risks of human trafficking and slavery. Under the statute, the disclosure requirements will be effective from January 1, 2012.



Highlights of the Law

Under the law, any retail company selling product in the State of California must post a public disclosure on its website stating that the company and its direct contractors:

  • do not employ slaves or trafficked persons, and
  • take steps to ensure that neither the company, nor its direct contractors, employs slaves or trafficked persons.


Beyond the policy statements, the law specifically requires that the company disclose on its website the extent to which, if at all, the company:

  • performs verification of product supply chains to evaluate and address risks of human trafficking and slavery including disclosure of the nature of the verification by an internal or independent third party;
  • conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains, including disclosure of the method if the audit is not performed on an unannounced basis by an independent third party;
  • requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which suppliers do business;
  • maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking; and
  • provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chain.



Berlin Packaging Can Help

We work very closely with our Supply Partners on this topic to provide the information required to support the compliance needs of our customers. This information gives our customers the necessary tools to evaluate their supply chain and ensure compliance with The Act.


Berlin Packaging is ready to help you with the California Transparency in Supply Chain Act of 2010. If you have any questions about the Act or if you need additional information, please contact your Packaging Consultant or fill out this form to have a Packaging Consultant contact you.



Useful Links

California Transparency in Supply Chain Act 2010

Explanation / Impact of "The Act" Outside California

Bureau Veritas Group Summary