Why it exists
Every certification program faces the same problem. The moment a finding becomes a public event, the rational move for a brand is to stop looking — test less often, test fewer lots, avoid asking questions whose answers create disclosure obligations. A program that punishes discovery gets less discovery, and the mark it issues becomes a statement about how little a brand knows.
This track is the answer to that. A brand that identifies a problem and reports it enters a defined, confidential process with its certificate intact. The corrective action is not reduced, the re-testing is not reduced, and the deadline is real — but the finding does not become a press cycle for having been honest.
The asymmetry is deliberate and it is the whole mechanism: self-reporting is cheaper than concealment. Concealment of a known exceedance is grounds for revocation, which is the most severe outcome the program has.
The two tracks
Same corrective action, same re-testing, same deadline. What differs is disclosure — and each direction carries a real benefit, which is why it is a choice rather than a default.
The finding, the affected lots and the corrective action stay between the brand and the program while the item is open and on schedule. Nothing appears in the public register, nothing is disclosed to retailers, and the certificate is unaffected.
The brand elects to publish the finding and its remediation on its own brand page. The record shows what was found, what was done and when it closed — a documented history of catching and fixing a problem rather than an unexplained gap.
A brand may move an item from confidential to public at any time. It cannot move one the other way once disclosed, because the disclosure has already happened.
What qualifies
The track is for findings a brand brings forward, and for trends that have not yet become exceedances. It is not a route for a failure the program discovered first.
| Situation | Eligible | Why |
|---|---|---|
| Brand identifies a trend before any exceedance | yes | The intended case. Caught by the brand’s own surveillance and reported before a limit was crossed. |
| Brand identifies a Tier 2 exceedance and reports it | yes | Eligible; a transitional variance may also apply under Part 2.3 while the corrective action runs. |
| Brand identifies a Tier 1 exceedance and reports it | partial | The track governs the record. The mark is still suspended — no transitional exceedance exists for a Tier 1 metal. |
| Supplier or process change with a known contamination risk | yes | Reportable before a result exists. Opening early is cheaper than opening after a failed lot. |
| Program surveillance finds the exceedance first | no | The track rewards disclosure. A finding the program made is handled through the standard status process. |
| Known exceedance not reported | no | Grounds for revocation. This is the behavior the track exists to make irrational. |
A Tier 1 exceedance is never made eligible by having been self-reported. Self-reporting changes how it is handled, not whether the mark is suspended.
How an item runs
The brand opens an item naming what was found, the affected products and lots, and a proposed direction. A completed root-cause analysis is not required to open.
The program and the brand agree what is affected: which SKUs, which lots, whether product on shelf is implicated, and whether reflex or speciated testing is needed.
The brand executes. Supplier requalification, process change, specification update — whatever the root cause requires, with a dated deadline recorded against the item.
Fresh lots run the full analyte panel at an accredited laboratory. A trend item requires enough lots to show the trend has actually turned, not one favorable result.
The item closes against the re-test evidence. Under the confidential track it closes without ever having been public; under the public track the closure is published with it.
An item that stays on schedule has no effect on the certificate or the public register. An item that misses its corrective-action deadline converts to the standard status process, and the status change is visible in the register like any other.
Limits of confidentiality
Confidentiality here is a commercial protection, not a shield against a safety obligation. Stating its boundaries plainly is what keeps the rest of it credible.
Nothing in this track delays a recall, overrides a reporting duty, or withholds evidence from a regulator who asks. A product that should not be on shelf comes off shelf, and the confidential record is produced to a regulator on request without a subpoena.
Opening an item
Items are opened from the brand portal by any seat with Quality or Administrator access. A brand without portal access yet can open one by contacting the program directly; the confidentiality applies from first contact, not from the time an account exists.
You will be asked what you found, which products and lots are affected, and what you propose to do. You do not need a completed root-cause analysis to open an item — the clock starts on the corrective action, not on the report.