The new Controlled Supply Chain Scheme (CSCS) under the Global Organic Textile Standard (GOTS) offers a simplified certification pathway tailored for small-scale textile operators, especially in low-risk countries. This controlled supply chain approach was introduced to prevent the exclusion of small facilities, cut costs and administrative burdens, and boost GOTS compliance across every link of the chain. In essence, CSCS allows a group of 4–30 small facilities (each with ≤20 workers) to be certified as a single entity. Importantly, all standard GOTS requirements still apply – CSCS simply streamlines certification without weakening organic or social standards.
Purpose and Scope of CSCS
Under CSCS, a supply chain is defined as a group of 4 to 30 small-scale facilities (textile processors or manufacturers), each employing no more than 20 people, located in low-risk countries. These criteria ensure the scheme targets genuinely small operators. A certified group is recognized as one Certified Entity with a single Scope Certificate. (A Scope Certificate is the official GOTS document listing all approved processes, facilities and products for that certified entity.) Low-risk countries are those with relatively high labour standards and protections, identified using international indices (ILO, ITUC, OECD, etc.). All participating organisations must agree in writing on their internal structure and designate key personnel for CSCS oversight.
Key points on scope and eligibility:
Group size: 4–30 facilities (each ≤20 workers).
Low-risk countries: Identified by global labour and human rights indices.
Facilities: Any site handling GOTS goods (processing, trading, retail, even warehouses) can join under the group’s Scope Certificate.
Internal inspector: The group must have at least one qualified Internal Inspector for audits.
Eligibility Criteria for Facilities
To qualify under CSCS, each facility must meet these conditions:
Small-scale: 20 or fewer permanent employees (part-time and seasonal workers are excluded from the count).
Location: Situated in a low-risk country (see definition above).
Commitment: Able and willing to participate in the CSCS internal inspection process (e.g. record-keeping, training, scheduling audits).
Facilities exceeding 20 employees cannot join a CSCS group. By grouping together, these small facilities can pool resources and share one GOTS certification, making “organic cotton certification simplified” and more affordable for each member.
Key Roles & Responsibilities in CSCS
Effective CSCS implementation relies on defined roles for management and inspections. Each key role can be held by a single person or multiple people, depending on group size, but the responsibilities include:
Supply Chain Manager (SCM): Oversees the entire CSCS supply chain. The SCM sets policies and timelines for GOTS compliance, ensures everyone understands GOTS criteria, reviews internal audit reports, and initiates corrective actions when needed.
Supply Chain Officer (SCO): (Also called Group Leader) Supports the SCM by managing a subset of facilities. The SCO communicates the SCM’s compliance goals to those sites, supervises day-to-day operations, and helps ensure local teams take corrective action as needed.
Factory Manager (FM): Each facility appoints an FM to manage that site. The FM enforces the policies set by the SCM/SCO and implements on-site corrective measures for any non-conformities found.
Internal Inspector (II): A trained auditor (minimum 2 years textile experience and ISO 19011/GOTS training) responsible for performing internal inspections across the supply chain. The II uses CB-provided checklists to verify environmental, chemical and social compliance in every facility, and reports findings to the SCM/SCO and the Certification Body (CB).
Each role is part of the senior management within its facility, and all must be documented and (where required) trained. For example, an II must complete a CB-approved training course before appointment.
Internal Inspection Procedures
Under CSCS, internal inspections replace many of the annual audits that a Certification Body would normally perform on each small facility. The CSCS procedure mandates a comprehensive audit system that demonstrates effective GOTS management across the entire chain. Key elements include:
Clear Policies & Goals: The group must set and maintain consistent policies covering environmental standards, chemical use, social working conditions, quality control, storage and transport.
Established CSCS System: Documented methods for processing, storage and transport must be in place and conform to GOTS, along with an implementation plan and compliance monitoring mechanism.
Documented Flow & Roles: The organisational structure, staff roles (and qualifications), material flow through each stage, and any key risks must be clearly recorded.
Training & Education: There must be a plan for training all personnel on GOTS requirements to ensure ongoing compliance.
Internal Standards: The supply chain sets its own internal checklists or standards (either chain-wide or per-facility) aligned with GOTS criteria.
Inspection schedule: In the first year under CSCS, all facilities are audited in person by the Internal Inspector. In later years, inspections become risk-based: at least one audit per facility occurs within a five-year cycle. These audits can be on-site, remote, or even desktop reviews depending on the situation. For example, smaller chains might inspect 3–6 facilities each year (with the rest done remotely), as suggested by the CSCS inspection guide.
Reporting and corrective action: After each audit, the SCM reviews the Internal Inspector’s report, implements corrective actions, and immediately notifies facility teams of any required fixes. The SCM then compiles all inspection reports (summarising non-conformities and corrective steps) and submits an annual report to the Certification Body, with any major issues flagged immediately. This internal control system ensures the chain stays GOTS-compliant between CB audits.
Certification Body (CB) Functions
Even with CSCS, a GOTS-approved Certification Body (CB) retains ultimate responsibility for certifying the group. The CB’s role shifts to focus on overseeing the chain’s internal control system rather than auditing every site. Key CB responsibilities include:
Evaluating Control Systems: The CB reviews the overall CSCS management structure, traceability of organic fibre, and mass-balance records to ensure integrity of the chain. It checks that the documented policies and procedures (from internal inspections) are sound.
Auditing Facilities: Each year, the CB conducts on-site audits of a subset of facilities. At a minimum, one tenth of the facilities listed on the Scope Certificate are inspected annually. The exact number may increase based on risk. For example, in a group of 16 factories, a CB might audit 4 sites (√16) if deemed high-risk. The main certified entity (the Scope Certificate holder) is always audited in person during initial certification and each recertification.
Reviewing Internal Reports: The CB examines the internal inspection reports and verifies that all corrective actions for identified non-conformities have been effectively implemented.
Issuing Certificates and Signatory Approval: After successful audits, the CB issues or updates the group’s Scope Certificate and any needed Transaction Certificates. The CB also authorises the use of the GOTS logo/signs on products per standard rules.
In every step, the CB ensures full alignment with GOTS standards. Importantly, the ultimate decision to grant or continue certification remains with the CB – CSCS simply changes how the chain is managed, not what is required.
Audit and Recertification Protocols
Under CSCS, initial certification requires the SCM to submit the first round of internal audit reports along with the application. From then on, annual internal reports are provided to the CB for recertification purposes, and any serious non-conformities must be reported immediately.
On the CB side, audits follow a formula that balances thoroughness with efficiency. In the first-year audit, the CB will inspect roughly the square root of the total facilities. For example, if 16 sites are in the group (A=16), √16=4 facilities would be audited (rounded up). Each distinct process type on the Scope (e.g. spinning, dyeing, weaving) must be covered by at least one site audit in the first year.
For subsequent recertifications, the CB inspects a minimum number of sites based on group size: 1 inspection if <10 facilities, 2 if <20, and 3 if <30. If needed for higher assurance, the CB can increase audits up to √N sites depending on risk. The CSCS guide provides examples: e.g. for 12 facilities, a well-managed chain would have just 2 audits (minimum), while a high-risk scenario might call for 4 audits.
Overall, CSCS combines internal audits with targeted CB audits. By leveraging trained inspectors within the group, the certification process becomes more flexible and cost-effective, while still meeting GOTS’s strict audit requirements.
Benefits of CSCS Certification
The CSCS model delivers clear advantages for small organic cotton producers and textile makers:
Cost Reduction: By outsourcing most inspection work to trained staff inside the chain, CSCS significantly lowers auditing and certification fees. Small facilities no longer pay as much for travel and external audits on every site.
Administrative Simplicity: One group certificate replaces many individual ones. Internal reporting and a shared compliance system reduce paperwork and bureaucracy for each facility.
Improved Access: More small operators can join the GOTS program. CSCS “helps smaller facilities stay competitive” and promotes inclusivity in organic textile supply chains.
Maintained Integrity: Despite simplification, GOTS standards remain uncompromised. Strong internal controls and CB oversight ensure product quality and traceability. In fact, CSCS can even enhance traceability by formalising group-level management.
In short, CSCS simplifies “organic cotton certification simplified” for low-volume manufacturers. It empowers rural or artisanal operators to enter the organic textiles market without prohibitive cost or complexity, all while fostering responsible production practices across the chain.
Next Steps and Call to Action
If your textile operations fit the criteria – or if you are an organic cotton producer working with small spinning/weaving facilities – it’s time to consider CSCS. Eligible groups should:
Review Eligibility: Ensure you have 4–30 small facilities (≤20 workers each) in a low-risk country.
Appoint Key Personnel: Identify or train a Supply Chain Manager, Internal Inspector and other roles as needed.
Develop Compliance Plans: Prepare your internal inspection system (policies, documentation, training program).
Contact a GOTS CB: Reach out to an accredited GOTS Certification Body to discuss a CSCS group certification and application requirements.
By taking these steps, your organisation can leverage the new GOTS CSCS certification pathway to simplify compliance and reduce costs. CSCS is available now (effective May 2025) and can be implemented immediately. We encourage all small-scale textile operators in eligible countries to explore CSCS as a way to streamline organic cotton certification and strengthen sustainable practices across their supply chain.