KATE SPADE & COMPANY Kate Spade & Company Classification Process Standard Operating Procedures Please note the information contained herein is strictly confidential and should only be shared with those directly associated with Kate Spade & Company

KATE SPADE & COMPANY Purpose of Classification It is the responsibility of the importer to ensure goods are properly classified Serves as preliminary basis of determining potential qualification under a duty preference trade program Determines duty percentage which ultimately affects profit margins Required for Importer Security Filing (ISF)/EU Advance Manifest Requirement Crucial component that is utilized by Customs for Compliance Audits 2

KATE SPADE & COMPANY Consequences of Non-Compliance Delays in customs clearance, potential fines, financial penalties, and storage charges, etc. – ISF Filing U.S. Customs may assess penalties for incorrect and or untimely information – Loss of competitive advantage Increased costs per imported goods Reduce profitability Loss of preferential duty treatment under Special Trade Agreement Increased risk of audits 3

KATE SPADE & COMPANY Classification Process Contact must provide line sheets to Annette Kate Spade 8 weeks prior to x-factory date This process is to be performed every season for all/any Kate Spade styles. If classification specialist requires additional information, the division contact should respond within hrs after initial request. 4

KATE SPADE & COMPANY Required Information for all Scarves PICTURE OF STYLE STYLE NUMBER COUNTRY OF ORIGIN FIBER CONTENT WHETHER KNIT OR WOVEN IF CONTAINS FAUX FUR; ACTUAL CONTENT OF THE FAUX FUR 5

KATE SPADE & COMPANY PICTURE OF STYLE STYLE NUMBER COUNTRY OF ORIGIN FIBER CONTENT WHETHER KNIT OR WOVEN WHETHER CONSISTS OF FELT IF CONTAINS FAUX FUR; ACTUAL CONTENT OF THE FAUX FUR 6 Required Information for all Hats

KATE SPADE & COMPANY Required Information for Belts PICTURE OF STYLE STYLE NUMBER COUNTRY OF ORIGIN FIBER CONTENT (i.e., Iron, Steel, etc.) WHETHER KNIT OR WOVEN EXTERIOR CONTENT INTERIOR CONTENT (content that touches the waist, gird) 7

KATE SPADE & COMPANY Required information for Gloves/Mittens PICTURE OF STYLE STYLE NUMBER COUNTRY OF ORIGIN FIBER CONTENT, INCLUDING CONTENT OF THE PALM IF DIFFERENT THAN THAT OF THE BODY OF THE GLOVES/MITTENS IF LINED; CONTENT OF THE LINING WHETHER KNIT OR WOVEN IF CONTAINS FAUX FUR, ACTUAL CONTENT OF THE FAUX FUR 8

KATE SPADE & COMPANY Garment Labeling Disclosure The Federal Trade Commission governs labeling regulations with regard to textile, wool and fur products. Every article should be marked with the following: Country of Origin (located in the center back of the garment) RN number Fiber Content Care Instructions The label must be: Permanent: Marking must be indelible and not easily removable, until it reaches the ultimate consumer. Legible: The lettering must be of the same size and color. It needs to be readily seen at normal eye distance. Conspicuous: It must be readily accessible to the purchaser. Documents such as Lab Tests must be kept on file as reference. 9

KATE SPADE & COMPANY Garment Labeling Disclosure Labeling Practices Fibers of less than 5% should be disclosed as “other fiber” or “other fibers”. “Wool” and “Spandex” should always be disclosed regardless of the percentage. Fiber contents must be reflected in order of predominance. Example:70% Cotton 20% Rayon 10% Nylon Multiple, non-functionally significant fibers in amounts of 5% or less, should be reflected with their aggregate percentage, even if it is greater than 5%. Example:90% Cotton 4% Spandex 6% Other Fibers Decorative trim exceeding 15% of the surface area requires disclosure. Example: 100% Cotton Trim: 100% Nylon 10

KATE SPADE & COMPANY Garment Labeling Disclosure Labeling Practices Sectional disclosure is required if a product has separate sections with different fiber content compositions. The content of each section should be identified separately on the label. Example: Body: 100% Cotton Sleeves: 80% Cotton/20% Polyester Fibers, whether natural or man-made, must be identified by their generic names. There is a 3% tolerance for fiber content on labels. This does not mean you can knowingly misrepresent the fiber amounts. The tolerance allows for a small amount of unintended inconsistency in the manufacturing process. 11

KATE SPADE & COMPANY Annette Diamond, Trade Compliance Analyst Tel. (201) Classification Contacts