REFILL & SANITATION STANDARDS POLICY (WHOLESALE)

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SECTION 1 - PURPOSE

Rustic Strength Products are formulated and packaged to maintain purity, stability, and safety while sealed in their original containers. When Products are transferred from their original packaging for refill or bulk dispensing, the risk of contamination, degradation, and loss of traceability increases significantly.

This Policy establishes mandatory sanitation, handling, dispensing, and recordkeeping requirements for any Retailer operating a refill model or transferring Product from original containers. Strict adherence to these standards is required to protect product integrity, consumer safety, and brand trust.

SECTION 2 - RESPONSIBILITY

Retailer is solely responsible for:

• All refill and dispensing operations
• Sanitation of containers and equipment
• Employee training and supervision
• Regulatory compliance
• Consumer safety after Product leaves original packaging

Rustic Strength does not supervise, inspect, or control Retailer’s daily refill operations. Compliance with this Policy is a condition of maintaining wholesale purchasing privileges. Failure to comply constitutes a material breach of the Wholesale Agreement.

SECTION 3 - GENERAL REFILL PRINCIPLES

1. Products should be sold in their original, sealed packaging whenever possible.
2. Each transfer from original packaging increases contamination and stability risk.
3. No Product may be diluted, blended, altered, or mixed with other brands unless expressly authorized in writing by Rustic Strength.
4. “Topping off” partially filled containers is prohibited.
5. Cross-contamination between different Products is strictly prohibited.

SECTION 4 - CONTAINER CLEANING & SANITATION REQUIREMENTS

4.1 Inspection Prior to Refill
Before refill, all containers must be inspected and rejected if:

• Cracked, warped, degraded, or cloudy
• Retaining visible residue
• Retaining odor from prior contents
• Structurally compromised
• Made of an incompatible material

Retailer is solely responsible for determining container compatibility.

4.2 Cleaning (Residue Removal)

All containers must be:

• Fully emptied.
• Washed in hot water with detergent using mechanical scrubbing.
• Rinsed thoroughly with clean hot water.
• Visually inspected to confirm removal of residue.

Dishwasher use is permitted if a heated wash and heated dry cycle is used.

4.3 Sanitizing (Microbial Reduction)

After cleaning, containers must be sanitized using one of the following methods:

Glass or Metal Containers:

• Submerged in boiling water for a minimum of 15 minutes; OR
• Sanitized using a commercial-grade sanitizing solution per manufacturer concentration and contact-time instructions.

Plastic Containers:

• Soaked in 3% hydrogen peroxide for a minimum contact time of 10 minutes; OR
• Treated with 70% isopropyl alcohol and allowed to air dry completely; OR
• Sanitized using an EPA-registered food-contact-safe sanitizer per manufacturer instructions.

All containers must:

• Be allowed to air dry completely.
• Contain no residual moisture prior to refill.

Moisture remaining inside containers is prohibited. The term “sanitize” as used herein refers to the reduction of microbial contamination to safe levels. Rustic Strength does not require or represent sterilization-level processes.

SECTION 5 - DISPENSING EQUIPMENT STANDARDS

Retailer must ensure:

• Dispensing pumps, spouts, valves, and tanks are cleaned and sanitized prior to use and between different Products.
• Separate dispensing equipment is used for different Products where feasible.
• Bulk containers are protected from environmental contaminants.
• Bulk containers are stored away from direct sunlight or extreme temperatures.
• Dispensing areas remain clean, dry, and free from debris.

Equipment failure, improper cleaning, or contamination is solely Retailer’s responsibility.

SECTION 6 - CUSTOMER-SUPPLIED CONTAINERS

Retailer must:

• Refuse visibly contaminated or incompatible customer containers.
• Visually inspect containers prior to refill.
• Decline refill if the container presents a contamination risk.

Rustic Strength is not responsible for contamination arising from customer-supplied containers.

SECTION 7 - LOT TRACEABILITY REQUIREMENTS

Retailer must maintain lot traceability for all bulk Products used in refill operations.

For each bulk container, Retailer must document:

• Product name
• Bulk lot number
• Date container was opened
• Date container was emptied

Loss of lot traceability is a serious compliance failure.

SECTION 8 - SANITATION & REFILL RECORDKEEPING

Retailer must maintain written or electronic records documenting:

• Date of container sanitation
• Sanitation method used
• Employee responsible
• Product dispensed
• Bulk lot number
• Date of refill activity

Records must be retained for a minimum of two (2) years. Records must be made available upon reasonable written request in the event of recall, regulatory inquiry, insurance investigation, or contamination claim.

SECTION 9 - EMPLOYEE HYGIENE & TRAINING

Retailer must ensure:

• Employees handling refill operations practice basic hygiene.
• Hands are clean prior to handling containers.
• Staff are trained on contamination prevention procedures.
• Only trained personnel conduct refill dispensing.

Retailer is solely responsible for employee compliance.

SECTION 10 - PROHIBITED PRACTICES

The following are strictly prohibited:

• Diluting Products without written authorization
• Mixing Products with other brands
• Blending different lots
• Topping off partially filled containers
• Repackaging with misleading or incomplete labeling
• Removing or obscuring original lot identifiers prior to documentation

Violation of these prohibitions constitutes a material breach.

SECTION 11 - REGULATORY COMPLIANCE

Retailer is solely responsible for compliance with:

• Local health department regulations
• Weights and measures laws
• Labeling requirements
• Environmental regulations
• Any applicable federal or state laws governing refill dispensing

Rustic Strength makes no representation regarding Retailer’s regulatory obligations.

SECTION 12 - LIABILITY

Once Product is transferred from its original sealed packaging, Rustic Strength:

• Makes no representations or warranties regarding Product condition.
• Assumes no responsibility for contamination, degradation, instability, or consumer injury.
• Disclaims liability arising from refill or redistribution activities.

Retailer assumes all risk and liability associated with refill operations.

SECTION 13 - RIGHT TO UPDATE STANDARDS

Rustic Strength reserves the right to modify this Policy at its discretion to protect product integrity, regulatory compliance, and brand standards. Updated standards become effective upon written notice or publication. Continued refill activity constitutes acceptance.

SECTION 14 - ACKNOWLEDGMENT

Operation of any refill or bulk transfer model constitutes acknowledgment and acceptance of this Policy. Failure to comply may result in suspension or termination of wholesale privileges.