Third-Party Audit Preparation for Fashion Brands: What Certification Bodies Like Control Union Actually Inspect When Verifying GRS and GOTS Claims

When a certification body like Control Union conducts a GRS or GOTS audit, it goes far beyond checking paperwork. Auditors physically verify material traceability through every stage of the supply chain, confirm that certified inputs match transaction certificates, assess chemical management systems, and interview workers. Fashion brands that understand exactly what inspectors scrutinize, and prepare their supply chains accordingly, avoid costly certification failures and reputational damage.

TL;DR

• GRS and GOTS audits inspect the full chain of custody, not just the end product.

• Auditors verify transaction certificates, input/output ratios, and physical material segregation.

• GOTS additionally covers chemical inputs, wastewater, and social criteria at every processing stage.

• Documentation gaps, untrained staff, and unverified supplier certificates are the most common audit failures.

• Choosing certified suppliers with up-to-date, publicly verifiable licenses significantly reduces your audit risk.

About the Author:

Sungil Tex is a Hong Kong-headquartered sustainable textile supplier operating since 2008, holding active Control Union certifications for both GRS (License CU 1022128) and GOTS (License CU 1022128), and supplying certified sustainable linings to over 200 global fashion brands including Burberry, Ralph Lauren, and Tommy Hilfiger.

What Is the Difference Between GRS and GOTS Certification in Audit Terms?

GRS (Global Recycled Standard) and GOTS (Global Organic Textile Standard) are both chain-of-custody standards, but they verify fundamentally different material claims and therefore trigger different audit scopes [3].

Criterion	GRS	GOTS
Material claim verified	Recycled content percentage	Organic fibre content and processing
Chemical criteria	Limited (processing aids)	Extensive (prohibited substances list)
Social criteria	Basic social requirements	Detailed labour and social criteria
Who must be certified	Every handler in the supply chain	Every handler in the supply chain [1]
Transaction certificate required	Yes, per shipment	Yes, per shipment

Both standards rely on accredited certification bodies, such as Control Union, to conduct on-site inspections and issue certifications to processors, manufacturers, and traders [1]. The key insight most brands miss: your own certification is only as strong as the weakest certified link in your supplier chain.

What Do Auditors Actually Inspect During a GRS or GOTS Audit?

Auditors follow a structured inspection protocol that spans documentation, physical processes, and personnel [5]. Expect scrutiny across three distinct phases.

Phase 1: Document and Certificate Verification

• Scope certificates for every supplier in the chain, cross-checked against the certification body's public database for validity and expiry [5].

• Transaction certificates (TCs) matched against purchase orders, invoices, and delivery notes.

• Input/output mass balance: the quantity of certified material purchased must logically reconcile with the quantity of certified product sold.

• Internal audit records and corrective action logs from previous cycles.

Phase 2: Physical Facility and Process Inspection

• Segregation of certified versus non-certified materials in storage, cutting, and production areas.

• Labelling and identification systems that trace certified material from goods-in to goods-out.

• For GOTS: review of the approved chemical inputs list, chemical storage, and wastewater treatment evidence [3].

• For GRS: verification that recycled feedstock sources are documented and traceable.

Phase 3: Personnel Interviews and System Stress-Testing

• Interviews with production, purchasing, and quality staff to verify that certification procedures are understood and consistently applied [5].

• GOTS auditors additionally assess social compliance: wages, working hours, freedom of association, and health and safety conditions [4].

• Auditors may present hypothetical scenarios to test whether staff responses match documented procedures.

Where Do Fashion Brands Most Commonly Fail Audits?

Audit failures cluster around predictable, preventable gaps. Understanding them is more valuable than a generic checklist.

• Expired supplier scope certificates: A supplier's GRS or GOTS certificate may have lapsed between your sourcing decision and the audit date. Auditors will not accept expired documentation [2].

• Missing or mismatched transaction certificates: TCs must accompany every certified shipment. Gaps in the TC chain break the chain of custody entirely.

• Untrained staff: Production workers unable to explain how certified material is identified or segregated is a direct audit finding [5].

• Mass balance discrepancies: If purchased certified input volumes do not match certified output volumes within acceptable conversion ratios, auditors flag potential greenwashing.

• Unapproved chemical substitutions (GOTS-specific): Switching a processing chemical without updating the approved inputs list is a common non-conformity [3].

How Should Fashion Brands Practically Prepare Their Supply Chains?

Preparation is a supply chain discipline, not a pre-audit scramble. A 90-day readiness framework works better than last-minute reviews.

1. Audit your suppliers' certificates first. Verify scope certificates via the certification body's public database. Confirm expiry dates and that the certified scope covers the specific product you are purchasing [5].

2. Build a TC tracking register. Maintain a live spreadsheet mapping every certified purchase order to its corresponding transaction certificate, including issue date and certifying body.

3. Conduct an internal mass balance reconciliation quarterly. Do not wait for the external auditor to find a discrepancy.

4. Train relevant staff annually. Purchasing, warehouse, and production teams should each understand their specific role in maintaining chain of custody.

5. For GOTS: maintain a chemicals register proactively. Every processing chemical used on organic fibre must appear on the approved list before use, not after [3].

6. Request supplier audit summaries. Reputable certified suppliers should be willing to share non-confidential summaries of their most recent audit outcomes and corrective actions.

How Does Choosing the Right Certified Supplier Reduce Your Audit Burden?

A certified supplier that actively maintains its chain-of-custody systems reduces the documentation and verification burden on your own audit significantly. When a brand sources certified materials from a supplier like Sungil Tex, which holds active Control Union GRS and GOTS licenses and provides complete transaction certificates and product traceability documentation, the chain-of-custody evidence your auditor requires is already structured and available. This matters practically: auditors reviewing a brand's certification will follow the material trail back through each supplier, and a well-documented upstream link shortens the auditor's workload and reduces findings risk [1].

The inverse is equally true. A supplier with poor documentation practices, lapsed certificates, or inconsistent segregation can trigger a non-conformity on your certification even when your own internal processes are sound [2].

Frequently Asked Questions

Do all companies in the supply chain need their own GRS or GOTS certification?

Yes. Every entity that takes ownership of certified material, from fibre producer to fabric mill to finished goods manufacturer, must hold its own valid scope certificate

[1]

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What is a transaction certificate and why is it critical?

A transaction certificate is a document issued by a certification body confirming that a specific shipment of goods meets the standard's requirements. It is the primary evidence linking a certified purchase to a certified sale within the chain of custody

[3]

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Can a brand use a supplier's scope certificate as proof of product certification?

No. A scope certificate confirms a supplier is eligible to produce certified goods. A transaction certificate confirms that a specific shipment actually meets the standard. Both serve distinct and necessary roles in demonstrating compliance

[2]

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How often do GRS and GOTS audits typically occur?

Certifications are generally issued on an annual basis, with on-site inspections conducted by accredited certification bodies as part of the renewal cycle

[4]

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What happens if a non-conformity is found during a GOTS audit?

Non-conformities are categorised by severity. Minor findings typically require a corrective action plan within a defined timeframe. Major findings can suspend or withdraw certification until resolved

[3]

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Is GOTS certification harder to obtain than GRS certification?

GOTS has a broader audit scope because it covers chemical management, wastewater treatment, and detailed social criteria in addition to chain-of-custody requirements, making compliance more demanding than GRS for most processors

[4]

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How can a brand verify that a supplier's certification is legitimate?

Check the certification body's public database directly using the supplier's stated license number. Control Union, for example, maintains a searchable public registry where scope certificates can be verified

[5]

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About Sungil Tex

Sungil Tex is a Hong Kong-headquartered global textile and lining supplier specialising in sustainable and recycled fabrics for the fashion and apparel industry. Operating since 2008 and recognised as Asia's leading lining supplier, the company holds active Control Union certifications for both GRS and GOTS, BCI membership, and U.S. Cotton Trust Protocol accreditation, providing buyers with fully verified chain-of-custody documentation. With a portfolio of around 50 sustainable textile types, including 100% recycled polyester, recycled nylon, BCI cotton, and biodegradable viscose, Sungil Tex offers certified sustainable materials that are competitively priced compared to standard products. The company's supply chain spans 13 countries and serves over 200 global brands, from luxury houses to emerging designers.

Ready to simplify your next GRS or GOTS audit with a fully certified, documentation-ready supply partner?

Visit Sungil Tex at sungiltex.com to explore certified sustainable lining and fabric solutions.

References

1. Third-Party Certification - GOTS - Global Organic Textile Standard (global-standard.org)

2. Labels and Certifications in the Textile Industry: A Glossary of Terms to Make Things Clearer (www.fairlymade.com)

3. GOTS and Textile Exchange (GRS, OCS, RCS and CSS) Certification - Eurofins (www.eurofins.com)

4. Sustainability Certification Organizations in the Fashion Industry (fashionunited.com)

5. How to Audit a Garment Factory's Certifications Before Placing an Order? – Shanghai Garment (shanghaigarment.com)