Compliance & Legal Documentation

Company Information

Cup Source, Inc. is a Delaware corporation (Entity No. 7204581) incorporated on March 12, 2015. The company operates as a wholesale distributor and private-label manufacturer of disposable and reusable beverage containers, food service packaging, and related accessories.

Detail	Information
Legal Name	Cup Source, Inc.
D&B Number	08-845-2190
EIN / Tax ID	82-4910375
DUNS Number	08-395-1027
NAICS Code	423990 (Miscellaneous Durable Goods Wholesalers)
Headquarters	1200 Commerce Way, Suite 400, Charlotte, NC 28202
DUNS Number	08-395-1027
DUNS Number	08-395-1027
NAICS Code	423990 (Miscellaneous Durable Goods Wholesalers)
Headquarters	1200 Commerce Way, Suite 400, Charlotte, NC 28202

Board of Directors

The Board of Directors convenes quarterly to review corporate strategy, financial performance, and compliance oversight. Current board composition:

1. Marcus Reynolds — Chairman of the Board & CEO
2. Dr. Priya Sharma — Independent Director
3. James Kowalski — CFO & Vice President
4. Linda Tanaka — Independent Director
5. Robert Okonkwo — General Counsel

Corporate Policies

Cup Source maintains the following internal governance documents:

• Code of Business Conduct & Ethics (adopted June 2018)
• Antitrust & Competition Compliance Policy
• Insider Trading Policy
• Whistleblower Protection & Reporting Procedure
• Related-Party Transaction Policy
• Anti-Bribery & Anti-Corruption Policy (FCPA compliant)

1. Acceptance of Terms

By accessing, browsing, or placing an order on Cup Source's website, mobile applications, or through our sales representatives, you agree to be bound by these Terms of Service. If you do not agree, you may not use our services.

2. Account Registration

To place wholesale orders, you must register a business account. Cup Source reserves the right to verify business credentials, including:

• Valid business license or resale certificate
• Employer Identification Number (EIN) or state tax ID
• Business physical address and phone number
• Bank account or credit card verification for payment terms

3. Pricing & Payment Terms

Pricing is determined by market conditions, order volume, and contract terms. Prices are quoted in USD and are subject to change without prior notice. Payment terms include:

Payment Method	Terms	Minimum Order
Credit Card (Visa/MC/Amex)	Net 0 (immediate)	$500
Wire Transfer	Net 30	$2,000
ACH / EFT	Net 45	$1,500
Letter of Credit	As negotiated	$10,000
Net 60 (Approved Accounts)	Net 60	$5,000

4. Orders & Cancellations

Orders are not confirmed until Cup Source issues an order acknowledgment. Cancellations may be made within 4 hours of order placement. After acknowledgment, cancellation is subject to a 15% restocking fee and any manufacturing costs incurred.

5. Intellectual Property

All product designs, branding materials, catalog content, and website content are the exclusive property of Cup Source, Inc. Unauthorized reproduction, distribution, or modification is strictly prohibited.

6. Limitation of Liability

Cup Source's total liability for any claim arising from the use of its products or services shall not exceed the total amount paid by the customer in the twelve (12) months preceding the claim. Cup Source is not liable for consequential, incidental, or punitive damages.

7. Governing Law

These Terms shall be governed by and construed in accordance with the laws of the State of North Carolina, without regard to its conflict of laws principles. Any disputes shall be resolved in the state or federal courts located in Mecklenburg County, NC.

1. Information We Collect

Cup Source collects information to provide and improve our wholesale services:

• Business Information: Company name, address, phone, email, tax ID, resale certificate
• Order Information: Purchase history, shipping addresses, billing details
• Account Credentials: Username, encrypted password, MFA tokens
• Website Data: IP address, browser type, cookies, usage analytics
• Communication Data: Support tickets, email correspondence, call recordings

2. How We Use Information

Personal and business information is used to:

• Process and fulfill wholesale orders
• Verify business credentials and resale status
• Communicate order status, shipping updates, and policy changes
• Provide personalized product recommendations
• Comply with legal and tax obligations
• Improve website functionality and user experience

3. Data Sharing & Disclosure

We do not sell personal or business data. Information may be shared with:

• Shipping Carriers: FedEx, UPS, DHL (for delivery fulfillment)
• Payment Processors: Stripe, PayPal (PCI-DSS compliant)
• Manufacturing Partners: Only for private-label order fulfillment
• Legal Authorities: When required by law or subpoena

4. Data Retention

Business records are retained for seven (7) years per IRS and state tax requirements. Account data for inactive accounts is archived after 36 months of inactivity.

5. Your Rights (GDPR / CCPA)

California residents and EU citizens have the right to:

1. Request access to personal data we hold
2. Request correction or deletion of personal data
3. Opt out of data sales (CCPA)
4. Object to automated decision-making
5. Withdraw consent at any time

Security Infrastructure

Cup Source employs a multi-layered security approach to protect customer data, order systems, and corporate communications:

Control Area	Implementation	Standard
Encryption (in transit)	TLS 1.3 across all connections	NIST SP 800-52r2
Encryption (at rest)	AES-256 for all databases	NIST SP 800-111
Access Control	Role-based access + MFA	ISO 27001 A.9
Penetration Testing	Annual third-party audit	OWASP Top 10
Incident Response	24/7 SOC monitoring	ISO 27035
Data Backup	Geographically redundant, 99.99% SLA	ISO 22301

Breach Notification

In the event of a confirmed data breach affecting customer information, Cup Source will notify affected parties within 72 hours of discovery, in compliance with applicable data breach notification laws. Notifications will include:

• The nature of the breach and data involved
• Steps taken to contain and remediate
• Recommended protective measures for affected parties
• Contact information for our data protection officer

Data Protection Officer

For all data protection inquiries, DPA requests, or security concerns:

Email: dpo@cupsource.com
Phone: +1 (800) 555-0199 ext. 4200
Mailing: DPO, Cup Source, Inc., 1200 Commerce Way, Suite 400, Charlotte, NC 28202

Shipping Terms

Shipping Method	Transit Time	Minimum Order	Cost
Standard LTL (Freight)	5–7 business days	$1,000	Calculated at checkout
Expedited LTL	3–4 business days	$1,000	+25% of standard
FedEx Ground	2–5 business days	$500	Free over $1,500
FedEx 2-Day	2 business days	$500	+15% of standard
FedEx Overnight	1 business day	$1,000	+35% of standard
Intl. Freight (DHL/UPS)	7–14 business days	$5,000	Calculated at checkout

International Shipping

International orders are shipped DDP (Delivered Duty Paid) for most destinations. Import duties and taxes may apply for select destinations. All shipments include:

• Commercial invoice
• Bill of lading
• Product safety data sheets (SDS)
• Country of origin documentation

Returns & Refunds

Condition	Eligibility	Restocking Fee
Undamaged, unopened stock	Within 30 days	10%
Product defect / quality issue	Within 90 days	None
Wrong item shipped	Within 15 days	None
Custom / private-label items	Non-returnable	N/A
Canceled after manufacturing	Subject to contract	Up to 50%

Warranty

All Cup Source products are warranted against manufacturing defects for a period of 90 days from delivery date. Products that fail under normal use will be replaced at Cup Source's discretion. This warranty does not cover damage from improper storage, mishandling, or unauthorized modifications.

Quality Management System

Cup Source operates under an ISO 9001:2015 certified Quality Management System (QMS). Every product undergoes the following quality checkpoints:

1. Raw Material Inspection: Incoming materials verified against specification sheets and tested for food-contact compliance
2. In-Process Monitoring: Statistical process control (SPC) at every production stage
3. Final Inspection: 100% visual inspection with automated defect detection
4. Random Sampling: AQL Level II sampling per ANSI/ASQ Z1.4 standard
5. Batch Testing: Chemical migration tests per FDA 21 CFR 176.170

Product Compliance Standards

Product Category	FDA Regulation	Additional Standards
Paper Cups	21 CFR 176.170 (Paper & Paperboard)	FSC certified, BPA-free
PET Cold Cups	21 CFR 177.1633 (PET Resin)	APCO compliant
PP Bowls	21 CFR 177.1520 (PP Resin)	MicroWave-safe rated
Lids (PS/PP)	21 CFR 177.1315 (Polystyrene)	Child-resistant options available
Compostable Cups	ASTM D6400 / EN 13432	TUV Austria OK Compost certified
Biodegradable Bags	ASTM D6868	USDA Biobased 40%+

Recall Procedure

In the event of a product recall, Cup Source will:

• Immediately notify all affected customers via email, phone, and certified mail
• Provide full refund or replacement within 5 business days
• Report to FDA's Division of Industry Operations and Expedited Reviews (DIOER)
• Post recall notices on the Cup Source website within 24 hours
• Coordinate with regulatory authorities on disposal instructions

FDA Registration

Cup Source is registered with the U.S. Food and Drug Administration as a food facility under the FDA Food Safety Modernization Act (FSMA). Registration number: 1884562109 (Last renewed: January 2024).

State & Local Registrations

Jurisdiction	Registration / License	Expiry
North Carolina (State)	Sales & Use Tax Permit #SUT-NC-88452190	Dec 2026
California (DTSC)	Hazardous Waste Generator Permit #CA-DTSC-44120	Mar 2026
New York (DEC)	Environmental Compliance Permit #NY-DEC-77201	Jun 2026
Florida (Department of Agriculture)	Food Handling License #FL-FDH-339201	Sep 2025
Texas (TCEQ)	Air Quality Permit #TX-TCEQ-AQ-55210	Aug 2026

Industry Memberships & Certifications

• Packaging for Produce (PPSC) — Member since 2017
• American Chemistry Council (ACC) — Associate Member
• FSC Chain of Custody Certificate #SGS-COC-10234
• Biodegradable Products Association (BPA) — Certified Member
APCO (Association of Plastic Containers) — Active Member
• International Safe Transit Association (ISTA) — Certified

Environmental Policy Statement

Cup Source is committed to minimizing the environmental impact of our manufacturing, distribution, and operations. We actively develop and supply sustainable packaging solutions that help our customers meet their own environmental goals.

Sustainability Metrics (FY2024)

Metric	Target	Actual	Status
Recycled Content in Products	30%	38%	✅ Exceeded
Renewable Energy (Operations)	50%	62%	✅ Exceeded
Landfill Waste Diversion	85%	91%	✅ Exceeded
CO₂ Reduction (vs. FY2020)	25%	29%	✅ Exceeded
Compostable Product Line	20% SKU share	34% SKU share	✅ Exceeded
Water Usage Reduction	15%	12%	🔄 In Progress

Compostable Product Standards

All compostable products sold by Cup Source meet the following standards:

• ASTM D6400: Standard specification for compostable plastics
• EN 13432: European compostability requirement
• AS 4736: Australian compostability standard
• TUV Austria OK Compost Industrial: Third-party certified
• NOAA Safe Composting: NOAA-compliant formulation

Extended Producer Responsibility (EPR)

Cup Source participates in EPR programs in the following jurisdictions:

• California — SB 1383 (Organic Waste Diversion)
• Colorado — SB 21-169 (Packaging Waste Reduction)
• Maine — ME PLI Program (Producer Responsibility Organization)
• Oregon — OR PLA Program
• Queen Anne's County, MD — Compostable Packaging Ordinance

Export Classification

Our products are classified under the following Harmonized Tariff Schedule (HTS) codes:

Product	HTS Code	Description
Paper Cups	4823.69.00	Cut paper & paperboard, folded or machine-made
PET Cold Cups	3923.30.00	Plastics — Tables, kitchenware
PP Bowls	3924.10.00	Plastics — Tableware & kitchenware
Lids & Sleeves	3923.29.00	Plastics — Sacks & bags
Compostable Cups	4823.90.40	Other processed paper
Bamboo Fiber Products	4602.12.00	Vegetable material baskets

Export Controls

Cup Source complies with all applicable U.S. export control regulations, including:

• Export Administration Regulations (EAR): Administered by the Bureau of Industry and Security (BIS)
• Office of Foreign Assets Control (OFAC): Sanctions screening on all international transactions
• Customs-Trade Partnership Against Terrorism (C-TPAT): Supply chain security certification
• AEO (Authorized Economic Operator): EU equivalent program participation

Restricted Destinations

Products cannot be shipped to countries subject to comprehensive U.S. embargo, including: Cuba, Iran, North Korea, Syria, and Crimea Region. Customers in restricted areas are screened at order placement.

The following certificates of compliance are maintained by Cup Source for all product categories. Click the download link for each certificate.

Certificate	Issuing Body	Valid Through	Scope	Download
ISO 9001:2015 QMS	SGS USA	Jun 2027	Manufacturing & Distribution	📥 Certificate
ISO 14001:2015 EMS	BSI Group	Oct 2026	Environmental Management	📥 Certificate
FDA Food Facility Registration	U.S. FDA	Jan 2026	Food-Contact Materials	📥 Registration
FSC Chain of Custody	SGS-Forest Stewardship Council	Mar 2026	Paper-Based Products	📥 Certificate
OK Compost INDUSTRIAL	TÜV AUSTRIA	Aug 2027	Compostable Product Line	📥 Certificate
APCO Compliance	APCO	Dec 2026	PET Plastic Cups	📥 Certificate
C-TPAT Certification	U.S. CBP	Jul 2026	Supply Chain Security	📥 Certificate
Microbial Safety Testing	NSF International	Sep 2026	Food Safety	📥 Certificate