Any factory that wants to manufacture goods bearing the Disney, Marvel, Star Wars, Pixar, or National Geographic brands must go through the Disney International Labor Standards (ILS) Program and obtain a Facility and Merchandise Authorization (FAMA). This guide explains, in practical terms, what the ILS Program requires, how the FAMA process works, which assessment pathway applies to Vietnam, and how manufacturers can prepare efficiently while avoiding the most common — and costly — mistakes.

1. What Is Disney ILS and Why Does It Matter?

Disney’s International Labor Standards (ILS) Program is the labor and workplace-conditions framework that The Walt Disney Company applies across its entire global supply chain — currently spanning roughly 40,000 facilities in nearly 100 countries. The Program requires Licensees and Vendors to ensure that facilities producing Disney-branded goods conduct regular ILS Audits and provide ILS Audit Reports, as set out in the ILS Program Manual (current edition: January 2024, subject to periodic revision). Disney manages Program requirements, statuses, and communications through its “Compass” system, accessible to authorized Licensees, Vendors, and their designated ILS Representatives.

The principles behind the Disney Code of Conduct for Manufacturers — the foundation of the ILS Program — are aligned with the core conventions of the International Labour Organization (ILO), covering child labor, forced labor, harassment and abuse, discrimination, freedom of association, workplace health and safety, and transparency.

2. FAMA: What It Is and What It Is Not

Facility and Merchandise Authorization (FAMA) is the authorization Disney issues to a specific Disney Licensee or Vendor to use a specific facility to produce a defined scope of Disney-branded merchandise.

It is important to understand what FAMA is not:

• It is not a general facility management-system certificate (unlike ISO 9001 or BSCI).
• It does not automatically transfer if the facility begins working with a different Licensee or Vendor.
• It is not issued automatically just because a facility passes an audit — Disney retains full discretion to accept, reject, or request clarification on any assessment report, and to inspect the facility at any time.

Crucially, the facility itself does not submit the FAMA Application. The Licensee or Vendor holding the contractual relationship with Disney is responsible for completing and submitting the FAMA Application through their designated Disney ILS Representative. This means the very first step for any manufacturer is to identify the correct Licensee/Vendor, deal or contract number, and ILS Representative — without this information, no assessment pathway can proceed to a valid FAMA outcome.

3. The Minimum Compliance Standard (MCS)

MCS is the compliance floor a facility must meet to be considered for Disney-branded production. It covers several critical areas:

Meeting MCS does not mean a facility has zero findings — non-conformities outside the MCS threshold still require continual improvement — but MCS violations are the “red lines” that can result in outright rejection of a FAMA application.

4. Requirements: Two Valid Assessment Pathways

Under Disney’s Country-Specific Submission Requirements Supplement, Vietnam is classified as a Permitted – Audit Required sourcing country. Within this classification, two assessment pathways apply, and choosing the correct one is essential:

Pathway A — Better Work Vietnam. Better Work — a joint program of the ILO and the International Finance Corporation (IFC) — operates in Vietnam, and factory participation in the garment/footwear sector is optional. However, if a facility does participate in Better Work, Disney will generally only accept the facility’s Better Work assessment, shared via the Better Work STAR portal (Third Party Access), rather than a separate ILS audit. For enrolled facilities, this is almost always the faster, lower-cost, and correctly recognized pathway.

Pathway B — Standalone Qualified ILS Audit. For facilities not enrolled in Better Work, a qualified ILS Audit must be conducted by an assessment body accepted under the ILS Program (e.g., SGS, Intertek, Control Union, Ecocert, QCCertification), following the audit protocol described in the ILS Program Manual.

A critical risk to avoid: booking a standalone social audit for a facility that is already a Better Work participant can result in Disney declining to accept the report — because it does not follow the required pathway for that facility’s status. Confirming pathway eligibility with the Disney ILS Representative before booking any audit is not optional; it is the single most effective way to avoid wasted cost and schedule delay.

5. How a Disney ILS Audit Is Conducted

For facilities following Pathway B, the independent assessment body typically follows this sequence:

1. Opening meeting, scope confirmation, and facility/organization mapping
2. Physical inspection of production areas, warehousing, utilities, clinic, canteen, emergency exits, chemical storage, and worker housing (if applicable)
3. Document review: permits, policies, labor records, timekeeping, wages, overtime, and benefits within a sample period
4. Confidential worker and management interviews, conducted without direct supervisors present
5. Cross-verification of consistency between records, interviews, and on-site observations
6. Closing meeting, findings confirmation, and issuance of the full audit report and Corrective Action Plan (CAP), if applicable

Audit duration (auditor-days) depends on workforce size, shift structure, number of buildings, and overall complexity — typically in the range of 12–16 auditor-days for a mid-to-large apparel or manufacturing facility.

6. The FAMA Submission Process, Step by Step

1. Precondition check — confirm Licensee/Vendor, deal information, and Disney ILS Representative.
2. Pathway determination — establish whether Better Work sharing or a standalone qualified ILS Audit applies.
3. Assessment execution — conducted by Better Work or a Disney-accepted independent assessment body.
4. CAP remediation (if findings arise) — closed within the program’s specified timeline.
5. FAMA Application submission — completed and submitted by the Licensee/Vendor, supported by the assessment report.
6. Disney review and decision — Disney may accept, request clarification, require re-assessment, or reject; processing can take approximately 30 days or longer depending on volume.

7. Why Training/Consultancy and Assessment Must Remain Separate

A well-run compliance program keeps two functions structurally separate: the party that helps the facility prepare (training, gap review, documentation readiness) and the party that conducts the independent assessment. This separation is not a bureaucratic formality — it is what preserves the objective, evidentiary value of the assessment report under Disney’s program principles. A consultancy that also performs the audit creates a conflict of interest that can undermine the credibility of the entire submission. Facilities should look for advisory partners who are explicit about this boundary, rather than firms that quietly offer to “guarantee a pass.”

8. Common Mistakes That Delay or Derail FAMA Applications

• Wrong pathway selection — booking a standalone audit for a Better Work-enrolled facility (or vice versa).
• Missing deal information — no confirmed Licensee/Vendor or contract number to anchor the submission.
• Incomplete scope declaration — undeclared buildings, shifts, dormitories, or subcontractors, which itself can constitute an MCS transparency violation.
• Unresolved CAP items — corrective actions not closed within the program’s required timeframe.
• Assuming FAMA portability — believing an existing FAMA with one Licensee automatically extends to a different Licensee or Vendor relationship. It does not; each Licensee/Vendor–facility relationship requires its own authorization.

9. Frequently Asked Questions

Does an existing ISO 9001 or BSCI certification satisfy Disney ILS requirements? No. Disney ILS is a distinct, independently managed program. Facilities must still undergo assessment under the ILS Program Manual or the Better Work pathway, regardless of other management-system certifications held.

How long does authorization remain valid? Maintaining a FAMA typically requires a new assessment annually, or on another schedule set by Disney — it is not a one-time, permanent authorization.

Can a consultancy guarantee a facility will pass? No credible advisor can guarantee outcomes, since the assessment is conducted independently and the final decision rests with Disney. A well-structured preparation program can, however, materially reduce the risk of critical findings and shorten processing time.

Contact for Business Advisory

ISC GLOBAL CO., LTD.

Hotline: +84 933 096 426 – +84 868 591 260

Email: info@iscglobal.asia | van.pham@iscglobal.asia

Website: iscglobal.asia | iscglobal.edu.vn

To manufacture products bearing Disney’s imagery, characters and brands – from Mickey and Frozen to Marvel – a factory must first be authorized by Disney through FAMA (Facility and Merchandise Authorization). This is the indispensable legal “ticket” for every factory, supplier (Vendor) and rights holder (Licensee) wishing to join The Walt Disney Company’s supply chain. The article below helps businesses fully understand the Disney FAMA standard and introduces ISC Global’s Disney FAMA certification consulting and training services.

What Is the Disney FAMA Standard?

FAMA – Facility and Merchandise Authorization is Disney’s formal approval allowing a production facility to manufacture, handle, finish, assemble or package products that bear Disney’s brands.

The core principle of FAMA is unambiguous: no Disney-branded product may be produced or handled at any facility unless and until that facility has received a Disney-signed FAMA. Each facility must have its own FAMA, and a separate FAMA application must be submitted for each geographic market in which the business works with Disney.

A “Disney-branded product” is defined as products in physical form that contain, incorporate or apply any of Disney’s intellectual property (names, marks, logos, characters, artwork, etc.). This includes products, components, packaging, advertising and promotional materials.

How Are Disney FAMA and the ILS Program Related?

FAMA does not stand alone; it is tightly linked to Disney’s International Labor Standards (ILS) Program. This is a point Vietnamese businesses often confuse.

• ILS is the system of requirements covering labor, business ethics, workplace safety and social responsibility, based on the Disney Code of Conduct for Manufacturers and the Minimum Compliance Standard (MCS).
• An ILS Audit is the on-site assessment that verifies the level of compliance with the Code and the MCS.
• FAMA is the resulting authorization: if required, the business must submit a qualified pre-production ILS audit report demonstrating compliance with the MCS before commencing production, alongside the FAMA application.

In other words: passing the ILS audit is the prerequisite, and FAMA is the formal permission for the factory to produce Disney merchandise.

Who Is Required to Have Disney FAMA?

FAMA applies to any facility (including subcontractors) owned by the Licensee/Vendor or by a third party, if that facility produces, processes, finishes, assembles or packages physical products that apply Disney’s intellectual property.

Excluded cases (no FAMA required):

• Facilities that produce only blank or generic products/components/materials that DO NOT contain Disney IP (e.g., plain cardboard boxes, plastic wrap, plain buttons).
• Suppliers of raw materials, fabric mills, or processors of generic commodity items (cotton, metal, paper…) that do not apply Disney IP.
• Agents, business offices and showrooms (if not involved in the production activities above).

Important note: Facilities may only be located in Permitted Sourcing Countries. Vietnam falls within the APAC (Asia–Pacific) region in Disney’s list of geographic markets.

Latest Update: Submitting FAMA via the Compass System (Since August 2024)

This is a key change that many businesses are not yet aware of. Effective August 2024, Disney has moved the ILS/FAMA process onto the digital platform Compass:

• If a business has an active Disney contract but has not received an invitation to access Compass, it must proactively request access at Compass.Disney.com.
• Before submitting a FAMA application for a facility, the business must first add that facility to its Facility List in Compass.
• The “Facility Actions” function in Compass can be used to check whether a facility has previously been declared to Disney.
• FAMA applications must be submitted directly within Compass (replacing the former email submission to the ILS Representative).

Mastering Compass operations and preparing the correct data is the factor that shortens review time – and is part of ISC Global’s support services.

The Disney FAMA Certification Process

1. Understand the requirements and assess the current state: master the Code of Conduct, the MCS and the scope of FAMA.
2. Remediate and prepare the factory: improve labor conditions, safety, documentation systems and business ethics to meet the MCS.
3. Access and set up Compass: request access and add the facility to the Facility List.
4. Conduct a pre-production ILS audit (if required) by a social compliance monitoring organization approved by Disney.
5. Submit the FAMA application in Compass along with supporting documents and a qualified audit report.
6. Disney reviews and signs the FAMA for the facility. Only upon receiving the signed FAMA may the facility produce Disney merchandise.
7. Maintain validity: submit periodic ILS audit reports and remediate violations within the required timeframes.

Validity and Maintenance of Disney FAMA

• A factory generally must renew/update its ILS audit report periodically (typically every 12 months) to maintain FAMA validity.
• When a contract is renewed, the business should submit a new FAMA application; however, Disney may not issue a new signed FAMA if the previously signed FAMA is still valid.
• A Disney-signed FAMA can also be presented to Customs officials to facilitate the importation of properly authorized Disney-branded products (when the facility is outside the territory where the goods are sold).

Common Mistakes That Cause Businesses to Fail or Delay FAMA

• Starting Disney production before receiving a signed FAMA – a serious violation.
• Failing the ILS audit due to MCS violations (overtime, occupational safety, underage labor, business ethics, etc.).
• Declaring facilities incompletely or incorrectly, or failing to declare subcontractors.
• Not mastering the Compass process and submitting incomplete or invalid applications.
• Failing to maintain periodic audits, causing FAMA to lapse.

ISC Global’s Disney FAMA Certification Consulting & Training Services

ISC Global Co., Ltd. accompanies businesses in obtaining and maintaining Disney FAMA in a structured, cost-effective and sustainable way:

1. Consulting to build a system that meets Disney ILS & FAMA

• Gap analysis of the current state against Disney’s Code of Conduct and the MCS.
• Remediation planning and development of documentation systems and management processes for labor, safety and business ethics.
• Consulting on facility declaration and FAMA application submission within the Compass system.

2. Awareness and internal capability training

• Training on the Code of Conduct, the MCS and ILS audit requirements.
• Training the team to prepare documentation, operate Compass and get ready for on-site audits.
• Internal auditor training and self-inspection processes.

3. Audit and certification support

• Internal audits, mock audits, and guidance on corrective action plans (CAP).
• Support in working with Disney-approved social compliance monitoring organizations.
• Accompaniment until the factory receives its signed FAMA.

4. Maintenance and renewal

• Support in planning periodic audits and maintaining FAMA validity.
• Timely updates whenever Disney changes its process, documentation or the Compass platform.

Why Choose ISC Global?

• Experts with deep knowledge of the Disney ILS/FAMA program who continuously track the latest changes (including the Compass system).
• Tailored solutions for specific product categories (apparel, toys, backpacks & bags, ceramics, housewares, packaging, etc.).
• End-to-end accompaniment from consulting, remediation, training and auditing through to maintenance and renewal.
• Optimized time and cost, minimizing the risk of audit failure and FAMA delays.

Frequently Asked Questions About Disney FAMA

Is Disney FAMA a standalone certification? FAMA is Disney’s authorization for each individual facility, tightly linked to compliance with the ILS program. Passing the ILS audit is typically a prerequisite for obtaining FAMA.

Does my factory need a FAMA for each market? Yes. A business must submit a separate FAMA application for each geographic market it works with Disney in; a facility used for multiple markets requires multiple FAMA applications.

How long is FAMA valid? FAMA is tied to maintaining the ILS audit; a factory typically must update its audit report periodically (every 12 months) to maintain validity.

Does a facility that only makes blank packaging need FAMA? No, if the product/material does not contain and does not apply Disney’s intellectual property, it falls under the exclusions.

Where is FAMA submitted? Since August 2024, FAMA applications are submitted directly within Disney’s Compass system after the facility has been added to the Facility List.

CONTACT US FOR DISNEY FAMA CERTIFICATION CONSULTING

ISC Global Co., Ltd. Hotline / Zalo:

• +84 933 096 426
• +84 868 591 260

Contact us now for a free consultation on a roadmap to obtain Disney FAMA certification and pass the ILS audit, tailored to your factory.

Email:

• info@iscglobal.asia
• van.pham@iscglobal.asia

Website:

• https://iscglobal.asia/
• https://iscglobal.edu.vn/