Ingredient and Declare Program Exception Verification

The Verifier will coordinate with the manufacturer to collect all applicable supplier data to verify the constituent chemistry of all raw materials within the manufacturer’s products meets the following criteria:

• CASRNs are provided for all applicable ingredients/materials and reported correctly. The Verifier should confirm any ingredients that do not require a reported CASRN per the Declare Special CASRN Reporting requirements.
• The Verifier will verify the full Product Inventory, to 100ppm, and confirm 100% of ingredients have been reviewed.
• As ILFI has a 1% by weight allowance for proprietary ingredients/materials, the Verifier will review and verify a manufacturer’s Product Inventory to 100ppm and determine that 1% or less of the product consists of proprietary chemistries and that all proprietary chemistries are disclosed by CASRNs and free of Red List chemicals.

The Verifier will vet the bill of materials and chemical inventory against the current version of the Red List, assuring all ingredients/materials that appear on the Red List and Watch List Priority for Inclusion List are identified.

• The full list of Red List CASRNs is published to the ILFI website. The full list of Red List and Watch List CASRNs are also included in the Declare submission platform on 3E Exchange (formerly Toxnot).
• If an ingredient is submitted using a European Community (EC) number or is a metal alloy submitted using a UNS or EN number, the Verifier will determine from the chemical formula and chemical structure whether the ingredient belongs to one of the Red List chemical classes. If the ingredient contains an element or functional group belonging to a Red List banned chemical class, the Verifier must submit the EC number or alloy number and chemical class to declare.support@living-future.org for direct addition to the Priority List and consideration for future addition to the Red List. The product can be marked Red List Free if it has no other Red List ingredients. However, with updates to the Red List, future labels may be Declared.
• If a polymer with no CASRN is submitted, the Verifier will ask the chemical screening questions listed for polymers with no CASRN in the Special CASRN Reporting Requirements. If the answers to the chemical screening questions are all “No” then the polymer can be considered Red List Free. An answer of “Yes” to any of the questions indicates that the polymer belongs to a Red List banned class. The polymer information polymer must be sent to declare.support@living-future.org for and the Declare label status will be “Declared.”
  

The Verifier will complete a supply chain review, documentation collection, and verification of information. The Verifier will request the following information from participating Declare manufacturers:

• Product inventory, product recipe and/or bills of materials for the specified products being assessed. All information will be reported down to the 100 ppm level to verify constituents are listed in accordance with the Declare program requirements.
• Supplier formulation confirmation for each ingredient/material listed on the bill of materials. Any combination of the following may be used to confirm 100% of a finished product’s formulation:
  • SDS or MSDS sheets for raw material ingredients within the Product Inventory/Recipe/BOM.
  • A written statement from the supplier listing the ingredient/material name and CASRN for all ingredients/materials in the supplied material to 100 ppm of the finished product pursuing a Declare label.
  • Reaction ingredients with a written statement from the manufacturer or supplier’s chemist detailing the inputs and results of the reaction.
  • Testing data confirming the material or chemical composition of the finished part/material. Testing data must explicitly show what is present in the product; testing data may not be used to simply show the absence of chemicals of concern.
• Small product hardware must be reported with an ingredient name and CASRN, when appropriate. Alloy numbers do not require reporting for metal small product hardware. Inventory or verification is not required for components that meet the definition of small product hardware. Product hardware will impact Declaration Status if Red List chemicals are used.
• Materials purchase confirmation for each ingredient/material present in the final product at or above 100 ppm. The following may be used to demonstrate purchasing compliance:
  • Purchase Orders from each supplier to validate the material they supplied is purchased by the product manufacturer.
  • Executed supplier contracts for parts/components whose formulation is specified as part of a contract.
  • For parts/components with testing data confirming the formulation, ingredient/material purchasing confirmation is not required.
• Supplier contact information including contact name, phone number and email address for suppliers or complete supplier surveys through 3E Exchange (formerly Toxnot).
• Product emissions chamber testing for all interior products with the potential to emit; emissions testing against CDPH Standard Method v1.2-2017 or approved equivalent. All equivalent emissions test must be either published as acceptable by ILFI or approved in writing prior to product submission.
• Confirmation of RoHS 2011 compliance for electrical components, including RoHS or CE Mark testing data or certification markers.