Exceptions and Declaration Status

The use of one or more Declare Program Exceptions by a manufacturer will impact a product’s Declaration Status and cannot result in a status of “LBC Red List Free”. Additionally, no products that disclose less than 99% of ingredients by weight may participate in the Declare program due to the limits of the Proprietary Ingredients Exception.

LBC Red List Free: An “LBC Red List Free” Declare label contains no LBC Red List ingredients, discloses 100% of contents by weight and makes use of no Declare Program Exceptions.

LBC Red List Approved: An “LBC Red List Approved” label discloses between 99% and 100% of contents by weight. The specific “% disclosed” may be found on the label to the right of the Declaration Status under I-13 Red List. “LBC Red List Approved” labels may make use of any LBC Temporary Exceptions alone or in combination, but they may not contain any Red List ingredients that are not covered by an existing Exception.

For a somewhat complex example, a structural composite wood product that contains an electronic component, could obtain a status of “LBC Red List Approved” if:

• it discloses 99%+ of contents,
• demonstrates that it complies with the Formaldehyde Exception requirements, and
• demonstrates RoHS compliance to use the Small Electrical Components Exception
• and it contains no Red List ingredients that are not covered by a Declare Program Exception.
  

Declared: A “Declared” label discloses 100% of contents by weight and necessarily includes Red List ingredients that are not covered by an existing Exception. It may also incorporate the use of any combination of Declare Program Exceptions, except for the Proprietary Ingredients Exception as this would result in disclosure of less than 100% of contents.

The use of the Proprietary Ingredients Exception (and therefore disclosure of less than 100%) in combination with the presence of any Red List ingredients not covered by a Declare Program Exception will prevent a product’s achievement of a Declare label until either the proprietary content, or the Red List ingredients, are removed.