What will change in Declare 2.0?
This latest iteration of the program seeks to push the industry towards a more holistic approach to material health. Declare 2.0 allows manufacturers to report on previously unrecognized impact areas, such as embodied carbon and wood sourcing. Additional compliance pathways for chamber testing are also now available, and will be explicitly stated on the label.
Along with the additional reporting information, adjustments have been made to the structure of the Declare label itself. A product’s Declaration Status is now solely tied to its compliance with the Red List Imperative and ingredient disclosure. Compliance with other applicable imperatives, including Healthy Interior Performance and Responsible Sourcing, are each referenced separately on the label.
With the latest iteration of the Red List, released with the latest version of LBC 4.0, came the LBC Watch List. The Watch List acts as a signal to manufacturers and project teams to identify chemicals and compound groups that ILFI has identified for potential future inclusion on the LBC Red List. Watch List chemicals identified as “Priority for Red List Inclusion” are now flagged on the label in orange to increase awareness, but do not affect Declaration status or overall LBC Compliance.
Have there been any changes to the ingredient reporting requirements in Declare 2.0?
No. Each submission still requires disclosure of all ingredients present in the final product to 100ppm (0.01%) with a CASRN and percentage by weight. The Proprietary Ingredients Exception also still allows manufacturers to hold up to 1% of ingredients by weight as undisclosed on the label and database, provided they can confirm there are no Red List ingredients present in the proprietary content.
When can I switch to the new Declare 2.0 label?
All existing labels will be eligible for transition to the updated Declare label and program requirements at the time of renewal.
All new labels submitted on or after February 1, 2020 will be processed under Declare 2.0.
Am I required to switch to the new Declare 2.0 label at the time of renewal?
Yes. All labels renewing on or after February 1, 2020 must transition to Declare 2.0. The last Declare 1.0 labels should therefore all expire on February 1, 2021, when Declare 1.0 will sunset.
Have there been any changes to pricing?
There will be slight adjustments made to the Declare label pricing structure. ILFI has not increased the Declare fee structure in three years; these increases reflect inflation and cover increasing time and resources for ILFI to provide customer service, support its technology platform, develop additional program advancements and provide marketing support.
Declare 2.0 also has modified tiers and fees to incentivize scaling. Tiered pricing is now available when a manufacturer has 10-25 labels and more than 25 labels.
The annual fee for a new label license is:
Manufacturers looking to pursue 100+ labels should contact ILFI about customized reduced pricing options.
Renewals receive a 20% discount. This renewal discount is available whether or not there are changes to the Declare label.
The annual fee to renew a label license is:
As an example, if you choose to purchase 10 Declare labels, the first 9 labels will be priced at $1,100 USD/label, and the 10th will be priced at $900 USD. The total will amount to $10,800 USD. When you renew the subsequent year, if you still possess 10 active labels, the subsequent renewal fee for each label will be $750 USD/label, or a total of $7,500 USD.
Declaration Status and LBC Compliance Changes in 2.0
How has “Declaration Status” changed in Declare 2.0?
A product’s Declaration Status is now solely tied to ingredient transparency and Red List compliance. Compliance with other applicable imperatives, including Healthy Interior Performance and Responsible Sourcing, are each referenced separately on the label.
What does “LBC Compliance” refer to in Declare 2.0?
“Living Building Challenge: Compliant” is now a holistic evaluation and designation given to a product that meets all applicable Imperative requirements of the Living Building Challenge. Compliance is determined separately from Declaration Status during ILFI’s review of the product submission. This designation takes into account compliance with the Red List Imperative, Healthy Interior Performance Imperative, and Responsible Sourcing Imperative. If a product is not compliant with all three Imperatives, the word “Compliant” will not appear on the label, however the product may be compliant with some of the Imperatives.
If my formulation is remaining the same when I renew next year, is there a chance my Declaration Status could change? What about my LBC Compliance?
Declaration Status: Maybe, but likely not. Although some chemical classes were re-named and/or consolidated, no new unique CASRNs were added to the Red List at the time that LBC 4.0 was launched in May 2019. A product’s Declaration Status is solely tied to a product’s compliance with the Red List (not the Priority for Red List Inclusion list). The Red List will be updated in May 2020, and after that will move to a schedule of updates on January 1 each year to provide consistent timing, therefore manufacturers renewing on or after May 2020 should refer to the latest version of the Red List to determine compliance.
Additionally, VOC emissions testing is now represented under I-14 Healthy Interior Performance. Therefore, products that could achieve LBC Compliant or Red List Free status only due to emissions testing may now be eligible.
LBC Compliance: Maybe, but likely not. The only ways your product’s compliance would be called into question would be if the product is wood-containing and does not meet one of the compliance options listed in the Manufacturer’s Guide, or if your product utilizes an exception that is being consolidated to exclude your current application. We will reach out to the few manufacturers this applies to.
How can I find up-to-date LBC Temporary Exceptions?
All currently valid LBC Temporary Exceptions that apply to the Declare program will be listed in the online Declare Manufacturer’s Guide starting on February 1, 2020. ILFI will also release the full suite of LBC Materials Petal Exceptions in March of 2020 which will include any Red List exceptions that cannot be used by Declare Manufacturers, but can be used by project teams to justify the use of a product with Red List Ingredients in it on an LBC Materials Petal Project.
Am I required to report embodied carbon data for my Declare label? Will I be penalized if I don’t include carbon data?
Embodied carbon reporting on a Declare label remains in pilot phase and will not be included on Declare 2.0 labels until further notice. When the option is opened to additional manufacturers, it will remain an optional reporting field, and will not affect Declaration Status or LBC Compliance. If a manufacturer opts to not include carbon data, the applicable fields will not appear on the label graphic or accompanying database entry.
Program Submission Changes
Has the submission process on Toxnot (3E Exchange as of September 2023) changed at all?
No. The process of creating a new submission and submitting for renewal has not changed— the new and updated fields will be visible on the “Declare Summary Data” page.
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