An active Declare label with a status of LBC Red List Free or LBC Red List Approved at the time of specification (when the project team places the product order with the manufacturer) is sufficient documentation of product compliance with I13 Red List. This remains true even if a constituent chemical in the product is added to the Red List prior to the label’s expiration date. ILFI will encourage project teams to download the Declare label information at the time of specification.
Products in Declare will be evaluated against the LBC Red List version that is active when a manufacturer submits the product for its annual label renewal. At that time, a product with a Declare status of LBC Red List Free or LBC Red List Approved may subsequently receive Declared status because a constituent chemical was subsequently added to the Red List and the product formulation wasn’t changed. ILFI will inform project teams that if they did not document the compliance status of the Declare label at the time of specification, they may cross-reference the Red List ingredient identified on the renewed Declare label with the contents of the Red List at the time of project registration, to demonstrate compliance.
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