Declare requires the disclosure of all intentionally added ingredients plus residuals at or above 100 ppm (0.01%). Within Declare, disclosure is defined as public disclosure on the label and in the Declare database of the ingredient name, associated CASRN (if applicable), and the percentage or percentage range by weight for each ingredient, with respect to the finished product (meaning “as delivered to the job site”). Naturally occurring impurities, and process chemicals do not need to be reported, will not be listed on the label, and will not be used to determine a product’s Declaration Status.
All Declare labels MUST demonstrate this content disclosure for at least 99% of the total product by weight, with an allowance for up to 1% proprietary ingredient withholding. Note: if the Proprietary Ingredients Exception is used, the product cannot contain any Red List chemicals that are not covered by a Declare Program Exception as products with a Declaration Status of “Declared” must disclose 100% of ingredients.
Product ingredients that qualify for Special CASRN Reporting Requirements may be exempt from reporting CAS Numbers and will still be considered fully disclosed when the special requirements are met.
Currently, product manufacturers have two options to organize and report ingredient content inventory: Just Substances, or Materials and Substances. This overview provided by Toxnot shows where these options can be found within the Toxnot interface. Both reporting options are LBC- and LEED-compliant. They are similar to the distinctions between Basic and Nested content inventories. in the Health Product Declaration (HPD).
Materials and Substances reporting is often well-suited to complex products by making it clearer where substances are present in the product as assembled. Chemical ingredients or substances are individually listed “within” their material or component.
Using the materials and substances approach, a manufacturer would organize their disclosure by each material or component, and then within each material list its constituent ingredients. For example, instead of listing: “Nylon 6, Polypropylene, Polyethylene Terephthalate, Blue Colorant” a materials and substances disclosure might list: “Backing: Polypropylene, Polyethylene Terephthalate; Fiber: Nylon 6, Blue Colorant.” The product’s Declare database entry will assign the percentage weight of substances proportional to the overall product, not to their material.
Just Substances reporting discloses chemical ingredients or substances only at the “substance” level regardless of the material organization of the product. Using the same example, the carpet would list polypropylene, polyethylene terephthalate, nylon 6 and the colorant, and will still assign the percentage of weight of substances proportional to the overall product.
Manufacturers must list the generic name for the components/parts and chemicals reported. Manufacturers may not list the trade name or brand name of supplied components or their ingredients without the expressed written consent of the supplier. The exception to this requirement is a supplier with an active Declare label. Manufacturers may reference the Declare ID for components that have already been disclosed through Declare.
All ingredients must be reported with a fixed percentage by weight or percentage ranges. If reported using a percentage range, the percentage delta may not exceed 20. For example, Nylon 6 may be listed as present from 14-34%, but not as 25-48% as this exceeds the range of 20. Ingredient ranges may be appropriate in order to accurately represent available product dimensions, multiple raw material suppliers, or slight changes due to multiple manufacturing locations. Ingredient ranges may also be used to mask the exact formulation of a product on the public database listing.
Ranges exceeding a delta of 20 must be justified and have their rationale submitted to firstname.lastname@example.org for approval. Examples of approved cases include:
- A manufacturer uses a single label to represent multiple available wood species options for a countertop. Since the wood range represents component options, the range of each wood type represented should each be listed as present from 0-95%.
- A carpet tile contains 60% thread, composed of some percentage of Nylon 6 and Nylon 6,6 which are used interchangeably in the supply chain. Listing both Nylon 6 and Nylon 6,6 as present from 0-60% represents this variability.
Listing Multiple Products
A product family, or multiple products, can be listed on a single Declare label if each of the products has identical content, or the content differences between the products do not exceed 10% of the total mass of the product.
All other information on the Declare label, except final assembly location, must be consistent across all listed products, including Responsible Sourcing and Healthy Interior Performance compliance.
Need more help with this?
Don’t hesitate to contact us here.