Ingredient Information Reported

Disclosure Threshold

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.

Disclosure Methods

Currently, product manufacturers have two options to organize and report ingredient content inventory: Just Substances, or Materials and Substances. This overview provided by 3E Exchange shows where these options can be found within the 3E Exchange (formerly 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.

Figure 1: Example of a Materials and Substances ingredient disclosure.

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.

Figure 2: Example of a Just Substances ingredient disclosure.

Ingredient Names

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.

Ingredient Percentages

All ingredients must be reported with a percentage by weight, which can either be a fixed number or a range. 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 14-36% as this exceeds the range of 20. Ingredient ranges may be appropriate in order to accurately reflect slight differences in product dimensions, raw material suppliers, or manufacturing locations. Ingredient ranges can also help protect proprietary formulations on the public database.

Exceptions for Larger Ranges

General pathway:

For instances where an ingredient percentage delta exceeds 20 in a product or product family and the manufacturer has sufficient reason to not report the product on multiple labels, the following pathway may be followed:

• Submit a written request to declare.support@living-future.org including a rationale for the products to be represented on one single label.
• The rationale must include a Bill of Materials (BOM) including all possible ingredients for all product options proposed to be listed on the single Declare label, with reporting to the 100 ppm threshold. The disclosure threshold must be set using the “highest resolution” case that discloses the most detail about the product family’s ingredients.
• Approval is at the sole discretion of Living Future.
  

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.
  

Product size and shape:

If a product family has a constant chemical composition but ingredient ranges exceed the percentage delta of 20 due to one or more product component differences in physical size or aspect ratio, it may still be reported on a single label by following this pathway:

• Submit a written request to declare.support@living-future.org including a rationale for those products to be represented on one single label.
• The rationale must include a Bill of Materials (BOM) for each product size or configuration, with reporting to the 100 ppm threshold. Ingredients must be the same across all products within the family, and the disclosure threshold must be set using the “highest resolution” case that discloses the most detail about the product family’s ingredients.
• Approval is at the sole discretion of Living Future.
  

Examples of approved cases include:

• A product family of lighting fixtures all use the same bulb, socket, chain, mounting strap, canopy, power cables and hardware but come with widely different sizes and shapes of lampshade (all made of the same material). The disclosure threshold is set using the smallest size of lampshade. Listing all sizes of lampshade as present from 26-71% represents this variability of component options.
  

Listing Multiple Products on a Single Label

A product family, or multiple products, can be listed on a single Declare label if each of the products has identical content, or the products meet the product family definition in the glossary. Manufacturers may request to list multiple members of a product family on a single label, the approval of which is at Living Future’s sole discretion.

Before approving any request, Living Future will consider factors such as potential differences in impacts along the products’ value chain, and if such request falls within the transparency of product ingredients and attributes intent of the Declare Program.

The manufacturer must submit sufficient evidence that product(s) fall within this definition with publicly available and officially published specification documentation, “cut sheets,” or other documentation deemed acceptable by Living Future.