How Annual LBC Red List Changes Affect Product Manufacturers

An LBC Red List annual update is published in January of each calendar year, and becomes effective for all products on the Declare submission platform and Declare database on February 1st. The only CASRNs that can be added to the LBC Red List with an annual update must have been designated as Priority for Red List Inclusion in the Red List and Watch List CASRN Guide for at least 12 months prior.

Declare labels are valid for one year (12 months) from the time of issuance. An active Declare label with a status of LBC Red List Free, LBC Red List Approved, or LBC Compliant at the time of specification 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, LBC Red List Approved, or LBC Compliant 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.

Please visit the Red List page on the ILFI website for additional information regarding annual updates to the Red List and to download the currently active 2022 LBC Red List CASRN Guide.

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