A product chemistry, formulation, or component using a Red List ingredient may be used in a product when it replaces one or more Red List ingredients and addresses regrettable substitutions.

Manufacturers must provide a detailed analysis to demonstrate they have created a new chemistry that does not rely on regrettable substitutions and eliminates the need for at least one Red List ingredient in the product.

The detailed analysis should be written by a chemist, toxicologist, knowledgeable product engineer, or qualified member of the manufacturer’s team, and show how the product eliminates one or more Red List ingredients. ILFI will engage with a third party to confirm accuracy of provided analysis.

Use of this exception is only approved through the formal Declare process and must be listed on an active Declare label to be considered valid.

Date added: January 2020
Date updated: July 2020

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