ADVOCACY
Project teams must advocate to all manufacturers that do not have products represented in the Declare program to register their products in Declare and disclose their product ingredients and identify any Red List ingredients. The intent of this requirement is to push manufacturers to adopt a spirit of Red List avoidance and ingredient transparency to a detailed level of disclosure of 100 parts per million (ppm). Declare labels allow manufacturers to push the market in the growing movement toward product transparency and health and hold the industry to a higher standard of healthier products. Project teams may use a developed template letter or email to complete the advocacy requirement.
Direct Engagement Compliance Path
As an alternative path, project teams may document in-depth conversations with 20 unique manufacturers that do not have active Declare labels, advocating that they join Declare and provide publicly available ingredient transparency for their products. Conversations may happen over email or by phone and must represent products in a minimum of three CSI Master Format Divisions.
Email conversations must be documented to demonstrate an exchange with the relevant manufacturer personnel and include detailed explanation of the program, Declare links/resources, and a personal note from the project team regarding the importance of ingredient transparency. These messages must be sent directly to an individual and may not be sent to general customer service inboxes. Conversations by phone must be documented with a summary of the main points of the conversation, the date and time of the call, and evidence of a brief follow-up email, providing Declare program resources and links, sent to the manufacturer personnel who participated in the call.
DECLARE
Declare labels provide transparent information about building materials’ ingredients and toxicity, as well as raw material sourcing location information, to better inform a discussion of materials health and sustainable resource extraction and management.
Any Declare label, regardless of Declaration Status, that is active during the specification, purchase, and/or installation of the material in the project can be counted toward the required number of Declare labels. Products with a new Declare label, issued after product installation, as a result of project team advocacy to the manufacturer may also contribute to the required number of labels. Third Party Verified Declare labels count as 1.5 labels.
DISTINCT PRODUCTS
The intent is for project teams to explore a variety of products with Declare labels and prioritize sourcing items from multiple manufacturers. Projects are required to include at least one Declare-labeled product for every 200sm (see Project Area below for specifics based on typology), with a cap at 20 distinct products. The required number of products is rounded up to the nearest whole number for all project area-based requirements. Any projects that are 4,000sm (43,056 sf) or more in size need to include at least 20 different Declare-labeled products. If projects of 4,000sm (43,056 sf) or more decide to cap the total number of Declare labels at 20, then those 20 Declare labels must be from at least 5 different manufacturers.
Table 12-1 Required Number of Declare Products and Manufacturers by Project Area
PROJECT AREA
The calculation basis for this requirement is dependent on typology. The project must contain one Declare label product per 200 square meters (sm) (2153 sf) of gross building area, leased area, or project area: new building and existing building projects must calculate the number of required Declare labels using the enclosed gross building area; Interiors projects must use the tenant’s leased area or interior scope area; and landscape and infrastructure projects must use the project area. The area used for this calculation must be consistent with the building/interiors/project scope area reported for all other Imperatives.
Figure 12-1 Sample Declare Label 