Project teams must request, and prioritize wherever possible, products that reflect the highest level of public ingredient disclosure and proof of Red List compliance. Use of Industry Standard Public Disclosure Programs (including the Living Product Challenge, Declare, and Health Product Declarations are encouraged by ILFI. These programs ensure consistency, clarity, and rigor in product disclosure. If documentation under one of these three programs is not available, project teams must work with manufacturers to acquire documentation that meets the vision described under Intent Clarifications including an ingredients list that is 100% disclosed at 100 ppm.
Active Living Product Challenge (LPC) Certification
As part of receiving any level of Living Product Challenge (LPC) certification, a product must have a Declare label with a Declaration Status of Red List Free or Red List Approved. As such, any product with an active LPC label meets the requirements of this Imperative. LPC Certification is considered active if it is current during the specification (at the time of material research and vetting for the project), purchase of, and/or installation of the material in the project. All Living Product Challenge version 1.1 and 2.0 labels are Third Party Verified and do not require additional documentation for this Imperative. If a label has expired since the product was specified, the project team may still use the product in the project with only the LPC label ID as documentation.
Active Declare Label
A Declare label is active if it is current during the specification, purchase of, and/or installation of the material in the project. If a label has expired since specification, the team may still use the product in the project with only the Declare label ID as documentation.
Declare labels come with one of three levels of Declaration Status – Red List Free, Red List Approved, or Declared.
- Red List Free products disclose 100% of product ingredients plus residuals present at or above 100 ppm (0.01%) in the final product, and do not contain any Red List chemicals. These products have been shown to meet the requirements of the Living Building Challenge Red List Imperative.
- LBC Red List Approved products meet the written requirements of the Living Building Challenge Red List Imperative, but rely on one or more Exceptions to demonstrate compliance. A minimum of 99% of product ingredients plus residuals present at or above 100 ppm (0.01%) in the final product are disclosed. The product may contain one or more Red List chemicals if they fall under an existing, published Exception. These products have been shown to meet the requirements of the Living Building Challenge Red List.
- Declared products disclose 100% of product ingredients plus residuals present at or above 100ppm (0.01%) in the final product, but contain one or more Red List chemicals that are not covered by an existing Exception. “Declared” labels require additional product research and vetting to locate a fully compliant product before the “Declared” product may be used on a Living Building Challenge project.
An active Declare label with a status of LBC Red List Free, LBC Red List Approved, or LBC Compliant at the time of specification (i.e. at the time of material research and vetting for the project) is sufficient documentation of product compliance with Imperative 13 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. Project teams are encouraged to download the Declare label information at the time of specification.
It may also happen that a product has a Declare status of LBC Red List Free, LBC Red List Approved, or LBC Compliant at specification, but when the label is renewed, it changes to Declared because a constituent element was subsequently added to the Red List and the product formulation wasn’t changed. In such a case, if the project team did not document the compliance status of the Declare label at the time of specification, it may cross-reference the Red List ingredient identified on the later Declare label with the contents of the Red List at the time of project registration, to demonstrate compliance. For a full explanation of the Declare program and Declaration Statuses, please visit the Declare website, or explore the Declare Manufacturer’s Guide, which provides detail that may be useful for project teams.
As Declare labels are the most streamlined pathway to demonstrating that a product can be used on an LBC project, under Imperative 14, Responsible Sourcing, ILFI requires project teams to advocate to all manufacturers of materials used on the project that are not in Declare that they register their products in Declare.
Published Health Product Declaration (HPD)
A published HPD is compliant with the current version of the HPD Open Standard. The Health Product Declaration (HPD) Open Standard provides a framework for product manufacturers and their ingredient suppliers to report and disclose information about product and associated health information. For more information, visit the HPD Collaborative website.
The HPD is a flexible format that allows manufacturers to self-disclose varying degrees of information about their products. To be compliant with Materials Petal documentation requirements, HPDs must be publicly disclosed, and must report intentionally added ingredients to 100 ppm. Project teams can then use the listing of Chemical Abstracts Service Registry Numbers on the HPD to confirm that the product is free of Red List ingredients.
To confirm that an HPD complies with Material Petal requirements, refer to the following guidance: hpd-collaborative.org/material-health-petal.
Ingredients List (Product Content Inventory)
Consistency and transparency regarding how products are inventoried and disclosed is important to the quality of claims. Therefore, ingredients lists disclosed through an Industry Standard Public Disclosure Program are preferred and should be requested by project teams.
Ingredients lists used for documentation that are not published through an Industry Standard Public Disclosure Program must list 100% of ingredients plus residuals present in the final product at or above a level of 100 ppm (.01%).
A compliant ingredients list must:
- Include the CASRN, alloy number (metals only), or meet the Special CASRN Reporting Requirements outlined below for all intentionally added ingredients and residuals present at or above 100 ppm in the final product.
- Include written confirmation from the manufacturer that all required ingredients and residuals have been reported when the ingredient list includes percentage ranges for quantities (i.e., 40-55%).
