The below descriptions clarify how to vet and document recycled content, salvaged, and surplus materials; and what is meant by “not creating a market for Red List materials.”
Recycled Content
Products and materials with recycled content are encouraged, but cannot have Red List materials as a primary ingredient or create a secondary market for Red List materials (see below regarding secondary markets). Unknown residuals in recycled content are considered unintentional trace amounts and are allowed to be present in the product. Thorough reporting of all known ingredients, including pre-consumer recycled content, generated by the manufacturer, is required. Pre-consumer recycled content from the manufacturer’s own feedstock may not use the unintentional trace amounts clarification.
Salvaged Materials
Like recycled materials, salvaged materials are encouraged, but cannot have Red List materials as a primary ingredient or create a secondary market for Red List materials (see below regarding secondary markets). Due to the nature of salvaged materials, full ingredient disclosure may not be available. A salvaged material with a suspected Red List ingredient can be used if the suspected ingredient meets the following criteria:
- Unintentionally added to the product due to its presence in recycled feedstock
- Not a primary ingredient
- Not necessary in the final product
Salvaged products do not require full ingredient reporting to 100 ppm. Instead, project teams must report the source of salvaged products and list all known ingredients and all suspected primary ingredients at the highest threshold possible.
Project teams are encouraged, but not required, to evaluate all salvaged materials for ingredients that may pose a human health risk, even in small quantities. For example, project teams should consider testing paint on salvaged wood products to avoid the installation of products with lead paint.
Surplus Materials
Surplus materials, unlike salvaged, are excess new materials that are left over from a previous project. Project teams are encouraged to utilize surplus materials sourced from other projects or from architectural salvage warehouses. Surplus materials cannot have Red List materials as a primary ingredient or create a secondary market for Red List materials (see below regarding secondary markets).
Project teams are required to collect full ingredient disclosure documentation for all surplus (new) materials sourced from projects by the same owner or general contractor, as the manufacturer of these materials is known and the project team has greater control of the initial materials purchase. Surplus materials sourced from other project teams and materials with known manufacturers and SKUs sourced from architectural salvage warehouses must contact the product manufacturer and document the highest threshold of ingredient disclosure possible per RL-018 Inventory Threshold Exception. Project teams may self-report the known and primary ingredients for products with no known manufacturer, SKU, or original supplier. A surplus material with a suspected Red List ingredient can be used if the suspected ingredient meets the following criteria:
- Unintentionally added to the product due to its presence in recycled feedstock
- Not a primary ingredient
- Not necessary in the final product
Market for Red List Materials
An ingredient is considered to be “creating a market for Red List Materials” when it is necessary for the performance of the product in question. For example, if a recycled plastic product is dependent on the functional attributes of recycled PVC, and couldn’t not be made without recycled PVC as an ingredient, then it is seen as contributing to the market for PVC and would not be allowed under this Imperative.
Recycled content materials that can be made with or without the Red List ingredient are allowed. Recycled and salvaged materials that create a secondary market for Red List materials are not allowed.
