Standard Language
Living Products are free of Red List materials or chemical substances. Through a Red List Free or LBC Compliant Third Party Verified Declare label, manufacturers must demonstrate that neither the product nor its packaging contain any Red List materials or chemical substances. Additionally, the manufacturing process may not produce byproducts or emissions that are considered toxic or included on the Red List.
Note: manufacturers who already possess a 3PV Declare label may submit their product inventory and Declare label as documentation of compliance, along with GreenScreen scores for the product inventory. The only additional requirement of this Imperative is to gather supplier confirmation that the product packaging is free of LBC Red List substances.
Methodology
The Declare program is a foundation of the material health approach in LPC. Obtaining a Third Party Verified Declare label provides manufacturers with a platform to transparently represent the contents of their products and demonstrate compliance with the Red List. Manufacturers must work with an ILFI-approved verifier to assemble and verify the submission. An abbreviated summary of the Declare label requirements and 3PV Review methodology is listed in this guide; for more detailed information, manufacturers and verifiers should refer to the Declare Manufacturer’s guide.
Overview:
- Obtain and publish your 3PV Declare label:
- Refer to the Declare Manufacturer’s Guide for the full set of rulings surrounding the Declare program.
- 3PV process requirements can be found here.
- Using your product inventory of all CASRNs present at 100ppm obtained through Declare, screen all CASRNs using GreenScreen List Translator and provide as documentation the associated scores.
KNOW: INVENTORY, SCREEN + VERIFY
Inventory: Identify Product Content
Identify all substances, including residuals, present at or above a threshold of 100 ppm in the final product with name, associated CASRN and percentage presence to build your materials inventory. This information may be collected from public documentation in rare cases; in most cases supplier outreach, either through direct contact of suppliers, or through use of platforms like ToxNot and the HPD that streamline outreach, will be required to get complete substance information.
A minimum of 99% of the substances present in the final product by weight must be publicly represented on the label, with an associated CASRN, if applicable. Manufacturers are allowed to keep up to 1% by weight proprietary, though they must confirm that proprietary content is free of Red List ingredients.
For some ingredients, a CASRN does not exist. In these cases, the manufacturer should reference the list of Special Conditions listed within the Declare Manufacturer’s Guide to determine whether their ingredient falls under one of these and proceed as instructed. If the ingredient does not fall within one of the existing Special Conditions, the manufacturer and assessor should contact the Institute for a ruling.
Compile backup documentation in accordance with the Declare Manufacturer’s Guide for 3PV Declare, for verification. This will include supplier contact information, purchase orders and ingredient information (not limited to Health Product Declarations, MSDS and SDS and supplier communication). Trade names of materials and supplier contact information are not publicly disclosed, but must be made available for verifier review.
Screen: Identify hazards using the Red List and GreenScreen List Translator
Use the ToxNot platform to submit the ingredient inventory to ILFI and screen all substances against the Red List to determine whether the product is free of all Red List ingredients (unless an ingredient is covered by an existing exception). A list of current Red List exceptions applicable to the Declare program can be found in the Declare Manufacturer’s Guide. Any CASRNs entered into ToxNot that correspond with one found on the Red List will be flagged in Red.
If any Red List ingredients are present that do not fall under an existing exception, the manufacturer must work to remove or replace those materials or ingredients in the product. While rare, if market realities prevent the removal of certain Red List ingredients from material or product applications, ILFI may consider the creation of a temporary exception that allows the manufacturer to obtain LBC Compliant status.
Living Product Challenge requires that manufacturers go a step beyond determining Red List compliance for their product, by also obtaining supplier confirmation that the product packaging is free of Red List Ingredients, with ingredient disclosure if possible.
The inventory must also be screened using the GreenScreen List Translator to compare ingredients against a much broader list of restricted substances lists and authoritative hazard lists. GreenScreen List Translator screening generally results in a designation of LT-1, LT-P1 or LT-UNK. A spreadsheet documenting the results of this screening must be provided.
Verify: Ensure accurate information
The Living Product Challenge requires that a third party verify the inventory and Declare label content for two reasons: first to ensure that manufacturer claims about product content and program alignment are accurate; second, in order to ensure that the content inventory used to provide a basis for chemical hazard assessment and optimization is accurate and complete.
Once the Product Inventory is complete, manufacturers will work with the approved Third Party Verifier to verify the accuracy of the information.
Verifiers are required to review the product inventory and all associated back-up documentation gathered in order to determine whether there are any remaining data gaps and to confirm that there are no Red List ingredients in the product that are not covered by an existing exception. The Verifier will cross reference the inventory with internal documentation such as Bill of Materials and SDS/MSDS and supplier communication to ensure that all materials are accurately inventoried and screened.
If any gaps or inconsistencies are found, the Verifier will work with the manufacturer to fill these and bring the product into compliance with the Declare requirements.
DISCLOSE
Now that the Third Party Assessor has confirmed what is in the product and has screened content to ensure that it is free of Red List ingredients present at or above the 100 ppm threshold, the next step is to disclose this information on a Third Party Verified Declare label.
All Declare labels and product ingredient lists are published by ILFI on the Declare database. This free and public database allows product specifiers to understand the ingredient make-up for a product in order to select transparent and healthier products.
The manufacturer and assessor should gather all information required for a Declare label beyond the product inventory, including manufacturer name, product name, end of life options for the product, etc. A full list of label requirements is outlined in the Declare Manufacturer’s Guide.
Manufacturers will work with the Third Party Verifier through the ToxNot platform to upload the content inventory template to the Declare website to generate and publish a Declare Label.
Product information and content inventory is reviewed by ILFI before being published on the database. As noted earlier, manufacturers may keep up to 1% of final product inventory proprietary using the proprietary ingredients exception.
Existing Declare Labels that go through the verification process will have the Declare third-party verified mark added to those labels and listed in the database as “Third-Party Verified”. New Declare Labels will be created with the 3PV mark showing they have been assessed by an ILFI approved third-party assessor to en¬sure the accuracy of the manufacturer’s supply chain, purchasing, and ingredient claims.
