8 Things Building Product Manufacturers Should Know About Declare Labels

What is a Declare Label and how can it help building product manufacturers? A Declare Label answers three questions. Where does a product come from? What is the product made of? And where does the product go at the end of its life? Building product manufacturers who develop Declare Labels have more opportunities to get specified for Living Building Challenge (LBC) projects as well as LEED v4 projects.

1) Declare Is A Label and A Platform

Declare is not only a product declaration but also a platform. The Declare database is free to use and compiles cryptic chemical analysis and raw material source location information into a simple to use nutrition label. The Declare Label was developed by the International Living Future Institute which is led by sustainable design experts. The organization is a nonprofit dedicated to building an ecologically-minded, restorative world for all people. The International Living Future Institute promotes social and environmental justice, seeks to counter climate change, and developed the world’s most rigorous green building standard.

2) The Declare Label Can Contribute LEED v4 Points

A building product manufacturer can contribute points in LEED v4 by developing a Declare Label. Like the Health Product Declaration (HPD) , the Declare Label can be used to meet the LEED v4 MR BPDO Material Ingredients credit.  Declare labels that achieve a declaration status of “Red List Free” or “Declared” can fulfill the credit disclosure requirements for LEED v4. According to the International Living Future Institute, The Red List contains the worst materials in the building industry.

3) The Declare Label Can Contribute to Multiple LBC Imperatives

If your product is being specified for an LBC project, there are many imperatives it may contribute to if your product has a compliant Declare Label. Imperatives are similar to LEED credits for the LBC. A Declare Label may contribute to the following imperatives: Healthy Interior Performance, Red List, Responsible Sourcing, Responsible Materials, and Net Positive Waste.

4) The Declare Label Has Three Red List Designations

A product’s compliance with the requirements of the Red List Imperative is represented by the product’s Declaration Status. “Red List Free” products disclose 100% of product ingredients present at or above 100 ppm (0.01%) in the final product and do not contain any Red List chemicals. “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. “Declared” products disclose 100% of product ingredients 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.

5) The Declare Label Is Recognized by The EPA and The WELL Building Standard

The Declare Label is recognized by the US Environmental Protection Agency (EPA) in its Recommendations of Specifications, Standards, and Ecolabels for Federal Purchasers. The list helps federal purchasers identify and procure environmentally sustainable products and services. In addition, the Declare Label has been approved as compliance pathways for the International WELL Building Standard. The WELL Building Standard was developed by integrating scientific and medical research and literature on environmental health, behavioral factors, health outcomes and demographic risk factors that affect health with leading practices in building design, construction and management.

6) The Declare Label Must Identify A Product’s End of Life Option

A minimum of one product end of life option must be reported for the Declare Label. These options include: Take Back Program, Salvageable/Reusable in its Entirety, Recyclable, Biodegradable/Compostable, Hazardous Waste, and Landfill. In addition, manufacturers must select the applicable CSI Masterformat Division that applies to the referenced product.

7) The Declare Label Requires Reporting of All Intentional Ingredients Above 100 PPM

Each product ingredient/substance must be reported with the chemical name, CASRN, and the percentage or percentage range by weight for each ingredient, in regard to the finished product. Naturally occurring impurities, and process chemicals do not need to be reported, will not be listed on the label, and will not be used to determine if a product is either “Red List Free” or “Red List Approved”. All Declare product content disclosure must be no less than 99% of the total product by weight, with allowance for up to 1% proprietary ingredient withholding.

8) The Declare Label Has Exceptions for Red List Ingredients

The goal of Declare is to move the building industry toward the phase-out of all toxic chemicals on the Red List. However, the Living Building Challenge recognizes there are significant limitations in the building materials industry. Exceptions have been granted by the Living Building Challenge to reflect current market limitations. Exceptions are temporary and will be removed if new products and formulations become available. For example, lead batteries for solar and life-safety back-up systems have been granted exceptions.

Building product manufacturers who need help navigating the Declare Label complexities might consider a third-party Declare Label consultant. A consultant can also help develop HPDs for LEED v4 requirements and LEED v4 documentation for getting your products specified. We encourage manufacturers to do their research and figure out the best solution for meeting the requirements of LEED, LBC, WELL, and other green building rating systems. Has your company developed a Declare Label? What were the biggest challenges?▪

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