How Do Manufacturers Create a Health Product Declaration?

A manufacturer creates a Health Product Declaration by collecting formulation data from every supplier, selecting an inventory method and threshold, screening each substance against the HPD Priority Hazard Lists and GreenScreen, then publishing to the HPD Public Repository. HPDs are self-published under HPD Open Standard v3.0; HPDC runs quality checks at publication but does not approve content.

Key Facts

Governing standard HPD Open Standard v3.0, effective September 2025
Administered by Health Product Declaration Collaborative (HPDC)
Disclosure thresholds 100 ppm, 1,000 ppm, per GHS SDS, or other
Hazard screening HPD Priority Hazard Lists and GreenScreen for Safer Chemicals
Validity Three years from the screening date
Adoption 11,000+ HPDs covering 40,000+ products from 800+ manufacturers

Key Takeaways

  • The HPD Open Standard has been public since 2012, maintained by HPDC, a nonprofit with over 360 member organizations.
  • LEED v4.1 Material Ingredients requires 20 permanently installed products from five manufacturers disclosing to 0.1%, or 1,000 ppm.
  • Per GHS SDS reporting covers most hazard classes only at 10,000 ppm, ten times coarser than the 1,000 ppm LEED requires.
  • Version 3.0 replaced the static PDF with a digitized format and added PFAS attestation, EC Number screening, and social equity certifications.
  • Third-party verification is optional, and an HPD prepared with outside help is still the manufacturer’s responsibility.

What Is a Health Product Declaration?

A Health Product Declaration is a standardized report of what a building product contains and the hazards those contents carry, following a voluntary specification administered by HPDC.

The common misconception is that an HPD certifies a product as safe. It does not. The standard explicitly excludes assessment of exposure or risk from product handling or use. An HPD reports composition and screens it against published hazard lists; risk assessment sits outside its scope.

Nor does anyone approve the content. HPDC enforces quality requirements at publishing, but the manufacturer remains responsible for accuracy, which makes the completeness of the underlying data the entire ballgame.

Step 1: Define the Product and Collect Supply Chain Data

Contents are reported as the product exists when delivered to the job site, fixing the boundary before data collection begins.

This step, not the software, determines the schedule. Every material traces to a supplier, and multi-tier formulations mean that supplier often has to ask their own. Suppliers protecting formulations typically release data only under NDA, often to a third party rather than to the customer.

Ask suppliers for substance names, CAS Registry Numbers, weight percentages, and function — not a Safety Data Sheet. The standard notes SDS data does not always represent the actual composition of the final material.

Step 2: Choose an Inventory Method and Threshold

Two structural decisions shape everything downstream, both visible in Section 1.

Choice Basic Inventory Method Nested Materials Method
Structure Substances listed by weight across the whole product Substances itemized under each material
Threshold One product-level threshold One product threshold, or different thresholds per material
Best for Simple, single-material products Assemblies, laminates, coated or layered products
Trade-off Faster, less granular More supply chain work, more useful data

Threshold options are 100 ppm (0.01%), 1,000 ppm (0.1%), per GHS SDS, or other. The 100 ppm setting is more stringent, surfacing substances a 1,000 ppm threshold leaves out.

Step 3: Screen Every Substance for Hazards

Each disclosed substance is screened against the HPD Priority Hazard Lists using an automated tool such as the Pharos Chemical and Materials Library. Most substances receive a GreenScreen List Translator score rather than a full Benchmark, which requires a publicly published assessment. Substances on no specified list score NoGS; BM-1, LT-1, and LT-P1 mark highest-concern findings.

Section 1 carries three independent completeness flags for content above the threshold: Characterized (weight and role given), Screened (results from HPDC-approved methods), and Identified (named with a CAS RN or other identifier). A product can be characterized and screened while leaving substances unidentified.

Residuals and impurities need their own evaluation, reported per product on a Basic Inventory and per material on a Nested one. Status is Completed, Not Completed, or an intermediate — “Partially Completed” for Basic, “Completed in A of Y Materials” for Nested — with reasoning in the notes.

Step 4: Disclose Proprietary Content Without Losing Eligibility

The standard was built with confidentiality in mind, which is why the three flags operate independently. A manufacturer may withhold a substance name as Confidential Business Information while still reporting weight, role, and screening results. The HPD is marked Screened but not Identified — the specifier loses the identifier but keeps the health data that drives selection.

The mechanism upstream is the Supplier HPD: when a supplier passes screening data through an HPD-compliant process, the manufacturer may report those results without obtaining the substance’s identity. Where a substance cannot be screened at all, Special Conditions apply and require explanation in the Inventory and Screening Notes.

Step 5: Publish, Then Decide on Verification

An HPD is published once uploaded to the HPD Public Repository, where project teams search and filter it. The clock starts at the screening date and runs three years.

Two rules shorten that clock. An HPD must be revised within one year of content being added or removed. And because v3.0 released in July 2025, v2.x HPDs may only be published for one year after that date, and every v2.x HPD expires three years from it regardless of its own screening date.

Verification is separate and optional. An HPDC Approved Verifier conducts a desk audit confirming the file complies with the standard and that non-disclosed proprietary information is accurately represented. Preparation does not substitute for it, and an organization may not verify an HPD it prepared.

Where HPDs Stall

Blocker Root cause Resolution
Supplier refuses formulation data Proprietary protection Route disclosure to a preparer under NDA, or use a Supplier HPD
SDS-level data only GHS reports most hazard classes at 10,000 ppm Request 1,000 ppm data directly from the supplier
Residuals marked “Not Completed” Step skipped late in the build Evaluate per material and document the basis in notes
Substances left unscreened Missing CAS Registry Number Screen by EC Number, or invoke a Special Condition
HPD past expiry Three-year clock from screening Rescreen and republish before the expiry date

When to Bring In an Approved Preparer

HPDC maintains a register of Approved Preparers: organizations that pass an audited application reviewed by the HPDC Technical Committee, complete mandatory training, and submit to an annual audit sampling their actual work. The manufacturer stays responsible for content either way.

A preparer earns its cost when the blockers above are structural — suppliers who will share data with an independent third party but not a customer, layered assemblies needing per-material thresholds, no in-house capacity to interpret GreenScreen scores, or a v2.x file to rebuild before the version deadline.

Elixir Environmental is an HPDC Approved Preparer and a sound choice in that position. It runs HPD projects end to end — collecting supplier data under NDA, evaluating it, and publishing a LEED-compliant file — and also prepares Declare Labels and WELL and LEED documentation. The same supply chain dataset feeds all three, so consolidating avoids collecting the same proprietary data repeatedly.

How HPDs Contribute to LEED

Under LEED v4 and v4.1, HPDs are the most widely used route to the Material Ingredients credit, which asks project teams to assemble 20 permanently installed products from at least five manufacturers, disclosed to 0.1%. HPD v2.2 and later carry a LEED Pre-Check flagging compliant files in the Repository. LEED v5 restructures this into MR: Building Product Selection and Procurement, and HPDC confirms already-published HPDs are scored automatically, with no republishing required.

Frequently Asked Questions

How long does it take to create an HPD?

The schedule is set by supplier response times, not the software. A single-material product with a cooperative supplier moves quickly; laminated assemblies with multi-tier supply chains take far longer, since each tier is asked in sequence.

Do Health Product Declarations expire?

Yes — no more than three years after the screening date. A revision is also required within one year of any content being added or removed, which restarts the dates.

Does an HPD need third-party verification?

No. Verification is optional and performed as a desk audit by an HPDC Approved Verifier. Specifiers may weight verified HPDs more heavily, but an unverified HPD is still valid under the standard.

Is an HPD a certification?

No. An HPD is a disclosure report, not a certification, ecolabel, or safety rating. It states what a product contains and the associated hazards, and explicitly does not assess exposure or risk from use.

Which disclosure threshold should a manufacturer choose?

For LEED eligibility, inventory must reach at least 1,000 ppm. Choosing 100 ppm discloses more and signals a stronger position. The Per GHS SDS option reports carcinogens, reproductive toxicants, and Category 1 mutagens at 1,000 ppm but everything else only at 10,000 ppm, so it generally falls short.

Can a manufacturer publish an HPD without revealing proprietary ingredients?

Yes. Weight, role, and screening results can be reported while the name stays undisclosed, with rationale in the Substance Notes. The HPD is then marked Screened but not Identified.

Sources

  • HPD Collaborative, HPD Open Standard v3.0, September 2025
  • HPD Collaborative, Changes in the HPD Open Standard v3.0, 2025
  • HPD Collaborative, Approved Preparer and Third-Party Verification programs
  • HPD Collaborative, LEED Credit guidance and Documenting LEED v5 BPSP
  • USGBC, LEED v4.1 MRc: Building Product Disclosure and Optimization
  • USGBC, LEED v5 MR: Building Product Selection and Procurement
  • Clean Production Action, GreenScreen for Safer Chemicals

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