22-0304 Declare Status Requirement and Annual Red List Updates

ILFI makes annual updates to the Red List and Watch List that may impact the Declaration Status of certified LPC products. Though a Red List Free or Red List Approved label is required at the time of certification, if ILFI makes additions to the Red List that impact the product's Declaration Status during its three-year certification period, the manufacturer is encouraged to remove the substance but may maintain a Declared label through the end of the certification period to meet this core Imperative of LPC. This may force the manufacturer to disclose any remaining proprietary ingredients, as these cannot be held proprietary in combination with the presence of a Red List ingredient not covered by an Exception—the Declared status requires 100% disclosure of all intentionally-added ingredients in a product at or above 100ppm (0.01%) in the final product. At the end of the three-year certification period, the manufacturer must remove the Red List ingredient or obtain an Exception that would allow them to regain Red List Free or Red List Approved Status, in order to successfully qualify for LPC recertification.

If a manufacturer adds a Red List ingredient to their own product during the three-year certification period that results in a Declared Status, they will not be exempt from this requirement and will lose certification at their next annual check-in.