18-1018 v3.0/Fred/Declare Status of Products 3.x

QUESTION:

Is there some mechanism for putting a date on the selection of products which are Declare labeled? During DDs, we ran through the database and selected all the Declare products we thought we could use, and predicated our designs on their use. Now we find that at handful of the manufacturers are no longer listed. (Though one at least is still showing the Declare label on their own website).

We presume that the products themselves are unlikely to have changed as much as the desire of the companies to maintain the cost of inclusion in the program. If the label status can change in the course of design, it seems to be a rather unfair whack-a-mole burden to add to the process. WOuld it be reasonable to continue forward with the material selected, and mention to the manufacturer that the (presumed) previous Declare label status was key critieria for us? I suppose it's really also a question if the design process is a protracted one, in that the results of any kind of materials vetting might actually have changed before the project is realized, how best can we proceed with a good conscience?

ANSWER:

I10-E26 Expired Declare Label

Products that had a Declare label with status of Red List Free or LBC Compliant at the time specifications were written meet the intent of this Imperative, and do not require further vetting for the project in question. The team must document any such products with dated specifications and verification that the products had a Declare label at the time of specification (ILFI can provide if needed). The team must also advocate to the manufacturer for label renewal. Expired Declare products cannot be specified on another project without updated ingredients information from the manufacturer.

Documentation: I10-a Due Diligence Documentation - Dated specifications
I10-b: Technical Documents - Active Declare label date validation
I10-c: Advocacy Letter - Advocacy to manufacturer to renew their label