Declare 2.1 End-of-Life & Circularity Documentation Guidance: Producer Responsibility & Recovery Programs

Last updated September 23, 2026

Introduction

The Declare 2.1 program update expands the options for reporting end-of-life and circularity pathways for products. This page provides practical guidance to help manufacturers identify appropriate information and supporting documentation for their selected pathways.

This is living guidance and will be updated as Living Future gains experience with implementation of Declare 2.1.

How to Use This Guidance

The Declare 2.1 Program Manual defines each End-of-Life & Circularity pathway and the information manufacturers must disclose. This page provides examples of documentation that may help demonstrate or support those pathways.

You do not need to create a new document specifically for Declare. Existing product, technical, program, certification, testing, or other documentation may be appropriate when it provides relevant information or evidence.

The examples on this page are illustrative, not exhaustive. Different products and industries may have different types of documentation that demonstrate or support the same pathway.

If you have information or documentation that is not described here, you may provide it with a brief explanation of how it supports your selected pathway.

General Principles

When selecting an End-of-Life & Circularity pathway:

Use existing documentation whenever possible.
Make sure the documentation relates to the declared product or applicable product component.
For recovery pathways, information should reflect realistic, currently available pathways, rather than theoretical or hypothetical future possibilities.
Where a pathway is geographically limited, documentation should help establish the applicable geographic scope.
Information or documentation may support more than one pathway.

When in doubt, provide the documentation you have and explain how you believe it supports the selected pathway. Living Future may request additional information or clarification when needed to understand the claim.

Intermediate Materials and Components

Some Declare products are intermediate materials, components, or assemblies intended to be incorporated into other products. In these cases, consider whether the selected pathway applies to the declared product itself or depends on the design, function, or end-of-life management of the finished product.

For example, a component may have its own established reuse or recycling pathway even though the repairability or disassembly of the finished product depends on how that component is incorporated. Manufacturers should select pathways based on characteristics and recovery options that can reasonably be attributed to the declared product or component.

Where a pathway depends primarily on the design or function of the finished product, the finished-product manufacturer may be better positioned to report that pathway.

Producer Responsibility & Recovery Programs

The Program Manual requires manufacturers to identify the program type (EPR, Voluntary Take-Back, Industry Stewardship, or Retailer Recovery), program name, link, applicable product scope, responsible party, and geographic availability.

What should I link to?

Provide a link to a publicly available webpage or other online resource that describes the recovery program and its applicability to the declared product or component.

Depending on the program, the link might be:

A manufacturer or retailer take-back program webpage or program guide
An EPR program or stewardship organization webpage
A government or regulatory webpage describing an applicable EPR program
A collection or recovery program webpage
A webpage identifying participating retailers or collection locations
Program terms, eligibility requirements, or instructions for returning products

The linked information should provide enough detail to establish that the program exists, applies to the declared product or component, and applies in the reported geographic area. If availability varies by geography, report the geographic scope that applies to the declared product or component.

A general statement that a manufacturer "supports recycling" or "takes responsibility for its products" is not sufficient to establish that a defined recovery program is available.

Helpful to know

A recovery program describes how a product is collected or managed; it does not necessarily establish the outcome after collection. Reporting a take-back or stewardship program does not, by itself, establish that the product is reusable, remanufacturable/refurbishable, or recyclable. Where the program provides a defined downstream recovery pathway, that pathway may also be reported separately under Circular Recovery Pathways when applicable.

Example: A flooring manufacturer has a published take-back program that identifies eligible flooring products, explains how customers can return them, and describes the geographic areas served. The manufacturer could provide the program webpage as the link for a Voluntary Take-Back Program.

How Much Documentation Is Needed?

For Producer Responsibility & Recovery Programs, the program link serves as the primary supporting source requested through the Declare submission. Additional documentation is not required through the Declare submission at this time.

Related Guidance

Getting Help

If you encounter a situation that is not addressed here, please share the question with the Declare team at declare.support@living-future.org.