17-0623 v2.1/Wolf Ridge Environmental Learning Center Living-Learning Space Renovation/LBC v2.1 + Declare Products + Newer LBC Sourcing Requirements

QUESTION

This post applies to LBC v2.1 Projects and I-14 Appropriate Sourcing.

We are running into a challenge with tracking compliance for I-14 Appropriate Sourcing in particular with manufacturers who have achieved Declare Label certification and the fact that the sourcing imperative has been so drastically revised in newer versions of the LBC. Specifically - some of the manufacturers who have current Declare Labels are unable/unwilling to provide us with the raw material sourcing locations that are required under LBC v2.1. Some have argued that as that Imperative no longer tracks/evaluates that raw ingredient information in the newer versions of the LBC, they are not required to disclose that information to us in order to still be an LBC-compliant product.

We are struggling with how to proceed with I-14 Appropriate Sourcing given that these are active participants in ILFI's Declare program - manufacturers really at the forefront of their industry - yet they are unable/unwilling to provide the additional documentation required by the older version of the LBC. We know that typically a project is required to upgrade the entire Petal from older versions to newer versions and we do not currently wish to do that.

Is there any alternative path available to us given this unique circumstance where Declare Labeled product manufacturers will not provide the information required by this past LBC version as it is not a requirement of the current LBC version? For example:

  • Could we have an exception and upgrade just I-14 Appropriate Sourcing to the I-13 Living Economy Sourcing LBC v3.1 requirements for this particular project?
  • Alternatively, could Declare Labeled products that meet the LBC v2.1 manufacturing distance requirements be exempt from the LBC v2.1 raw material distance requirements for I-14 Appropriate Sourcing?

ANSWER

Based on the circumstances created by the evolution of the Standard and the transparency already demanded of Declare manufacturers, the Institute is creating a new Clarification: 
Declare Products and Source Locations
Projects pursuing I14 Appropriate Sourcing under LBC v2.1 are exempt from meeting source location distance requirements for products with a Declare label. 


Post ID 6564

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