19-0625 v3.X FSC Mix Product with Declare Label "LBC Compliant"

Question:

Our Team is vetting options for architectural wood doors. We are interested in using "Oregon Door". This door has a Declare Label, checked as "LBC Compliant"; however, material ingredients are FSC Mix wood, as opposed to FSC 100% as required for the Red List. 
Supporting Data for I11-02 states that acceptable documentation for red-list compliant products include "Living Building Challenge Compliant of Red List Free Declare label ID number". 
Declaration Status also defines "LBC Compliant" as meeting "the current requirements of the Living Building Challenge, but rely on one or more Exceptions to demonstrate compliance. Labels are, at minimum, 99% disclosed and/or may contain one or more Red List ingredients that fall under an existing LBC Exception. They have been shown to meet emissions testing criteria, if applicable, and meet the Red List requirements of the Living Building Challenge."
With that said, can you please confirm that 1) Oregon Door would be considered compliant for use on this project? and 2) This scenario would also apply to other products with LBC Compliant or Red List Free Declare labels? and 3) Is additional vetting of alternative products required in this scenario?

Link to product Declare label: https://living-future.org/declare-products/fsc-naf-particleboard-door-w-veneer-face-skin/

Answer:

  1. Yes, the FSC Mix Oregon Door product with an active Declare label and a status of LBC Compliant may be used for your LBC project as long as your team demonstrates due diligence in attempting to source a comparable door product that is FSC 100%.
  2. Projects pursuing the Living Building Challenge may use products with wood as an ingredient and with active Declare labels that have a status of Red List Free or LBC Compliant as long as due diligence to find FSC 100% is documented.
  3. Yes, due diligence - vetting of alternative comparable products - is required in order to demonstrate effort in attempting to source a product with FSC 100% wood rather than FSC Mix wood.

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