20-0615 Alternative Compliance Path to Declare
QUESTION:
This project is the first project to pursue CORE certification in Spain and one of the first in Europe. The Declare Database has a limited number of products available in the European market. We are making every attempt to convince local, regional and European product manufacturers to obtain a Declare label. We are able to convince a number of European product manufacturers to pursue a Declare label for their products. These manufacturers will get their products certified during the design and/or construction phase of the project. Despite making every attempt to convince product manufacturers to certify their products using Declare, it seems we may have difficulties to reach the required total of 20 Declare labels from manufacturers active in the Spanish market. To comply with the intent of the Imperative we would like to include, as an alternative to Declare, a limited number of products that have a Cradle to Cradle certification. For this project we propose to request the product manufacturer to disclose their product ingredients and we would verify those ingredients using the Candidate List of Substances of Very High Concern (SVHC) as well as the Red List. Would this be acceptable as an alternative compliance? If so, for how many products?
ANSWER:
The Institute is not prepared to approve an alternative to Declare in order to meet the requirement in I12 Responsible Materials of including one Declare product per 200 square meters of gross building area.
Also note that with the small number of Declare products in Spain*, you may want to take particular care in sourcing non-Declare products from within 500 km in order to meet the requirement of I12 Responsible Materials to source 20% of products from within 500 km. If you are able to source at least 20% of non-Declare products from within 500 km, then you will have the flexibility to source the required number of Declare products from anywhere.
*As of 6/15/20, there currently appears be at least a few Declare products in Spain: