20-1011 Ingredient Disclosure Threshold

STAFF POST:
Applicable to projects registered under LBC version 3.1 and earlier.

Project teams are required to prioritize products with an ingredient disclosure of 100 ppm (0.01). Project teams do not need to seek more granular information about a product than 100 ppm, the same disclosure level required for the Declare program. If an intentionally-added Red List ingredient is present at less than 100 ppm, the product is still considered Red List free and compliant with the LBC requirements.

When project teams have exhausted available public ingredient disclosure resources- including the Declare database, HPD Public Repository, and mindful Materials- and an appropriate product cannot be found with the required ingredient disclosure at 100 ppm, the team may then source products with less granular levels of disclosure. Project teams should seek the highest level of disclosure possible, prioritizing 100 ppm disclosure, then 1,000 ppm (0.1%), and then 10,000 (1%) disclosure thresholds. Products with a disclosure threshold less granular than 10,000 ppm are not considered compliant and will only be accepted if properly documented using the General Red List Exception. Project teams are expected to review products listed on public ingredient disclosure resources, but are not required to engage with manufacturers directly before accepting less granular levels of ingredient disclosure.

Products vetted and documented prior to October 12, 2020 do not require re-vetting if the provided ingredient disclosure is less than 100 ppm. In this instance, project teams must advocate to a minimum of 25 manufacturers of products with a level of disclosure below 100 ppm. The required advocacy must state the value of 100 ppm ingredient disclosure and request that the manufacturer publicly disclose product ingredients to 100 ppm. All products vetted after October 12, 2020 must prioritize ingredient disclosure at 100 ppm, as outlined above. ILFI encourages project teams to submit a brief narrative with the project's certification documentation highlighting the product vetting process and methods for prioritizing the highest possible levels of ingredient disclosure.

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