Declare Building-Product Transparency Program

Declare Building-Product Transparency Program

1. What Is Declare Building-Product Transparency Program?

The Declare Building-Product Transparency Program is a voluntary product-disclosure program administered by Living Future, formally the International Living Future Institute. It combines an ingredient label, a public product database, and screening against the Living Building Challenge (LBC) Red List. Unlike a conventional consulting matrix, Declare has formal submission requirements and defined product designations. Its central question is: what is this building product made of, and how does its disclosed composition align with the program’s requirements?

Manufacturers of insulation and roofing products should use Declare to structure concrete decisions: which formulations to disclose, where supplier information is missing, and whether an ingredient warrants substitution. Executives should treat the label as the output of a product-information process, not simply a marketing asset.

2. Origin and Background

Living Future launched Declare in 2012 to make it more feasible for building projects to identify and avoid products containing LBC Red List chemicals. The original problem was practical: project teams needed usable ingredient information rather than having to investigate each material independently. The label and searchable database provided a standardized disclosure mechanism.

Declare 2.1 launched on August 20, 2026. It retained ingredient disclosure, Red List screening, three declaration statuses, and optional third-party verification while clarifying reporting requirements for complex materials and expanding transparency fields. The management implication is to use current guidance rather than replicate an older submission template.

3. How Declare Building-Product Transparency Program Works

The program starts with the finished product’s composition. Its standard reporting threshold is 100 parts per million (ppm), equivalent to 0.01% by weight. Disclosure covers intentionally added ingredients and residuals at or above the applicable threshold. Ingredients are normally reported using chemical names, Chemical Abstracts Service (CAS) registry numbers, and percentages or percentage ranges.

Understand the three declaration statuses

StatusMeaningExecutive interpretation
LBC Red List FreeFull required disclosure, with no Red List ingredients under the applicable reporting rules.Check that the label covers the product configuration being supplied.
LBC Red List ApprovedAt least 99% disclosure and compliance through one or more approved exceptions.Read the exceptions; do not equate this designation with Red List Free.
DeclaredFull required disclosure, but one or more Red List ingredients are not covered by an approved exception.Transparency has been achieved, but the disclosed chemistry may not meet the project’s requirements.

These categories distinguish disclosure and Red List alignment; they are not a numerical sustainability ranking.

Labels also communicate information such as assembly locations, expected service life, and end-of-life pathways. Independent verification is an additional assurance pathway, not an automatic feature of every label.

For windows and cladding, define the assessment boundary carefully: glass, frames, finishes, gaskets, and adhesives may require different evidence. Do not interpret transparency for one component as coverage of an entire assembly.

For management purposes, supplement the official label with an internal register connecting formulations, suppliers, evidence gaps, applicable exceptions, and corrective actions. This register is an implementation tool, not an additional Declare designation.

4. When to Use Declare Building-Product Transparency Program

Declare is most useful when ingredient transparency is an explicit specification or procurement requirement. It can also structure a manufacturer’s response to recurring material-information requests. The program connects product disclosures with building-certification and materials-procurement frameworks, including LBC, LEED, and WELL; teams should verify the applicable project pathway rather than promise automatic credit eligibility.

Particularly useful questions include:

  • Which product families can support the requested disclosure today?
  • Which upstream suppliers are preventing a complete submission?
  • Which variants need separate assessment because their ingredients differ?
  • Where would reformulation improve alignment without compromising performance or economics?

Useful inputs include formulation records, supplier composition declarations, manufacturing information, relevant test evidence, and customer specification requirements. Involve product engineering, procurement, quality, sustainability, and technical sales.

Budget separately for internal assessment, supplier engagement, external review, and any reformulation testing. Supplier responsiveness and evidence quality should determine the schedule.

Declare is not sufficient when the decision concerns structural performance, installed cost, project-specific exposure, or total environmental impact. Its usefulness depends on accurate product boundaries, representative composition data, and disciplined interpretation of its limited claims.

5. How to Apply Declare Building-Product Transparency Program: Step-by-Step

The following management workflow complements, rather than replaces, Living Future’s formal application process.

  1. Clarify the decision and scope. Identify the customer requirement, target designation, product families, manufacturing locations, and planning horizon. Decide whether the immediate objective is disclosure, supplier-data completion, or reformulation. Assign an accountable product or technical leader.

  2. Gather composition evidence. Assemble bills of materials, formulation revisions, supplier declarations, and supporting documentation. Request chemical-level information rather than relying on purchased-material trade names. Safety data sheets can withhold chemical identities or concentrations as trade secrets, so do not assume they provide complete ingredient inventories.

  3. Define the units of analysis. Assess finished-product formulations and their covered variants. Map differences in binders, facings, pigments, treatments, and supplier sources. Confirm whether variants can share a label under current program rules; do not average incompatible recipes.

  4. Construct the submission and decision register. Prepare the ingredient inventory and required product information. The submission platform supports component-level organization, chemical identifiers, ingredient weights, exceptions, and supporting product attributes. Alongside it, maintain an internal evidence-gap and action register.

  5. Interpret the screening results. Separate missing disclosure from disclosed Red List content. Examine applicable exceptions and unresolved identifiers. Treat an incomplete supplier response as uncertainty—not as evidence that an ingredient is absent. Escalate ambiguous reporting questions before publication.

  6. Convert findings into operating changes. Decide whether to pursue disclosure, obtain better supplier evidence, substitute an input, or retain a transparently disclosed formulation. Embed product lifecycle management controls so formulation changes, supplier substitutions, and label updates remain connected.

  7. Test alternative assumptions. Examine composition ranges, alternate suppliers, recycled-feedstock variability, and proposed reformulations. Ask whether each change affects label coverage or designation. Preserve the program’s disclosure requirements; sensitivity analysis is not permission to relax them.

  8. Align stakeholders and maintain ownership. Review the evidence with engineering, procurement, quality, and commercial teams. Approve customer-facing claims, assign renewal responsibilities, and establish escalation routes for product changes. Measure evidence completeness and closure of unresolved items, not just labels published.

A rollout across several plants or product families may benefit from program management support to coordinate supplier requests, engineering tests, submissions, and specification deadlines.

6. Example: Declare Building-Product Transparency Program in Action

Illustrative scenario: Northline Facade Materials, a fictional manufacturer, supplies mineral-fiber insulation boards in unfaced, faced, and decorative-faced configurations. Architects on two commercial projects request ingredient transparency. Technical sales has product literature, but procurement and engineering hold different versions of supplier information.

The company selects Declare because it needs a standardized composition disclosure and a clear interpretation of Red List alignment. Its team assesses each configuration separately, mapping the core, binder, facing, laminating adhesive, and surface treatment. It uses current recipes, supplier composition declarations, and manufacturing records rather than assuming the common core makes all variants equivalent.

The unfaced product has sufficient evidence to proceed to application. The faced version has an unresolved supplier-disclosure gap. Screening identifies a non-exempt Red List ingredient in the decorative treatment; full disclosure alone would therefore not make that version Red List Free.

Northline submits the unfaced formulation for review, negotiates a program-compatible disclosure arrangement for the facing, and trials a replacement decorative treatment. Engineering validates the proposed change against moisture, adhesion, and fire-performance requirements before release.

The central insight is that Northline has three different workstreams: publishing supported information, resolving uncertainty, and changing chemistry. Management assigns separate owners and milestones instead of treating all three as a label-design exercise.

7. Strengths and Limitations

Strengths

  • Accessible product information. A standardized label and public database make complex ingredient information easier to exchange between manufacturers and project teams.
  • Clear diagnostic distinctions. Teams can organize action around disclosure gaps, exceptions, and ingredients requiring further evaluation.
  • Operational discipline. Applying the program can provide a practical reason to connect supplier evidence, formulations, and technical sales documentation.

Limitations

  • Limited claim scope. A Declare designation does not establish that a product is generally sustainable, non-toxic, safe, or superior.
  • Evidence dependence. Missing or unrepresentative supplier information should limit confidence in the internal assessment.
  • Incomplete decision coverage. Supplement the label with performance validation, environmental assessment, and commercial analysis before making substitution decisions.

The most consequential misuse is selecting a product solely because of its designation while overlooking whether its configuration, performance, and supporting evidence match the intended application.

8. Common Pitfalls and How to Avoid Them

  • Confusing transparency with approval. A Declared product can disclose its ingredients fully while containing non-exempt Red List substances. Read the designation, not just the presence of a label.
  • Using overly broad product families. Different finishes or adhesives can invalidate a shared assessment. Map formulation differences before deciding label coverage.
  • Equating silence with absence. An unreported additive is an evidence gap. Obtain supporting information rather than assigning a favorable internal conclusion.
  • Reformulating without validation. An ingredient change can introduce performance or processing problems. Require engineering approval before commercial release.
  • Leaving labels outside change control. Product-information changes can make an existing submission inaccurate. Living Future’s terms require manufacturers to stop further label printing or application and notify the program when submitted information is no longer accurate.

9. How Declare Building-Product Transparency Program Relates to Other Frameworks

Health Product Declaration

A Health Product Declaration (HPD) is a standardized report of product contents and associated health information, including hazard-screening results. Prefer HPD when the information request calls for its reporting format or broader hazard information. Declare provides a concise label and explicit LBC Red List designation. Prepare a consistent underlying inventory before using either; reconcile boundaries and disclosure thresholds when producing both.

Life-cycle assessment and environmental product declarations

Life-cycle assessment evaluates environmental impacts, while an environmental product declaration (EPD) communicates standardized environmental information. These tools address questions that ingredient disclosure alone cannot answer. Use them alongside Declare when evaluating material substitutions, checking that functional units, system boundaries, and product-category rules support meaningful comparison.

Stage-Gate product development

Stage-Gate organizes development work into stages separated by management decision gates. Use Declare screening to identify disclosure or chemistry issues, then place reformulation within a gated development process. For construction products, the gates should require appropriate performance validation, supplier qualification, production readiness, and supported claims before launch.

10. Key Takeaways

  • Use Declare to structure ingredient transparency and Red List alignment—not to certify overall sustainability.
  • Assess actual finished-product configurations, including finishes, facings, and adhesives.
  • Separate missing evidence from disclosed ingredients that need further evaluation.
  • Connect disclosure findings to supplier engagement, engineering decisions, and change control.
  • Combine the label with performance, environmental, and commercial analysis before substitution.

11. FAQs About Declare Building-Product Transparency Program

Is Declare a certification of overall product sustainability?

No. Declare communicates defined ingredient information and program attributes. Neither participation nor a Red List designation establishes that every health, safety, or environmental characteristic has been assessed. Customer-facing language should remain within the designation’s scope.

Can an LBC Red List Approved product meet a project’s requirements?

Potentially. This status relies on approved exceptions. Review the actual exception, product coverage, label validity, and applicable project requirements before accepting the product. Do not treat Approved and Free as interchangeable.

Can smaller building-product manufacturers use Declare?

Yes. A practical starting point is one commercially important formulation with a manageable supplier base. Keep the internal workflow proportionate, but do not reduce evidence requirements to fit available resources. Resolve disclosure gaps before expanding to additional variants.

How long does applying Declare take?

There is no useful universal timetable. Schedule the work around formulation complexity, supplier responsiveness, evidence reconciliation, external review, and any selected verification. If reformulation is necessary, include engineering testing and production qualification rather than assuming label preparation is the only task.

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