Table of Contents:
How does disclosure benefit me as a supplier?
Creating disclosures benefits suppliers by reducing the number of requests you’ll receive for product data, making it easier to show compliance with regulatory needs, and commit to sustainability leadership. The use of supplier disclosure tools also helps your company better understand the potential hazards in your products. Additionally, by contributing this data and helping us to be more transparent, it allows us to respond to customer requests, potentially increasing demand for the items you supply us.
Why public ingredient disclosure?
Often referred to as “nutrition labels for products,” public ingredient disclosure is the process by which companies can transparently report the chemical and material ingredients that make up their products. There are a variety of platforms and programs that exist to structure this disclosure. All share certain features such as de minimis thresholds, some form of hazard screening, and a public document format and/or database to make the information accessible to interested customers. The demand for these documents is driven by several factors. Those include LEED green building certification, Living Building Challenge certification, and an increased awareness around the potential hazards of the chemicals that are found in products throughout product life cycles.
Why are your customers asking you for ingredient transparency?
Customers have grown interested in ingredient transparency in recent years as our understanding of the hazards associated with building products throughout their life cycles has increased, along with our recognition of the health impacts of spending 90% of our time indoors. Architects and designers, as well as large owners and developers in the green building space (e.g., LEED and Living Building Challenge) are especially interested in this information as they work to create sustainable buildings that contribute positively to occupant health and well-being.
As demand increases from end-use customers, it cascades through the supply chain and pushes the product manufacturer, the chemical company, and every supplier in between to know and disclose more about their products.
I want to help but don't have the time to learn new tools. Are there organizations available who can help me respond to these requests?
I want to help but don’t have the time to learn new tools. Are there organizations available who can help me respond to these requests?
Yes! We understand that managing different tools can be difficult, and obtaining supply chain information is often difficult and complex. To support suppliers and manufacturers in ingredient transparency efforts:
HPDC has Approved Preparers that can help prepare Supplier HPDs
ILFI has Ecosystem members that are available to help you create Toxnot Shared Materials and navigate materials transparency requests.
Additionally, your customer may have consultants that they already work with that may be available to help.
We already give our customers this information! Why am I being asked for this again?
We very much appreciate your efforts in contributing to a world full of transparently disclosed, healthy materials. All manufacturers and suppliers are in a different place in their sustainability journey and we recognize that. Each manufacturer sent this letter out individually to their supply chain and has had the opportunity to customize the email message or call associated with it in order to tailor it to their relationship with suppliers as needed.
No matter how much you are already able to disclose, we still wanted to send you this letter to:
Thank engaged manufacturers for any disclosure they have already provided
Send a consistent ask to the market to make it clear what is needed
Identify tools for disclosure that are secure and allow you to reduce redundancy of responding to requests from us and other manufacturers
Engage any new suppliers that we have not interacted with yet
What if I can’t disclose everything?
As you may have seen in the letter, in order to fully comply with these mandates from our customers, we require material composition disclosure to a level of 100 ppm (0.01%), and need your assistance accordingly. However, we have heard that in some cases that level of disclosure is not possible. We understand the concern around intellectual property and thus use systems that provide suppliers with the ability to control the level of disclosure. While disclosure to 100 ppm is ideal, our customers prefer to purchase products that come with partial disclosure of ingredients and hazard information over those products with no disclosure of such information. Therefore, any response is preferable to no response in our work to generate safer, more sustainable products, and sales of our products and your materials. We also expect that the level of disclosure will become more granular over time. We observe increasing demand from our customers for this information. We are also getting better at understanding our supply chains and how best to research and publicly report information. We’re hoping you will join us on this journey, and that this can serve as a sustained partnership moving forward.
How can you protect your proprietary information?
A variety of options exist to ensure the security of proprietary information on both Toxnot and HPD Builder. Both approaches allow users to disclose hazard information while keeping chemical identification information proprietary if desired.
Toxnot’s software is designed to help users protect their data and customize IP protections. For those who want the efficiency benefits of sharing a material on Toxnot but are concerned about specific proprietary formulations, Toxnot lets users mark specific chemicals as proprietary, control data sharing settings, and approve who can see data. This allows users to share and manage hazard information with key stakeholders, but not specific CAS numbers. An NDA for any data not shared publicly is a standard part of terms for all users.
Read more about Toxnot’s privacy and confidentiality here: Privacy and Confidentiality
HPD Open Standard and HPD Builder
Protecting your proprietary information is a core focus of the HPD Open Standard and supporting software tools such as the HPD Builder. The HPD is a flexible reporting format that allows manufacturers and suppliers to publicly report as much or as little data as they prefer. When entering data on substances in the HPD Builder, users may mark substances as proprietary, and the CASRN and/or name of the substance will not be shared externally. The HPD Builder also supports users sharing hazard information without identifying the substance. Data entered by manufacturers into the HPD Builder remains the property of the manufacturer. Read more about the HPD Builder’s protections here: HPD Terms of Service
If you have concerns about your intellectual property and privacy, we suggest you engage with your customers directly. It is possible that a solution may exist within an established disclosure program. We as product manufacturers want to work to improve human and environmental health outcomes over time, and that means improving transparency within our industries.
Why is each of the emails I receive a little different?
Manufacturers who are part of the LP50 and Health Product Declaration Collaborative have collaborated to build a common letter to send to their suppliers. However, each company’s products, its relationships with its suppliers, outreach techniques and the nature of its supply chain is different. Therefore, it was necessary to allow manufacturers flexibility of message to meet their individual needs, while maintaining consistency of the letter and request. All members of the LP50 are working towards more transparency throughout the supply chain in order to meet the needs of their customers and the sustainability goals of their own companies. We hope that these letters and the emails that accompany spark individual dialogues between suppliers and manufacturers, as well as serve to shift the market. Ultimately the goal is to make responding to requests and communicating our products’ sustainability attributes easier for all of us.
What is Toxnot?
The International Living Future Institute’s (ILFI’s) Declare program uses Toxnot’s software platform for efficient, scalable participation in LP50 goals. On Toxnot’s platform, suppliers enter material and ingredient data once, and report publically for free. From there, they can disclose to multiple standards without re-entering data.
Toxnot supports reporting to Declare, Red2Green, HPDs, C2C and GIGA Origin/mindful MATERIALS. Compliance documentation for California Prop 65, EU REACH, EU RoHS and Conflict Minerals is also available.
Additionally, when you upload material data on Toxnot, you may create a searchable, secure database for anyone looking to use your specific ingredients and materials in their own product reporting- further reducing inefficiencies. Data security is customizable on Toxnot with a variety of supplier-controlled options for ingredient and hazard information, depending upon the intellectual property preferences. Visit Toxnot.com/LP50 to learn more.
What is the HPD Builder?
The HPD Builder is a tool provided by the HPD Collaborative to assist manufacturers and suppliers in reporting and sharing data with the knowledge that it is fully compliant with the HPD Open Standard. The Supplier HPD portal to the HPD Builder, which is provided at no cost to suppliers, provides a streamlined interface specifically for ingredient management and interactive communication with manufacturers and other suppliers in the supply chain. It provides for direct communication and transfer of data with suppliers’ customers, using the HPD Builder. Automated data exchange is available bi-directionally with Toxnot, to enable ease in publishing HPDs prepared using the Toxnot platform, and sharing data prepared in the HPD Builder with Toxnot partners, such as Declare. Once an HPD has been published to the HPD Public Repository, there is automated data sharing with public product libraries, such as GIGA Origin, mindful MATERIALS, Ecomedes, and Sustainable Minds, enabling authenticated, published HPD reports to meet a wide variety of reporting and data requirements. Visit LP50 to access HPD Builder and Supplier HPD.
What is the LP50?
The Living Product 50 (LP50) is a collaboration of leading manufacturers working to ensure that healthy, high performing building materials with full ingredient transparency are widespread. The LP50 works toward transparency in all things. They started a conversation with the design community on the manufacture of safe and transparently disclosed products and materials.
Can Suppliers join the LP50?
Yes! We already have suppliers who are a part of the LP50 and would love to further grow the group if you are passionate about leading the sustainable materials movement with us. We may also form a supplier group as needed in the future to dig in on needs and business value of sustainability for suppliers. Reach out to LP50@living-future.org for more information or visit LP50.
How do ingredient disclosures contribute to green building certifications?
Living Building Challenge (LBC): All LBC projects seeking the materials petal require that all products used have associated ingredient disclosures AND are compliant with the LBC Red List.
LEED: The LEED program has points available for ingredient disclosures within its materials and resources section. Health Product Declarations and, Declare Labels can all qualify for this credit if they meet minimum reporting thresholds detailed in the LEED guidance.
WELL: The WELL Building Standard has restrictions/bans on certain chemicals, but also has a Material Transparency optional credit (97 in WELL v1) that accepts Declare Labels, Health Product Declarations, and any others accepted by USGBC’s v4 MR credit.
What is a Declare label?
Declare is a voluntary self-disclosure program that aims to transform the building materials industry toward healthier products through ingredient transparency.
Declare requires the reporting of all intentionally added ingredients plus residuals at or above 100 ppm present in the final product. Manufacturers may withhold up to 1% of the final product by weight to protect their proprietary information and that of their suppliers’.
Declare was created to support project teams working to build to Living Building Challenge standards in obtaining ingredient transparency and avoiding worst-in-class chemicals and compounds contained within the Red List.
The program complies with Living Building Challenge, LEED and WELL, among other building certifications, and is also a way for manufacturers to demonstrate their leadership. Declare labels are supported by the ToxNot platform.
What is an HPD?
The Health Product Declaration (HPD) Open Standard provides a framework and specification for product manufacturers and their ingredient suppliers to report and disclose information about product contents and associated health information. The HPD Open Standard is a consensus, stakeholder standard governed by the HPD Collaborative (HPDC), a not-for-profit member organization. Over 250 manufacturers, architecture firms, and other stakeholder organizations are members of HPDC, and over 500 have published HPD reports in the HPD Public Repository.
A Product HPD or a Supplier HPD is a report that complies with the HPD requirements for formatting and standardized data reporting. HPDs are typically generated using an automated tool like the HPD Builder or Toxnot. More information, including information on becoming a member of HPDC, is available here.
What are Toxnot Shared Materials?
Toxnot Shared Materials allow you to easily share repeatedly requested material data with multiple customers. Rather than responding to each request individually, you can post your material data on Toxnot Shared Materials (also called Public Materials) for your customers to easily access and pull into their own transparency reporting. On Toxnot, the material data can be shared publicly or just with interested customers, but the LP50 is specifically requesting the material data to be shared publicly as part of the transparency efforts. Read more about the details of Shared Materials here: Create a Shared Material.