The HPD is a flexible format that allows manufacturers to self-disclose more or less information about their products. Publicly disclosed HPDs compliant with the Materials Petal must report to 100 ppm all intentionally added ingredients, with CASRNs. Project teams can then use the HPD’s listing of CASRNs to confirm that the product is free of Red List ingredients. 

To confirm that the HPD complies with Material Petal requirements, look for the following indicators. (Only fields with specific requirements are noted.)

Required at the top of “Section 1: Summary” on the HPD:

  • Threshold level: Must be 100 ppm
  • Characterized/Screened/Identified: All indicators must be “Yes” or “Yes Ex/SC” 

Required at the bottom of “Section 1: Summary” on the HPD:

  • Third Party Verified: “Yes” is preferred but either response is allowed
  • Published and Expiry Dates: A date entry is required here indicating that the HPD is published. The HPD may be expired at the time of the LBC submittal as long as the date range is applicable to the product that was specified and procured for the project.
  • The URL for the HPD Public Repository must appear, indicating that the HPD is public:

Required in Section 2: Content in Descending Order of Quantity:

  • Check that no CAS RNs are on the LBC Red List. For HPD v2.2 and earlier, project teams need to perform this check manually. For HPD v2.3, Red List ingredients will be flagged on the HPD.

Also note the following:

  • HPDs must be published, i.e., they must be available via the HPD Public Repository. Draft HPDs shared directly with the LBC project and not published are not acceptable documentation.
  • Using the HPD Public Repository to find LEED-v4-compliant HPDs (Option 1 or Option 2) is a useful filter to find HPDs that are more likely to be LBC-compliant. However, LBC requirements go beyond LEED v4.
  • As of HPD v2.2 (available in March 2020), all published HPDs carry an "HPD Unique Identifier" in the upper left of page 1. As long as the HPD is compliant with the requirements listed above, this may be provided to ILFI as documentation in lieu of uploading the HPD itself.

RL-004 Proprietary Ingredients Exception:

ILFI has an exception for proprietary ingredients.

Manufacturers are required to disclose as much of a product’s content inventory as possible. They may not withhold more than 50% of ingredients as proprietary. If the product cannot be avoided in the project, the manufacturer must confirm in writing that the product is Red List compliant at 100 ppm. Manufacturers must include the percentages of all disclosed ingredients or confirm the percentage withheld to demonstrate disclosure of a minimum of 50%. 

This exception may be used in combination with the Threshold Exception to document Red List compliance at 1,000 ppm, if no products with 100% disclosure can be sourced at 100 ppm or 1000 ppm.

An ingredients list of non-proprietary ingredients is still required for I10-2 Supporting Data.

HPDs can be used as documentation for this Exception. The HPD must meet the requirements described above, with the following differences:

  • The HPD may be marked “No” for “Identified” under Section 1 but marked “Yes” or “Yes Ex/SC” for “Characterized” and “Screened.” This indicates that the identity of one or more ingredients have been withheld, but all ingredients have been listed, with health information disclosed.  
  • For HPDs under HPD v2.2 and earlier, none of the ingredients marked “Undisclosed” in Section 2 of the HPD may be assessed as GreenScreen Benchmark- 1, i.e., they may not have a “BM-1” score listed.