There is some very good in this credit, plus some bad that could completely moot the value of the good. On the good side, the intent is excellent. The credit continues to support a virtuous cycle of disclosure and assessment and product improvement. And the language describing the HPD and GreenScreen is good and the Cradle to Cradle language is good enough.

On the bad side the credit has two big problem areas that could totally undo it:

1) Complexity: With three options that include ten nonparallel paths for compliance, each with several different percentages, benchmarks and languages, this credit is getting more complicated with each comment period and communicates the impression to project teams that this is a very difficult credit to achieve and confuses manufacturers trying to determine how to comply. This is not necessary. The credit must be simplified to insure that teams don’t just walk away in frustration.

2) Easy out options that undermine the credit: Three of the ten paths in the credit language pose a serious threat to industry adoption of the HPD and more broadly to the goal of providing standardized, comparable disclosure and assessment of product contents – encouraging manufacturers to provide incomplete, misleading information in a variety of formats that make it more difficult for their customers to compare products and make informed choices instead of using the standardized HPD. And rewarding regulatory compliance instead of meaningful avoidance of chemicals of concern.

The “Manufacturer Inventory” allows products to contribute to the inventory point if the manufacturer posts an unstructured non-standard incomplete inventory of ingredients without disclosure of hazard instead of doing an HPD.
The “International Alternative Compliance Path” allows products to contribute to the optimization point that are only avoiding a small fraction of the chemicals that the other paths (GreenScreen or Cradle to Cradle) require – and these are chemicals that every EU company is already avoiding to meet EU regulatory requirements so there is no leadership.
The “Product Manufacturer Supply Chain Optimization” sounds a lot like current regulatory requirements on the industry. It needs a lot of work to be meaningful.

This credit needs radical simplification. The ten divergent complex pathways can be boiled down to two Options with a clear standardized single documentation track for each.
1) Health Product Declaration (for disclosure) plus GreenScreen (for optimization_
OR
2) Cradle to Cradle certification

Drop the confusing Manufacturer inventory and the way too easy International path and send the Supply Chain optimization off to the Credit Library for work. This credit does not need to be complicated.