Chase the supplier declarations behind each component, keep the per-state filing record and its clocks in one place, and leave verification and submission to the product steward.
A declaration is requested, and the request is logged with its channel, its date and the component it covers.
02
A supplier answers, and the reply is filed against the component and the state definition it was asked under.
Reason
03
A sub-tier goes silent, and the escalation runs on and is recorded rather than rolled up as a clean no.
04
A component stays open, and it is carried as an allowed unknown value, never as an absence.
05
A window opens: the Minnesota duty dates from 1 January 2026, the submission from 15 September 2026.
Decide
06
A federal window opens 31 January 2027 or sixty days after EPA announces, whichever is earlier.
07
A record is assembled, and it goes to the product steward who verifies and submits where a programme asks it.
Out
08
A product leaves the supply chain, and the Minnesota five-year retention clock starts there, not at the filing.
09
Execute write actions only inside the approval boundaries agreed during implementation.
→Product statement
The agent assembles the record; a named person verifies and submits. In 40 CFR part 705 the only certification covers the confidentiality claims, not the chemistry.
Example workflow
One component, request to filing
AgentHuman
1Component record receivedBill of materials, supplier declaration, test report or product record
2Evidence gatheredDeclarations, questionnaires, test data and the chase history behind each one
3Position draftedPer-state obligation, the evidence under it, open unknowns and confidence
Stages 1 to 4 run unaided, and nothing is filed at any of them — the agent is assembling, and the steward's lane opens at the confidence gate.
5DecisionBranches at the confidence threshold
High confidence
Goes to the product steward to review.
Low confidence
Adds a regulatory counsel read first.
Steward approval
The record is held with its unknowns, its chase history and the confidence.
Approve · Amend · Send to counsel
Approved — released to file▼
6Product and filing records updatedOnly where write access and approval policy allow it
7Outcome evaluatedDeclaration coverage, unknowns closed, filing acceptance and post-filing corrections
Amendments
Steward amendments are counted in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required8 items
Verifying a state report as accurate and complete.
Determining that a substance is present or absent.
Deciding that a Proposition 65 warning is required.
Drafting, placing or clearing on-pack warning copy.
Automation boundaryAgent acts unaided
✓Request declarations per component and log each request.
✓Carry each position with the evidence and the date behind it.
✓Track registration, reporting and renewal clocks per state.
✓Report the components still open, and why each one is open.
The verification is a person's. If the report was wrong, that file is what the state reads back.
Signing the EPA confidentiality certification.
Deciding that a filing obligation bites in a state.
Judging whether a declaration supports a position.
Changes to state, definition or approval rules.
Example output
One component, annotated
What the agent records is attached to the declaration it came from.
Substance output · single componentIllustrative example
Component
What the evidence shows
States in scope
Evidence on file
Confidence
Verification
Coated zip pull
Supplier declares no intentionally added PFAS; the coating sub-tier has not answered
Minnesota and Connecticut
Supplier declaration
74%
Held for the product steward
As receivedTaken from the declaration and the chase log as filed — nothing on this side is asserted by the agent.
Declarations usedSupplier declarationThird-party test reportSub-tier request open
Why this stays unknownMinnesota contemplates allowed unknown values; the agent may not close one.
ActionApproveAmendSend to counsel
What the score decidesBelow the configured threshold the record adds a counsel read before it reaches the steward.
Value
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value landsValue 01 – 04
Every componentFrom the declarations on file
03Assembly
Build the position from the evidence
Draw on the declarations and test data on file. The Minn. Stat. §116.943 duty dates from 1 January 2026; MPCA has extended the initial submission to 15 September 2026 — an administrative date sitting on a statutory one.
01Approved path
Intentionally added is a finding
Minn. Stat. §116.943 puts it as a function test: deliberately added so the continued presence performs a specific function. Other states word it their own way, so the finding is made per state.
02Human review
Not the conformity file
The catalogue agent leaves warning fields to your specialist; this agent assembles what is in the product and what the supply chain said, and a named person decides whether that requires a warning.
04Build an evidence trail
The component, the declaration under it and the person who submitted stay on the filing.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
Product and bills of materialsAkeneo · Salsify Component and BOM records
Supplier declarationsAssent · Sphera 3E · Supplier portals
Test data and laboratoriesSGS · Eurofins Intertek · Bureau Veritas
Agent
Chemical & substance disclosure
Reads the evidence Chases the gaps Holds for the steward
Filing portalsMinnesota PRISM EPA CDX · state portals
A portfolio-level declaration-coverage figure can read as sound while one substance class holds most of the unanswered components. Nestack reports coverage by substance class, not only in total.
Slice performance — reported separately, not only in aggregateIllustrative example
Slice
Failure rate
Lift
Lift vs. threshold
Status
PFAS, coated textile parts
7.1%
3.6×
Review
PFAS, sub-assembly hardware
5.0%
2.6×
Review
Listed chemicals, food contact
3.5%
1.8×
Watch
Single-material moulded parts
2.3%
1.2×
Normal
Bar: unanswered-declaration lift vs. moulded-part baseline · scale 0–4.0× · tick marks the 2.0× review threshold2 of 4 slices over threshold
Evidence-linked improvement
The cycle shuts on a standing test
A cycle is done when the unanswered supplier has become a case the next release must pass. That suite is what the next filing.
Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn
01Detect
The unanswered-declaration rate rises in one substance class.
02Diagnose
The zip pull nobody had a declaration for is read back through its chase log until the cause narrows to one.
03Improve
Stamp the change; the components behind it are filed against that number.
04Verify
Each touched component case is run again, and one red stops the release.
05Learn
It stays a standing test, and the substance rules move with it.
Learn → DetectThe return edge. The next round of detection meets a longer suite than this one.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, record assembly, evaluation, integration, then production validation and handover.
WorkstreamWeek 1Week 2Week 3Week 4Week 5Week 6
01Substance obligation discovery and boundary work.
02Supplier and test-data source assessment.
03Per-state definition and deadline rule mapping and confirmation.
04Bill-of-materials and declaration intake.
05Position assembly and evidence binding.
06Confidence scoring and unknown routing.
07Steward verification workflow.
08PIM and supplier-portal integration.
09Declaration and scope cases.
10Guardrails and disclosure controls.
11Component-trail instrumentation.
12Deployment, documentation and Agent Care handover.
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallelFinal scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
Capability✓ in scope · — not at this tierPilotOne line, one stateProductionProduction filing systemsAdvancedMultiple states / brands
Introduced at Pilot
Assembly to your states and rules✓✓✓
Steward approval✓✓✓
Declaration-coverage baseline✓✓✓
Introduced at Production
Reporting by substance class—✓✓
Approval workflow in your systems—✓✓
Approved write-back—✓✓
Bill-of-materials integration—✓✓
Introduced at Advanced
Multi-programme definition rules——✓
Multi-stage disclosure approvals——✓
High component volume——✓
Multi-state disclosure controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build priceConfirmed after discovery based on integrations, workflow complexity, transaction volume, approval controls and deployment requirements.
Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bringWe build with it
01Your bills of materials and state list→Component ingestion and declaration filingWeek 1
02Representative supplier declarations→Coverage baseline, evidence binding and unknown handlingWeek 2
03Your per-state definition and deadline rules→Per-state definition and deadline rule mappingWeek 1
04Access to relevant APIs, feeds or exports→Supplier and test-data assessment, then integration setupWeek 2
05Filings you would not want reopened→Supplier cases and the evaluation suiteWeek 4
06What no filing may infer→Confidence scoring, unknown routing, guardrails and approval controlsWeek 3
07A named product steward to review records→Steward verification workflow, then pilot and production validationWeeks 5–6
Nothing else is requiredDeployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
Nothing here is sized for the page; the weeks alone decide, and the fifth carries a pair of them.
PhaseW1W2W3W4W5W6
DiscoveryW1
BuildW2 – W3
EvaluateW4 – W5
Pilot & LaunchW5 – W6
Week focusW1Substance obligation discovery, definition mapping and the automation boundaryW2Supplier-declaration integration and the coverage baselineW3Record assembly, chase logic and approval controlsW4Evaluation suite, unknown handling and failure-mode testingW5Filing-portal integration, pilot components and targeted correctionsW6One reporting window run under the product steward, then Agent Care handover
Reading the bandEach bar runs across the weeks its work is named in and no further. The week 5 overlap is real.
At the end of W6When the filing validates, Agent Care takes the agent on.
DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Retail AI agent
Build a substance-disclosure agent around the filings you owe.
It does not draft warnings, does not decide warning placement, does not maintain label artwork, and does not clear on-pack copy. Next step: bring one product family and we map which programmes reach it, chase what is missing, and hand your steward the record they verify from.
