Certification and Registration
CARB/EPA Formaldehyde Emission Certification for Composite Wood Products
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CARB/EPA Formaldehyde Emission Certification for Composite Wood Products
CARB ATCM Formaldehyde Regulation
The California Air Resources Board (CARB), also known as CARB, is the “clean air agency” within the California Environmental Protection Agency. CARB is responsible for maintaining air quality and protecting the public from toxic air pollutants. According to the California Department of Public Health, formaldehyde can irritate the skin, eyes, nose, and throat. Frequent exposure may even cause cancer and asthma. Consumers are primarily exposed to formaldehyde through adhesives used to bond fibers, particles, and wood veneers together. These materials are commonly found in particleboard, medium-density fiberboard (MDF), and other hardwood plywood products, which are ultimately used to manufacture finished products such as flooring, furniture, and cabinets.
In 2008, CARB established strict standards to regulate formaldehyde emissions, known as the “Airborne Toxic Control Measure (ATCM 93120).” Manufacturers of composite wood products sold in the California market are required to demonstrate compliance with CARB ATCM 93120 low formaldehyde emission requirements.
Classification of Composite Wood Products
Hardwood Plywood (HWPW): (A) Panels composed of multiple layers of wood veneer bonded together with adhesives, commonly known as plywood.
(B) Panels composed of multiple layers of veneer bonded with composite core materials, including lumber core, composite core, special material cores, or special backer materials. The face panels of HWPW can be made of hardwood or decorative softwood materials. HWPW includes wall panels and industrial panels and can also be used for flooring production.
Particleboard (PB): Refers to panels made from cellulose materials (usually wood), where dispersed particles (as opposed to fibers, flakes, or strands) are bonded together with resin and compressed into wood panels.
Medium Density Fiberboard (MDF): A type of engineered wood panel manufactured by mechanically separating and chemically processing cellulose fibers (usually wood), adding adhesives, waterproofing agents, and other additives, and then forming the material under high temperature and high pressure. MDF with a thickness of 8 mm or less is referred to as thin MDF.
Laminated Products: Products made by applying wood veneer or grass-based plant veneers similar to wood veneer onto particleboard, medium-density fiberboard, or hardwood plywood.
EPA TSCA Title VI Formaldehyde Emission Standard
On December 12, 2016, the US. Environmental Protection Agency (EPA) took direct action by adopting California’s standards and revising the final rule published in the Federal Register, establishing new national standards for formaldehyde emissions from composite wood products. This regulation is known as Title VI of the Toxic Substances Control Act (TSCA Title VI). It requires any company that imports, manufactures, sells, supplies, or offers for sale hardwood plywood, medium-density fiberboard, particleboard, and/or products containing composite wood materials in the United States to demonstrate compliance with TSCA Title VI requirements.
Companies selling hardwood plywood, medium-density fiberboard, particleboard, and/or products containing composite wood materials in the United States must indicate compliance with TSCA Title VI.
Before March 22, 2019, products certified under CARB were also considered compliant with TSCA Title VI. However, after this date, wood products must be certified by an EPA-recognized Third-Party Certifier (TPC) and carry the appropriate labels. In addition, manufacturers producing finished products (such as furniture) using composite wood products must maintain traceability. They must be able to provide records demonstrating that they purchased composite wood products certified under TSCA Title VI.
EPA requires that testing must be conducted by certified and recognized Third-Party Certifiers (TPCs). Regulated composite wood panels and finished products containing such composite wood panels must be certified by Third-Party Certifiers (TPCs) approved by the California Air Resources Board (CARB) and recognized by EPA to comply with TSCA Title VI or CARB ATCM Phase 2 emission standards when manufactured (in the United States) or imported (into the United States).
CARB ACTM vs EPA TSCA Title VI
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CARB ATCM |
EPA TSCA Title VI |
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Responsible Authority |
California Air Resources Board |
US. Environmental Protection Agency |
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Applicable Scope |
California |
United States |
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Effective Date |
Introduced in two phases between 2009 and 2013. The initial emission standard (Phase 1) was implemented first, followed by a stricter emission standard (Phase 2). Since January 1, 2014, only products meeting Phase 2 requirements may be sold in California. |
Effective on May 22, 2017. The compliance date for emission standards was June 1, 2018. Since March 22, 2019, all composite wood products (such as panels) and finished products (such as flooring and wood products) must comply with TSCA Title VI. |
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Emission Standards |
Applies to three types of composite wood products (panel products): Hardwood Plywood (HWPW), Particleboard (PB), and Medium Density Fiberboard (MDF, including thin MDF). Finished products containing compliant composite wood products are also required to meet emission standards. |
Consistent with CARB requirements. |
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Applicable Parties |
Manufacturers (panel producers); finished product manufacturers; distributors, importers, and retailers of panels and finished products. |
Consistent with CARB requirements. |
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Certification Body |
Manufacturer |
Manufacturer |
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Audit Frequency |
Once every quarter |
Once every quarter |
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Record Retention |
2 years |
3 years |
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Formaldehyde Limits |
HWPW veneer core – 0.05 ppm PB particleboard – 0.09 ppm MDF medium density fiberboard – 0.11 ppm TMDF thin medium density fiberboard – 0.13 ppm |
HWPW veneer core – 0.05 ppm PB particleboard – 0.09 ppm MDF medium density fiberboard – 0.11 ppm TMDF thin medium density fiberboard – 0.13 ppm Laminated product – 0.05 ppm |
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Test Methods
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ASTM E1333 Large Chamber Method ASTM D6007 Small Chamber Method |
Consistent with CARB requirements |
Certification Process
SATISFY provides technical guidance for US. CARB and EPA formaldehyde emission certification, efficiently supporting composite wood panel manufacturers and finished composite wood product manufacturers in bringing their products to the US. market.
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