EPA – the Environment Protection Agency
– has anticipated, to June 1st, 2018, the entry into force in the United States of America of the regulation concerning formaldehyde emission from the composite wood products "Formaldehyde Emission Standards for Composite Wood Products Rule" adopting the limits of formaldehyde emissions already set by CARB
"California Air Resources Board
EPA has adopted the California law enacted by CARB which imposes compliance with the following formaldehyde emission limits to producers, importers, distributors and panel transformers: 0.05 parts per million for the plywood panels; 0.09 for particle board (chipboard); 0.11 for fiber panels (MDF) and 0.13 ppm for thin MDF panels, ie with a thickness of up to 8 mm.
Furthermore, the above mentioned panels, if veneered with wood or bamboo (woody grass veneer) using urea-formaldehyde resins must comply with the limit of 0.05 ppm for the Laminated Products. Until March 22nd
, 2024, transformers (being the producers of veneered panels) will be able to demonstrate compliance with the limits through compliant test reports; after this date, these productions must also comply with the product certification requirements of the raw panels (product certification with 4 audits / year and not only compliant test reports).Starting from the 1st of June 2018
all wood-based panels and products containing panels
, such as furniture, in order to enter the US market, must comply with the formaldehyde emission limits mentioned above.
Manufacturers of wood-based panels who want to export their products to the US will therefore have to produce panels that comply with the emission limits set by CARB ATCM Phase II
or U.S. EPA TSCA Title VI
(both prescribe the same limits) and certify them through a TPC (Third Party Certifier) recognized by CARB and EPA. The panels or their packaging must then be labeled as conforming to the TSCA Title VI (Toxic Substances Control Act)
, reporting the manufacturer's name, the lot number, the TPC number recognized by the EPA and the declaration that the product conforms to the Title VI of the TSCA.
Finished products incorporating wood-based panels, in order to enter the USA, must then be produced with certified materials that comply with the emission limits set by CARB or EPA and must also be labeled as compliant with TSCA Title VI (Toxic Substances Control Act)
. The label can be applied to the finished product or on its packaging and must contain at least: the name of the manufacturer of the finished product; the date on which the finished products were produced (month/year format); the declaration that the finished product conforms to the TSCA Title VI. Clearly, manufacturers of finished products incorporating the wood products subject to regulation (see list above), must keep the documents certifying the conformity and certification of the panels incorporated in the products for three years, and exhibit them at the request of the client or of the supervisory authority.
The third-party certifiers recognized at the time by CARB - among which, the Italian CATAS and Cosmob were automatically approved by the EPA for the first two years of activity, with specific renewal procedures. Manufacturers of wood-based panels can therefore turn to these certification bodies. In order to issue certification certificates that comply with the TSCA Title VI, however, the TPC must have begun the recognition process and be officially approved by the EPA.
The panels already certified according to the emissions required by the CARB Phase 2 regulation and the products made with them will be considered compliant with the TSCA Title VI regulations in force in the USA until March 22, 2019. After this date the materials must be certified and labeled as TSCA Title VI.
It is also noted that the state of California will accept products labeled as compliant with U.S. EPA TSCA Title VI
as compliant with CARB formaldehyde emission standards, as the standards are identical.
To consult certified producers: https://www.arb.ca.gov/toxics/compwood/tpc/listofmills.htm
For in-depth material:
For comparison between the two regulations:
- https://www.arb.ca.gov/toxics/compwood/comparisontable.pdfFor info:
+39 0432 email@example.com
+39 0432 firstname.lastname@example.org