EPA & CARB P2 Standards for Plywood Products

EPA & CARB P2 Standards for Plywood Products

1. What action did EPA take with this final rule?

EPA finalized a rule to reduce harmful exposures to formaldehyde emitted into the air from certain composite wood products. This rule implements the formaldehyde emission standards and other provisions required under the Formaldehyde Standards for Composite Wood Products Act, which added Title VI to the Toxic Substances Control Act (TSCA). The final rule also establishes a third-party certification program for laboratory testing and oversight of formaldehyde emissions from manufactured and/or imported composite wood products.

2. What are composite wood products and what types are covered by the final rule?

Composite wood products are created by binding strands, particles, fibers, veneers, or boards of wood together with adhesives (i.e., glues). There are three composite wood products regulated under the final rule: hardwood plywood, medium-density fiberboard (MDF, which includes thin-MDF), and particleboard. These composite wood products are commonly used in the manufacture of furniture, kitchen cabinets, flooring, picture frames and wooden children’s toys, among other products.

3. What is formaldehyde and how is it used in composite wood products?

Formaldehyde is a colorless, flammable, strong-smelling chemical that is used in resins (i.e., glues) used in the manufacture of composite wood products (i.e., hardwood plywood, particleboard and medium-density fiberboard).

4. What are the health effects of formaldehyde exposure?

Formaldehyde exposure can have a negative effect on health, both in the short and long term. Formaldehyde can cause irritation of the skin, eyes, nose, and throat. High levels of exposure may cause some types of cancers.

5. When do the rule requirements come into force?

The formaldehyde emission standards come into force beginning June 1, 2018.

By June 1, 2018, and until March 22, 2019, regulated composite wood panels and finished products containing such composite wood panels that are manufactured (in the United States) or imported (into the United States) must be certified as compliant with the TSCA Title VI or the California Air Resources Board (CARB) Airborne Toxic Control Measures (ATCM) Phase II emission standards by a third-party certifier (TPC) approved by CARB and recognized by EPA.

All regulated composite wood products, and finished goods containing composite wood products, manufactured in or imported into the United States after March 22, 2019 are required to be certified as TSCA Title VI compliant by an EPA TSCA Title VI TPC with all of the required accreditations.

Additionally, laminated products not exempted from the definition of hardwood plywood must be tested and certified as meeting the hardwood plywood formaldehyde emission standard beginning March 22, 2024.

6. Who is subject to the final rule requirements?

Those who sell, supply, offer for sale, manufacture or import composite wood products are subject to the final rule requirements. This includes manufacturers, importers, fabricators (e.g., furniture makers) distributors and retailers. Third party certifiers (TPCs) who certify that composite wood products are compliant with the EPA rule and accreditation bodies who accredit and oversee the TPCs are also affected by the rule.

7. What are the formaldehyde emissions standards for covered composite wood products?

The formaldehyde emission standards vary by type of regulated product. In the table below, the product is aligned with its emission standard in parts per million (ppm).

Product Emission Standard

Hardwood Plywood – Veneer Core 0.05 ppm of formaldehyde

Hardwood Plywood – Composite Core 0.05 ppm of formaldehyde

Medium-Density Fiberboard 0.11 ppm of formaldehyde

Thin Medium-Density Fiberboard 0.13 ppm of formaldehyde

Particleboard 0.09 ppm of formaldehyde

8. How does this regulation differ from the California Air Resources Board (CARB) Airborne Toxic Control Measures (ATCM) Phase II regulation?

The formaldehyde emission standards for composite wood products under the final rule, and set by Congress, are identical to the CARB ATCM Phase II emission standards. EPA worked to align the other requirements of the federal rule with the California requirements. However, there are a few differences. Unlike the California requirements, among other things, the final rule requires:

Records be kept for three years versus two years;

Importers to provide import certification under TSCA beginning March 22, 2019;

Manufacturers to disclose upon request formaldehyde testing results to their direct purchasers; and

Laminated products not exempted from the definition of hardwood plywood to be tested and certified as meeting the hardwood plywood formaldehyde emission standard beginning March 22, 2024.

9. Are compliant wood products labeled?

Yes. Beginning June 1, 2018, regulated composite wood products, and finished goods containing composite wood products, manufactured in or imported into the United States are required to be labeled as CARB ATCM Phase II or TSCA Title VI compliant.  All regulated composite wood products, and finished goods containing composite wood products, manufactured in or imported into the United States after March 22, 2019 are required to be labeled as TSCA Title VI compliant.

Until March 22, 2019, CARB ATCM Phase II compliant composite wood panels are considered TSCA Title VI compliant, and the CARB ATCM Phase II label will satisfy the TSCA Title VI labeling requirement. All composite wood panels manufactured in or imported into the United States after March 22, 2019 must be TSCA Title VI compliant and the label on composite wood panels must include the panel producer’s name, lot number, an EPA-recognized TSCA Title VI Third-Party Certifier number, and a TSCA Title VI compliance statement.

Until March 22, 2019, the CARB Phase II label on finished goods will satisfy the TSCA Title VI labeling requirements. The labels on finished goods produced in or imported into the United States after March 22, 2019 must include the fabricator’s name, the date the finished good was produced (in month/year format), and a TSCA Title VI compliance statement.

10. How does EPA ensure that composite wood products do not exceed the emission standards?

EPA established a third-party certification program for laboratory testing and oversight of formaldehyde emissions from manufactured and/or imported regulated composite wood products. This helps to ensure only composite wood products compliant with the formaldehyde emission standards enter the supply chain. For more information, read Small Entity Compliance for Formaldehyde Standards—General Audiences (PDF).