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CPA: Quick Guide To The EPA Formaldehyde Regulation

If you manufacture finished goods that contain particleboard, medium density fiberboard (MDF) or hardwood plywood (HWPW), then you likely have been preparing to comply with the Environmental Protection Agency’s (EPA’s) Formaldehyde Emissions Standards for Composite Wood Products rule. If this is the first time you have heard of this Regulation, known also as “TSCA Title VI” after the statutory authority for the regulation, there is still time to prepare for compliance, but time is of the essence. This article provides a general outline of the TSCA Title VI requirements applicable to manufacturers of finished products containing composite wood panels, as well as the key dates for compliance, which have only just been finalized through recent litigation.

TSCA Title VI covers all finished goods and component parts made with particleboard, MDF and HWPW. Fabricators that make component parts using a wood or woody grass veneer (such as bamboo) attached to a composite wood core that is later used in a finished product may also meet the definition for “laminated product” producers, which triggers several additional requirements starting March 22, 2024. TSCA Title VI does include a “de minimis” exemption for finished goods or component parts sold directly to end users if its composite wood content does not exceed 144 square inches on its largest face. This exemption applies only to labeling; products such as small picture frames and others that meet the de minimis definition must still be made with compliant composite wood and comply with recordkeeping requirements.

The central requirement for manufacturers of finished goods is that they use compliant composite wood and that this is documented throughout the supply chain. On March 13, 2018, the U.S. District Court for the Northern District of California issued an order altering many TSCA Title VI compliance dates, including those related to sourcing. Fabricators must either begin using TSCA Title VI certified composite wood panels in all component parts and finished goods by June 1, 2018, or be able to prove that the composite wood panels or component parts were manufactured before, or were in inventory prior to, that date. The Court has now also allowed California Air Resources Board Airborne Toxic Control Measure Phase 2 (“CARB 2”) certified composite wood panels to be considered TSCA Title VI compliant until March 22, 2019.

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