About EPA/CARB Regulations
CARB ATCM 93120 regulations were originally enacted in 2008 and apply to composite wood products including hardwood and decorative plywood (HWPW), medium density fiberboard (MDF), and particleboard (PB) that is sold, offered for sale, supplied, used, or manufactured for sale in the U.S. state of California. CARB ATCM 93120 regulations also require that finished goods and laminated products must be made using only CARB-certified composite wood products. Compliance to CARB Phase 2 formaldehyde emission standards and requirements is currently mandatory for all composite wood panels as well as component parts and finished goods containing such materials that are manufactured, imported, distributed, or sold in the state of California.
EPA TSCA Title VI regulations were originally enacted in 2018 and apply to composite wood products including hardwood and decorative plywood (HWPW), medium density fiberboard (MDF) and particleboard (PB) as well as to component parts and finished goods containing such materials that are sold, supplied, offered for sale, or manufactured (including imported) in the United States. The formaldehyde emission standards specified in EPA TSCA Title VI are similar to those set by CARB ATCM 93120, Phase 2 regulations; however, there are differences in the testing, record keeping and labeling requirements that apply.
TSCA Title VI regulations also require that laminated products made using a formaldehyde-containing resin must also be third-party certified. A laminated product is defined as a product in which a wood or woody grass (e.g., bamboo) veneer is adhered to a TSCA Title VI-certified plywood, MDF, or particleboard platform using a formaldehyde-containing resin. A laminated product is a component part used in the construction or assembly of a finished good. Laminated product producers must achieve third-party certification by an EPA-approved third-party certifier on or before March 22, 2024. Laminated product producers that use a No-Added Formaldehyde (NAF) or phenol resin during the veneer-lamination process are not required to achieve third party certification provided they comply with the additional record-keeping provisions as specified in the TSCA Title VI regulation.
For composite wood panels and laminated products to be certified as conforming to CARB 93120 or EPA TSCA Title VI regulations, the panels must have been produced by either:
a manufacturer who is independently certified by a EPA/CARB-approved Third Party Certifier (TPC), or;
a manufacturer who has obtained exemption from third party certification on the basis of the use of Ultra-Low Emitting Formaldehyde (ULEF) or No-Added Formaldehyde (NAF) resins.
The manufacturer must perform routine quality control testing of the composite wood products it produces to verify the products meet EPA and CARB formaldehyde emission standards and is labeled accordingly. Additional documentation, record-keeping, and TPC oversight and independent testing requirements also apply.
