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The issue of formaldehyde emissions from composite wood products has been a concern since the gas was deemed carcinogenic in 2004. Now, with new standards coming into force in the US and Europe, manufacturers need to ensure compliance.

What are composite wood products?

Composite wood products are wood-based panels manufactured from wood pieces, particles or fibers that are bonded together with adhesives such as glues and resins. 

The US Act (see below) covers the following composite wood products:

  • Hardwood plywood composite core (HWPW-CC)
  • Hardwood plywood veneer core (HWPW-VC)
  • Particleboards (PBs)
  • Medium density fiberboards (MDFs), including thin-MDFs
  • Laminate products within the meaning of HWPW

What is formaldehyde?

Formaldehyde is a colorless, flammable gas at room temperature with a strong irritating odor. Urea-formaldehyde resins are used in the manufacture of composite or pressed wood products.

High levels of exposure may cause some types of cancer. In 2004, the International Agency for Research on Cancer (IARC) reclassified formaldehyde from ‘probable carcinogenic to humans’ to ‘carcinogenic to humans’.

Which products are affected by formaldehyde emissions?

Some examples are:

  • Cabinets, children’s toys, composite wood panels, counter tops
  • Flooring, furniture
  • Mobile homes/recreational vehicles, moldings in homes
  • Picture frames 
  • Shelving

United States

The Formaldehyde Standards for Composite Wood Products Act (the Act) is a landmark piece of US legislation. It aims to ensure formaldehyde emissions from composite wood panels are within prescribed standards before being used to manufacture consumer goods such as indoor and outdoor furniture.

Implemented by the Environmental Protection Agency (EPA) in December 2016 and effective on all but a few provisions from December 12, 2017, the final rule provides the basis for, among others:

  • Formaldehyde emission standards in composite wood panels 
  • Third-party certification programs 
  • Incentives for products manufactured from ultra low-emitting formaldehyde resins (ULEF) and no added-formaldehyde-based resins (NAF) 
  • Product labeling 
  • Accreditation Bodies (ABs) and Third-Party Certifiers (TPCs)

What are the formaldehyde emission standards for composite wood products?

The Act establishes formaldehyde emission standards - using chamber methods (ASTM E1333 or ASTM D6007) - that are identical to those in Phase 2 of the Air Toxic Control Measure (ATCM) to control formaldehyde emissions under the California Air Resources Board (CARB). See Table 1, below:

Formaldehyde Emission Standards for Composite Wood Products, 40 CFR 770

Composite wood Method Requirement Effective Date
HWPW-VC ASTM E1333 or ASTM D6007 ≤ 0.05 ppm December 12, 2017
HWPW-CC ≤ 0.05 ppm
PB ≤ 0.09 ppm
MDF ≤ 0.11 ppm
Thin-MDF ≤ 0.13 ppm
Laminated products within the definition of HWPW ≤ 0.05 ppm December 12, 2023

Table 1.

What are the impacts of the Act on companies?

Composite wood panels and finished products containing composite wood are required to comply with the Act. The obligations facing economic operators in the supply chain depend upon their roles - and they may have one or more roles (Table 2).

Item Economic Operator Requirement
1 Manufacturers of composite wood panels
  • Undergo Third-Party Certification program, including quarterly testing and routine quality testing
  • Documentation and record keeping
  • Label compliant panels
2 Fabricators
  • Documentation and record keeping
  • Label compliant finished goods
3 Laminators
  • Documentation and record keeping
  • Label compliant laminated products.
4 Importers, distributors and retailers
  • Documentation and record keeping
  • Import certification from December 12, 2018 (importers)

Table 2.

According to the Act, products that are certified by a CARB-approved TPC are also considered certified under Toxic Substances Control Act Title VI until December 12, 2018. TSCA Title VI is the federal law for formaldehyde emissions in composite wood.

European Union (EU)

The EU does not have a specific piece of community-wide legislation regulating formaldehyde emission in composite wood panels. However, some member states such as Austria, Germany, Denmark and Sweden have national legislation restricting formaldehyde emission in these products (Table 3).

The method often adopted for meeting these requirements is EN 717-1 ‘Wood-based Panels – Determination of Formaldehyde Release – Formaldehyde emission by the chamber method’.

Jurisdiction Legislation Scope Requirement
Austria Formaldehyde Regulation (BGBl. Nr. 194/1990) § 1 Wooded materials (chipboards, coated chipboards, cladding boards, veneer boards, single-layered or multi-layered solid wood boards, PBs and MDFs) ≤ 0.1 ml/m3
Denmark Statutory Order No. 289 of June 22, 1983 Chipboards, plywood and similar panels in furniture and furnishings ≤ 0.15 mg/m3
Germany Chemikalien-Verbotsverordnung, Section 3 Coated or uncoated wooden panels (PBs, block boards, plywood and fiberboards) ≤ 0.1 ml/m3
Sweden Chemicals Agency’s Chemical Products and Biotechnical Organisms Regulations (KIFS 2008:2), Sections 19 and 20 Wood-based boards (PBs, plywood, wood-fiber boards, block boards and similar wood-based boards) ≤ 0.124 mg/m3

Table 3.

France is set to join this group of countries regulating emissions. Its environmental law on labeling requirements for volatile organic compounds (VOCs) in furniture containing wood-based panels is likely to adopt proposals to label the category of formaldehyde emissions in these products. If approved, the new law will go into effect on January 1, 2020. 

Why Choose SGS?

SGS is an approved CARB TPC and has world-class expertise in the regulatory landscape, as well as accredited testing laboratories. In addition, we’re dedicated to sharing our knowledge on formaldehyde emissions in composite wood through our training and advisory services.

As a trusted partner for panel manufacturers, fabricators of finished goods, distributors, importers and retailers, we help organizations avoid the cost and inconvenience of non-compliance. 

If you’re releasing a composite wood product onto the US and international markets, you can trust SGS.

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HingWo Tsang, Ph.D.
Global Information and Innovation Manager
Hardlines
SGS Hong Kong Limited
t: +852 2774 7420