SAFEGUARDS | Consumer Products NO. 006/17

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The California Air Resources Board (CARB) has recently published a revised advisory to assist the composite wood products industry with labeling requirements for panels and finished goods.

In April 2007, the Airborne Toxic Control Measure (ATCM) was approved by the California Air Resources Board (CARB) to reduce formaldehyde emissions from composite wood panels. This was approved by the Office of Administrative law in 2008 [1]. The scope applies to hardwood plywood-veneer core (HWPW-VC), hardwood plywood-composite core (HWPW-CC), particleboards (PBs) and medium-density fiberboards (MDFs).

The formaldehyde emission standards in the ATCM were implemented in 2 phases. Phase 1 was implemented in January 2009 and Phase 2 was implemented during 2010-2012.

In July 2009, we [2] informed you that the CARB published a revised advisory clarifying the labeling requirements for panel manufacturers, fabricators of finished goods and importers, distributors and retailers of panels and finished goods. That revision specified minimum information requirements and other recommendations.

On January 10, 2017, the CARB posted the latest revision to the advisory on labeling requirements. This advisory [3], dated November 2016, contains a number of important changes, including:

  • Information to be included on the label for panel manufacturers and fabricators of finished goods.
  • The use of language to reflect the latest implementation of the law.

Highlights of the latest advisory on labeling requirements are summarized in Table 1.

Advisory Number 384 – Revised, November 2016
Labeling Requirements for Panel Manufacturers, Fabricators, of Finished Goods, and Importers, Distributors, and Retailers of Panels and Finished Goods
Label Panel manufacturer Fabricator Distributor / Importer / Retailer
Minimum information
  • Name
  • Product lot number or batch number
  • CARB-assigned number for third-party certifier (TPC)*
  • Marking to denote ‘compliance with phase 2 requirements of the ATCM’
  • Name
  • Date finished goods were produced (mm/yyyy)
  • Statement of compliance with the ATCM
  • Finished goods made with NAF/ULEF based resins to be labeled as such

No additional labeling required

(Distributors and importers only require labeling if products are modified)

Other recommendations
  • Label each individual panel
  • Date of manufacture (mm/dd/yyyy)
  • Statement of compliance containing at least the word ‘California’ or ‘CARB’, section 93120, compliance phase or NAF/ULEF
  • Label both finished goods and box containing finished goods
  • Statement of compliance containing the word ‘California’ or ‘CARB’, section 93120, compliance phase or NAF/ULEF
Example of label

Company ABC

Lot number 3, 02/05/2016

California 93120 Phase 2

Compliant for Formaldehyde


Company ABC


California 93120 Phase 2

Compliant for Formaldehyde


California 93120 Complaint for Formaldehyde – Produced with all NAF-based products


California 93120 Compliant for Formaldehyde – Produced with all ULEF-based products

*Not required if the products are exempt from third party certification by using no-added formaldehyde (NAF) and contain certain ultra low-emitting formaldehyde (ULEF) based resins after approval by CARB.


SGS will follow up and inform interested parties as development on formaldehyde emissions in composite wood products under CARB and other legislation as they occur. Throughout our global network of laboratories, we are able to provide a range of services, including analytical testing and consultancy for the emission of formaldehyde in composite wood products destined for California and international markets. Please do not hesitate to contact us for further information.


For enquiries, please contact:

Hingwo Tsang
Global Hardlines Information and Innovation Manager
t: +852 2774 7420

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