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Manufacturers and suppliers of manmade wood products need to understand the new regulations in order to ensure their products are compliant.

On July 7, 2010, President Obama signed into law the Formaldehyde Standards for Composite Wood Products Act (the Act), adding Title VI to the Toxic Substances Control Act (TSCA) and requiring the US Environmental Protection Agency (EPA) to regulate formaldehyde in composite wood products. 

Formaldehyde was classified as ‘carcinogenic to humans’ by the International Agency for Research on Cancer (IARC) in 2004. Exposure to this colorless, strong smelling, flammable gas can cause a variety of symptoms and adverse effects in humans, including itching and stinging of the eyes, respiratory problems, skin dermatitis, nausea and headaches. The Act’s emphasis on composite or pressed wood products stems from the fact these articles often use adhesives containing urea-formaldehyde resins. 

The Final Rule issued by the EPA following the introduction of the Act gives prominence to the need for traceability. In addition to the testing conditions placed upon manufacturers, all economic operators in the supply chain – including fabricators, importers, distributors and retailers – must comply with requirements on documentation and record keeping. In addition, the Final Rule also makes demands upon specific economic operatives, including requirements over labeling and importation certification.

Scope

The Act requires composite wood panels to be tested and certified by an EPA-recognized third-party certifier (TPC). These are to be used in the manufacture of finished goods before they are offered for sale in the US.

Regulated products include:

  • Hardwood Plywood-Composite Core (HWPW-CC)
  • Hardwood Plywood-Veneer Core (HWPW-VC)
  • Particleboards (PBs)
  • Medium Density Fiberboards (MDFs)
  • Thin-MDFs
  • Laminated products within the meaning of HWPW (manufactured using a resin other than phenol formaldehyde (PF) or no added-formaldehyde (NAF) to attach the veneer to a compliant platform)
  • Finished goods manufactured using composite wood products, e.g. children’s wooden toys, counter tops, flooring, picture frames, shelving, travel trailers and campers, and fabricated wood buildings

Stakeholders should note that wood panels manufactured with no-added formaldehyde (NAF) or ultra-low emitting formaldehyde (ULEF) resins can qualify for reduced testing and certification exemptions.

Formaldehyde Emission Standards

Under the terms of the Act, the standards introduced are identical to those in Phase 2 of the Airborne Toxic Control Measures (ATCM) introduced by the California Air Resources Board (CARB) to reduce formaldehyde emissions in composite wood products. These formaldehyde emission standards can be tested using ASTM E1333 (large chamber) or ASTM D6007 (small chamber). See table below for individual product requirements and effective dates:

Formaldehyde Emission Standards using ASTM E1333 or ASTM D6007
Composite Wood Requirement Compliance Date
HWPW-VC or HWPW-CC ≤ 0.05 ppm June 1, 2018
PB ≤ 0.09 ppm June 1, 2018
MDF ≤ 0.11 ppm June 1, 2018
Thin-MDF (≤ 8mm thickness) ≤ 0.13 ppm June 1, 2018
Laminated products within the meaning of HWPW ≤ 0.05 ppm March 22, 2024

Third-Party Certification

Before a product can be offered for sale in the US it must be certified as compliant by an EPA TSCA Title VI TPC. This certification process involves the following:

  • Contact information
  • Manufacturer’s quality control manual
  • Contact information for the quality control (QC) manager
  • List of products and their resin systems
  • At least 5 formaldehyde test results carried out by an EPA TSCA Title VI TPC using a specified method
  • Results of at least 5 quality control tests
  • Linear regression equation and correlation data
  • Results of the initial onsite inspection by an EPA TSCA Title VI TPC

In addition to this, the EPA-approved TPC must also perform quarterly inspections of panel manufacturers and conduct emission tests, and the manufacturer must monitor day-to-day operations for consistency using one of several small-scale methods, e.g. ASTM D6007 (small chamber) or Dynamic Micro Chamber (DMC).

To assist the industry during the introduction of the Act, TPCs that are currently CARB-approved will be recognized as an EPA TSCA Title VI TPC until March 22, 2019. After this date, all TPCs must be fully recognized by the EPA TSCA Title VI accreditation body.

SGS Solutions: Formaldehyde Emission Certification Services

With a global network of specialists and EPA-recognized TPC laboratories in Hong Kong, Guangzhou, Shanghai and Taiwan, SGS helps companies around the world understand and comply with the requirements of the Act. 

Services include: 

  • Consultancy on how the Act applies to your composite wood products
  • Certification of panel manufacturers (mills), including gap assessments, setting up an in-house lab and quality control system, correlation testing and quality control personnel
  • Factory inspection services
  • Correct labeling procedures
  • Documentation and record keeping 

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To learn more about SGS Formaldehyde Emission Certification Services, you can download our new white paper, Understanding the US Formaldehyde Requirements to Market Compliant Composite Wood Products or contact:

Hing Wo Tsang Ph.D
Global Information and Innovation Manager
t: (+852) 2774 7420
www.sgs.com/hardlines