SGS in Hong Kong Continues to Certify Composite Wood Products Beyond March 2019
We are pleased to announce that in October 2018 SGS in Hong Kong became the first Third-Party Certifier (TPC) to be accredited by the Hong Kong Accreditation Service (HKAS), an Accreditation Body (AB) recognized by the US Environmental Protection Agency (EPA) to provide services under the Formaldehyde Emission Standards for Composite Wood Products Rule.
This achievement enhances our platform to continue testing and certifying composite wood products beyond March 22, 2019 for the US market, and further positions SGS as a global leader in certifying these products and related services.
In the United States, formaldehyde emissions from composite wood products are governed by the 'Formaldehyde Standards for Composite Wood Products Act' (the Act). This landmark piece of legislation was signed into law in July 2010 and became the amendment and Title VI of the 'Toxic Substances Control Act' (TSCA). It contains requirements for composite wood panel manufacturers, fabricators of finished goods, and importers, distributors and retailers of composite wood panels and finished goods. This Act is administered by the US Environmental Protection Agency (EPA).
The Final Rule, as amended by the EPA, includes provisions for formaldehyde emission standards in hardwood plywood composite core or veneer core (HWPW-CC or VC), particleboards (PBs), medium-density fiberboards (MDFs), thin-MDFs, laminated products within the meaning of HWPW, third party certification programs for panel manufacturers, incentives for products manufactured using ultra-low emitting formaldehyde resins (ULEF) and no added-formaldehyde-based resins (NAF), product labeling, record keeping, import certification, ABs, TPCs, and other requirements for composite wood products.
Examples of Composite Wood Products
The Act regulates HWPW-CC, HWPW-VC, PBs, MDFs, thin-MDFs, and laminated products within the meaning of HWPW, as well as finished goods produced from these composite wood materials. Examples of finished goods containing these materials include the following:
- Composite wood panels
- Furniture and related products
- Kitchen cabinets
- Mobile homes/recreational vehicles, molding in homes
- Picture frames
- Prefabricated wood buildings
- Travel trailers and campers
- Wooden toys
What are the Formaldehyde Emissions Standards?
The formaldehyde emission standards are identical to those in Phase 2 of the Air Toxics Control Measure (ATCM) to Reduce Formaldehyde Emissions from Composite Wood Products under the California Air Resources Board (CARB). These standards are tested using ASTM E1333-14 (large chamber) or, upon a showing of equivalence, ASTM D6007-14 (small chamber). The compliance dates for composite wood products are summarized in Table 1.
|Composite Wood||Formaldehyde Emission||Compliance Date|
|HWPW-CC or HWPW-VC||≤ 0.05 ppm||June 1, 2018|
|PB||≤ 0.09 ppm||June 1, 2018|
|MDF||≤ 0.11 ppm||June 1, 2018|
|Thin-MDF (≤ 8 mm thickness)||≤ 0.13 ppm||June 1, 2018|
|Laminated products within the meaning of HWPW||≤ 0.05 ppm||March 22, 2024|
Table 1. Formaldehyde Emission Standards for Composite Wood Products
Third-Party Certification Program
The Act recognizes CARB-TPCs through reciprocity with the CARB program. According to the Act, composite wood products certified by CARB-approved TPCs (that are also recognized by the EPA) are considered certified until March 22, 2019, a transitional period for CARB-approved TPCs to certify composite wood products under TSCA Title VI without an accreditation issued by an EPA TSCA Title VI AB. After March 22, 2019, CARB-TPCs must be fully accredited to remain recognized as an EPA TSCA Title VI TPC to continue certifying composite wood products as TSCA Title VI compliant.
Economic Operators and Product Labeling
Composite Wood Panel Manufacturers
Panels are to be labeled individually or as bundles, in the form of a stamp, tag or sticker. A traceability system such as color-coded edge markings is required for bundles in case panels become separated from the bundle. The information on the label must include:
- Name of composite wood panel manufacturer
- Lot number
- EPA-recognized TPC identification number
- Statement that the products are TSCA Title VI Certified. Until March 22, 2019, composite wood panels certified as compliant with CARB ATCM Phase II emission standards are to be labeled as compliant with either TSCA Title VI or CARB-ATCM Phase II emission standards. After March 22, 2019, composite wood panels must be certified and labeled as TSCA Title VI compliant
Fabricators are to label each finished good, box or bundle containing finished goods in the form of a stamp, tag or sticker. Finished goods, including component parts that are sold separately to end users, are exempt from labeling requirements if the surface area of the largest face of these composite wood products is not more than 144 square inches.
The information on the label must include:
- Name of fabricator or substitute with downstream fabricator, importer, distributor or retailer
- Date the finished goods were manufactured (month/year)
- Statement that the goods are TSCA Title VI compliant
Importers, Distributors and Retailers
These economic operators are required to retain a copy of the label for finished goods, including component parts that are sold separately to end users, that are not individually labeled to customers.
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