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EPA Implements Formaldehyde Emission Standards for Composite Wood Products

Approximately five-and-a-half years after they statutorily entered into force and more than three years after implementing regulations were originally due, the Environmental Protection Agency is finally implementing the U.S. standards for formaldehyde emissions from hardwood plywood, medium-density fibreboard and particleboard that were included in the Formaldehyde Standards for Composite Wood Products Act of 2010. The EPA indicates that it worked with the California Air Resources Board to help ensure that its final rule is consistent with current California requirements for composite wood products. According to Assistant EPA Administrator Jim Jones, “the new rule will level the playing field for domestic manufacturers who have a high rate of compliance with the California standard and will ensure that imported products not subject to California’s requirements will meet the new standard and thus, not contain dangerous formaldehyde vapors.”

Under the EPA final rule, one year after publication the rule in the Federal Register all hardwood plywood made with a veneer or composite core, particleboard, medium-density fibreboard and finished goods containing these materials (referred to as composite wood products, including products used or installed in manufactured housing) imported, sold, supplied, offered for sale or manufactured in the United States will be required to comply with the following emission standards, which are identical to California’s CARB ATCM Phase 2 standards.

  • for hardwood plywood made with a veneer core or a composite core, 0.05 parts per million of formaldehyde
  • for medium-density fibreboard, 0.11 ppm of formaldehyde
  • for thin medium-density fibreboard, 0.13 ppm of formaldehyde
  • for particleboard, 0.09 ppm of formaldehyde

The definition of hardwood plywood only includes products that are panels and are intended for interior use. Exempted from the scope of this definition are laminated products made by attaching a wood or woody grass veneer to a compliant core or platform with either a phenol-formaldehyde resin or a resin formulated with no added formaldehyde as part of the resin cross-linking structure. To be eligible for this exemption, laminated product producers must maintain records demonstrating their eligibility. Seven years after the final rule is issued, laminated product producers whose products are not exempted from the definition of hardwood plywood are required to test their products to ensure they comply with the formaldehyde emission standard for hardwood plywood.

The emission standards will apply regardless of whether the composite wood product is in the form of a panel or a component part or incorporated into a finished good. However, the following products are excluded from the standards.

  1. any finished good that has previously been sold or supplied to an end user, an individual or entity that purchased or acquired it in good faith for purposes other than resale (e.g., an antique or second-hand furniture dealer)
  2. hardboard
  3. structural plywood as specified in PS-1-07, Voluntary Product Standard—Structural Plywood
  4. structural panels as specified in PS-2-04, Voluntary Product Standard—Performance Standard for Wood-Based Structural-Use Panels
  5. structural composite lumber as specified in ASTM D5456-06, Standard Specification for Evaluation of Structural Composite Lumber Products
  6. oriented strand board
  7. glued laminated lumber as specified in ANSI A190.1-2002, Structural Glued Laminated Timber
  8. prefabricated wood I-joists as specified in ASTM D5055-05, Standard Specification for Establishing and Monitoring Structural Capacities of Prefabricated Wood I-Joists
  9. finger-jointed lumber
  10. wood packaging, including pallets, crates, spools and dunnage
  11. composite wood products used inside (i) new vehicles (other than recreational vehicles) that are constructed entirely from new parts and that have never been the subject of a retail sale or registered with the applicable state or other governmental agency, (ii) new rail cars, (iii) new boats, (iv) new aerospace craft and (v) new aircraft.
  12. windows that contain composite wood products if the windows contain less than five percent by volume of composite wood products in relation to the total volume of the finished window
  13. exterior doors and garage doors that contain composite wood products if (i) the doors are made from composite wood products manufactured with no-added formaldehyde-based resins or ultra low-emitting formaldehyde resins, or (ii) the doors contain less than three percent by volume of composite wood products in relation to the total volume of the finished exterior door or garage door

Only certified composite wood products, whether in the form of panels or incorporated into component parts or finished goods, will be allowed to be imported, sold, supplied, offered for sale or manufactured upon entry into force of the emission standards, unless the product is specifically exempted. To obtain and maintain certification, panel producers must establish quality assurance/quality control programmes, conduct regular quality control testing of product emissions, and have an EPA-recognised third-party certifier conduct or oversee quarterly formaldehyde emissions testing. Accreditation bodies may begin to apply for accreditation 60 days after the rule is published, and TPCs may apply to certify compliance after their accreditation body is recognised by the EPA and they are properly accredited.

The EPA has clarified in a separate questions-and-answers document that, while finished goods do not require formaldehyde emissions testing and certification, the component parts of the finished good that are considered to be regulated composite wood products must be tested to ensure they comply with the emission standards. There are recordkeeping requirements for the compliant composite wood products that are component parts of the finished goods that document they are certified as being compliant. The EPA has also indicated that formaldehyde emission testing is required to be conducted by panel producers and TPCs. Fabricators and retailers, for their part, are responsible for ensuring the purchase of only compliant composite wood products, whether they are unfinished panels or incorporated into component parts of finished goods.

Producers of composite wood product panels made with no-added formaldehyde-based resins will be able to apply to a TSCA Title VI TPC or CARB for a two-year exemption from the testing and certification requirements. The emission standards for composite wood products made with no-added formaldehyde-based resins are as follows.

  • no test result higher than 0.05 ppm of formaldehyde for hardwood plywood and 0.06 ppm for particleboard, medium-density fibreboard and thin medium-density fibreboard
  • no higher than 0.04 ppm of formaldehyde for 90 percent of the three months of routine quality control testing data

Similarly, producers of composite wood product panels made with ultra low-emitting formaldehyde resins will be able to apply to a TSCA Title VI TPC or CARB for approval either to conduct less frequent testing or a two-year exemption from the testing and certification requirements. The emission standards for reduced testing for composite wood products made with ultra low-emitting formaldehyde resins are as follows.

  • no test result higher than 0.05 ppm of formaldehyde for hardwood plywood, 0.08 ppm for particleboard, 0.09 ppm for medium-density fibreboard and 0.11 ppm for thin medium-density fibreboard
  • for 90 percent of the six months of routine quality control testing data required, no higher than 0.05 ppm of formaldehyde for particleboard, no higher than 0.06 ppm of formaldehyde for medium-density fibreboard, and no higher than 0.08 ppm of formaldehyde for thin medium-density fibreboard

The emission standards for an exemption from the testing and certification requirements for composite wood products made with ultra low-emitting formaldehyde resins are as follows.

  • no test result higher than 0.05 ppm of formaldehyde for hardwood plywood or 0.06 ppm of formaldehyde for particleboard, medium-density fibreboard, and thin medium-density fibreboard
  • for 90 percent of the six months of routine quality control testing data required, no higher than 0.04 ppm of formaldehyde

Panels or bundles of panels that are sold, supplied or offered for sale in the United States must be labelled with the panel producer’s name, the lot number, the number of the EPA TSCA Title VI TPC, and a statement that the products are TSCA Title VI certified. If a composite wood panel is not individually labelled, the panel producer, importer, distributor, fabricator or retailer must have a method (e.g., colour-coded edge marking) sufficient to identify the supplier of the panel and linking the information on the label to the products. This information must be made available to potential customers upon request. The label may be applied as a stamp, tag or sticker.

A panel producer number may be used instead of a name to protect identity, so long as the identity of the panel producer can be determined at the request of the EPA. Only panels or bundles of panels manufactured in accordance with the regulations may also be labelled that they were made with no-added formaldehyde-based resins or with ultra low-emitting formaldehyde resins, as applicable, in addition to the other required information. Panels imported into or transported across the United States for quarterly or quality control testing purposes must be labelled “For TSCA Title VI testing only, not for sale in the United States”, although these panels may be re-labelled if test results are below the applicable emission standards.

Importers, distributors and retailers must leave intact labels on finished goods, including component parts sold separately to end users. Finished goods, including component parts sold separately to end users, containing only a de minimis amount of regulated composite wood products are excepted from the labelling requirements. A finished good, including component parts sold directly to consumers, will be deemed to contain a de minimis amount of regulated composite wood products if its regulated composite wood product content does not exceed 144 square inches based on the surface area of its largest face. This exception does not apply to finished goods or component parts that are designed to be used in combination or in multiples to create larger surfaces, finished goods or component parts.

Importers, fabricators, distributors and retailers must take reasonable precautions to ensure that the composite wood products they sell, supply, offer for sale or hold for sale, whether in the form of panels, component parts or finished goods, comply with the applicable emission standards. Importers must demonstrate that they have taken reasonable precautions by maintaining, for three years, bills of lading, invoices or comparable documents that include a written statement from the supplier that the composite wood products, component parts or finished goods are TSCA Title VI compliant or were produced prior to the date that is one year after publication of the final rule in the Federal Register and by ensuring that certain records are made available to the EPA within 30 calendar days of a request.

Panel producers must also maintain certain records for a period of three years, except that records demonstrating initial eligibility for reduced testing or third-party certification exemption must be kept for as long as the panel producer is producing composite wood products with reduced testing or under a third-party certification exemption.

Content provided by Picture: HKTDC Research
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