On September 8, EPA hosted a virtual workshop to address guidance the agency is preparing for manufacturers of laminated products. Laminated products are defined under TSCA Title VI as a composite or veneer core with attached wood or woody grass veneer (e.g., bamboo) made by a fabricator as a component part used in the construction or assembly of a finished good.
Beginning March 22, 2024, manufacturers of laminated products made with no-added formaldehyde (NAF) or phenolic resins will need to keep additional records but will be exempt from other requirements, most notably testing and certification. Laminated products made with urea formaldehyde or other formaldehyde resins must meet all of the requirements for hardwood plywood, including emissions, by the same compliance date. A provision in the formaldehyde emission standard at 40 CFR § 770.4(b) allows persons to petition EPA to be exempt from these requirements.
Through last week’s workshop and public comment process, EPA is soliciting feedback on the development of this guidance. Topics of focus include a product’s formaldehyde emission potential, resin chemistry and alternatives, among other items. The public comment submission deadline is November 4, 2020. CPA will monitor developments and report back to members. See EPA Public Comment Portal.