CPA has been at the forefront of developing standards for formaldehyde emissions and have actively supported national regulations in the U.S., reflecting the North American industry’s strong commitment to product stewardship.
The CPA advocated in support of both the California Air Resources Board’s (CARB) Airborne Toxic Control Measure and U.S. EPA Formaldehyde Emissions Regulation (TSCA Title VI), the the two chief regulations affecting product emissions in the U.S. These have effectively become global standards and are widely known as the most stringent in the world today. CPA has also actively supported Health Canada in its development of a national standard closely aligned with TSCA Title VI.
The association also sponsors all ANSI standards related to particleboard, MDF, hardboard and engineered wood siding & trim, as well as CPA’s Eco-Certified CompositeTM sustainability standard and certification program, all of which address product emissions and impose stringent and verifiable requirements.
EPA TSCA Title VI
The EPA’s national formaldehyde regulation, known as TSCA Title VI, is widely recognized as the most stringent formaldehyde emissions regulation of composite wood in the world today. It implements “The Formaldehyde Standards for Composite Wood Products Act,”, a bipartisan, bicameral law passed in 2010 that CPA actively supported in cooperation with the Sierra Club, labor union and health advocate stakeholders. Known now as Title VI of EPA’s Toxic Substances Control Act (TSCA Title VI), the law directs EPA to set formaldehyde emission limits and establish a rigorous third-party verification scheme based on the existing California Air Resources Board formaldehyde regulations.
As of March 22, 2019, composite panel producers and manufacturers of products containing them around the world must comply with the requirements of TSCA Title VI if they wish to sell in the U.S. market. These requirements include:
- Quarterly audits and lot-by-lot testing with results reported to EPA-approved third-party certifier.
- Testing of collected samples must be done at an EPA-approved laboratory.
- Non-complying lots must be isolated and properly managed.
- Composite panel producers, finished product manufacturers, distributors and retailers must also meet record keeping and labeling requirements to ensure chain-of-custody and proper notice.
No other regulatory regime in the world today for composite wood panels carries this level of oversight to ensure each production lot destined for the U.S. market has been tested for compliance with the extremely low TSCA Title VI emission limits. CPA members are proud to have supported the TSCA Title VI and its implementing regulations and will be strong advocates for strong enforcement by EPA to best protect consumers and ensure fair competition among manufacturers.
CARB ATCM 93120
The California Air Resources Board “Airborne Toxic Control Measure to Reduce Formaldehyde Emissions from Composite Wood Products” (CARB Rule) is the toughest production standard of its kind in the world and the model for EPA’s national regulation, TSCA Title VI. Initially approved in May 2007, CPA worked closely with the CARB in supporting its development and initial implementation. The North American composite panel industry also made voluntary investments in technology, quality assurance and third-party verification programs in order to meet the state’s stringent formaldehyde standards for all 50 states, even though the regulations only applied in California.
CPA has provided longstanding support for CARB’s strong regulatory enforcement. One of the most high-profile cases involving Chinese-made laminate flooring is a prime example of the continued need for strong regulatory oversight to protect consumers and ensure a level playing field for manufacturers around the world.
CPA also continues to work with California regulators on subsequent updates and amendments to this rule, actively supporting future amendments that better align the CARB rule with TSCA Title VI. CARB is expected to propose new amendments in next few years.
Health Canada published its final formaldehyde regulations for composite panels in the July 7 issue of Canada Gazette, Part II, Volume 155, Number 14. The rules, which have been under development for several years, cover particleboard, medium density fiberboard, thin medium density fiberboard, hardwood plywood and laminated products. The regulations are effective 18 months after publication, with the exception of laminated products which have a five year deadline after the effective date.
The rules are modeled after those developed by the U.S. Environmental Protection Agency (EPA) under the Toxic Substances Control Act (TSCA) Title VI regulation. The emission standards under the Health Canada regulations mirror those of TSCA Title VI. Third-party certification (TPC) and testing requirements, which were not part of the agency’s original proposal, were added and vary slightly from the U.S. regulations due to the authority under the Canadian Environmental Protection Act. CPA and others encouraged Health Canada to include the TPC requirements to level the playing field in North America. For details on the regulations, please visit Canada Gazette.