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 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.
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.
For over 30 years, North American composite panel manufacturers have been at the forefront of developing standards for formaldehyde emissions and have actively supported national regulations in the U.S. that are widely recognized as the most stringent in the world today.
- Worked closely with the California Air Resources Board (CARB) to support development and implementation of California’s formaldehyde emissions regulation.
- Voluntarily applied the California emissions limits to all U.S. production.
- Led efforts along with the Sierra Club and other NGOs to secure bipartisan legislation calling for a national formaldehyde emissions regulation.
- Actively supported EPA’s development of implementing regulations – known as TSCA Title VI - based on the California standard.
CPA and its members continue today their commitment to controlling formaldehyde emissions by advocating to both EPA and CARB for strong enforcement to best protect consumers and ensure fair competition among manufacturers. CPA is also providing technical support to Canadian and Mexican regulators seeking to develop regulations that mirror the EPA’s TSCA Title VI.
Meeting emissions standards is something CPA members take great pride in, and it should provide consumers with the utmost confidence that North American producers take their regulatory obligations seriously.
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, distributers and retailers must also meet recordkeeping 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.
Resource Guide: What the EPA Formaldehyde Rule Means to You (Updated 3/20/18)
At-a-Glance: EPA Rule At-a-Glance (Updated 3/20/18)
CPA Webinar: TSCA Title VI - March 23, 2018
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 late 2019.
Canadian Formaldehyde Regulation
On May 3, 2017, the Canadian House of Commons passed unanimously (283-0) a Private Members’ motion calling on the Canadian Government to adopt regulations on formaldehyde emissions from composite wood that are similar to those under TSCA Title VI. Health Canada has since taken the lead in developing draft regulations in cooperation with Environment and Climate Change Canada. Both agencies have jointly published a draft consultation document and hosted a public stakeholder meeting to take comment. Health Canada has publicly stated that it expects to publish draft regulations in the Canada Gazette, Part I, in 2019.
CPA strongly supports a national, Canadian regulation that is aligned with TSCA Title VI.
CPA sponsors the Eco-Certified CompositeTM sustainability standard and certification program, a voluntary industry sustainability standard for manufacturers of composite wood. In addition to meeting a number of criteria related to carbon footprint, wood sourcing, and sustainable manufacturing, composite panel plants must commit to meeting the CARB and EPA TSCA Title VI formaldehyde emissions requirements for 100% of its panels 100% of the time. This standard sets ECC-Certified mills apart from the rest of the world’s producers, requiring an attention to detail and rigorous commitment to compliance that is unmatched. Many of the world’s producers can ship noncomplying panels to other jurisdictions, including in their own countries, where the TSCA Title VI emission limits do not apply. ECC certification offers the highest level of assurance that users and specifiers receive trusted, compliant product.
Products carrying the ECC-certified logo are produced in a manufacturing plant that is audited and certified by CPA. ECC certification requires an on-site qualification audit and subsequent annual audits of individual manufacturing facilities. These inspections include review of the plant’s quality control manual, personnel, wood yard and all relevant record on production and formaldehyde testing. This level of oversight ensures that the sustainability criteria – including the 100% 100% of the time requirement – are being made on a plant-wide scale. MORE INFO (ECC page or the 2-pager?)
CPA also sponsors all ANSI standards related to particleboard, MDF, hardboard and engineered wood siding & trim, which address product emissions and impose stringent and verifiable requirements.