Environmentally Friendly Products

CARB - California Air Resources Board

CARBFormaldehyde is produced on a large scale worldwide. One major use includes the production of wood binding adhesives and resins. The ARB evaluated formaldehyde exposure in California and found that one of the major sources of exposure is from inhalation of formaldehyde emitted from composite wood products containing urea-formaldehyde resins. The International Agency for Research on Cancer (IARC) reclassified formaldehyde from “probably carcinogenic to humans” to “carcinogenic to humans” in 2004, based on the increased risk of nasopharyngeal cancer. Formaldehyde was also designated as a toxic air contaminant (TAC) in California in 1992 with no safe level of exposure. State law requires ARB to take action to reduce human exposure to all TACs.

CARBStaff of the Air Resources Board (ARB) conducted a formal rulemaking process to address formaldehyde exposure from composite wood products. On April 26, 2007, ARB approved an airborne toxic control measure (ATCM) to reduce formaldehyde emissions from composite wood products including hardwood plywood, particleboard, medium density fiberboard, thin medium density fiberboard (thickness ≤ 8mm), and also furniture and other finished products made with composite wood products.

The ATCM to control formaldehyde emissions from composite wood products was approved on April 18, 2008 by the Office of Administrative Law. The regulation has been filed with the Secretary of State to be codified into Title 17 of the California Code of Regulations, and is immediately effective. The first emission standards will be implemented on January 1, 2009. The final regulation text is now available.

Sell Through Provisions:
Grace Period from January 1, 2009
Panel Manufacturer
3 Months
Distributors – Raw panels
5 Months
Importers – Raw Panels
3 Months
Distributors/Importers – Finished Products
18 Months
18 Months
Retailers – Raw Panels
12 Months
Retailers – Finished Products
18 Months

Key Definitions
Component Part - A fabricated part that contains one or more composite wood products and is used in the assembly of finished goods.

Distributor – Any person to whom a composite wood products or finished good is sold or supplied for the purposes of resale or distribution in commerce, except that manufacturers and retailers are not “distributors”.

Fabricator – Any person that uses composite wood products to make finished goods. “Fabricator” includes producers of laminated products.

Finished Goods – Any good or product, other than a panel, containing hardwood plywood, particleboard, or medium density fiberboard. Component parts are not “finished goods,” although they are used in the assembly of finished goods. “Finished Goods” do not include used goods such as antiques or second-hand furniture. For the purposes of this subsection, a “used good” means a “finished good” that has been previously been sold or supplied to the ultimate purchaser. “Ultimate Purchaser” means the first person in good faith purchases or acquires a “finished good” for purposes other than resale.

Hardboard – A composite panel composed of cellulosic fibers, made by dry or wet forming and hot pressing of a fiber mat with or without resins, that complies with one of the following ANSI standards: “Basic Hardboard” (ANSI A135.4-2004), “Prefinished Hardboard Paneling” (ANSI A135.5-2004), or “Hardboard Siding” (ANSI 135.6-2006).

Hardwood Plywood (HWPW) – A panel composed of an assembly of (A) hardwood layers or piles of veneer or (B) veneers in combination with a platform consisting lumber core, composite core, a special core material, or special back material, joined with an adhesive. The face veneer may be composed of a hardwood or decorative softwood species (ANSI/HPVA HP-1-2004). “Hardwood Plywood” includes wall paneling, industrial panels, and “hardwood plywood” panels used in making flooring. “Hardwood Plywood” does not include laminated products, military specified plywood, or curved plywood.

Importer –
The person or entity as defined in the regulations of the Bureau f Customs and Border Protection, 19 Code of Regulations, Section 101.1.

Laminated Product –
A finished good or component part of a finished good made by a fabricator in which a laminate or laminates are affixed to a platform. If the platform consists of a composite wood product, the platform must comply with the applicable emission standards.

Panel – Any particleboard, medium density fiberboard, or hardwood plywood board produced for sale, supply, or distribution by a composite wood product manufacturer.

Retailer – Any person or entity that sells, offers for sale, or supplies directly to consumers composite wood products or finished goods that contain composite wood products.

Third Part Certifier – An organization or entity approved by the Executive Officer that: (A) verifies the accuracy of the emission test procedures and facilities used by manufactures to conduct formaldehyde emission tests, (B) monitors manufacturer quality assurance programs, and (C) provides independent audits and inspections.

Veneer – Thin sheets of wood peeled or sliced from logs for use in the manufacture of wood products such as plywood, laminated veneer lumber, laminated products, or other products.

Final Regulation
Obligation of Distributor
Obligation of Fabricator
Requirements for Fabricators
Labeling Advisory
Enforcement Sell Through Advisory
Additional information is available on the Composite Panels Associations CARB resource page