EPA PANEL LABELING REQUIREMENTS FOR PRODUCERS OF REGULATED COMPOSITE WOOD PANELS
EPA and CARB distinguish between composite wood panels manufactured by certified facilities versus component parts or finished goods such as flooring, cabinetry, or furniture which are made by a Fabricator using certified composite wood panels.
Please refer to the following requirement specified in EPA TSCA Title VI:
EPA TSCA Title VI §770.45 (a) states: “Panels or bundles of panels that are imported, sold, supplied, or offered for sale in the United States must be labeled 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.”
What does this mean to you?
If you are a certified manufacturer of HWPW-VC, HWPW-CC, MDF, thin-MDF and/or Particleboard panels:
- You must ensure each panel or bundle of panels contains a compliant label. The label, must be applied as a stamp, tag, or sticker.
- Each label must contain four (4) required elements: 1) Panel producer’s name, 2) Lot Number, 3) TPC Number, 4) Statement of Compliance. All label information must be in the English language.
- Panel producers that have achieved exemption from certain EPA/CARB quality control testing and reporting requirements based on the use of No-Added Formaldehyde (NAF) and/or certain Ultra-Low Emitting Formaldehyde (ULEF) resins are permitted to include a statement which indicates that panels were made using NAF or ULEF resins, as applicable. This statement is in addition to the four (4) required labeling elements described in item 2 above. Adding a reference to the use of ULEF or NAF resins is optional and is only permitted by those entities that have achieved written approval for exemption by both CARB and the TPC.
- Panel producers must retain a copy of the label used for each lot of certified panels you manufacture and sell. Copies of the labels must be retained for a minimum of three (3) years after the date of production.
- Panel producers must comply with the minimum labeling content requirements (as described above). However, you have flexibility to specify the color, font, or other formatting details – so long as all required label information is readable in English, not in code, and can easily allow anyone (including the public) to determine that the material is compliant with the formaldehyde regulations.
- Finally, as specified in TSCA Title VI Part 770.45(f): “All panels (or bundles of panels)… must be properly labeled… before being imported into the United States…”
This requirement is critical. Panels and/or bundles of panels that have not been properly labeled are not permitted to be imported or distributed in the USA for any reason. Labeling errors are considered by EPA to be critical violations and panel producers can be held legally responsible for failing to comply with this and other EPA/CARB formaldehyde emission, certification, and record-keeping requirements.
If you have any questions regarding these requirements or if you would like to verify your facility’s operational conformity regarding this or other matters, please do not hesitate to contact the Benchmark Certification Team at firstname.lastname@example.org or by calling +1 (541) 484-9212.