No one wants risk – particularly risk that can be harmful to people or the environment. That’s why Benchmark has developed a thorough formaldehyde emissions certification program that conforms to EPA and CARB regulations. The best part? It’s flexible and allows you to choose an approach that meets your production and sales objectives – at an affordable cost. Here’s what you need to know.
About EPA and CARB Regulations
Eligibility & Process
About EPA/CARB Regulations
CARB ATCM 93120 regulations were originally enacted in 2008 and apply to composite wood products including hardwood and decorative plywood (HWPW), medium density fiberboard (MDF), and particleboard (PB) that is sold, offered for sale, supplied, used, or manufactured for sale in the U.S. state of California. CARB ATCM 93120 regulations also require that finished goods and laminated products must be made using only CARB-certified composite wood products. Compliance to CARB Phase 2 formaldehyde emission standards and requirements is currently mandatory for all composite wood panels as well as component parts and finished goods containing such materials that are manufactured, imported, distributed, or sold in the state of California.
EPA TSCA Title VI regulations were originally enacted in 2018 and apply to composite wood products including hardwood and decorative plywood (HWPW), medium density fiberboard (MDF) and particleboard (PB) as well as to component parts and finished goods containing such materials that are sold, supplied, offered for sale, or manufactured (including imported) in the United States. The formaldehyde emission standards specified in EPA TSCA Title VI are similar to those set by CARB ATCM 93120, Phase 2 regulations; however, there are differences in the testing, record keeping and labeling requirements that apply.
TSCA Title VI regulations also require that laminated products made using a formaldehyde-containing resin must also be third-party certified. A laminated product is defined as a product in which a wood or woody grass (e.g., bamboo) veneer is adhered to a TSCA Title VI-certified plywood, MDF, or particleboard platform using a formaldehyde-containing resin. A laminated product is a component part used in the construction or assembly of a finished good. Laminated product producers must achieve third-party certification by an EPA-approved third-party certifier on or before March 22, 2024. Laminated product producers that use a No-Added Formaldehyde (NAF) or phenol resin during the veneer-lamination process are not required to achieve third party certification provided they comply with the additional record-keeping provisions as specified in the TSCA Title VI regulation.
For composite wood panels and laminated products to be certified as conforming to CARB 93120 or EPA TSCA Title VI regulations, the panels must have been produced by either:
- a manufacturer who is independently certified by a EPA/CARB-approved Third Party Certifier (TPC), or;
- a manufacturer who has obtained exemption from third party certification on the basis of the use of Ultra-Low Emitting Formaldehyde (ULEF) or No-Added Formaldehyde (NAF) resins.
The manufacturer must perform routine quality control testing of the composite wood products it produces to verify the products meet EPA and CARB formaldehyde emission standards and is labeled accordingly. Additional documentation, record-keeping, and TPC oversight and independent testing requirements also apply.
Benchmark’s certification approach is designed to rigorously evaluate a manufacturer’s production operation and products considering EPA and CARB requirements, while also providing an affordable and flexible program structure that can be tailored to meet your specific production and sales objectives.
Because each manufacturing operation is different, the time needed to achieve certification varies due to several factors such as the complexity of the certification effort and the client’s current state of readiness. Whatever the situation, our certification process is straight forward, and we work hard to ensure you are supported throughout the process. From helping you to understand your obligations to providing you with practical testing solutions, we’ll be with you every step of the way.
Eligibility and Process
Determining eligibility is a critical step in ensuring that certification is the right path for you. While we aren’t bound to geographical location, it is important to know who is required to pursue EPA/CARB formaldehyde certification.
Producers of the following types of composite wood products are required to achieve EPA/CARB certification:
Hardwood and Decorative Plywood (including veneer core and composite core)
Medium Density Fiberboard (defined as MDF panels with a total thickness greater than 8mm)
Thin-Medium Density Fiberboard (defined as MDF panels with a total thickness less than or equal to 8mm)
Laminated products consisting of a wood or woody-grass veneer adhered to a particleboard, MDF, or hardwood plywood platform using a formaldehyde-containing resin.
What’s the general certification process?
Benchmark applies a methodical process to deliver you the peace of mind needed that your products meet applicable regulatory requirements;
- Client submits completed application for EPA/CARB certification
- Benchmark reviews application, confirms initial eligibility, and defines the tentative scope of certification
- Benchmark and client sign certification agreement
- Client selects method for conducting routine formaldehyde quality control testing
- Client prepares a Quality Control Manual and submits to Benchmark for approval
- Benchmark conducts initial site audit to validate compliance
- Benchmark completes initial qualification testing and quality control test method correlations as required by EPA and CARB regulations
- Certification readiness review
- Certification decision making and document preparation
The bottom line:
Certification to EPA/CARB formaldehyde regulations isn’t something that should be taken lightly, and we understand how overwhelming the process may seem. Don’t sweat it. Give us a call. We’ve got your back.