The U.S. Environmental Protection Agency (EPA) recently passed a final rule which will impact a number of wood import products beginning in 2017.
The Formaldehyde Emission Standards for Composite Wood Products Act of 2010 grants the EPA the authority to implement and enforce provisions for laminated products, product testing requirements, labeling, recordkeeping and import certification related to composite wood.
The new rule will require products sold, supplied, offered for sale, manufactured, or imported in the United States to be labeled as TSCA Title VI compliant, effective December of 2017. The requirements were initially scheduled to take effect in July of 2017 but have since been delayed.
Products which could be subject to the new rule include: hardwood, plywood, medium-density fiberboard, particleboard as well as household and other finished goods containing these products.
Formaldehyde is commonly used as an adhesive in wood products such as furniture, flooring, cabinets, bookcases and building materials. Formaldehyde is a chemical which can potentially be harmful depending on the exposure. Due to the health risks associated with formaldehyde, the EPA has passed this rule to discourage the use of formaldehyde in manufacturing of products intended for sale in the United States.
According to Furniture Today, the key points in the final rule for home furnishings manufacturers and importers include:
- The rule exempts laminated products made with synthetic face veneers, oriented strand board (OSB), curved plywood and PS-1 and PS-1 structural plywood.
- For covered laminated products (products that are made with a wood or woody-grass veneer attached to medium-density fiberboard or particleboard), fabricators have one year from the rule's publication date to confirm their platform/core panel meets the EPA emission limits, which mirror the emission limits in the CARB (California Air Resources Board) rule. (Manufacturers who produce finished home furnishing products that contain laminated composite panel components are considered "fabricators" in the EPA and CARB rules.)
- Fabricators of covered laminated products also have one year from the rule's publication date to label products TSCA Title VI compliant and to meet the rule's record-keeping requirements (including a certification statement from the composite wood panel supplier that the platform/core is TSCA Title VI compliant).
- Importers of laminated products have two years from the rule's publication date to obtain TSCA Title VI import certification.
A second phase of compliance will commence seven years from the rule's publication date. During this phase, if a company is still producing laminated products using urea-formaldehyde (UF) resins, it will be subject to testing and certification requirements. If a company is using no-added-formaldehyde (NAF) resin or phenol-formaldehyde (PF) resin, the company will remain exempt from testing and certification. Phase two will encourage companies to switch to NAF/PF resins, which is safer for the end consumer.
Marisol International can help you import wood products with compliance. Contact our experts today for more information.