CA Formaldehyde in Composite Wood FAQ
Q: What is "CARB"?
A: CARB stands for California Air Resources Board. CARB is a department of the California Environmental Protection Agency. They have established both the California Air Toxics Program and the Airborne Toxic Control Measures (ATCM).
Q: What are composite wood products?
A: Any product made from panels of wood pieces, particles or fibers pressed and/or adhered together with resin. The main types covered by this regulation are hardwood plywood (HWPW) used in decorative wall covering, cabinets and furniture, particle board (PB) used in sub-flooring and shelving, and medium density fiberboard (MDF) used in drawer fronts, cabinets and furniture tops, including thin MDF.
Q: What is formaldehyde and why is it used in composite wood products?
A: Formaldehyde is an organic compound that exists naturally in the environment, our bodies, and in food. It is a central building block in the synthesis of many other compounds. Due to its effectiveness, formaldehyde is used in a variety of products from disinfectants to textiles.
It is used in wood composite products as an adhesive in which it links with other components to form strong bonds. Since it is naturally occurring, it is a very affordable ingredient available for use.
Q: Who is affected by this regulation?
A: The regulation affects ALL parties in the supply chain. This includes manufacturers, distributors, importers, fabricators, and retailers involved with the sale, supply, or distribution of composite wood product in California.
Q: How do I become certified under this regulation?
A: Only the raw wood manufacturers are required to be certified. Manufacturers need to contract with a Third Party Certifier (TPC). The TPC will set-up their quality program which will include training of personnel, auditing and inspections of the manufacturing site as well as the testing program.
Q: Is the regulation applicable to softwood plywood?
A: If softwood plywood is marketed as HWPW, then it would be subject to the regulation.
Q: Is the regulation applicable to curved or bent plywood?
A: Curved plywood is excluded from the regulation at this time. CARB will evaluate emissions data from curved plywood to determine if it should be included. There is no timeframe provided for this evaluation. If bent plywood is made from flat panels composed of composite wood, then the flat panels would need to comply.
Q: Is composite wood made from NAF or ULEF exempt?
A: Testing is required for three months for no-added formaldehyde (NAF) and six months for ultra-low emitting formaldehyde (ULEF) products from the start of manufacturing. Upon CARB approval, NAF and some ULEF products can be exempted from on-going testing.
Q: Are E1 boards acceptable for use without any further testing?
A: No. While CARB's Phase 1 limits are comparable to the E1 limits, there are differences in the test methods and amount of in-plant quality control required. CARB also requires the raw panel manufacturer to be certified by a Third Party Certifier, which is not required in the EU.
Q: Do painted/laminated products still need to comply with emission limits?
A: Yes, the emission limits apply to the raw unfinished wood. Painting or laminating the composite wood does not exempt it from testing.
Q: Are products sold via internet subject to the regulation?
A: Yes, any product sold in California is subject to the regulation.
Q: Who will bear responsibility for non-compliant products?
A: The importer (i.e. party importing product into CA) will ultimately be held responsible. However, all players in the supply chain from the raw board manufacturer to the retailer are potentially liable until the enforcement investigation determines otherwise. There is no product certification or chain of custody that will insulate anyone from an enforcement action. CARB enforcement staff will evaluate each situation on a case by case basis.
It is important to note that CARB will enforce this standard through random product testing and a strict chain of custody requirement.
Q: Does non-compliant material require a label during the sell-through dates?
A: No, non-compliant material does not require a label during the sell-through dates. The fabricator should be able to demonstrate that the material was legal for use under the sell-through provisions. Records such as an invoice should be maintained to demonstrate that the material was purchased either prior to the effective dates or during the manufacturer's sell-through period.
Q: What is required to be listed on the label?
A: There are different labeling requirements depending on the stage of the supply chain. Listed below are the manufacturer's and fabricator's requirements. Retailers do not have labeling requirements. However, it is strongly recommended that the fabricator's label remain on the product during retail sale. CARB has provided an advisory document for labeling requirements at: http://www.arb.ca.gov/toxics/compwood/outreach/labelingadv.pdf
Manufacturer's Labeling Requirements
• Manufacturer's name
• Product Lot number or batch code
• Recommended but not required: Date of manufacture
• CARB assigned Third Party Certifier number (not required for no-added or certain ultra-low-emitting formaldehyde based resins)
• Statement of compliance such as "California 93120 compliant for formaldehyde Phase 1"
Fabricator's Labeling Requirements
• Fabricator's name
• Date finished product was produced
• Statement of compliance (the phase is not required to be listed) or statement of no-added or ultra-low-emission formaldehyde
Q: Where is the label required to be placed?
A: The label is required to be placed on either outer packaging or directly on the product or panel. Even though it is not required, CARB has recommended that both the outer package and the product be labeled. If individual pieces, such as a box of flooring, are sold as a set, each panel is recommended to be labeled in case of separation unless there is no chance of this happening and all product will be used at the same time. If panels come in a bundle but are intended to be sold separately, each panel is required to be labeled by the manufacturer or fabricator.
Q: Why has CARB extended the sell-through dates?
A: CARB has chosen to extend the dates for retailers, distributors, importers, and fabricators of composite wood products for Phase 1 based on an excessive amount of pre-Phase 1 inventory, or inventory not meeting the Phase 1 requirements, remaining in distribution and retail markets. Raw panel manufacturers have been able to meet the Phase 1 requirements and are producing Phase 1 compliant panels. However, to avoid a bottleneck due to the current economic conditions, CARB has extended the dates appropriately.
For details on the specific dates, please visit the CARB advisory link: http://www.arb.ca.gov/toxics/compwood/outreach/09_04_advisory.pdf
• The CARB Formaldehyde in Composite Wood website: http://www.arb.ca.gov/toxics/compwood/compwood.htm
• The Third Party Certifier Program: http://www.arb.ca.gov/toxics/compwood/certifiers.htm
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