As the cost of solid wood products continues to rise, composite wood products offer increasingly attractive combinations of performance and pricing for many types of furniture, construction materials, and a broad range of other applications. These composite wood products typically consist of thin layers or small pieces of wood, or wood fibers, granules, or chips, held together with adhesives, and formed under heat and pressure.
Common examples of composite wood products include:
Adhesives commonly used to hold the pieces or fibers of wood together include a variety of resins. Many of these resins are produced by reacting formaldehyde, an important industrial chemical, with one or more other component chemicals, producing a cross-linked adhesive structure that can be very strong and durable. However, some formaldehyde is often “left over” from the chemical reaction, and remains in the finished composite wood product.
As this leftover formaldehyde evaporates from the product into the air, sufficiently high concentrations can cause respiratory problems, and are suspected as a contributing cause to other health issues. Both domestically produced and imported composite wood products have been reported as linked to these concerns.
To address this issue, the Environmental Protection Administration (EPA) has established formaldehyde emission standards for specified types of composite wood products. After March 22, 2019, any of these composite wood products, or products containing them, must be labeled as being compliant with the EPA standards. The requirements apply to both domestically produced and imported products, and are included in Title VI of the Toxic Substances Control Act (TSCA) reglations at 40 CFR 770.
Composite wood products specifically subject to the EPA formaldehyde emissions standards include these three types:
hardwood plywood (only if made with a veneer core or a composite core)
Composite wood products not subject to the EPA formaldehyde emission standards include:
structural panels and composite lumber
oriented strand board
prefabricated wood I-joists
those used inside a new vehicle (other than a recreational vehicle), or inside new rail cars, boats, aircraft, or aerospace craft
windows containing less than 5% composite wood products by volume
exterior doors or garage doors manufactured with NAF or ULEF resins, or containing less than 5% composite wood products by volume
molded products not fabricated from regulated composite wood panels
If composite wood products subject to the EPA standards are used to produce other items such as cabinets or furniture, those other items – incorporating the regulated material – are also subject to these standards. Again, these requirements apply to both domestically produced and imported products.
To qualify for labeling as compliant with EPA standards, a composite wood product must be certified by a recognized third-party certifier, approved by EPA. A list of currently approved certifiers is available on the EPA website.
The EPA required compliance label may be a stamp, tag, or sticker. For composite wood panels, the label must include:
the panel producer’s name
product lot number
identity of the EPA third party certifier
a statement that the product is TSCA Title VI compliant
For finished goods which contain regulated composite wood products, the label must include:
the finished goods fabricator’s name
date the finished good was produced (in month/year format)
a statement that the finished good is TSCA Title VI compliant
To avoid potential problems with imports of finished goods such as cabinets or other furniture into the US, finished goods manufacturers should keep detailed records of the TSCA Title VI certifications provided by their suppliers for each batch of composite wood panels or other regulated items, as well as which batch (or batches) of component materials are used in each finished product item or production run.
If imported products contain regulated composite wood panels or other component materials, but are not marked as TSCA Title VI compliant, the shipment containing these products may be refused entry into the US. If so, the shipment will generally have to be either exported or destroyed, at the importer’s expense.
Importers and exporters should also note that the TSCA Title VI certification required for specified types of composite wood products is entirely separate from the regular TSCA statement that chemicals in a shipment either comply with TSCA requirements, or are not subject to those requirements.
Additional answers to “frequently asked questions” about the TSCA formaldehyde emission standards and related issues, including product certification and labeling, are also available on the EPA website.
Transmark Customs Brokers routinely assists importers and their suppliers in handling a broad range of products, and we are always ready to share the benefits of our knowledge and experience with our valued clients.