Regulatory Compliance


The federal Formaldehyde Standards for Composite Wood Products Act adopted in 2010 and finalized six years later replaced a California regulation that long preceded it and that was known by the acronym of the agency that created it: CARB.

In 1992, the California Air Resources Board (CARB) identified formaldehyde as a toxic air contaminant. The Airborne Toxic Control Measure (ATCM) to reduce formaldehyde emissions from composite wood products was promulgated in 2007 based upon the toxic human health effects found from exposures to formaldehyde emissions.

The California Office of Environmental Health Hazard Assessment determined there was no safe exposure threshold level for formaldehyde. Formaldehyde emissions were evaluated in the state of California, and formaldehyde emissions due to resins from composite wood products were found to be a major source.

At the time, formaldehyde emissions from composite wood products were not regulated on the federal level except for a voluntary standard established by the U.S. Department of Housing and Urban Development. CARB decided to limit formaldehyde emissions from three wood products: hardwood plywood (HWPW), particleboard (PB), and medium density fiberboard (MDF). Based on the research conducted, these three products had the highest formaldehyde emission rates, because they are made with urea formaldehyde resins.

There are many options for manufacturers to reduce formaldehyde emissions, including using alternative resin systems. Included in the California standards are less stringent requirements for manufacturers using ultra low-emitting-based resins and no-formaldehyde-based resins.

CARB divided its standards into two phases to allow manufacturers, importers, distributors, fabricators and retailers ample time to comply. Phase 1 occurred from January to July in 2009, and Phase 2 implementation was from January 2010 through July 2012, depending on the type of composite wood product.

Federal regulators relied heavily on the CARB rule as they developed the federal Formaldehyde Standards for Composite Wood Products Act, finalized in December 2016. Emission limits in the federal regulation are identical to those set forth in CARB Phase II.

EPA worked to align other requirements in the federal rule with the California requirements. However, there are a few differences. Unlike the California requirements, among other things, the federal rule requires:

  • Records be kept for three years versus two years;
  • Importers to provide import certification (began March 22, 2019);
  • Manufacturers to disclose formaldehyde testing results to their direct purchasers upon request; and,
  • Laminated products not exempted from the definition of hardwood plywood to be tested and certified as meeting the hardwood plywood formaldehyde emission standard beginning March 22, 2024.