Formaldehyde Emissions from Composite Wood and Wood Laminate
In 2013, the Environmental Protection Agency (EPA) issued a proposed rule that would regulate the amount of formaldehyde emissions from composite wood, such as hardwood plywood, medium-density fiberboard, and particleboard. Additionally, the proposed rule would regulate laminated wood products, impose more precise labeling on covered products and require compliance information to be passed down from manufacturer/importer through the distribution chain.
On December 12, 2016, EPA published a final rule to reduce exposure to formaldehyde emissions from certain wood products produced domestically or imported into the United States. The rule regulates laminated wood products, imposes more precise labeling on covered products and requires compliance information to be passed down from manufacturer/importer through the distribution chain. Any musical instrument made of composite or laminate wood is impacted by the new regulations.
April 10, 2018. NAMM Statement in response to the American National Standards Institute Proposal. View here.
On April 4. 2018, the Environmental Protection Agency issued a Federal Register notice with updated compliance dates for the agency’s Formaldehyde Emissions Standards for Composite Wood Products Final Rule. This change is the result of a lawsuit filed by the Sierra Club which had challenged the agency’s extension of the compliance date to December 12, 2018 from December 12, 2017. The result of the Court’s decision is the following:
- By June 1, 2018, regulated composite wood panels and finished products containing such composite wood panels that are manufactured (in the United States) or imported (into the United States) must be certified as compliant with either the TSCA Title VI or the California Air Resources Board (CARB) Airborne Toxic Control Measures (ATCM) Phase II emission standards, which are set at identical levels, by a third-party certifier (TPC) approved by CARB and recognized by EPA. Previously, these products were required to be TSCA Title VI compliant by December 12, 2018.
- Until March 22, 2019, regulated products certified as compliant with the CARB ATCM Phase II emission standards must be labeled as compliant with either the TSCA Title VI or the CARB ATCM Phase II emission standards. Regulated products manufactured in or imported into the United States after March 22, 2019 may not rely on the CARB reciprocity of 40 CFR 770.15(e) and must be certified and labeled as TSCA Title VI compliant by an EPA TSCA Title VI TPC with all of the required accreditations.
- After March 22, 2019, CARB-approved TPCs must comply with additional accreditation requirements in order to remain recognized as an EPA TSCA Title VI TPC and to continue certifying products as TSCA Title VI compliant.
The information is available under the “Compliance Date Amendment” portion of the Formaldehyde Emission Standards for Composite Wood Products website.