TSCA Title VI: What it Means for Your Business

Distributors of hardwood plywood, MDF and particle board products will find it easier than ever to meet the needs of builders nationwide under the U.S. Environmental Protection Agency’s final rule-tightening formaldehyde emissions standards under Title VI of the Toxic Substances Control Act (TSCA).

Hardwood plywood

UPDATE: EPA extends the compliance date for formaldehyde emission standards for composite wood products to March 22, 2019.

Once the new rule goes into effect, it will bring the federal regulation into consistency with the stringent requirements already set by the California Air Resources Board (CARB). Distributors working with panel manufacturers like Timber Products Company, which is already in compliance with CARB, can be assured of meeting the new federal regulations.

Why New Standards?

The Formaldehyde Emission Standards for Composite Wood Products Act, which President Obama signed into law in 2010, adopted the CARB emission standards for formaldehyde from composite wood products under Title VI of the TSCA. The standard limits formaldehyde emissions from hardwood plywood to 0.05 parts per million (ppm), 0.11 ppm for MDF, 0.13 ppm for thin MDF, and 0.09 ppm for particle board

Formaldehyde-based resins that have traditionally been used to bind engineered wood products have been found to continue off-gassing following production. The results can range from irritation of the skin, eyes, nose, and throat. However, since 2010, adhesive manufacturers have designed new solutions that mimic the levels of formaldehyde found in natural wood. For example, Timber Products’ hardwood plywood uses high-quality, no-added urea formaldehyde (NAUF) and ultra-low emitting formaldehyde (ULEF) adhesives that emit less than .05 ppm of formaldehyde.

In 2013, the EPA proposed two rules providing a framework for third-party certification and implementation of an updated standard. Ultimately, the rules were combined and updated after taking into account thousands of comments from impacted parties. The new requirement goes into effect one year after the final rule’s publication in the Federal Register—a date that has been continuously delayed.

With a few exceptions, the final federal rule will catch up to standards already established by CARB for products manufactured, supplied and used in California. The rule applies to the manufacture and sale of products throughout the United States, as well as the sale and use of relevant imported products.

New Requirements for Panel Producers

Under the finalized rule, panel manufacturers must submit their products for laboratory testing and achieve third-party certification. All panel producers are required to have products tested by a third-party certifier to prove compliance with the EPA’s emissions limits. In addition, all panel producers must now perform the regular on-site quality control tests that Timber Products Company currently has in place to ensure compliance with the emissions standards.

Within one year of the final rule, you can expect all composite wood materials you purchase to be labeled in some form as TSCA Title VI-compliant. According to the EPA, labels must include:

  • The panel producer’s name
  • Lot number
  • An assigned EPA-recognized TSCA Title VI third-party certifier number
  • A statement that the products are TSCA Title VI-compliant

A Few Exceptions

Among the notable differences between the new standard and the requirements previously put in place by CARB is a requirement that laminated products are not exempt from the definition of hardwood plywood, an exemption that CARB previously had allowed. However, most laminators will have seven years to comply with the new requirements.

The updated rule also mandates that records be kept on hand for longer (for three years, as compared to the two years required by CARB), importers must be able to provide import certification under TSCA by July 2018, and manufacturers need to disclose formaldehyde testing results to their direct purchasers upon request.

Under these new requirements, building product suppliers can easily find assurance that the panel manufacturers with which they work are meeting the stringent quality standards set by industry regulations—and providing safe products to their customer base.

To find more information on how Timber Products Company stays CARB-compliant, see our information on air quality and emission regulations.

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