Frequently Asked Questions: Applicable Products
(HWPW = hardwood plywood; HWPW-VC = hardwood plywood veneer core; HWPW-CC = hardwood plywood composite core; PB = particleboard; MDF = medium density fiberboard)
- What composite wood products are subject to the Composite Wood Products Airborne Toxic Control Measure (ATCM)? The ATCM establishes formaldehyde emission standards for panels of HWPW-VC, HWPW-CC, PB, MDF, and thin MDF (< or = 8 mm). The ATCM requires that finished goods and laminated products made with the materials subject to the formaldehyde emission standards, that are sold, offered for sale, supplied, used, or manufactured for sale in California, be made with materials that comply with applicable emission standards (e.g., Phase 2).
- What specific products are not covered by the ATCM? Materials that are not covered by the ATCM include, but are not limited to hardboard, natural wood, and certified structural plywood, certified structural panels, structural composite lumber, oriented strand board, glue laminated timber, prefabricated wood I-joist, finger jointed lumber, cellulosic fiber insulating board or "composite wood products" used inside of new vehicles, rail cars, boats, aerospace craft or aircraft (please also refer to question #14).
- What are examples of finished goods? Finished goods mean any good or product other than a panel, containing HWPW-VC, HWPW-CC, PB, MDF, or thin MDF. Finished goods include, but are not limited to furniture, cabinets, shelving, countertops, flooring, moldings, caskets, base boards, rosettes, corbels, etc.
- Who is subject to the ATCM? The ATCM applies to manufacturers, distributors, importers, fabricators, and retailers of the products identified in question 1, as well as third-party certifiers of panel manufacturers.
- Does the ATCM apply to block board? No. While block board is considered a type of HWPW, emission standards were only established for HWPW-VC and HWPW-CC. Block board is made with a core made of solid wood strips, not veneer core or composite core.
- Are molded products, such as toilet seats, subject to the regulation? If the products (toilet seats) are compression molded, meaning that flat panel products (such as MDF, PB, or HWPW) are not used in manufacturing of these products, then the product is exempt from the regulation.
- If a company that produces molded toilet seats wants to have their product tested by a CARB-approved third-party certifier (TPC) for formaldehyde emissions, should these products be labeled to let consumers know that the product is compliant? There are no prohibitions on a company voluntarily having a CARB approved TPC test a product for formaldehyde emissions. However, these products should not be labeled as CARB compliant and they should not include a statement of CARB compliance on their label because they are not subject to the regulation. Nevertheless, they could use labels that indicate the product is "low formaldehyde" or some other terminology that does not refer to the CARB regulatory requirements.
- Are chair backs and seats made by molding wood flour and resin into the desired shape considered particleboard and do they require emission testing? No, such products would not be considered to be a composite wood product under the ATCM.
- Does the ATCM apply to low-density fiberboard (LDF) or high density fiberboard (HDF)? Yes, depending on how they are marketed and used and if they meet the ANSI standard for MDF. The ATCM applies to MDF that meets the ANSI standard for MDF, A208.2-2002. Because the ANSI standard for MDF is based on performance and is independent of density, some products marketed as LDF and HDF are also subject to the ATCM. Products that are labeled as LDF or HDF, meet the ANSI A208.2-2002 standard and are marketed for use in typical MDF applications such as furniture manufacturing, shelving, molding, and kitchen cabinets, would be subject to the ATCM.
- Does the ATCM apply to insulating fiberboard or cellulosic fiber insulating board? No. Cellulosic fiber insulating board or insulating fiberboard made to the specifications in ASTM C208-08a include sound deadening board, roof insulation board, ceiling tiles and panels, wall sheathing, backer board and roof deck. These products are not made with synthetic (such as formaldehyde-based) resins and do not meet the definition of HWPW-VC, HWPW-CC, MDF or particle board which are subject to the emission standards in the ATCM.
- The regulation is applicable to hardwood plywood. However, what if the plywood is made with a softwood like spruce? Is it then exempt? The ANSI/HPVA HP-1-2004 standards that apply to HWPW allow for the use of hardwood or decorative softwood face veneers. Hence, if softwood is used as the face veneer, the HWPW would be subject to the ATCM.
- A plywood product is made with phenol formaldehyde (PF) resin and softwood face veneers. It meets the specifications for PS 1-09 structural plywood and is labeled as such. The product is used as paneling and wainscoting in both interior and exterior applications. Is it exempt from the ATCM? The product would be exempt if it is certified to PS-1 (Voluntary Product Standard for Structural Plywood). If the product is not certified to PS-1, it would need to be third-party certified to meet the Phase 2 emission standard for hardwood plywood.
- Are decorative wood pieces (such as corbels, moldings, rosettes, transition blocks, etc.) subject to the regulation? Decorative wood pieces made out of solid wood are not subject to the regulation. However, if these decorative wood pieces (such as corbels, moldings, rosettes, transition blocks, etc.) are made out of products that contain HWPW-VC, HWPW-CC, PB, or MDF, then these goods would be subject to the regulation as a finished good.
- Is wood packaging (e.g., pallets, crates) subject to the ATCM? No. While wood packaging may contain composite wood products (i.e., HWPW, MDF, or PB), and be considered "finished goods" subject to the ATCM, it was not CARB's intent to regulate wood packaging as "finished goods." By "wood packaging" we mean pallets, skids, boxes, crates, reels, spools and containers used for handling, sorting, storing, shipping, and transporting goods.
- Can uncertified structural products be used to make wood packaging? Yes. Uncertified structural products may be used to make wood packaging. By "wood packaging”, we mean pallets, skids, boxes, crates, reels, spools and containers used for handling, sorting, storing, shipping, and transporting goods. While wood packaging may contain composite wood products (i.e., HWPW, MDF, or PB), and be considered "finished goods" subject to the ATCM, it was not our intent to regulate wood packaging as "finished goods." Wood packaging is not subject to the ATCM (see questions #14, and #27).
- Does the ATCM apply to molded pallet blocks? No. Molded pallet blocks that are made in individual molds (i.e., not cut from a flat panel) and made specifically as molded pallet components are not subject to the emission standards for HWPW, MDF, or PB in the ATCM (also see question #14 regarding pallets).
- Is packing material or "dunnage" subject to the ATCM? No. Packing material, also referred to as "dunnage" is essentially loose, waste material such as composite wood products that are used for packaging or covering shipments in order to protect cargo from damage during transport. Dunnage is not considered to be a finished good and is not subject to the ATCM.
- Does the ATCM apply to rental items such as rental furniture? Furniture that is rented prior to the effective dates of the emission standards is exempt, because such furniture is considered to be "used goods," which are exempt from the definition of finished goods. At the end of the rental period, the furniture may be sold as used furniture. However, if a furniture rental company purchases new furniture after the effective dates of the emission standards, for purpose of renting that furniture in California, the new furniture must be made with materials that comply with applicable emission standards.
- My company supplies just a few products that contain a very small amount of composite wood products to California retail stores. Would CARB take size, volume or quantity of composite wood products used for finished goods into account? The regulation does not allow exemptions for de minimus use of the regulated products in finished goods. The regulation applies to all products, (e.g., picture frames, plaques, toys, etc.) containing HWPW, PB, or MDF, and there is no minimum amount that is exempt. However, the ATCM does include de minimus use exemptions for windows and doors only, see Section 93120.7 (b)(1).
- Does the ATCM apply to curved or bent plywood? Curved plywood is excluded from the definition of HWPW and is not subject to the ATCM. Due to the difficulty differentiating between finished products that were made using plywood made in a curved mold/press and plywood made from panels that were bent, CARB exempted both curved and bent plywood. Curved/bent plywood comprises a small segment of the composite wood products, for which there is not a standard test method for measuring formaldehyde emissions.
- Does the ATCM apply to bamboo flooring? It depends on the type of bamboo flooring. Bamboo floorings are typically made in two basic forms: solid bamboo planks or as engineered bamboo planks. Solid bamboo flooring is generally manufactured into three different types: vertical grain solid strip, flat (horizontal) grain solid strip, and strand woven bamboo. Vertical grain bamboo is comprised of narrow bamboo strips, which are glued together on edge and pressed together. Flat grain (horizontal) bamboo is made up of thin, flat strips of bamboo stacked on top of each other and pressed together. Strand woven bamboo is made from thin, shredded bamboo strands or fibers, which are mixed with resin and pressed together.
Floorings consisting solely of bamboo veneers (manufactured in the manner listed above) are not subject to the ATCM. The definition of HWPW in the ATCM specifies the use of hardwood or decorative softwood face veneers. Since bamboo is a grass, plywood made using bamboo face veneers is exempt from the regulation at this time. Since solid bamboo floorings are not subject to the ATCM, such products are not required to be labeled. Flooring that consists of a bamboo veneer laminated to a lumber-core platform is also not subject to the regulation, as the platform does not meet the definition for either HWPW-VC or HWPW-CC (please also see question #22).
Engineered bamboo flooring consists of a bamboo veneer (e.g., strand woven bamboo is cut into thinner slices) affixed to a composite wood platform (medium density fiberboard, hardwood plywood, or particleboard). Such products are considered laminated products and subject to the ATCM. The composite wood platform material contained in the bamboo flooring is required to be certified to meet the Phase 2 formaldehyde emission standard; however, the overall flooring product does not have to be third-party certified. Since engineered bamboo floorings are subject to the ATCM, such products are required to be labeled. (For additional information refer to labeling FAQs).
- What if bamboo is used in a flooring product, such as bamboo fibers for PB or MDF panels? Bamboo particles or fibers used to make PB or MDF falls into the definition of cellulosic materials used to make these products. Therefore, bamboo PB and bamboo MDF are required to be third-party certified.
- If I am a retail store owner and I acquire displays to be used by me and not sold to the public, do the displays need to be made from CARB certified composite wood products? Yes. Displays containing composite wood products are finished goods and must meet the requirements for finished goods. All displays (finished goods) sold/supplied into California must meet the ATCM requirements. Note: Fabricators that are selling and/or supplying finished goods for display purposes to a downstream client, (even though these items are not intended for resale by that downstream client) are required to made with materials that are compliant with applicable emission standards and a statement of compliance must be provided on the bill of lading or invoice for products intended for sale or supply to California. Fabricators fall under the applicability provision in the ATCM Section 93120 (c) (4).
- Are lumber core products subject to the regulation? No. HWPW with a lumber-core is exempt from the regulation. The ATCM has two HWPW standards, neither of which includes lumber-core: one for HWPW-VC and one for HWPW-CC. HWPW-VC does not have a lumber-core (made of wood strips), and HWPW-CC is defined in the regulation as being made with a PB, MDF, or PB or MDF in combination with veneer (combination core).
- How are warranty stocks (also known as replacement parts) considered under the regulation? Existing stocks of replacement parts may be sold indefinitely. No labeling is required on such parts. After the applicable sell-through periods have ended, then any new replacement parts must be made of complying materials. Replacement parts, as well as components parts that are sold and/or supplied as individual items (e.g., in a situation where a consumer is buying a replacement part such as a cabinet door), are subject to labeling requirements. If component parts and/or warranty stocks that are supplied to a fabricator (e.g., from a fabricator of component parts) and will be used in a finished good, component parts do not need to be labeled, but the invoices or bills of lading must include the statement of compliance to indicate that the shipment of components parts or replacement parts are made of complying composite wood products.
- Is MDF made by a "wet-forming" process subject to the ATCM? No. MDF mats can be manufactured by either wet or dry forming processes. In "wet-forming," the fibers are carried in a water suspension and the product is often made without an adhesive. In "dry forming," the fibers are transported by air and a resin is added to form the fiber mat. The ATCM defines MDF as "... panels composed of cellulosic fibers made by dry forming and pressing of a resinated fiber mat (ANSI A 208.2-2002)." As MDF panels made by "wet-forming" are not specified in the ATCM, they are not subject to the requirements of the ATCM.
- The ATCM excludes certain types of structural plywood from the definition of composite wood products, namely those meeting the Voluntary Product Standards for Structural Plywood (PS 1) and Wood-based Structural-use Panels (PS 2). Are other types of structural plywood, such as those made to comply with standards other than PS 1 or PS 2, also excluded from the definition of composite wood products? CARB excluded structural plywood products that conform to the PS 1 or PS 2 standards that are used for a variety of structural applications in North America. PS 1 and PS 2 structural plywood were excluded from the definition of composite wood products in the ATCM for reasons of public safety and also because they are made to be exterior grade products. To provide the water resistance necessary for exterior applications, structural plywood is made with phenol formaldehyde (PF) or polymeric methylene diphenyl diisocyanate (pMDI) resins, both of which are low emitting with regard to formaldehyde, as opposed to interior-grade industrial panels typically made with urea-formaldehyde (UF)resins.
We recognize that "structural plywood" is made in other parts of the world to meet standards other than PS 1 or PS 2. Product standards for composite wood panels in countries outside of the U.S. in some cases do not clearly differentiate between panels made for structural vs. nonstructural applications. For example, structural plywood standards vary around the world, owing to differences in region-specific building codes, market needs, and manufacturing methods. In North America, structural plywood is commonly used for building structures, while in other countries clear distinctions are not made with respect to structural plywood for interior vs. exterior applications. While standards in other countries are not directly comparable with the requirements specified for North American PS 1 and PS 2 structural plywood, we believe that products that are certified to structural plywood standards should also be exempt from the requirements of the ATCM. At this time, staff has determined that structural plywood that is certified to the following standards is not subject to the formaldehyde emission standards: The exemption applies only to products that are marked as compliant with those standards specified above, so as to clearly distinguish them as exempt products for purposes of the ATCM. (For the list of structural panels exempt from the ATCM, please refer to question #2).
Australian "AS/NZS 2269" European "EN 636 3S" (including CE label) Canadian CSA (Canadian Standards Association) "CSA O121" Douglas fir plywood, "CSA O151" Canadian softwood plywood, "CSA O153" Poplar plywood, and "CSAO325" Construction sheathing;
- Is uncertified structural plywood subject to the ATCM? Yes. Structural products must be certified to the applicable structural products standards in order to be exempt from the ATCM (see questions #2 and #27). Structural products include structural plywood, oriented strand board, and glued laminated timber. Uncertified structural products means such products that are not able to be certified to the applicable structural standards (e.g., fail to meet certain structural strength requirements). In February 2019, U.S. EPA released a FAQ (EPA FAQ #7 for regulated stakeholders) that states that uncertified structural panels that have accompanying documentation of being made by a structural panel producer may be sold or used, and are exempt from the EPA TSCA Title VI regulation. Within California, uncertified structural plywood is not exempt from the ATCM. CARB will regulate uncertified structural plywood as hardwood plywood, unless it is used to make wood packaging (see question #14). Uncertified structural plywood must be third-party certified as compliant with the applicable formaldehyde emission standard for hardwood plywood if it is intended for sale or use in making finished goods that are subject to the ATCM.
- Within California, is certified structural plywood that is also fire rated subject to the ATCM? No. A fire rating does not determine if a type of plywood is subject to the ATCM (see question #27). Certified structural plywood is not subject to the ATCM. Uncertified structural plywood is subject to the ATCM.
- Does the ATCM apply to laminated veneer lumber (LVL)? No. Laminated veneer lumber is a certified structural product intended for exterior uses and consists of all plies or veneers oriented with parallel grains. The Standard Specification for Evaluation of Structural Composite Lumber Products (ASTM D 5456) includes LVL products. Being a certified structural product, LVL is exempt from the ATCM.
- Does a veneer core platform affixed to a laminate that is composed of a thin MDF fall under the regulation? If a product has HWPW-VC as a platform with thin MDF affixed to the face and back, then this product is considered to be a laminated product under the regulation. This laminated product, made with third-party certified composite wood products (the HWPW-VC platform and thin MDF laminates) does not need to be tested by a CARB-approved third-party certifier to be compliant. Hence, the company that affixes the thin MDF to the HWPW-VC platform is a fabricator of a laminated product, and not a panel manufacturer.
- Is a product consisting solely of layers of wood veneers or plies with the grains of each layer oriented in the same direction (parallel grain) considered hardwood plywood? Yes. The American National Standard for Hardwood and Decorative Plywood defines hardwood plywood as a product intended for interior use in which the face veneer is hardwood or decorative softwood, and consists of adjacent layers or plies at approximate right angles, although some layers or plies may be oriented in the same direction (parallel grain). CARB will consider a product intended for interior use that consists solely of layers or plies oriented in the same direction to also be hardwood plywood.
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