Frequently Asked Questions: Exemptions
(HWPW = hardwood plywood; HWPW-VC = hardwood plywood veneer core; HWPW-CC = hardwood plywood composite core; PB = particleboard; MDF = medium density fiberboard)
- Military is exempt. What about federal government institutions such as UNICOR that manufactures furniture for government offices and the military? Military specified plywood is exempt from the ATCM. If UNICOR is manufacturing furniture for government offices, they would be considered a fabricator under the ATCM for products sold to California and must comply with the regulation.
- The ATCM includes an exemption for windows. Does the exemption include bay windows? Yes. Requirements for fabricators include an exemption for windows if the window product contains less than five percent by volume of HWPW, PB, or MDF combined, in relation to the total volume of the finished window product. The definition of a window specifies that a frame includes jambs, stiles, sashes, and rails, and excludes sills, window headers and window seats. Because sills, window headers, and window seats are excluded from the definition of a frame, they cannot be factored into the exemption. Therefore, if sills, window headers, and window seats contain composite wood, the composite wood must comply with the ATCM and the finished window product must be labeled appropriately.
- Other than windows, what other exemptions does the ATCM contain? Exemptions have also been provided for exterior doors and garage doors if these products contain less than three percent by volume of HWPW, PB, or MDF combined, in relation to the total volume of the finished door product made from composite wood products. The ATCM does not apply to finished goods sold outside of California or to products subject to federal requirements governing the construction of manufactured homes (for additional information, refer to question #2 of Applicable Products FAQs).
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