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Formaldehyde
  • The Formaldehyde Standards for Composite Wood Products Act aims to reduce emissions of formaldehyde from composite wood products by establishing formaldehyde emissions limits.
  • All entities along the supply chain, from the manufacture to the sale of composite wood products, are affected by the final rule requirements.

Formaldehyde is a colorless, flammable gas at room temperature and has a strong odor. Formaldehyde can cause irritation of the skin, eyes, nose, and throat. High levels of exposure may cause some types of cancers. The primary way people can be exposed to formaldehyde is by breathing air containing off-gassed formaldehyde. Everyone is exposed to small amounts of formaldehyde in the air that has off-gassed from products, including composite wood products. Formaldehyde is found in:

  • Resins used in the manufacture of composite wood products (i.e., hardwood plywood, particleboard, and medium-density fiberboard);
  • Building materials and insulation;
  • Household products such as glues, permanent press fabrics, paints and coatings, lacquers and finishes, and paper products;
  • Preservatives used in some medicines, cosmetics, and other consumer products such as dishwashing liquids and fabric softeners; and
  • Fertilizers and pesticides.

TSCA actions related to formaldehyde

The Formaldehyde Standards for Composite Wood Products Act signed into law on July 7, 2010, added Subchapter VI to the Toxic Substances Control Act (TSCA) to reduce emissions of formaldehyde from composite wood products by establishing formaldehyde emissions limits for domestic or imported hardwood plywood, particleboard, and medium-density fiberboard sold, supplied, offered for sale, or manufactured in the U.S., whether in the form of an unfinished panel or incorporated into a finished good.

Effective May 22, 2017, Environmental Protection Agency (EPA) regulation 40 CFR 770, Formaldehyde Standards Composite Wood Products, set limits on how much formaldehyde can be released from composite wood products and established a program in which independent certifying organizations will verify that composite wood panel producers comply with the limits on formaldehyde releases. It should be noted that EPA has amended this regulation several times since it was first promulgated in order to strengthen, relax, increase flexibility with, or delay the effective dates of the provisions. These amendments have also been made to conform to voluntary consensus standards and allow for remote inspections under limited circumstances. Therefore, check out the latest version of Part 770 for your compliance efforts.

All entities along the supply chain, from the manufacture to the sale of composite wood products, are affected by the requirements of Part 770. This includes panel producers, fabricators, third-party certifiers, importers, distributors, retailers, and accreditation bodies. If a business is unsure if it fits into one of these categories, it may wish to refer to the table below. Examples of each category include (but are not limited to) the following:

Applicable categoryExamples
Importers, distributors, and retailers
  • Furniture stores or merchant wholesalers
  • Lumber, plywood, millwork, and wood panel merchant wholesalers
  • Building material and supplies dealers
  • Manufactured (mobile) home dealers (also includes trailer homes)
  • Recreational vehicle dealers and merchant wholesalers
  • Other construction material merchant wholesalers, or wholesale distributors of manufactured homes and/or prefabricated buildings
Panel producers
  • Veneer product manufacturing
  • Plywood product manufacturing
  • Engineered wood product manufacturing
  • Laminated product producers (see table note)
Fabricators
  • Manufactured (mobile) home manufacturing
  • Prefabricated wood building manufacturing
  • Motor home and recreational vehicle manufacturing
  • Travel trailer and camper home manufacturing
  • Furniture and related product manufacturing
  • Laminated product producers (see table note)
Third-party certifiers (TPCs)
  • Laboratories conducting independent third-party formaldehyde emissions testing of regulated composite wood products
Accreditation bodies (ABs)
  • Product ABs
  • Laboratory ABs
Note: Laminated product producers are fabricators and, beginning March 22, 2024, laminated product producers are also hardwood plywood panel producers except as provided at 770.4. According to 770.2(e):
  • Beginning June 1, 2018, laminated product producers must comply with the requirements of Part 770 that are applicable to fabricators.
  • Beginning March 22, 2024, producers of laminated products must comply with the requirements of Part 770 that are applicable to hardwood plywood panel producers (in addition to the requirements of Part 770 that are applicable to fabricators) except as provided at 770.4.
  • Beginning March 22, 2024, producers of laminated products that, as provided at 770.4, are exempt from the definition of “hardwood plywood” must comply with the recordkeeping requirements in 770.40(c) and (d) (in addition to the requirements of Part 770 that are applicable to fabricators).