EPA TSCA Title VI Laminated Products

Title VI of the Toxic Substances Control Act (TSCA) in the United States addresses the regulation of formaldehyde emissions from composite wood products, including laminated products. Laminated products can include various types of furniture, cabinets, flooring, and other household items where layers of wood or wood-based materials are bonded together.

What is Laminated Product?

A laminated product according to EPA TSCA Title VI Definition:

  • Is a component part used in the construction or assembly of a finished good;
  • Has a wood or woody-grass veneer;
  • Is adhered to a TSCA Title VI-certified HWPW, MDF, or PB core or platform;
  • Is produced by either the fabricator of the finished good in which the product is incorporated or a fabricator who uses the laminated product in the further construction or assembly of a component part.

The Environmental Protection Agency (EPA) regulates formaldehyde emissions from these products to protect public health and the environment. Formaldehyde is a colorless, flammable gas at room temperature and has a strong odor. The primary way you 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. Exposure to formaldehyde may cause adverse health effects, potentially causing health issues such as respiratory irritation and adverse effects on indoor air quality.

Under Title VI of the TSCA, the EPA has established emission standards and labeling requirements for composite wood products, including laminated products. Manufacturers, importers, distributors, and retailers of these products must comply with the regulations, which aim to reduce formaldehyde emissions and provide consumers with information about the products’ emissions.

What are the requirements for a laminated product producer?

Beginning March 22, 2024, Laminated Product Producers whose products

  • are not exempted from the definition of hardwood plywood
  • will be included as producers of hardwood plywood and
  • will be required to test and certify their products to ensure they comply with the Formaldehyde Emission Standard for hardwood plywood

Laminated Product Producers must:

Under the 40 CFR 770.4 exemption, use a no-added formaldehyde (NAF) or phenol-formaldehyde (PF) resins to attach veneer to composite wood products, and adhere to the recordkeeping requirements starting beginning March 22, 2024.

The “manufactured-by” date for laminated product producers is 22 March 2024

Laminated product producers must achieve TSCA Title VI certification by 22 March 2024 UNLESS :

  • Purchase and use only No-Added Formaldehyde (NAF) or Phenolic Formaldehyde (PF) resins
  • Comply with the additional laminated product producer record-keeping requirements specified in 770.40(c)

Important Note:

Laminated product producers exempt from the hardwood plywood definition beginning March 22, 2024 must keep records for composite wood products and resins, including those they purchase or produce.

Compliance with Title VI typically involves testing products for formaldehyde emissions and ensuring that they meet the EPA’s standards. Additionally, manufacturers and other entities in the supply chain may be required to maintain records and provide documentation to demonstrate compliance.

Formaldehyde Emission Limit 

Overall, Title VI of the TSCA plays a crucial role in protecting public health and the environment by regulating formaldehyde emissions from laminated products and other composite wood materials.

For more information on EPA TSCA Title VI Laminated Products or regarding the requirements for a laminated product producer, please reach out to us via email at services.sg@gicgrp.com.

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