(1) What is EPA and CARB?
EPA-TSCA is a certificated program launched by the U.S. Environmental Protection Agency to regulate formaldehyde emissions from composite wood products. CARB-ATCM is the California Air Resources Board (CARB) launched a certification program to regulate formaldehyde emissions from composite wood products.
All compound wood products manufactured, processed, distributed and sold in the United States are required to obtain EPA certification except for exempted products. Meanwhile ,besides the exempted products, all composite wood products manufactured, processed, distributed and sold in California are required to obtain CARB certification.
EPA -TSCA and CARB-ATCM certification includes product testing and factory audit, valid for 2 years. However, factory requires to be audited and board sampled testing by authorized third party to ensure mills ‘s production process control and formaldehyde emission meets EPA-TSCA or CARB-ATCM requirements.
EPA Will no longer accept CARB certificate since Mar. 2019. If the factory’s product exported to California, both EPA and CARB certification are required. If only export to other places of United States exclude California ,only EPA regulation requirements need to be met .
(2) Composite wood products Board type
| Board Type | Definition | Formaldehyde amount restriction |
| Hardwood Plywood | Wood board adhesive with a combination by (A) hardwood chips or several layers of thin or (B) board combined with substrates consisting of wood cores such as composite cores, special core materials, or special backboard materials. Panels can be made of hardwood or decorative cork. | 0.05 ppm |
| Medium Density Fiberboard | Board made of cellulose fiber (usually wood) made from fiber mats soaked in resin by dry molding and hot press. | 0.11 ppm |
| Particle Board | Board made of a cellulose material (usually wood) in the form of dispersed particles (distinct from fibers, flakes, or fine strips) that is compressed with a resin. | 0.09 ppm |
| Laminated Products | A product made of adding wood or wood grass veneers to boards such as particle boards or medium density fiberboards. | 0.05ppm |
| Finished goods | Any goods or products containing hardwood plywood, particle board or medium density fiberboard, except boards. Excludes used goods, such as antiques or second-hand furniture. | Nil |
(3) What’s the difference of EPA and CARB？
| CARB | EPA TSCA Title VI |
| Quality Control Department structure | Quality Control Department structure including quality control managers and personnel names/functions |
| Sampling procedure | Sampling procedure |
| Sample treatment method | Sample treatment method including maximum testing lasting time |
| Small scale test frequency | Small scale test frequency |
| The handling procedure of Formaldehyde emissions due to unexpected production change | The handling procedure of Formaldehyde emissions(including resign amount increase, molar ratio increase ，hot press time reduction |
| Additional small scale test | Additional small scale test |
| Record kept (2 years) | Record kept (3 years) |
| Resign amount and pressing time for each product type | Resign amount and pressing time for each product type |
| NIL | Labeling requirement Description of each product Reduce the testing frequency (if applicable ) Non-conformity product handling |
(4) EPA/CARB Certificated path
Mills have testing capability?
NO:
Subcontract testing or Establish Lab
YES:
Step 1: Personnel & Product assessment
Step 2:
1）Correlation testing
2）QC manual
Step 3: Quality management system establish
Step 4: Internal audit
Step 5: TPC factory audit
Step 6: Certificated
(5) What kind of products can be exempted from EPA certification?
The EPA regulation states that below products can be exempted from this regulation:
1. A veneer formed by a wood or grass to a phenolic resin or a resin that does not add formaldehyde on a substrate that meets EPA requirements.
2. Second-hand furniture or antiques, etc.
3. Hard fiberboard, structural plywood, structural board, structural composite wood, directional particle board, plywood wood, prefabricated wood Type I support beams, fingering boards, wooden packaging including pallets, crates, spools and mats.
4. Composite wood products used in new rail cars, boats, etc.
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SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 97,000 employees, SGS operates a network of over 2,600 offices and laboratories around the world.
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