Small Entity Compliance
Guide for Mills
Formaldehyde Emissions Standards for
Composite Wood Products
Title VI of the Toxic Substances Control Act
&EPA
United States
Environmental Protection
Agency
January 2017
EPA-740-B-17-001

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&EPA
United States
Environmental Protection
Agency
This guide was prepared pursuant to section 212 of the Small Business
Regulatory Enforcement Fairness Act of 1996, Pub. L. 104-121 as amended
by Pub. L. Number 110-28. THIS DOCUMENT IS NOT INTENDED, NOR
CAN IT BE RELIED UPON, TO CREATE ANY RIGHTS ENFORCEABLE BY ANY
PARTY IN LITIGATION WITH THE UNITED STATES. The statements in this
document are intended solely as guidance to aid you in complying with
the formaldehyde emissions standards for composite wood products in
Title VI of the Toxic Substances Control Act (TSCA) and the implementing
regulations in 40 CFR part 770. EPA may decide to revise this guide without
public notice to reflect changes in EPA's approach to implementing TSCA
Title VI or to clarify information and update text.
To determine whether EPA has revised this guide and/or to obtain copies,
contact EPA's Small Business Ombudsman Hotline at (800) 368-5888
or (202) 566-1970 in DC, or consult the EPA's formaldehyde website at
http://www.epa.gov/formaldehyde. The full texts of TSCA Title VI and the
implementing regulations are also available at this website.
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Introduction
This document is published by EPA as the official compliance guide for small entities, as required by the Small
Business Regulatory Enforcement Fairness Act of 1996. Before you begin using the guide you should know that
the information in this guide was compiled and based on the Formaldehyde Emission Standards for Composite
Wood Products regulation published on December 12, 2016. EPA is continually improving and upgrading its
rules, policies, compliance programs, and outreach efforts. You can determine whether EPA has revised or
supplemented the information in this guide by consulting EPA's formaldehyde website at http://www.epa.gov/
formaldehyde.
Contents
This guide is organized as follows:
Introduction
Regulation Summary and Compliance Timetable
Who Must Comply
How to Comply
For More Information
Appendix and Acronym List
Terminology
Throughout this guide, when the term "composite wood
product"is used, it refers to the three composite wood products
generally regulated by TSCA Title VI—hardwood plywood,
medium-density fiberboard (MDF) and particleboard.
Other key terminology are defined in the Appendix:
Glossary of Environmental Terms.
Who Should Use this Guide?
This guide is for mills and other entities that are "panel
producers" under the Formaldehyde Standards for Composite
Wood Products Regulations. For example, many of the
following types of businesses are likely to be covered by
this guide: veneer, plywood, and engineered wood product
manufacturing (NAICS code 3212).
What Does This Guide Cover?
This guide specifically covers the requirements for mills
(panel producers) of regulated composite wood products
under the Formaldehyde Standards for Composite Wood
Products Act (TSCA Title VI) and the implementing regulations,
found at 40 CFR part 770. Specifically, this guide defines
key terms, discusses which entities are regulated as panel
producers, and summarizes the emission standards, quality
control testing, and third-party certification requirements.
This compliance guide explains your federal compliance
obligations with respect to the formaldehyde regulations
under TSCA Title VI. There may be other state or local
requirements which apply to you that are different from, or
more stringent than, the federal requirements. For more
assistance in this area, contact your EPA regional office or
state environmental agency.
Figure 1 outlines thestructureoftheTSCATitleVI program
and shows the relationships between EPA and the various
groups involved in implementation of the regulation. Mills
and other entities that are "panel producers" are identified in
blue with their relationship to the remainder of the TSCA Title
VI program.
OTHER GUIDES TO CONSIDER: OTHER GUIDES TO
CONSIDER: There are other separate small entity compliance
guides available for different entities along the value chain,
including:
1.	Importers, Distributors and Retailers;
2.	Fabricators and Laminated Product Producers; and
3.	Accreditation Bodies (ABs) and Third-Party Certifiers (TPCs).
Each of these guides can be found at https://www.epa.gov/
formaldehyde/small-entity-compliance-guides-formaldehyde-
emission-standards-composite-wood-products.
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FIGURE 1 - TSCA TITLE VI PROGRAM
Reciprocity
Retailers
Importers
Distributors
Fabricators
EPA-recognized
Third Party
Certifiers (TPCs)
CARB-approved
Third Party
Certifiers (TPCs)
Panel
Producers
EPA-recognized
Product &
Laboratory
Accreditation
Bodies (ABs)
California Air
Resources Board
(CARB)
I LAC
International Laboratory
Accreditation
Cooperation
IAF
international
Accreditation Forum
NOTE: If your composite wood products are manufactured,
sold or supplied in California, you must also comply with the
California Air Resource Board's Airborne Toxic Control Measure
(CARB ATCM) to control formaldehyde emissions from composite
wood products. More information on the CARB ATCM can be
found online at http://www.arb.ca.gov/toxics/compwood/
compwood.htm.
How Do I Obtain a Complete Copy of This
Rule?
A complete copy of the final rule arid supporting
documents can be found in Federal Register (Vol. 81, No. 81,
p. 89674) at https://www.regulations.gov/document?D=EPA-
HQ-OPPT-2016-0461 -0001.
A copy of the final rule can also be found at https://
www.epa.gov/formaldehyde/resources-guidance-
materials-formaldehyde-emission-standards-composite-
wood-products. See section entitled "For More
Information" of this compliance guide for additional
information resources.
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Regulation Summary and Compliance Timetable
Regulation Summary
TSCA Title VI establishes formaldehyde emission
standards for three types of composite wood products:
hardwood plywood, MDF, and particleboard. The purpose
of TSCA Title VI and its implementing regulations is to
reduce formaldehyde emissions from these composite wood
products, which will reduce exposures to formaldehyde,
resulting in benefits for human health.
The regulations require the covered composite wood
products to be tested to ensure compliance with the TSCA
Title VI formaldehyde emission standards and certified by an
EPA TSCA Title VI Third-Party Certifier (TPC). Limited testing
and certification exemptions are available for products
made with no-added formaldehyde (NAF) resins or ultra low-
emitting formaldehyde (ULEF) resins. To ensure that only
compliant products enter and move through the product
supply chain, the regulations contain recordkeeping,
reporting, and labeling requirements. The formaldehyde
emission standards are identical to the emission standards
currently in place in California, and the regulations are as
consistent as practical with the requirements currently in
effect under the California Air Resource Board's Airborne
Toxic Control Measure (CARB ATCM). CARB-approved TPCs
are eligible for recognition under the EPA program through
reciprocity with the CARB program.
Compliance Timetable
After December 12, 2017, all panel producers must
comply with the regulations.
Table 1 provides a summary of the regulatory
requirements and compliance dates. The "Who Must
Comply" section of this guide provides more detail on the
rule requirements for mills and other entities that are panel
producers and what they must do to document compliance
with the regulation.
Table 1. Summary Requirement and Compliance Dates
Requirement
Compliance Date
Composite Wood Product Producers
Products must comply with emission standards:
•	Hardwood plywood (made with a veneer core or a composite core) = 0.05 parts per million
(ppm)
•	Particleboard = 0.09 ppm
•	MDF = 0.11 ppm
. Thin MDF = 0.13 ppm (40 CFR §770.10)
December 12, 2017
Products must be certified by an EPA TSCA Title VI TPC unless they are eligible for a limited
exemption for products made with NAF-based or ULEF resins.
(40 CFR §§ 770.15, 770.17, 770.18)
December 12, 2017
Products must undergo quarterly testing and routine quality control testing using specified
methods. (40 CFR §770.20)
December 12, 2017
Panels must be labeled with the producers name (or other identification), lot number, TPC
number, and a statement of compliance with TSCA Title VI.
(40 CFR §770.45)
December 12, 2017
Records, including testing, production, purchaser, transporter, and non- complying lot
information, must be kept for 3 years. Records demonstrating initial eligibility for reduced
testing or a limited third-party certification exemption for products made with NAF-based or
ULEF resins must be kept for as long as exemption eligibility is claimed.
(40 CFR §770.40)
December 12, 2017
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Who Must Comply
What Is a Composite Wood Product?
A "composite wood product" means hardwood
plywood made with a veneer or composite core, MDF, and
particleboard.
What Entities Are Regulated as "Panel
Producers?"
Panel producers are manufacturing plants or other
facilities that manufacture composite wood products on the
premises. Mills that produce hardwood plywood, MDF, and/
or particleboard are panel producers. Entities that import
hardwood plywood, MDF, and/or particleboard, but do not
make those products themselves, are not panel producers.
Nevertheless, these importers are required to take steps
(through recordkeeping) to ensure that they are purchasing
composite wood products or component parts that comply
with the emission standards and to document these steps.
Some laminated product producers will be regulated
as panel producers. A laminated product is a component
part used in the construction or assembly of a finished
good. In addition, a laminated product must be produced
by either the fabricator of the finished good in which the
product is incorporated or by a fabricator who uses the
laminated product in the further construction or assembly
of a component part. Laminated product producers that
make laminated products by attaching a wood or woody
grass veneer to a compliant core or platform with a phenol-
formaldehyde (PF) resin or a resin formulated with NAF as
part of the resin cross-linking structure are exempt from
the definition of hardwood plywood, and thus they are not
treated as hardwood plywood panel producers under the
regulations. Laminated product producers whose products
do not use a PF resin or resin formulated with NAF as part of
the resin cross-linking structure will be subject to the testing
and certification requirements for hardwood plywood after
December 12, 2023. EPA has also included a petition process
through which any person can petition the Agency to expand
the exemption for laminated products from the definition of
the term "hardwood plywood," discussed later in this guide.
Are Any Mills Exempted or Not Covered as
Panel Producers?
While there is a de minimis standard for some of the
requirements for finished goods, there is no de minimis
standard for panel producers making composite wood
products. However, the regulations only apply to certain
products. Use the "Glossary of Environmental Terms"
included as an appendix to this guide to define the
following terms, as needed. Answer the yes or no questions
belowto determine whetheryour mill is making regulated
products.
1.	Are your products "panels"? If yes, proceed to the next
question. If no, the products are unregulated.
2.	Are the products composite wood products (see glossary
for full definitions)? If no, the products are unregulated.
If yes, continue to next step.
Hardwood Plywood;
MDF; and
Particleboard.
3.	Are your panels grandfathered in because they were
manufactured (or imported) after December 12, 2017?
If yes, those panels are unregulated. If no, continue to
next step.
4.	Are the panels subject to an exemption (see below)? If
yes, the products are unregulated. If no, the products
are regulated under TSCA Title VI. Note that some of
the exemptions are for finished goods, not panels. You
are only eligible for those exemptions if you are making
the panel and also using the panel to make the finished
good.
Hardboard;
Structural plywood, as specified in the standard
entitled 'Voluntary Product Standard—Structural
Plywood' and numbered PS 1-07;
Structural panels, as specified in the standard entitled
'Voluntary Product Standard—Performance Standard
for Wood- Based Structural-Use Panels'and numbered
PS 2-04;
Structural composite lumber, as specified in
the standard entitled 'Standard Specification for
Evaluation of Structural Composite Lumber Products'
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and numbered ASTM D 5456-06;
Oriented strand board;
Glued laminated lumber, as specified in the standard
entitled 'Structural Glued Laminated Timber' and
numbered ANSI A190.1-2002;
Prefabricated wood l-joists, as specified in the standard
entitled 'Standard Specification for Establishing and
Monitoring Structural Capacities of Prefabricated
Wood l-Joists' and numbered ASTM D 5055-05;
Finger-jointed lumber;
Wood packaging (including pallets, crates, spools,
and dunnage);
Composite wood products used inside a new—
i.	Vehicle (other than a recreational vehicle) constructed
entirely from new parts that has never been—
a.	The subject of a retail sale; or
b.	Registered with the appropriate State agency
or authority responsible for motor vehicles or
with any foreign state, province, or country;
ii.	Rail car;
iii.	Boat;
iv.	Aerospace craft; or
v.	Aircraft;
Windows that contain composite wood products,
if the window product contains less than 5 percent
by volume of hardwood plywood, particleboard, or
MDF, combined, in relation to the total volume of the
finished window product; or
Exterior doors and garage doors that contain
composite wood products, if— (A) the doors are made
from composite wood products manufactured with
NAF resins or ultra low-emitting formaldehyde (ULEF)
resins; or (B) the doors contain less than 3 percent
by volume of hardwood plywood, particleboard, or
MDF, combined, in relation to the total volume of the
finished exterior door or garage door.
Are There Any Incentives to Use NAF-based
Resins or ULEF resins in my products?
Yes, there are incentives in place. You can apply to your
EPA TSCA Title VI TPC or to CARB for reduced testing or
third-party certification exemptions for products made with
NAF-based resins on ULEF resins. The applications must
contain one test pursuant to test method ASTM El 333-10 or
ASTM D6007-02 and at least three months of quality control
testing results for products made with NAF-based resins and
two tests pursuant to test method ASTM El 333-10 or ASTM
D6007-02 and six months of quality control testing results
for products made with ULEF resins. TPCs have 90 days to
review the applications to make sure the emission standards
and other requirements are met. These exemptions last for
two years and can be renewed.
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How to Comply
The regulations are designed to ensure compliance with
TSCA Title VI formaldehyde emission standards so that only
compliant products are sold, supplied or offered for sale in
the United States. In order to achieve this, panel producers
are required to get their panels tested and certified. They
are also required to label their products and follow the
recordkeeping and reporting requirements.
Emission Standards
Product
Emission Standard
Hardwood Plywood -
Veneer Core
0.05 ppm of formaldehyde
Hardwood Plywood -
Composite Core
0.05 ppm of formaldehyde
MDF
0.11 ppm of formaldehyde
Thin MDF
0.13 ppm of formaldehyde
Particleboard
0.09 ppm of formaldehyde
*Note: ppm refers to parts per million.
The emission standards are based on test method ASTM
El 333-10.
Product Testing Requirements
The regulations require quality control testing and
quarterly testing. Quality control testing is done on a regular
basis and can be done at the facility if there is testing
equipment on-site. The main purpose is to monitor the day-
to-day operations of the facility's quality control program
and ensure that changes in production do not result in non-
complying lots. Quarterly testing is conducted by an EPA
TSCA Title VI TPC and is necessary for the products to be
certified.
Quality control tests must be performed at a set
frequency.
Product Quality Control Testing
Frequency
At least one test per week per product type if
the weekly hardwood plywood production is
>100,000 ft2 and < 200,000 ft2
At least two tests per week per product type
if the weekly hardwood plywood production
is >200,000 ft2 and < 400,000 ft2	
At least four tests per week per product type
if the weekly hardwood plywood production
is > 400,000 ft2	
If weekly production of hardwood plywood
at the panel producer is 100,000 ft2 or less,
but more than 100,000 ft2 is produced each
month, at least one test per 100,000 ft2 for
each product type produced; or, if less than
100,000 ft2 of a particular product type is
produced, one quality control test of that
product type every month that it is produced
MDF (including Once per shift (eight or twelve hours, plus
thin-MDF)	or minus one hour of production) for each
Particleboard production line for each product type
Additional quality control tests must be conducted when
there is:
A change in the resin formulation that increases
formaldehyde to urea ratio;
An increase by more than 10 percent in the amount of
formaldehyde resin used by square foot or by panel;
A change of more than 20 percent in the adhesive
application rate;
A decrease in designated press time by more than 20
percent, or
If the quality control manager or employee believes
the panel being produced may not meet the applicable
standard.
The following test methods are approved for use as
quality control test methods, with a showing of correlation
to ASTM El 333-10:
•	ASTM D6007-02;
•	ASTM D5582 -00;
EN 717-2 (Gas Analysis Method);
DMC (Dynamic Micro Chamber), 2007 Georgia Pacific
Small Entity Compliance Guide for Mills	8
•	Hardwood
Plywood -
Veneer
Core
•	Hardwood
Plywood -
Composite
Core

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User's Manual;
DMC (Dynamic Micro Chamber), 2012 Georgia Pacific
User's Manual;
EN 120:1992 (Perforator Method); or
JIS A 1460:2012 (24-hr Desiccator Method).
Third-Party Certification Requirements
Panel producers must apply to an EPA TSCA Title VI TPC
to have their products certified. The application requires:
Contact information;
The panel producer's quality control manual;
Contact information for the quality control manager;
List of products and their resin systems;
At least five formaldehyde tests results (conducted by a
EPA TSCA Title VI TPC using a specified test method);
The results of at least five quality control tests;
Linear regression equation and correlation data (The
correlation must be based on a minimum sample size
of five data pairs and a simple linear regression where
the dependent variable (Y-axis) is the quality control test
value and the independent variable (X-axis) is the ASTM
El333-10 test value. Either composite wood products
or formaldehyde emissions reference materials can be
used to establish the correlation); and
Results of the initial onsite inspection by an EPA TSCA
Title VI TPC.
EPA TSCA Title VI TPCs must act on a panel producer's
complete application within 90 calendar days of receipt. EPA
TSCA Title VI TPCs will perform quarterly inspections of their
panel producers and quarterly emission tests.
EPA TSCA Title VI Third-Party Certifiers
For a complete list of all EPA TSCA Title VI TPCs, visit
EPA's webpage at https://www.epa.gov/formaldehyde/
formaldehyde-emission-standards-composite-wood-
products.
For a list of all CARB-approved TPCs, visit CARB's web
page at http://www.arb.ca.gov/toxics/compwood/listoftpcs.
htm.
When contracting with an EPA TSCA Title VI TPC, you
may wish to consider such factors as geographic proximity,
language of business operations, and the types of products
that the EPA TSCA Title VI TPC has experience certifying.
CARB and TSCA Title VI
If a product is certified by a CARB-approved TPC that
is also recognized as an EPA TSCA Title VI TPC, it will be
considered certified under TSCA Title VI until December
12, 2018. CARB TPCs must be recognized by EPA to certify
products under TSCA Title VI, however, CARB TPCs have until
December 12, 2018 to become fully accredited pursuant to
the EPA final rule.
Non-complying Lots
It is a violation of the regulations to sell, supply, or offer
for sale a non-complying lot. If this occurs, it is important
to take steps to minimize the impact of the violation. You
are required to notify the recipients of the lot within 72
hours of becoming aware of the failing test results for that
lot. You will have to either recall the non-complying lot
or work with the recipients to treat, retest and certify the
non-complying lot. The notification of a non-complying
lot should include a statement that the composite wood
products belonging to the non-complying lot should be
isolated from other composite wood products and must
not be further distributed in commerce. You should also
include a description of how you plan to either recall the
non-complying lot or how you will treat, retest, and certify
the lot. You also will have to notify your EPA TSCA Title VI TPC
about the disposition of the non-complying lot.
Provisions for Small Entities
There are no small entity exemptions and there is no
de minimis standard based on the size of smaller panel
producers.
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Reporting Requirements for Panel
Producers
In addition to the information in an application to have
a product certified, a panel producer must provide certain
information to its EPATSCATitle VITPC, and direct purchasers
of its products. Below is a list of reporting requirements.
What is the
notification/
report?
Who do you
notify/
report to?
When do you
send the
notification/
report?
Change in quality
control manager
Your TPC
Within 10 calendar
days of change
Significant changes to
production that could
affect formaldehyde
emissions
Your TPC
Within 72 hours
Notification of
shipment of non-
complying lot
Fabricators,
importers,
distributors, and
retailers that
received the lot
With 72 hours of
receiving non-
complying test
result
Information on the
disposition of non-
complying lots
Your TPC
Within 7 calendar
days
Product data reports
Your TPC
Monthly
Records on quarterly
emission testing
Direct
Purchasers
If they request
this information,
provide it prior to
sale
Developing a Quality Control Manual
The quality control manual provides facility-specific
information needed to ensure consistent production of
compliant composite wood products. Your EPA TSCA Title VI
TPC will need to approve your quality control manual and
may wish to collaborate with you in producing the manual.
At a minimum, the manual will need to include:
The organizational structure of the quality control
department (including key employee names and titles);
Sampling procedures;
Method of handling samples, including a specific
maximum time period for analyzing quality control
samples;
Frequency of quality control testing;
Procedures used to identify changes in formaldehyde
emissions resulting from production changes;
Provisions for additional testing;
Recordkeeping procedures;
Labeling procedures;
Average percentage of resin and press time for each
product type;
Product types, and if applicable, a description of product
variables covered under each product type;
Procedures for reduced quality control testing, if
applicable; and
Procedures for handling non-complying lots.
Generating Monthly Product Data Reports
Monthly product data reports must contain a data sheet
for each product type with emissions test and production
information, and a quality control graph containing the
quality control limit, the shipping quality control limit (if
applicable), the results of quality control tests and any retest
values.
Recordkeeping Requirements for Panel
Producers
Panel producers must keep the following records for
three years:
Records of quarterly emission tests;
Records of quality control tests;
Production records, including a description of the
composite wood product(s), the date of manufacture,
lot numbers, and tracking information allowing each
product to be traced to a specific lot produced;
Records of changes in production, including changes
of more than 10 percent in the resin use percentage,
changes in resin composition that result in a higher
ratio of formaldehyde to other resin components, and
changes in the process, such as changes in press time by
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more than 20 percent;
Purchaser information;
Transporter information;
Information on the disposition of non-complying lots;
and
Representative copies of labels used.
For panel producers taking advantage of the reduced
testing or reduced third-party certification provisions, the
records demonstrating eligibility for those provisions must
be kept for as long as the panel producer is taking advantage
of those provisions.
Product Labeling
You have two labeling options: label each panel
separately, or label bundles of a panels. Should panels
become separated from the bundle, you will need a method
to link them to their proper bundle, such as color-coded
edge marking. The label can be a stamp, tag, or sticker.
The labels must have the panel producer's name, the
lot number, the identification number of the EPA TSCA Title
VI TPC, and a statement that the products are TSCA Title VI
certified. You can use an identification number instead of the
panel producer name, butyour customers must have enough
information to linkyour panels back to you. If you are taking
advantage of the reduced testing or third-party certification
provisions for NAF-based resins or ULEF formaldehyde resins,
you may label your panels as being made with these resins,
but you are not required to do so.
How Is My Compliance Determined, and
What Happens if the Agency Discovers a
Violation?
To maximize compliance, EPA implements a balanced
program of compliance assistance, compliance incentives,
and traditional law enforcement. EPA knows that small
businesses that must comply with complicated new statutes
or rules want to do the right thing, but may lack the requisite
knowledge, resources, or skills. Compliance assistance
information and technical advice helps small businesses
to understand and meet their environmental obligations.
Compliance incentives, such as EPA's Small Business
Policy, apply to businesses with 100 or fewer employees
and encourage persons to voluntarily discover, disclose,
and correct violations before they are identified by the
government (more information about EPA's Small Business
Policy is available at https://www.epa.gov/enforcement/small-
businesses-and-enforcement). EPA's enforcement program
is aimed at protecting the public by targeting persons or
entities who neither comply nor cooperate to address their
legal obligations.
EPA uses a variety of methods to determine whether
businesses are complying, including facility inspections,
reviewing records and reports, coordinating with U.S.
Customs and Border Protection on importing, and responding
to citizen tips and complaints. Under TSCA, EPA may file an
enforcement action against violators seeking penalties of
up to $37,500 per violation, per day. The proposed penalty
in a given case will depend on many factors, including the
number, length, and severity of the violations, the economic
benefit obtained by the violator, and its ability to pay. EPA
has policies in place to ensure penalties are calculated fairly.
These policies are available to the public. In addition, any
company charged with a violation has the right to contest
EPA's allegations and proposed penalty before an impartial
judge or jury.
EPA encourages small businesses to work with the
Agency to discover, disclose, and correct violations. The
Agency has developed self-disclosure, small business, and
small community policies to modify penalties for small and
large entities that cooperate with EPA to address compliance
problems. For more information on compliance assistance
and other EPA programs for small businesses, please contact
EPA's Small Business Ombudsman at (202) 566-2075.
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For More Information
Get additional information at http://www.epa.gov/
formaldehyde.
The regulations can be found in the Federal Register
(Vol. 81, No. 81, p. 89674) at https://www.regulations.gov/
document?D=EPA-HQ-OPPT-2016-0461 -0001.
Where Can I Go If I Have Questions or Need
Further Assistance?
Please contact EPA's TSCA Hotline with questionsby
telephone at (202) 554-1404, by fax at (585) 232-3111 or by
email at tsca-hotline@epa.gov.
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Appendix
Acronym List
ATCM
Airborne Toxic Control Measure
CARB
California Air Resources Board
FR
Federal Register
MDF
Medium-Density Fiberboard
NAF
No-Added Formaldehyde
TPC
Third-Party Certifier
TSCA
Toxic Substances Control Act
ULEF
Ultra Low-Emitting Formaldehyde
Glossary of Environmental Terms
Accreditation Body or AB means an organization that
provides an impartial verification of the competency of
conformity assessment bodies or TPCs.
Bundle means more than one composite wood product,
component part, or finished good fastened together for
transportation or sale.
Component part means an object other than a panel that
contains one or more composite wood products and is
used in the construction or assembly of finished goods.
Component parts that are sold directly to consumers are
considered finished goods.
Composite core means a platform for making hardwood
plywood or laminated products that consists of particleboard
and/or MDF, or combination core.
Finished good means any good or product, other than
a panel, that contains hardwood plywood (with a veneer
or composite core), particleboard, or MDF and that is not
a component part or other part used in the assembly of a
finished good. Site-built buildings or other site-built real
property improvements are not considered finished goods.
Hardwood plywood means a hardwood or decorative
panel that is intended for interior use and composed of (as
determined under ANSI/HPVA HP-1-2009 (incorporated
by reference, see 40 CFR §770.99)) an assembly of layers or
plies of veneer, joined by an adhesive with a lumber core, a
particleboard core, a MDF core, a hardboard core, a veneer
core, or any other special core or special back material.
Hardwood plywood does not include military-specified
plywood, curved plywood, or any plywood specified in
PS-1-07, Voluntary Product Standard—Structural Plywood
(incorporated by reference, see 40 CFR §770.99), or PS-2-
04, Voluntary Product Standard—Performance Standard
for Wood-Based Structural-Use Panels (incorporated by
reference, see 40 CFR §770.99). In addition, hardwood
plywood includes laminated products except as provided at
40 CFR §770.4.
Laminated product means a product in which a wood
or woody grass veneer is affixed to a particleboard core
or platform, a MDF core or platform, or a veneer core or
platform. A laminated product is a component part used in
the construction or assembly of a finished good. In addition,
a laminated product 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.
Laminated product producer means a manufacturing plant
or other facility that manufactures (excluding facilities that
solely import products) laminated products on the premises.
Laminated product producers are fabricators and, after
December 12, 2023, laminated product producers are also
hardwood plywood panel producers except as provided at
40 CFR §770.4.
Lot means the panels produced from the beginning of
production of a product type until the first quality control
test; between one quality control test and the next; or from
the last quality control test to the end of production for a
particular product type.
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Medium-density fiberboard or MDF means a panel
composed of cellulosic fibers made by dry forming and
pressing a resinated fiber mat (as determined under ANSI
A208.2-2009 (incorporated by reference, see 40 CFR
§770.99).
No-added formaldehyde-based or NAF resin means a resin
formulated with no added formaldehyde as part of the resin
crosslinking structure in a composite wood product that
meets the emission standards in 40 CFR §770.17(c).
Non-complying lot means any lot of composite wood
product represented by a quarterly test value or quality
control test result that indicates that the lot exceeds the
applicable standard for the particular composite wood
product in 40 CFR §770.10(b). A quality control test result
that exceeds the quality control limit is considered a test
result that indicates that the lot exceeds the applicable
standard. Future production of the product type(s)
represented by a failed quarterly test are not considered
certified and must be treated as a non- complying lot until
the product type(s) are re-qualified through a successful
quarterly test.
Panel means a thin (usually less than two inches thick), flat,
usually rectangular piece of particleboard, MDF or hardwood
plywood. Embossing or imparting of an irregular surface
on the composite wood products by the original panel
producer during pressing does not remove the product
from this definition. Cutting a panel into smaller pieces,
without additional fabrication, does not make the panel into
a component part or finished good. This does not include
items made for the purpose of research and development,
provided such items are not sold, supplied, or offered for
sale.
Panel producer means a manufacturing plant or other
facility that manufactures (excluding facilities that solely
import products) composite wood products on the premises.
Particleboard means a panel composed of cellulosic
material in the form of discrete particles (as distinguished
from fibers, flakes, or strands) that are pressed together with
resin (as determined under ANSI A208.1 -2009 (incorporated
by reference, see 40 CFR §770.99). Particleboard does not
include any product specified in PS-2-04, Performance
Standardfor Wood-Based Structural-Use Panels (incorporated
by reference, see 40 CFR §770.99).
Production line means a set of operations and physical
industrial or mechanical equipment used to produce a
composite wood product in one facility utilizing the same
or similar equipment and quality assurance and quality
control procedures.
Resin system means type of resin used, including but not
limited to urea- formaldehyde, soy, phenol-formaldehyde, or
melamine-urea-formaldehyde.
Thin medium-density fiberboard or thin MDF means
medium-density fiberboard that has a thickness less than or
equal to 8 millimeters or 0.315 inches.
Third-party certifier or TPC means a conformity assessment
body that provides both product certification services
and laboratory testing services (either directly or through
contracted services).
Ultra low-emitting formaldehyde or ULEF resin means a
resin in a composite wood product that meets the emission
standards in 40 CFR §770.18(c).
Veneer means a sheet of wood or woody grass with a
maximum thickness of 6.4 millimeters (1/4 inch) that is rotary
cut, sliced, or sawed from a log, bolt, flitch, block, or culm;
including engineered veneer.
Veneer core means a platform for making hardwood
plywood or laminated products that consists of veneer.
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Woody grass means a plant of the family Poaceae (formerly
Gramineae) with hard lignified tissues or woody parts.
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