Small Entity Compliance
Guide for Fabricators and
Laminated Product Producers
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-17-003

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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
PAR TY 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 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 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 regulated by TSCA Title VI—hardwood plywood,
medium-density fiberboard (MDF) and particleboard.
Other key terminology is defined in the Appendix:
Glossary of Environmental Terms.
Who Should Use this Guide?
This guide is intended to be used by small businesses
that are fabricators, which includes laminated product
producers (e.g., laminators) of component parts or finished
goods that contain regulated composite wood products.
Fabricators can be any person, or entity, who incorporates
regulated composite wood products into component parts
or the assembly of finished goods. Note that, in addition to
being a fabricator, any manufacturing plant or other facility
manufacturing laminated products on the premises is
considered a laminated product producer.
The following types of businesses are likely to be covered
under by this regulation:
Manufactured home (mobile home) manufacturing
(NAICS code 321991);
Prefabricated wood building manufacturing (NAICS
code 321992);
Motor home manufacturing (NAICS code 336213)
Travel trailer and camper manufacturing (NAICS code
336214); and
Furniture and related product manufacturing (NAICS
code 337).
Although you may find that your business does not
fit into one of these NAICS codes, it is still possible to be a
fabricator or laminated product producer under TSCA Title VI
based on the product(s) you are manufacturing or producing.
Please note that persons and entities in the construction
trades who are renovating or remodeling buildings are not
fabricators according to this rule - those persons or entities
in the business of constructing premanufactured houses,
modular home fabrication, and the like, however, would be
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.	Accreditation Bodies (ABs) and Third-Party Certifiers
(TPCs), and
3.	Mills (Panel Producers).
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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included under the rule as fabricators.
Figure 1 outlines the structure of the TSCA Title VI
program and shows the relationships between EPA and the
various groups involved in implementation of the regulation.
Fabricators are identified in blue with their relationship to the
remainder of the TSCA Title VI program.
What Does This Guide Cover?
This guide covers the requirements under the
Formaldehyde Emission Standards for Composite Wood
Products Rule (TSCA Title VI) for fabricators, including
laminated product producers and the related implementing
regulations. Note that there are other entities covered under
the rule, including panel producers, whose responsibilities
are covered in the other compliance guides mentioned at the
beginning of this document.
This compliance guide is limited to 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 which are different from,
or more stringent than, the federal requirements. For more
assistance in this area, contact your EPA regional office or state
FIGURE 1 - TSCA
environmental agency.
NOTE: If you are fabricating component parts or finished goods
that contain composite wood products in California, orofferthem
for sale 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 came be found online at
http://www.arb.ca.gov/toxics/compwood/compwood.htm.
How Do I Obtain a Copy of the Rule?
A complete copy of the final rule and 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.
TLEVI PROGRAM
Reciprocity
EPA-recognized
Third Party
Certifiers (TPCs)
CARB-approved
Third Party
Certifiers (TPCs)
Panel
Producers
Retailers
EPA-recognized
Product &
Laboratory
Accreditation
Bodies (ABs)
Importers
Distributors
Fabricators
California Air
Resources Board
(CARB)
I LAC
International Laboratory
Accreditation
Cooperation
IAF
International
Accreditation Forum
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Regulation Summary and Compliance Timetable
Regulation Summary
The purpose of the regulation is to reduce formaldehyde
emissions from regulated composite wood products, which
will reduce exposures to formaldehyde, resulting in benefits
for human health. TSCA Title VI establishes formaldehyde
emission standards for three types of composite wood
products: hardwood plywood, MDF (including thin MDF),
and particleboard. The required formaldehyde emissions
standards are as follows:
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; and
Thin MDF = 0.13 ppm.
These formaldehyde emission standards are identical to
the emission standards currently in place in California under
the California Air Resources Board Air Toxics Control Measure
for formaldehyde (CARB ATCM).
The regulation requires that regulated composite wood
products be tested and certified by an EPA-recognized
third-party certifier (TPC) to ensure compliance with the
formaldehyde emission standards. EPA maintains a listing
of recognized TPCs on its publicly available formaldehyde
webpage. Please visit https://www.epa.gov/formaldehyde/
formaldehyde-emission-standards-composite-wood-
products for a complete listing of the TPCs EPA is currently
recognizing. Fabricators and laminated product producers
are required to purchase and use compliant composite wood
products and component parts and can only sell compliant
component parts and finished goods that contain such
products. In addition to the fabricator category, the regulation
establishes two types of laminated product producers:
Non-Exempt Producers of laminated products that are
not exempt from the definition of hardwood plywood
because their products use a resin other than phenol
formaldehyde (PF) or no added-formaldehyde (NAF) to
attach a veneer to a compliant platform; and
Exempt Producers of laminated products that are exempt
from the definition of hardwood plywood because their
products are made using a PF or NAF resin to attach a
veneer to a compliant platform or because their products
were exempt by rulemaking as described at 40 CFR §770.4.
The regulation also contains recordkeeping, reporting,
and labeling requirements for fabricators and laminated
product producers.
Compliance Timetable
The TSCA Title VI rule is effective February 10, 2017. EPA
established a manufactured-by date (i.e., compliance date)
for composite wood products of December 12, 2017, and a
manufactured-by date for laminated products of December
12, 2023. From December 12, 2017 to December 12, 2023,
fabricators and laminated product producers are considered
essentially the same and both must comply with the general
requirements for fabricators (i.e., they must use compliant
cores or platforms, they must keep fabricator records, and
they must follow the labeling requirements for fabricators).
On December 12, 2023, laminated product producers
making laminated products exempted from the definition of
hardwood plywood also must, as a condition of the exemption,
maintain records demonstrating that products made after the
manufactured-by date for laminated products are eligible for
the exemption. On December 12, 2023, producers of non-
exempt laminated products must comply with the testing,
certification, and recordkeeping requirements for hardwood
plywood composite wood product producers in addition to
the requirements for fabricators.
Table 1 provides a summary of the regulatory
requirements and compliance dates. The "How to Comply"
section of this guide provides more detail on the rule
requirements for fabricators and laminated product producers
and what they must do to document compliance with the
regulation.
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Table 1. Summary Requirement and Compliance Dates
Requirement
Compliance Date
Fabricators (other than Laminated Product Producers)
Bills of lading, invoices, or comparable documents must be obtained and maintained for 3 years.
(40 CFR §§ 770.30, 770.40)
December 12, 2017
Finished goods must be labeled with the producer's name, the date the good was produced, and
a statement of TSCA Title VI compliance. (40 CFR §770.45)
December 12, 2017
Producers of Laminated Products That Are Not Exempt from the Definition of Hardwood Plywood
Bills of lading, invoices, or comparable documents must be obtained and maintained for 3 years.
(40 CFR §§770.30, 770.40)
December 12, 2017
Finished goods must be labeled with the producer's name, the date the good was produced, and
a statement of TSCA Title VI compliance. (40 CFR section 770.45)
December 12, 2017
Laminated products must comply with the hardwood plywood emission standard of 0.05 ppm,
and the testing, certification, and recordkeeping requirements for composite wood products. (40
CFR §§ 770.10, 770.15, 770.20, 770.40)
December 12, 2023
Producers of Laminated Products That Are Exempt from the Definition of Hardwood Plywood
Bills of lading, invoices, or comparable documents must be obtained and maintained for 3 years.
(40 CFR §§ 770.30, 770.40)
December 12, 2017
Finished goods must be labeled with the producer's name, the date the good was produced, and a
statement of TSCA Title VI compliance. (40 CFR §770.45)
December 12, 2017
Records demonstrating purchase/use of compliant platforms and NAF or PF resins. (40 CFR
§770.40)
December 12, 2023
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Who Must Comply
How Can I Tell If I Am Subject to This Rule?
You are subject to 40 CFR part 770 if you are a fabricator
or laminator of component parts or finished goods that
contain hardwood plywood, MDF or particleboard. If you
fabricate component parts or finished goods that contain
only exempt products, the rule does not apply to you. The
following products are exempt:
Hardboard;
Structural plywood;
Structural panels;
Structural composite lumber;
Military-specified plywood;
Curved plywood;
Oriented strand board;
Glued laminated lumber;
Prefabricated wood l-joists;
Finger-jointed lumber;
Wood packaging (pallets, crates, spools, dunnage);
Composite wood products used inside a new vehicle,
other than a recreational vehicle, including rail cars,
boats, and aircraft;
Windows that contain composite wood products, if the
windows contain less than 5 percent composite wood
product by volume;
Exterior doors and garage doors that contain composite
wood products, if:
i.	The doors are made from composite wood products
manufactured with NAF resins or ultra low-emitting
formaldehyde (ULEF) resins; or
ii.	The doors contain less than 3 percent composite
wood product by volume.
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How to Comply
What Must I Do to Comply?
General Requirements for Fabricators and
Laminated Product Producers
The following discusses the requirements for
fabricators. Also recall that on the manufactured-by date for
composite wood products, which is December 12, 2017, all
laminated product producers must comply with the general
requirements for fabricators. On the manufactured-by date
of December 12, 2023 for laminated products, laminated
product producers making exempt laminated products also
must, as a condition of the exemption, maintain records
demonstrating that exempt products made after the
manufactured-by date for laminated products are eligible for
the exemption. After December 12, 2023, producers of non-
exempt laminated products must comply with the testing,
certification, and recordkeeping requirements for hardwood
plywood, in addition to the requirements for fabricators.
Recordkeeping
As a fabricator you do not need to conduct formaldehyde
emissions testing or comply with third-party certification
requirements; however, you must ensure that you purchase
only compliant composite wood products after December
12,2023, whether they are unfinished panels or incorporated
into component parts or finished goods, and you must keep
records to demonstrate that you have done so for three
years from the date of import or purchase of the composite
wood product. These records would include bills of lading,
invoices, or a comparable document with a written statement
certifying that the purchased composite wood product is
Title VI compliant.
If you purchase directly from a composite wood product
mill, you are entitled to request a copy of the quarterly
formaldehyde emissions test results that represent the
panels you are purchasing and that document whether or
not the panels are in compliance with the required emissions
standard. The test results are solely for your information; you
are not required to keep them as part of your recordkeeping
obligations under the rule. You are also not required to pass
them along to your downstream purchasers.
Non-compliant Lots
If you are notified by your supplier that composite
wood product panels that you purchased belong to a non-
complying lot, which means that a sample taken from the
lot to which they belong failed either a quarterly or quality
control formaldehyde emissions test, you must not supply
component parts or finished goods made with those panels
to your customers. The rule requires your panel producer
supplier to notify you within 72 hours of them receiving a
notice of a failing test result. Your supplier must either recall
the non-compliant panels for treatment and retesting, treat
and retest the panels while they remain in your possession,
or work with you to dispose of the panels. As the fabricator,
after receiving notification that you have been given a
non-compliant lot, you are responsible for notifying any
of your purchasers of composite wood product belonging
to the non-compliant lot (as applicable) within 72 hours of
being notified of the non-compliant lot and provide your
purchasers with:
Panel producer name, contact information, and date of
notice;
A description of the products to assist in identifying the
product;
The nature of the failed test;
A statement that the non-compliant lot must be isolated
and cannot be further distributed in commerce; and
A description of the steps the panel producer intends
to take to either recall the composite wood products
belonging to the non-compliant lot or to treat and retest
the products and certify the lot.
Labeling
Fabricators of finished goods containing composite
wood products must label every finished good they produce
or every box or bundle containing finished goods. If a
finished good (including component parts sold separately
to end users) is not individually labeled by the fabricator,
the importer, distributor, or retailer must retain a copy of
the label, be able to identify the products associated with
that label provided by the fabricator, and make the label
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information available to potential customers upon request.
Finished goods, including component parts sold
separately to end users, containing only a de minimis
amount of regulated composite wood product are exempted
from the labeling requirements. A finished good, including
component parts sold directly to consumers, contains a
de minimis amount of regulated composite wood product
if its regulated composite wood product content does not
exceed 144 square inches, based on the surface area of
its largest face. The labeling exception does not apply to
finished goods or component parts that are designed to be
used in combination or in multiples to create larger surfaces,
finished goods, or component parts.
Labels may be stamps, tags, or stickers and are required
to include the fabricators name, date the finished good was
produced (month/year format), and a statement that the
goods are Title VI compliant, in legible English.
The rule also allows fabricators to substitute their name
with that of the downstream fabricator, importer, distributor,
or retailer on the label so long as they obtain and maintain
written consent from the downstream entity. In addition,
finished goods fabricated from composite wood panels
made with ULEF or NAF resins may be labeled as being made
with these resins or as being made with a combination of
compliant composite wood, NAF, and ULEF, if that is accurate.
Stockpiling
You are not permitted to sell any composite wood
products, component parts, or finished goods containing
composite wood products which you have stockpiled.
Stockpiled products are products that, in an annual year
between July 7,2010 and June 12,2017you have purchased
or fabricated at an annual rate at least 20 percent greater
than your average rate of purchase or fabrication during
the 2009 calendaryearforthe purpose of circumventing the
emission standards and the other requirements of this rule.
EPA recognizes that there may be valid reasons for purchasing
or fabricating products at a higher rate, including an actual
increase in demand or sales, a reasonably-anticipated
increase in demand due to an event like a natural disaster,
or a planned business expansion. Products are "stockpiled"
only if they were purchased or fabricated for the purpose of
circumventing the emission standards.
Records
You must take reasonable precautions to ensure that
you purchase only composite wood products, or component
parts containing composite wood products, that have been
produced in compliance with TSCA Title VI. This means that
you must specify TSCA Title VI compliant products when
ordering or purchasing from suppliers.
There are specific recordkeeping requirements for
laminated product producers who make products that are
not exempt from the definition of hardwood plywood, and
for those who make products that are exempt. See sections
below.
Petitioning for Exemption
Under 40 CFR §770.4(b), any person may petition the
agency to initiate a rulemaking to expand the exemption
for laminated products from the definition of the term
"hardwood plywood" using additional resin systems outside
of the PF and NAF categories. Each petitioner should provide
in their application all available and relevant information
explicitly compiled to support the requested exemption,
including:
Basic business information;
Studies conducted on exemption request;
Data on the cost and benefit of reduction in emissions
data, as available;
Formaldehyde emissions data directly related to
exemption request; and
Resin chemistry related to exemption request.
EPA views the formaldehyde emission potential and
benefits in reduction information as the most important
considerations in the decision making process. As such,
EPA is requesting the submitted information package be
comprehensive in order to enable the Agency to make a
reasoned determination on the exemption request. EPA will
provide the petitioner with an acknowledgement of receipt
of the petition package, via letter, within 15 calendar days.
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EPA will follow up with another letter once the Agency
decides to initiate a rulemaking or deny the request. Note
that the petition and any accompanying data including EPA
correspondence and final decision letter would be placed in
a public docket regardless of initiation of a rulemaking effort
or rejection of the petition.
Should the Agency decide to initiate a rulemaking
based on the petition, a proposed rule will be published
in the Federal Register with a public comment period of
generally 30 days. After the public comment period closes
and any public comments are reviewed, the Agency will take
final action on the proposal.
If exemptions are madefor additional resin formulations,
laminated product producers will still be required to meet
the requirements as "fabricators" using an exempted resin
system as it currently exists for PF and NAF resins in the TSCA
Title VI rule. Petition packages must be sent to:
Requirements for Laminated Product
Producers Making Products Exempt from the
Definition of Hardwood Plywood
Like fabricators, laminated product producers making
products exempt from the definition of hardwood plywood
(i.e., products made with PF resins, products made from
resins formulated with no-added formaldehyde as part
of the resin cross-linking structure, or products made
with resins that have been exempted by rulemaking via a
petition process) will be required after December 12,2017 to
maintain for 3 years from date of purchase/shipment/import
noted on the record bills of lading, invoices, or comparable
documents with a written statement from your supplier that
the composite wood product panels or component parts
are TSCA Title VI compliant. These records must be kept
for three years from the date of purchase/shipment/import
noted on the record.
After December 12, 2023, additional records must be
maintained for exempt products for a minimum of three
years from the date the products are produced, including:
1.	For PF or NAF resins that you purchased, purchase
records, resin trade name, resin manufacturer contact
information, and resin supplier contact information;
2.	For resins produced in-house, records demonstrating
the production of NAF or PF resins;
3.	For composite wood product panels thatyou purchased,
purchase records and panel producer contact
information; and
4.	For composite wood product panels produced in-
house, records demonstrating that the panels have been
certified by an EPA TSCA Title VI Third-party Certifier
(TPC) or were produced under a limited TPC exemption
under 40 CFR §770.17 or 40 CFR § 770.18 for panels
made with NAF resins or ULEF resins.
Requirements for Laminated Product
Producers Making Products That Are Not
Exempt from the Definition of Hardwood
Plywood
After December 12, 2023, laminated product
producers whose products are not exempt from the
definition of hardwood plywood must follow all of the
requirements for hardwood plywood producers as
discussed in the "Small Entity Compliance Guide for
Mills" at https://www.epa.gov/formaldehyde/small-
entity-com pi iance-gu ides-form aldehyde-emission-
standards-composite-wood-products. This includes
testing and third-party certification, recordkeeping,
and labelling requirements for hardwood plywood
panels.
Small Entity Compliance Guide for Fabricators and Laminated Product Producers
Director, National Program Chemicals Division
Office of Pollution Prevention and Toxics (MC7404T)
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460-001

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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 questions by
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
PF
Phenol-Formaldehyde
TPC
Third-Party Certifier
TSCA
Toxic Substances Control Act
ULEF
Ultra Low-Emitting Formaldehyde
Glossary of Environmental Terms
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.
Fabricator means a person or entity who incorporates
composite wood products into component parts or into
finished goods. This includes laminated product producers,
but persons or entities in the construction trades are not
fabricators by renovating or remodeling buildings.
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.
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).
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Panel means a thin (usually less than two inches thick),
flat, usually rectangular piece of particleboard, hardwood
plywood or MDF. 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.
Phenol-formaldehyde or PF resin means a resin that
consists primarily of phenol and formaldehyde and does not
contain urea-formaldehyde.
Purchaser means any panel producer, importer, fabricator,
distributor, or retailer that acquires composite wood
products, component parts, or finished goods for purposes
of resale in exchange for money or its equivalent.
Resin system means type of resin used, including but not
limited to urea- formaldehyde, soy, phenol-formaldehyde, or
melamine-urea-formaldehyde.
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.
Woody grass means a plant of the family Poaceae (formerly
Gramineae) with hard lignified tissues or woody parts.
Small Entity Compliance Guide for Fabricators and Laminated Product Producers

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