
PRODUCTS AND BUSINESSES COVERED
Composite Wood Products
- Particleboard.
- Medium Density Fiberboard (MDF).
- Thin MDF (< 8 mm in thickness) [has different emission requirements and compliance deadlines than regular MDF].
- Hardwood Plywood made with a veneer core.
- Hardwood Plywood made with a composite core (particleboard or MDF) [has different compliance deadlines than veneer core hardwood plywood].
Business Activities Covered
- Finished products for sale or use in California may only contain CARB compliant composite wood products certified by a CARB approved Third Party Certification (TPC) agency. Fabricators must specify and only use compliant composites.
- Manufacturers of composite wood products for sale or use in California must obtain certification by a CARB approved TPC.
- Manufacturers, importers and distributors of composite wood products for sale or use in California, have record keeping, labeling and notification obligations.
- Fabricators of finished products containing composite wood products and distributors have record keeping, labeling and notification obligations.
- California retailers of composite wood products and fabricated products containing composite wood products have labeling and record keeping requirements.
- Third Party certifiers of composite wood products have record keeping, monitoring and reporting requirements.
RESOURCES
Composite Panel Association (CPA)
703.724.1128 or jbradfield@cpamail.org | www.pbmdf.com
www.CARBrule.org - the reliable resource for compliance
California Air Resources Board (CARB)
916.327.5615 or btakemot@arb.ca.gov
www.arb.ca.gov/toxics/compwood/compwood.htm
EMISSION LIMITS AND DEADLINES
Products meeting the emission limits above (see chart) must also be certified by a CARB approved third party certification program unless they are approved Ultra Low Emission Formaldehyde (ULEF) or No Added Formaldehyde (NAF) products (see certification exemptions).
Sell Through Provisions for Moving Inventory Beyond the Manufacturing Deadlines*
- Manufacturers and Importers of composite wood products: 3 months beyond the Phase 1 and Phase 2 ATCM manufacturing deadlines.
- Distributors of composite wood products: 5 months beyond the Phase 1 and Phase 2 ATCM manufacturing deadlines.
- Retailers of composite wood products: 12 months beyond the Phase 1 and Phase 2 ATCM manufacturing deadlines.
- Fabricators and Distributors of finished products containing composite wood products: 18 months beyond the Phase 1 and Phase 2 ATCM manufacturing deadlines.
- Retailers of fabricated products containing composite wood products: 18 months beyond the Phase 1 and Phase 2 ATCM manufacturing deadlines.
*see table below
Labeling, Notification and Record keeping Requirements for Fabricators
- Must use composites that comply with the emission and certification requirements of the rule.
- Records showing date of purchase for composites must be kept for 2 years.
- Label required for every product or product box applied as a stamp, tag, sticker or bar code.
- Label must include the fabricator’s name, the production date and the compliance standard of the product being used (i.e. Phase 1, Phase 2, ULEF, NAF).
- Receiving written documentation of product compliance from suppliers and providing it to customers is recommended.

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