Are Your Wood Composite Products TSCA Title VI Compliant?

Date of Publication: February 2, 2021

For importers who deal with products containing composite wood, there are specific requirements to be aware of. One of these is TSCA Title VI, which went into effect in 2019 and concerns formaldehyde emissions.

Understanding TSCA Title VI

The Formaldehyde Standards for Composite Wood Products Act, or TSCA Title VI, went into effect on March 22, 2019. Established by the Environmental Protection Agency (EPA), TSCA Title VI places tight restrictions on composite wood products to limit the health consequences of formaldehyde. Formaldehyde is a colorless gas that is found in many composite wood products. Exposure to unsafe amounts of formaldehyde can lead to adverse health effects, which is why EPA and TSCA Title VI work to limit the amount of formaldehyde in wood composite products imported into the United States.

Under TSCA Title VI, all composite wood products must be tested and certified prior to entry into the United States. This ensures that composite wood products with unsafe quantities of formaldehyde do not enter the United States, where they could cause harm to consumers or others who handle the products.

Impacted Products

Under the 2019 rule of TSCA Title VI, the regulated composite wood products are:

  • Hardwood plywood
  • Particleboard
  • Medium-density fiberboard

Many types of products include these regulated types of composite wood. Some common products that contain hardwood plywood, particleboard, or medium-density fiberboard include:

  • Musical instruments
  • Furniture
  • Cabinets
  • Toys
  • Craft products
  • Building materials

Even if a product only contains a very small amount of one of the above types of composite wood, they are still required to undergo inspection due to TSCA Title VI.

Ensuring TSCA Title VI Compliancy

To avoid delays or restrictions when importing wood composite products into the United States, importers should follow the steps in this checklist to ensure that their products are TSCA Title VI compliant.

  • Communicate with their fabricators or manufacturers who use composite wood panels to create either the finished product or a component part of the finished product.
  • Confirm that their fabricators have their panels certified by an EPA accredited Third Party Certifier (TPC) and that they are TSCA Title VI compliant.
  • Keep a three-year record of all steps to ensure compliancy.
  • Appropriately label all products containing wood composite
  • Provide a TSCA Title VI certification with each product shipment

By being aware of TSCA Title VI and its impact on the importation of wood composite products, importers can avoid delays and complications by ensuring their wood composite products are in compliance with the 2019 rule.

This content is intended for informational purposes. Due to the generality of this content, the provided information may not be applicable in all situations. We encourage the reader to review the most up-date-regulations directly with the U.S. government’s sources on TSCA Title VI, which can be found here.

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