In the July edition of Bark Bits, we reported on US legislation which requires imported composite wood products to meet standards with regards to formaldehyde emissions. Prior to printing, members had been reporting issues at US border points with products made wholly or in part from plywood and OSB. While researching this legislation, we were informed that when exporting composite wood products to the US that shippers must provide a declaration which identifies that the composite wood products meet the US standard.
However, after printing, we have been informed that this may not be the case, and that there may have been some misunderstanding at US border entry points.
We reached out to Kurt Bigbee at the APA-The Engineered Wood Association for clarification. After discussion, Mr. Bigbee provided the following information (highlights for emphasis ours):
5. Exemptions. a. Statutory exemptions. TSCA section 601(c) exempts a number of products from the formaldehyde emission standards for composite wood products. These exemptions include, but are not limited to: Hardboard, structural plywood, structural panels, oriented strandboard, glued laminated lumber, prefabricated wood I-joists, finger-jointed lumber, wood packaging, composite wood products used inside new vehicles other than recreational vehicles, windows that contain less than five percent by volume of composite wood products, exterior doors and garage doors that contain less than three percent by volume of composite wood products, and exterior and garage doors that are made with NAF-based or ULEF resins. EPA is incorporating these exemptions into the implementing regulations. Composite wood products, component parts, and finished goods that qualify for these exemptions are exempt from all of the provisions of the implementing regulations. However, component parts and finished goods made of a mixture of exempt products and regulated products are not exempt. For example, a cabinet made up of structural plywood and hardwood plywood would be subject to the labeling and recordkeeping requirements of this final rule. The hardwood plywood in the cabinet would also be subject to the emission standard for hardwood plywood as well as the testing and certification provisions of this rule.
The Toxic Substances Control Act hotline was also contacted, and confirmed the information above and cited section 770.1 of the Formaldehyde Emission Standards for Composite Wood Products document.
If you are engaged in shipping composite wood products, or wood packaging with composite wood product components, it is advisable that you should familiarize yourselves with the rules, and the exemptions. Mr. Bigbee did also note however that as most products manufactured in North America meet the standards, it may be wise to confirm product conformance with the manufacturer or vendor, and identify this on your shipping documents.
We would ask that any members encountering difficulty at US border entry points with composite wood products contact the CWPCA office with details so we may address with the proper authorities as may be necessary.
