CBP and EPA Warning on Plywood, MDF and Particleboard
Rob Gardenier | M.E. Dey & Co.
Formaldehyde is used in the manufacture of plywood, MDF and Particleboard. On March 22, these articles will require reporting under the Toxic Substances Control Act (TSCA). Here’s what you need to know:
- TSCA Title VI import certification applies to composite wood products, component parts containing composite wood products, and finished goods – including panels of hardwood plywood veneer, MDF, particleboard, and parts of furniture, picture frames, furniture, wooden toys, etc. that contain these items.
- Shipments must include an invoice or Bill of lading stating that the products are TSCA Title VI certified
- Goods must be labeled showing that they are certified/compliant with TSCA Title VI
- Importers must retail records for 3 years
- If requested, importers must provide records to EPA within 30 calendar days
- De minimis rule of 144 square inches ONLY applies to the labelling requirements – these items MUST still be certified/compliant and be reported in the entry
- EPA stated that CARB (the CA requirements) are completely separate from TSCA requirements. As of 3/22/19, the importers must comply with TSCA labelling and certification, there is no more overlap between the two.
For further information, visit the EPA site for a complete overview of the formaldehyde emissions standards for composite wood products (Link)