CARB 2 set for global impact

In the state of California it is believed that formaldehyde is a carcinogen that has no known safe level of exposure. So, in April 2007, the Californian Air Resources Board (CARB) of the state’s Environmental Protection Agency (EPA) adopted a code for stricter formaldehyde emission regulations to be applied to composite wood products – its stated aim being the protection of California’s citizens.

Irrespective of whether one agrees with this reasoning, the CARB regulations, which are being implemented in two phases, have to be met for all hardwood plywood, particleboard and MDF products intended for sale, supply, use, or manufactured for sale in California at any point during their lifetime. Finished goods containing these products are also covered.

CARB is becoming an important issue in Europe too. Traditionally European Standards have been set locally, but in this increasingly globalised economy, standards set elsewhere can impact on Europe. Because CARB standards are now being extended across much of North America, some leading European-based manufacturers and retailers have opted to standardise their output so that their products can be marketed and are acceptable across all their markets. Hence they are including CARB 2 in their procurement specification in Europe. These measures are in addition to their existing obligations under EU REACH regulations.

Phase 1 CARB standards have now been in effect for nearly two years, but the much tougher Phase 2 formaldehyde emission standards for hardwood plywood with veneer core came into effect on January 1, 2010. These same, more demanding CARB 2 emission limits will come into place for MDF and particleboard from January 1, 2011.

These limits will be principally based on the primary test method or large chamber test method as per ASTM E 1333-96 (2002). Manufacturers who use no added formaldehyde-based resins are not required to comply with these regulations if they obtain CARB’s written approval. Similarly, manufacturers who use ultra-low-emitting formaldehyde (ULEF) resins are allowed to test their products less frequently than is otherwise required. Both of these approvals last two years, after which the manufacturer can apply for re-approval.

Importers, distributors, fabricators, and retailers of composite wood panels for use in California have been told that they must always buy compliant panels and they are responsible for checking on suppliers and for verifying the supply chain. A list of certified mills and approved third-party certifiers (from North America, Europe, Australia, and Asia) is maintained by CARB.

Higher costs

Implementation of formaldehyde regulations will raise panel costs because they will result in incurring the higher costs of formaldehyde-free adhesives, plus the costs of potential implementation of necessary technologies in the processing, additional testing, and required certification of compliance with the regulations.

While CARB may not have jurisdiction to impose fines on overseas manufacturers, it will be its US distributors, importers, fabricators, retailers, and third-party certifiers who will be held accountable and fined. CARB regulations will be rigorously enforced both on domestic and imported products, thereby creating a level playing field.

Similar to CARB, formaldehyde compliance regulations for composite wood products will become effective on January 3, 2011 throughout the US. The Formaldehyde Standards for Composite Wood Products Act, which was effectively established in July 2010 when a Bill was signed into US law, is based on the CARB Measure and applies to hardwood plywood, particleboard, MDF, and finished goods sold, supplied, or manufactured in the US that contain composite wood products. The EPA is required to publicise these regulations and revise any existing import regulations by January 1, 2013 to warrant compliance with the formaldehyde emission standards. The regulatory bodies, as they continue to re-evaluate the formaldehyde emission limits from wood-based composites, should consider that a value of “zero” for formaldehyde emission is not attainable even for solid woods as detectable levels can be expected since formaldehyde is a metabolism product that is always present in nature.

Because of this strict enforcement of these regulations in the US, coupled with uncertainty of where manufactured products may end up, European distributors and manufacturers are increasingly specifying CARB 2 compliant panel products.