New Standards Update: Formaldehyde Emission For Composite Wood Products

Under Title VI of the Toxic Substances Control Act (TSCA,) formaldehyde emissions are regulated for three types of composite wood products: hardwood plywood, medium-density fiberboard (MDF), and particleboard. To reduce formaldehyde emissions from these composite wood products, TSCA Title VI and the implementing regulations were created. By doing so, human exposure to formaldehyde was reduced, resulting in health benefits for workers and consumers.

The U.S. Environmental Protection Agency (EPA) Formaldehyde Standards for Composite Wood Products was originally published in the Federal Register on December 12, 2016, at 40 CFR Part 770. The standards require formaldehyde emissions limits, testing, third-party certifications, reporting, recordkeeping, and labeling. Compliance deadlines are also set forth.

An EPA-recognized third-party certifier (TPC) must confirm that any composite wood product, covered by TSCA Title VI, complies with the formaldehyde emission standards. To obtain certification by a TPC, the  manufacturer must submit such information as emissions tests results, quality control tests findings, linear regression equation and correlation data, etc. The TPC will grant certification to products that demonstrate compliance with the emission standards and their quality control requirements. To maintain the certification for a product, the manufacturer must conduct quality control testing and submit to quarterly testing and inspections by its TPC.

New Final Rule

On November 1, 2018, the EPA proposed amending 40 CFR 770 to improve regulatory clarity and better align with the Airborne Toxic Control Measures Phase II program of the California Air Resources Board (CARB).

EPA held a public consultation in March 2022 to propose technical updates to 40 CFR 770. A pair of technical updates were proposed for the standards in September 2022. And a final rule (88 FR 10468) for amending the Formaldehyde Standards for Composite Wood Products was published on February 21, 2023.

The final rule, which became effective March 23, 2023, contains several important changes to the Act – including:

TPCs can now utilize external evaluation resources to complete the certification process, such as contracted inspection. However, evaluation activities should only be outsourced to competent (normally accredited) facilities – used and managed in a way that provides confidence in the results, as well as records that support that confidence.

When unsafe conditions prevent TPCs from physically visiting the area, remote inspections may be conducted. A government entity must certify that unsafe conditions were identified during the inspection by the TPC. For example, the COVID-19 global pandemic prevented some TPCs from visiting composite wood product manufacturing facilities to conduct on-site inspections and sample collection. So EPA provided its interpretation of its regulation – allowing TPCs and composite wood product manufacturing panel producers to conduct the required quarterly inspections and sample collection via teleconference.

Ten voluntary consensus standards have been updated to reflect the editions currently in use by regulated entities and industry stakeholders. The purpose is to ensure that standards are in line with industry requirements and better align with CARB requirements.

This update also clarifies timing of panel tests after production, corrections to equivalency determinations, and data requirements for no-added formaldehyde-based resins and ultra-low-emitting formaldehyde resins.

Who is Affected?

Manufacturers, importers, sellers, suppliers, and/or providers of hardwood plywood, medium-density fiberboard, particleboard, and/or products containing composite wood materials are affected by this final rule. Those who test or work with companies that certify such materials may also be affected by this final rule.

Note: The August 2020 edition of HETI Horizons, entitled “Regulating Formaldehyde In Wood Products”, discussed what is formaldehyde, formaldehyde exposure, and the key steps to minimizing exposures. Please see our website or request a copy from

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EPA’s Formaldehyde Emission For Composite Wood Products available at:

CFR PART 770 – Formaldehyde Standards For Composite Wood Products available at: