On March 22, the TSCA Title VI import certification requirement that applies to composite wood products, component parts containing such composite wood products, and finished goods containing such composite wood products that are imported into the U.S. went into effect. Composite wood products are created by binding strands, particles, fibers, veneers, or boards of wood together with adhesives. There are three composite wood products regulated under the final rule:

  1. Hardwood Plywood
  2. Medium-Density Fiberboard (MDF, which includes thin-MDF)
  3. Particleboard

These composite wood products are commonly used in the manufacture of furniture, kitchen cabinets, flooring, picture frames and wooden children’s toys, among other products. 

On March 22, all composite wood panels manufactured in or imported into the United States must be TSCA Title VI compliant and the label on composite wood panels must include the panel producer’s name, lot number, an EPA-recognized TSCA Title VI Third-Party Certifier number, and a TSCA Title VI compliance statement. Prior to this date, the CARB ATCM Phase II label satisfied the requirement.

Similarly, the labels on finished goods imported into the United States must include the fabricator’s name, the date the finished good was produced (in month/year format), and a TSCA Title VI compliance statement.

The easiest way to check whether your product is subject to these regulations is to use our HTS lookup tool here. If the HTS is flagged as EP7, a positive certification statement is required. It cannot be disclaimed.

Among other things, EPA has instructed importers to do the following in recently published tips for the trade, found here:

  • Keep Records. Take reasonable precautions by retaining, for three years, bills of lading, invoices, or comparable documents that include a written statement from the supplier that the composite wood products (or component parts/finished goods) are TSCA Title VI compliant.
  • Provide Records on Request. When EPA requests, make available within 30 days records identifying (1) the panel producer and the date the composite wood products were produced; and (2) records identifying the supplier, if different, and the date the composite wood products (or component parts/finished goods) were purchased.

To determine if you need to file under this new requirement, you can contact the TSCA hotline at (202) 554-1404. The TSCA hotline office operates Monday through Friday from 8:30 am to 5:00 pm EST. You can also send an email to tsca-hotline@epa.gov.

The EPA has published a full FAQ here, where you can find the precise emission standards in parts per million (ppm).

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