Key takeaways
- Any MDF, particleboard or hardwood plywood in a piece of furniture must come from a mill certified by an EPA-recognized third-party certifier (TPC).
- Panels carry a label with the producer, lot number, TPC number and “TSCA Title VI certified”; finished goods or their boxes say “TSCA Title VI compliant” with the fabricator's name and month and year of production.
- US importers keep supplier compliance statements and traceability records for three years and certify TSCA compliance at import.
- CARB's rule is still in force in California. It accepts the TSCA Title VI label, and where the two differ the stricter rule applies there.
- An inspection checks labels, mill certificates and panel traceability; emission tests are done by labs under certifier supervision.
Which products are covered
TSCA Title VI is the federal Formaldehyde Standards for Composite Wood Products Act, put into effect by the US Environmental Protection Agency (EPA) as 40 CFR 770. It covers composite wood products whether they are sold as panels, used in component parts or built into finished goods, and whether they are made in the US or imported.
| Covered | Not covered |
|---|---|
| Hardwood plywood with a veneer or composite core, for interior use | Solid wood and finger-jointed lumber |
| Medium-density fiberboard (MDF), including thin MDF of 8 mm or less | Hardboard, oriented strand board, structural plywood and structural panels |
| Particleboard | Glued laminated lumber, structural composite lumber and wood I-joists |
| Laminated products: a wood veneer fixed to a particleboard, MDF or veneer core (for example a veneered tabletop) | Wood packaging such as pallets and crates |
| Any finished good containing these, such as cabinets, desks, tables and beds | Antiques and second-hand furniture already sold to an end user |
Emission limits and certification
| Product | Limit (ppm formaldehyde) |
|---|---|
| Hardwood plywood, veneer or composite core | 0.05 |
| Particleboard | 0.09 |
| MDF | 0.11 |
| Thin MDF (8 mm or less) | 0.13 |
The limits apply to the panel, but compliance is shown through certification, not by testing each sofa or cabinet. A panel producer applies to an EPA TSCA Title VI third-party certifier (TPC). The TPC supervises emission tests, inspects the mill every quarter and checks the mill's own quality-control tests. Only certified panels may be sold or imported, whether loose or inside finished goods.
Panels made with no-added formaldehyde (NAF) or ultra low-emitting formaldehyde (ULEF) resins can get reduced testing, but they must still meet the rules and be labeled.
Key dates:
- 1 June 2018. Emission standards, certification and labelling apply to products made or imported from this date.
- 22 March 2019. Importers must comply with the TSCA import certification rules at 19 CFR 12.118 to 12.127, and the transition for CARB-approved certifiers ended.
- 22 March 2024. Factories that make laminated products must meet the rules for hardwood plywood producers, unless the product qualifies for an exemption.
Labelling and records
| Item | Label must show |
|---|---|
| Panels or bundles of panels | Panel producer's name (or producer number), lot number, the EPA TSCA Title VI TPC number and a statement that the products are TSCA Title VI certified. Unlabeled single panels need a method, such as color-coded edge marking, that links them to the label. |
| Finished goods, or every box or bundle of them | In legible English: the fabricator's name, the production date (month/year) and a statement that the goods are TSCA Title VI compliant. A downstream importer or retailer's name may replace the fabricator's with written consent. |
Finished goods whose composite wood content is no more than 144 square inches on the largest face do not need a label under TSCA, though the wood must still comply. California's CARB rule has no such exception: every finished good must be labeled.
Importer records. For three years, importers must keep bills of lading, invoices or similar documents with the supplier's written statement that the goods are TSCA Title VI compliant. They must also be able to give EPA, within 30 days, records naming the panel producer and production date, and the supplier and purchase date.
CARB. California's Airborne Toxic Control Measure (17 CCR 93120 to 93120.12) has required Phase 2 products since January 2014 and remains in force. CARB accepts panels and finished goods labeled TSCA Title VI compliant, and for goods sold in California the stricter of the two rules applies.
What this means for furniture made in India
Composite wood is not limited to panel furniture. MDF and particleboard carcasses are the obvious case, but solid sheesham, mango or acacia pieces can also have plywood or MDF backs, drawer bottoms, shelves or tabletop cores. Any of these makes the piece a finished good under TSCA Title VI.
- Certified panel supply. Each board must come from a mill certified by an EPA-recognized TPC, whether the mill is in India or abroad. Board bought from a trader without labels or lot numbers cannot be traced to a certified mill.
- Substitution. A factory that runs short can buy local board to finish an order. It looks the same once painted or veneered, so the records are the only proof.
- In-house veneering. A workshop that presses wood veneer onto MDF or particleboard makes laminated products. Since 22 March 2024 it must meet hardwood plywood producer rules, unless it uses a certified core with a phenol-formaldehyde or no-added formaldehyde resin and keeps records to prove it. These laminated product rules cover wood veneer, not synthetic laminates.
- Finished goods labels. The factory, as fabricator, must label each piece or carton before shipment. Agree the wording and placement with your supplier in the purchase order.
What inspection can check, and what needs a lab
| An inspector at the factory can check | Needs lab testing |
|---|---|
| Finished goods or cartons carry the TSCA Title VI compliant label with fabricator name and month/year | The formaldehyde emission level of a panel, measured to ASTM E1333 or ASTM D6007 |
| Panels in the factory store carry labels or edge marks with producer, lot and TPC number | Whether board taken from finished furniture meets the limit, as a screening check |
| The mill's TPC certificate covers the panel type and thickness used, and the TPC appears on EPA's list of recognized certifiers | |
| Purchase invoices link the panel lots to your order, and the panel types in the bill of materials are the ones actually used |
A lab test on a finished piece can flag a problem, but it does not replace mill certification. Under TSCA Title VI, compliance rests on certified panels and the paper trail that links them to your goods.
How Clear To Load checks this in India
On a furniture inspection in India, the inspector can photograph panel labels in the factory store, compare panel lots with purchase invoices and the mill's certificate, and check the finished-goods label on sampled pieces and cartons. If you want a screening test, we pull and seal samples for an accredited lab of your choice through lab testing coordination.
The report arrives within 24 hours of the inspection and ends in a verdict: Cleared to load, Hold or Not cleared. An inspection does not certify compliance; that rests on the mill certification and your records. To add these checks to an order, book an inspection. For upholstered pieces, see also California TB 117-2013 and 16 CFR 1640.
Sources
- 40 CFR Part 770, Formaldehyde Standards for Composite Wood Products (eCFR)
- EPA: Formaldehyde Emission Standards for Composite Wood Products
- EPA: Recognized third-party certifiers under TSCA Title VI
- CARB: Composite Wood Products Program
- CARB: Comparison of CARB and U.S. EPA TSCA Title VI requirements (updated Jan 2024)