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Regulation to Reduce Formaldehyde Emissions

Composite Wood Products

If you are a manufacturer, an importer, a distributor or a retailer of any finished product containing manufactured wood, you should be aware that the Environmental Protection Agency’s rule regarding formaldehyde emissions is back on. While the new Administration had attempted to delay the program’s effective date, that effort was met with resistance and threats of legal challenges. While we at Legal Label will have more to say about this subject in coming weeks and months, you should be aware now that the new federal program will be imposing new emissions standards for hardwood plywood, medium-density fiberboard and particleboard as of December, 2017. Laminated wood components will not fall within the scope of the new rule for 7 years and, as of now, structural plywood is exempt as well.

Labels for finished products containing such manufactured wood will also be required as will vigorous record-keeping rules.
Notably, every company in the supply chain will bear the burden of record-keeping.
Legal label will be assist to your company with its new label obligation.
Finally, note that EPA and the State of California are working together to figure out how best to phase out the California program already in existence. As is usual in these situations, a transition period will most likely be provided, thereby easing the changes with product labels
While we have yet to see a lot of details about this new program, we do advise every affected company to now start working with its wood panel suppliers in an effort to anticipate the new requirements. Do not wait!
Stay tuned for further details.

EPA Final National Rule Issued

Does your company produce, or import, any products with manufactured wood components? (Think adjustable bases or furniture pieces among other products.) If so, then you should become familiar with the Environmental Protection Agency’s final rule regarding formaldehyde emissions associated with manufactured wood such as particle board, plywood and the like. New label obligations as well as compliance with emissions standards become effective in 2017, meaning that each company needs to carefully consult with its wood suppliers and assess very soon whether a redesign of its products is necessary. Moreover, record-keeping requirements will soon be imposed upon each company in the stream of commerce. CONTACT Ms. Mattiace for additional information at 1-877-481-0734.

U.S Senate Updates Legislation

Toxic Substances Control Act (TSCA)

The U.S. Housed passed a bill to update the TSCA, which governs the use of chemicals in consumer products, followed by the U.S. Senate unanimously passing the legislation, and will soon be sent to President Obama, whom is expected to sign this update into law.

This legislation includes a “grandfather” provision allowing state chemical laws or regulations that were already in place before 4/22/2016, (such as CA’s Prop 65) to remain in place. States will still be able to target specific chemicals, but the EPA will preempt any previous action that as occurred after 4/22/2016. Pending actions will need to wait for EPA review. This may take several years to be able to implement this new legislation. ISPA will be involved with this work and will provide updates. More from ISPA