Frequently Asked Questions
This page last reviewed May 11, 2015
I. Frequently Asked Questions (FAQs) Categories
(updated May 2015)A. Applicable Products
B. Emission Testing
G. No-added formaldehyde (NAF) and Ultra-low emitting formaldehyde (ULEF) products
H. Public Health
I. Resin Chemistry
J. Third Party Certification (TPC)
(HWPW = hardwood plywood; HWPW-VC = hardwood plywood veneer core; HWPW-CC = hardwood plywood composite core; PB = particleboard; MDF = medium density fiberboard)
II. Questions and Responses
A. Applicable Products
1. What composite wood products are subject to the Composite Wood Products Airborne Toxic Control Measure (ATCM)? The ATCM establishes formaldehyde emission standards for panels of HWPW-VC, HWPW-CC, PB, MDF, and thin MDF (≤ 8 mm). The ATCM requires that finished goods and laminated products made with the materials subject to the formaldehyde emission standards, that are sold, offered for sale, supplied, used, or manufactured for sale in California, be made with materials that comply with applicable emission standards (e.g., Phase 2).
2. What specific products are not covered by the ATCM? Materials that are not covered by the ATCM include, but are not limited to hardboard, natural wood, and certified structural plywood, certified structural panels, structural composite lumber, oriented strand board, glue laminated timber, prefabricated wood I-joist, finger jointed lumber, cellulosic fiber insulating board or “composite wood products” used inside of new vehicles, rail cars, boats, aerospace craft or aircraft (please also refer to question #24).
3. What are examples of finished goods? Finished goods mean any good or product other than a panel, containing HWPW-VC, HWPW-CC, PB, MDF, or thin MDF. Finished goods include, but are not limited to furniture, cabinets, shelving, countertops, flooring, moldings, caskets, base boards, rosettes, corbels, etc.
4. Who is subject to the ATCM? The ATCM applies to manufacturers, distributors, importers, fabricators, and retailers of the products identified in question 1, as well as third party certifiers of panel manufacturers.
5. Does the ATCM apply to block board? No. While block board is considered a type of HWPW, emission standards were only established for HWPW-VC and HWPW-CC. Block board is made with a core made of solid wood strips, not veneer core or composite core.
6. Are molded products, such as toilet seats, subject to the regulation? If the products (toilet seats) are compression molded, meaning that flat panel products (such as MDF, PB, or HWPW) are not used in manufacturing of these products, then the product is exempt from the regulation.
6A. If a company that produces molded toilet seats wants to have their product tested by a CARB-approved third party certifier (TPC) for formaldehyde emissions, should these products be labeled to let consumers know that the product is compliant? There are no prohibitions on a company voluntarily having a CARB approved TPC test a product for formaldehyde emissions. However, these products should not be labeled as CARB compliant and they should not include a statement of CARB compliance on their label because they are not subject to the regulation. Nevertheless, they could use labels that indicate the product is “low formaldehyde” or some other terminology that does not refer to the CARB regulatory requirements.
7. Are chair backs and seats made by molding wood flour and resin into the desired shape considered particleboard and do they require emission testing? No, such products would not be considered to be a composite wood product under the ATCM.
8. Does the ATCM apply to low-density fiberboard (LDF) or high density fiberboard (HDF)? Yes, depending on how they are marketed and used and if they meet the ANSI standard for MDF. The ATCM applies to MDF that meets the ANSI standard for MDF, A208.2-2002. Because the ANSI standard for MDF is based on performance and is independent of density, some products marketed as LDF and HDF are also subject to the ATCM. Products that are labeled as LDF or HDF, meet the ANSI A208.2-2002 standard and are marketed for use in typical MDF applications such as furniture manufacturing, shelving, molding, and kitchen cabinets, would be subject to the ATCM.
9. Does the ATCM apply to insulating fiberboard or cellulosic fiber insulating board? No. Cellulosic fiber insulating board or insulating fiberboard made to the specifications in ASTM C208-08a include sound deadening board, roof insulation board, ceiling tiles and panels, wall sheathing, backer board and roof deck. These products are not made with synthetic (such as formaldehyde-based) resins and do not meet the definition of HWPW-VC, HWPW-CC, MDF or particle board which are subject to the emission standards in the ATCM.
10. The regulation is applicable to hardwood plywood. However, what if the plywood is made with a softwood like spruce? Is it then exempt? The ANSI/HPVA HP-1-2004 standards that apply to HWPW allow for the use of hardwood or decorative softwood face veneers. Hence, if softwood is used as the face veneer, the HWPW would be subject to the ATCM (please also refer to question #11).
11. A plywood product is made with phenol formaldehyde (PF) resin and softwood face veneers. It meets the specifications for PS 1-09 structural plywood and is labeled as such. The product is used as paneling and wainscoting in both interior and exterior applications. Is it exempt from the ATCM? The product would be exempt if it is certified to PS-1 (Voluntary Product Standard for Structural Plywood). If the product is not certified to PS-1, it would need to be third party certified to meet the
Phase 2 emission standard for hardwood plywood.
12. Are decorative wood pieces (such as corbels, moldings, rosettes, transition blocks, etc.) subject to the regulation? Decorative wood pieces made out of solid wood are not subject to the regulation. However, if these decorative wood pieces (such as corbels, moldings, rosettes, transition blocks, etc.) are made out of products that contain HWPW-VC, HWPW-CC, PB, or MDF, then these goods would be subject to the regulation as a finished good.
13. Is wood packaging (e.g., pallets, crates) subject to the ATCM? No. While wood packaging may contain composite wood products (i.e., HWPW, MDF, or PB), and be considered “finished goods” subject to the ATCM; it was not CARB’s intent to regulate wood packaging as “finished goods.” By “wood packaging” we mean pallets, skids, boxes, crates, reels, spools and containers used for handling, sorting, storing, shipping, and transporting goods.
14. Does the ATCM apply to molded pallet blocks? No. Molded pallet blocks that are made in individual molds (i.e., not cut from a flat panel) and made specifically as molded pallet components are not subject to the emission standards for HWPW, MDF, or PB in the ATCM (also see question #13 regarding pallets).
15. Is packing material or “dunnage” subject to the ATCM? No. Packing material, also referred to as “dunnage” is essentially loose, waste material such as composite wood products that are used for packaging or covering shipments in order to protect cargo from damage during transport. Dunnage is not considered to be a finished good and is not subject to the ATCM.
16. Does the ATCM apply to rental items such as rental furniture? Furniture that is rented prior to the effective dates of the emission standards is exempt, because such furniture is considered to be “used goods,” which are exempt from the definition of finished goods. At the end of the rental period, the furniture may be sold as used furniture. However, if a furniture rental company purchases new furniture after the effective dates of the emission standards, for purpose of renting that furniture in California, the new furniture must be made with materials that comply with applicable emission standards.
17. My company supplies just a few products that contain a very small amount of composite wood products to California retail stores. Would CARB take size, volume or quantity of composite wood products used for finished goods into account? The regulation does not allow exemptions for de minimus use of the regulated products in finished goods. The regulation applies to all products, (e.g., picture frames, plaques, toys, etc.) containing HWPW, PB, or MDF, and there is no minimum amount that is exempt. However, the ATCM does include de minimus use exemptions for windows and doors only, see Section 93120.7 (b)(1).
18. Does the ATCM apply to curved or bent plywood? Curved plywood is excluded from the definition of HWPW and is not subject to the ATCM.
19. Does the ATCM apply to bamboo flooring? Flooring consisting solely of bamboo veneers is not subject to the ATCM. The definition of HWPW in the ATCM specifies the use of hardwood or decorative softwood face veneers. Since bamboo is a grass, plywood made using bamboo face veneers is exempt from the regulation at this time. Flooring that consists of a veneer of bamboo laminated to a platform would be considered to be a laminated product under the ATCM. In this case, if the platform is a composite wood product subject to emission standards for HWPW, PB, or MDF, the platform must comply with the ATCM. Flooring that consists of a bamboo veneer laminated to a lumber-core platform is not subject to the regulation as the platform it does not meet the definition for either HWPW-VC or HWPW-CC (please also see question #21).
19A. What if bamboo is used in a flooring product, as bamboo fibers for PB or MDF panels? Bamboo particles or fibers used to make PB or MDF falls into the definition of cellulosic materials used to make these products. Therefore, bamboo PB and bamboo MDF are required to be third party certified.
20. If I am a retail store owner and I acquire displays to be used by me and not sold to the public, do the displays need to be made from CARB certified composite wood products? Yes. Displays containing composite wood products are finished goods and must meet the requirements for finished goods. All displays (finished goods) sold/supplied into California must meet the ATCM requirements.
Note: Fabricators that are selling and/or supplying finished goods for display purposes to a downstream client, (even though these items are not intended for resale by that downstream client) are required to made with materials that are compliant with applicable emission standards and a statement of compliance must be provided on the bill of lading or invoice for products intended for sale or supply to California. Fabricators fall under the applicability provision in the ATCM § 93120 (c) (4) available at: http://www.arb.ca.gov/regact/2007/compwood07/fro-final.pdf.
21. Are lumber core products subject to the regulation? No. HWPW with a lumber-core is exempt from the regulation. The ATCM has two HWPW standards, neither of which includes lumber-core: one for HWPW-VC and one for HWPW-CC. HWPW-VC does not have a lumber-core (made of wood strips), and HWPW-CC is defined in the regulation as being made with a PB, MDF, or PB or MDF in combination with veneer (combination core).
22. How are warranty stocks (also known as replacement parts) considered under the regulation? Existing stocks* of replacement parts may be sold indefinitely. No labeling is required on such parts. After the applicable sell-through periods have ended, then any new replacement parts must be made of complying materials.
Replacement parts, as well as components parts that are sold and/or supplied as individual items (e.g., in a situation where a consumer is buying a replacement part such as a cabinet door), are subject to labeling requirements.
If component parts and/or warranty stocks that are supplied to a fabricator (e.g., from a fabricator of component parts) and will be used in a finished good, component parts do not need to be labeled, but the invoices or bills of lading must include the statement of compliance to indicate that the shipment of components parts or replacement parts are made of complying composite wood products.
*Existing stocks include pre-Phase 1 and Phase 1 products; however, the sell-through provision for replacement parts/warranty stocks will be subject to change and further clarified via the amendment process of the ATCM.
23. Is MDF made by a “wet-forming” process subject to the ATCM? No. MDF mats can be manufactured by either wet or dry forming processes. In “wet-forming,” the fibers are carried in a water suspension and the product is often made without an adhesive. In “dry forming,” the fibers are transported by air and a resin is added to form the fiber mat. The ATCM defines MDF as “… panels composed of cellulosic fibers made by dry forming and pressing of a resinated fiber mat (ANSI A 208.2-2002).” As MDF panels made by “wet-forming” are not specified in the ATCM, they are not subject to the requirements of the ATCM.
24. The ATCM excludes certain types of structural plywood from the definition of composite wood products, namely those meeting the Voluntary Product Standards for Structural Plywood (PS 1) and Wood-based Structural-use Panels (PS 2). Are other types of structural plywood, such as those made to comply with standards other than PS 1 or PS 2, also excluded from the definition of composite wood products? CARB excluded structural plywood products that conform to the PS 1 or PS 2 standards that are used for a variety of structural applications in North America. PS 1 and PS 2 structural plywood were excluded from the definition of composite wood products in the ATCM for reasons of public safety and also because they are made to be exterior grade products. To provide the water resistance necessary for exterior applications, structural plywood is made with low-emitting formaldehyde resins, such as phenol formaldehyde (PF) resin, as opposed to interior-grade industrial panels typically made with urea-formaldehyde (UF) resins. We recognize that “structural plywood” is made in other parts of the world to meet standards other than PS 1 or PS 2. In cases where we are able to identify products with structural and resin properties equivalent to certified PS 1 or PS 2 structural plywood, they will also be exempt from the requirements of the ATCM.
Product standards for composite wood panels in countries outside of the U.S. in some cases do not clearly differentiate between panels made for structural vs. nonstructural applications. For example, structural plywood standards vary around the world, owing to differences in region-specific building codes, market needs, and manufacturing methods. In North America, structural plywood is commonly used for building structures, while in other countries clear distinctions are not made with respect to structural plywood for interior vs. exterior applications. Typically, exterior grade products that meet the PS 1 or PS 2 standards are made using PF or polymeric methylene diphenyl diisocyanate (pMDI) adhesives to comply with prescribed bond durability requirements that products made for interior applications cannot meet.
While standards in other countries are not directly comparable with the requirements specified for North American PS 1 and PS 2 structural plywood, we believe that products that are equivalent to PS 1 or PS 2 structural plywood, and certified as such, should also be exempt from the requirements of the ATCM. At this time, staff has determined that structural plywood that is certified to the following standards is not subject to the formaldehyde emission standards:
- Australian “AS/NZS 2269”
- European “EN 636 3S” (including CE label)
- Canadian CSA (Canadian Standards Association) “CSA O121” Douglas fir plywood, “CSA O151” Canadian softwood plywood, “CSA O153” Poplar plywood, and “CSAO325” Construction sheathing
The exemption applies only to products that are marked as compliant with those standards specified above, so as to clearly distinguish them as exempt products for purposes of the ATCM. (For the list of structural panels exempt from the ATCM, please refer to question #2).
25. Would structural plywood that is a “downfall” (products that do not meet all the required properties of PS1 or PS2 structural plywood) be exempt from the ATCM? No, structural plywood “downfall” is not exempt from the requirements of the ATCM. From a formaldehyde emissions standpoint, it is likely that downfall is also a low-emitting product, but from an enforcement perspective, the sale and supply of uncertified and unmarked structural plywood products to California creates an unenforceable situation since downfall products are not labeled and unverifiable. As a side note, downfall products may be used for packaging applications (e.g., for use in making pallets, crates, boxes, etc.) which are not subject to the requirements of the ATCM (please see question #13).
26. Does the ATCM apply to LVL (Laminated Veneer Lumber)? No. The Structural Composite Lumber products (ANSI A. 190.1 Structural Glued Laminated Timber), standard includes LVL products which are exempt from the composite wood products ATCM.
27. Does a veneer core platform affixed to a laminate that is composed of a thin MDF fall under the regulation? If a product has HWPW-VC as a platform with thin MDF affixed to the face and back, then this product is considered to be a laminated product under the regulation. This laminated product, made with third party certified composite wood products (the HWPW-VC platform and thin MDF laminates) does not need to be tested by a CARB-approved third party certifier to be compliant. Hence, the company that affixes the thin MDF to the HWPW-VC platform is a fabricator of a laminated product, and not a panel manufacturer.
B. Emission Testing
28. Who is required to emission test their products? Manufacturers of HWPW-VC, HWPW-CC, PB, MDF, and thin MDF are required to conduct emission testing of their products. The objective of the emission testing is to verify that the composite wood products produced comply with the emission standards on an on-going basis, to ensure the accuracy of production control and to ensure that low-emitting products are sold in California. Fabricators of finished goods are not subject to third party certification requirements and do not have to emission test their finished goods or laminated products to verify compliance with the ATCM.
29. Why does CARB test composite wood products in finished goods? The ATCM requires that composite wood products (e.g., hardwood plywood, particleboard, and medium density fiberboard) contained in finished goods (e.g., flooring, furniture, and cabinets) comply with the formaldehyde emission standards. To verify compliance, CARB tests emissions of composite wood products as well as the emissions of such products contained in finished goods.
30. How does CARB test emissions of composite wood products in finished goods? CARB uses ASTM D 6007-02 - Standard Test Method for Determining Formaldehyde Concentration in Air from Wood Products Using a Small Scale Chamber, specified in section 93120.9(c) of the ATCM, to verify that composite wood products contained in finished goods comply with the emission standards.
Pieces of composite wood products contained in finished goods (e.g., laminate flooring that consists of a laminate affixed to a medium density fiberboard core material, or a cabinet door that consists of particleboard with melamine laminate affixed to the face and back of the door) are prepared to expose the composite wood product for emissions testing. CARB’s sample preparation procedures are documented in: “Standard Operating Procedure for Finished Good Test Specimen Preparation Prior to Analysis of Formaldehyde Emissions from Composite Wood Products,” which can be found at the following link: http://www.arb.ca.gov/toxics/compwood/outreach/compwood_sop_fg_decon_091313.pdf
There is some variability and uncertainty associated with sample preparation and emissions testing. This is not unique to testing of composite wood products. CARB staff accounts for this when considering whether or not enforcement action should be taken.
31. Are fabricators or retailers of finished goods required to conduct testing? No. Some companies have chosen to periodically test composite wood products from their suppliers. The ATCM requires fabricators of finished goods to use compliant composite wood material in their finished goods; to label their finished goods or boxes containing finished goods; and to provide documentation (i.e., invoices or bills of lading) with a statement of compliance to their customers. The ATCM also requires fabricators and retailers to keep records to document the steps they have taken to ensure that the goods that they make or sell comply with the ATCM. Fabricators and retailers are in violation of the regulation if they sell products that violate the emission standards.
32. What defines a reasonable correlation between a manufacturer’s quality control data and a third party certifier’s compliance testing data? Third party certifiers are required to establish a correlation (i.e., linear regression equation) between a manufacturers’ routine quality control testing data and their third party certifier’s primary or secondary test method data. All correlations must be based on a minimum of five data pairs. CARB relies on third party certifiers to establish reliable correlations to ensure on-going compliance of composite wood products offered for sale and supply to California.
33. Will CARB supply correlations for small-chamber-to-large-chamber and desiccator-to-large-chamber? No. The correlations will be calculated for manufacturers of composite wood products based on the primary or secondary test method data received from their third party certifier (see FAQ section J), under the requirements established by CARB.
34. The Dynamic Microchamber (DMC) is used extensively in the composite wood industry. Will it be CARB approved using the InterScan sensor? The dynamic Microchamber (DMC) and the new GP™ DMC are both approved for use as alternate small scale test methods for conducting formaldehyde emission testing for composite wood products. For further information, please refer to the following link at: http://www.arb.ca.gov/toxics/compwood/outreach/testmethods.htm.
34. The Dynamic Microchamber (DMC) is used extensively in the composite wood industry. Will it be CARB approved using the InterScan sensor? The dynamic Microchamber (DMC) and the new GP™ DMC are both approved for use as alternate small scale test methods for conducting formaldehyde emission testing for composite wood products. For further information, please refer to the following link at: http://www.arb.ca.gov/toxics/compwood/outreach/testmethods.htm.
35. What would constitute an acceptable demonstration of compliance for a manufacturer of a very low emitting product? The ATCM contains special provisions for CARB-certified manufacturers that produce composite wood products with very low formaldehyde emissions. The special provisions are provided for composite wood products made with no-added formaldehyde (NAF) or ultra-low emitting formaldehyde (ULEF) resins. To receive CARB approval as a NAF or ULEF product manufacturer, applicants are required to submit three months of quality control test data for NAF products and six months for ULEF products, along with primary or secondary method test data provided by their third party certifier. Upon CARB approval, NAF and some ULEF products are exempt from on-going testing for two years; other ULEF products may be granted a reduction in frequency for on-going quality control testing for two years. Please refer to the following link for additional information concerning the NAF/ULEF requirements: http://www.arb.ca.gov/toxics/compwood/naf_ulef/naf_ulefapp.pdf (Attachment A).
36. Can testing of finished furniture products conducted for non-CARB formaldehyde emission standards be considered reasonable prudent precautions under the rule? No. Testing of furniture products for compliance with non-CARB emission standards (e.g., European formaldehyde standards) would not constitute reasonable prudent precautions. A finished good could be made with non-complying composite wood, but due to the application of a laminate or a coating, may be able to pass the non-CARB emission standard. Under the rule, only actions taken to ensure that compliant composite wood products were used to make the furniture being offered for sale or supply to California would be considered to be reasonable prudent precaution.
37. Can a manufacturer use a small emissions chamber (ASTM D 6007) as a routine quality control test method? Yes, but a small chamber test data needs to be correlated to paired primary or secondary test method collected by their third party certifier. Manufacturers may deem a small emissions chamber as equivalent to a primary method (section 93120.9), but their data cannot be used as a demonstration of product compliance in their quarterly tests for certification purposes. Quarterly tests for purposes of certification must be conducted by their third party certifier.
38. What is the difference between primary testing, secondary testing, and the quality control testing conducted by a manufacturer? Manufacturers of composite wood products are required to conduct small scale quality control testing of their products at the manufacturing plant to ensure that their panels do not exceed applicable emission standards. Appendix 2 of the ATCM states that manufacturers have three options for conducting quality control testing: a desiccator (ASTM D 5582-00), a small chamber (ASTM D 6007-02), or an alternative small scale test that can be shown to correlate to the primary or secondary test methods. The primary and secondary test methods are used by third party certifiers to verify compliance of manufacturers with applicable emission standards. Certifiers work with manufacturers to establish correlations between the manufacturer’s small scale quality control tests and the primary or secondary method tests. Certifiers have the option of using either the primary or the secondary method. The primary method is defined as the large chamber test method (ASTM E-1333-96(2002)). The secondary test method consists of operating a small emissions chamber (ASTM D 6007-02) that has been deemed equivalent to a large chamber following the procedures specified in the ATCM.
39. For hardwood plywood with a composite core (HWPW-CC), does the core need to be tested and certified as complying with the applicable emission standard? Unless the core is being offered for sale separately, it does not need to be tested. Only the HWPW-CC needs to be tested and certified as complying. However, if the HWPW-CC is being sold as having been made with no-added formaldehyde (NAF) resins, the NAF designation applies to the entire composite wood product (the core and the resins used to affix the veneers) and in that case the core would need to be tested as part of the NAF product demonstration.
40. How does CARB enforce the composite wood products ATCM? CARB’s approach to enforcing the composite wood products ATCM is consistent with our approach to enforcing all of our regulations. CARB conducts inspections at various points in the product distribution chain from manufacturers to retailers. Inspections may include review of products for compliance with labeling requirements, review of documentation, and/or collection of samples for emissions testing. Additional investigation may result from an initial inspection. Other enforcement activity may include requests for documents and use of other investigative tools. Enforcement options include administrative, civil, and/or criminal penalties.
41. When enforcing the regulations, will CARB require the retailer to produce chain-of-custody documents even if product emissions are compliant? Would this be a punishable violation of regulations? Yes. Recordkeeping is an important part of the ATCM. In the course of inspecting a retailer, we can ask to see the chain-of-custody documents that verify the emission characteristics of the products being offered for sale.
42. In what form and how long are records required to be kept? Records must be kept in electronic or hard copy form for a minimum of two years and provided to CARB or local air district personnel upon request.
43. How will CARB police wood products sold into California via the Internet? CARB's enforcement staff will purchase products from Internet retailers and if through enforcement testing the product is found to be noncompliant, CARB will track the paper trail for the noncompliant product back through the distribution chain (e.g., manufacturers, distributors, importers, or fabricators) to determine who is in violation of the ATCM.
44. How will CARB enforce composite wood products that are produced overseas? In the case of noncompliant products being imported from overseas, it is likely that in most cases the importer will ultimately be held responsible as they are bringing the goods into California. However, importers, as well as distributors, retailers, fabricators, or manufacturers can all be held responsible for the products that they sell or supply in California. Parties bringing composite wood products into California are responsible for knowing and following the law. In the event of a violation of the emission standards, everyone from the board manufacturer to the retailer and all parties in between are potentially liable until the enforcement investigation determines otherwise. There is no product certification or chain of custody that insulates anyone from an enforcement action. CARB enforcement staff will evaluate each situation on a case by case basis.
45A. Will an importer who happens to be a good faith purchaser, obtaining all the required documentation be at more fault than a distributor who purchases from a domestic mill? No. Any party bringing noncompliant goods into California is subject to enforcement action by CARB. Importers of noncompliant foreign goods are equally liable as distributors of noncompliant domestic products.
45B. Does it matter if the importer is importing raw board or a finished product (furniture)? All composite wood products, including raw boards and finished goods containing composite wood products, are required to comply with the ATCM and will be equally enforced.
46. In order to be best prepared for a potential inspection, what type of information should fabricators and retailers have available for CARB enforcement staff? With regard to potential inspections, fabricators and retailers need to keep records to show they’ve taken “reasonable prudent precautions” to ensure compliance. These records need to be kept in hard copy or electronic form and must show that the fabricators and retailers instructed their suppliers of the need for complying products. The fabricators and retailers must also keep records to show that their suppliers have
stated that the products being provided comply with the formaldehyde emission standards.
47. How will CARB test pre-assembled case goods made of composite wood products (e.g., a small table) that are painted, with no edges unsealed? CARB will purchase case goods, deconstruct them, remove the paint, and test the exposed composite wood product surface using our enforcement test method. CARB staff has developed the sample preparation protocol to be followed to remove the layer of paint or laminate, and then will determine if the composite wood product in the case good complies with applicable standards or not.
48. We make furniture using structural plywood, which is not visible in the finished furniture. What records do we need to keep to demonstrate that we are not using regulated composite wood products (PB, MDF, HWPW)? Structural plywood that meets either the NIST (National Institute of Standards and Technology) PS 1-07 or PS 2-04 standard is excluded from the definition of composite wood products in the ATCM, and no records are required to be kept by the ATCM. However, fabricators would be advised to keep invoices to show that the composite wood they use is structural plywood and not HWPW (for more information concerning structural plywood, please refer to question #24).
49. Are manufactured homes or mobile homes subject to the ATCM? The ATCM does not apply to HWPW or PB manufactured, sold, supplied for installation, or installed in manufactured homes subject to the United States Department of Housing and Urban Development (HUD) regulations. However, the ATCM does apply to any MDF or thin MDF products installed in manufactured homes designated for sale in California.
50. Military is exempt. What about federal government institutions such as UNICOR that manufactures furniture for government offices and the military? Military specified plywood is exempt from the ATCM. If UNICOR is manufacturing furniture for government offices, they would be considered a fabricator under the ATCM for products sold to California and must comply with the regulation.
51. The ATCM includes an exemption for windows. Does the exemption include bay windows? Yes. Requirements for fabricators include an exemption for windows if the window product contains less than five percent by volume of HWPW, PB, or MDF combined, in relation to the total volume of the finished window product. The definition of a window specifies that a frame includes jambs, stiles, sashes, and rails, and excludes sills, window headers and window seats. Because sills, window headers, and window seats are excluded from the definition of a frame, they cannot be factored into the exemption. Therefore, if sills, window headers, and window seats contain composite wood, the composite wood must comply with the ATCM and the finished window product must be labeled appropriately.
52. Other than windows, what other exemptions does the ATCM contain? Exemptions have also been provided for exterior doors and garage doors if these products contain less than three percent by volume of HWPW, PB, or MDF combined, in relation to the total volume of the finished door product made from composite wood products. The ATCM does not apply to finished goods sold outside of California or to products subject to federal requirements governing the construction of manufactured homes (please refer to question #2).
53. Will CARB accept European E0 or E1 boards as meeting the Phase 2 standard? No. While CARB’s Phase 2 standards are comparable to some E0 and E1 emission levels, differences in the test methods and the amount of in-plant quality assurance testing done in Europe varies considerably from CARB’s requirements. Even if boards meet the E1 standard, the mills producing those boards would need to be certified by an independent, CARB-approved third party certifier and have test data to show that it also meets the CARB Phase 2 standard using the primary or secondary test method, if they are offered for sale in California as panels or in finished goods. During the implementation of the Phase 2 standards, composite wood products are required to have emission levels well below E1 to be acceptable for sale in California.
54. In some upholstered products, the frame is cut from plywood, but the products are covered in material. How should such products be labeled as compliant finished goods? It is up to the fabricator to decide how to label the upholstered product - the label (e.g., tag and statement on the invoice) could be affixed with a staple and must clearly state that the product is legal for sale in California.
55. Is labeling the packaging on bulk products permitted? For example, can a single label be attached to the outer packaging material of a skid of work surfaces? The ATCM requires that a label shall be applied on “every finished good produced, or on every box containing finished goods.” One label on the box will comply with the ATCM; however, we strongly recommend that both the box and finished good be labeled.
56. Can the label identifying the manufacturer’s name and the date of manufacture be a separate label from the label that states that the product was made with Phase 2 compliant hardwood plywood, particleboard, and/or medium density fiberboard? Separate labels can be used to identify fabricator name, production date, and that the finished good was made with complying composite wood products, as long as the labels are all visible (e.g., inside a cabinet door or on the back of a credenza).
57. If an unboxed or blanket-wrapped chair, desk, and shelving unit were packed on a single skid, would a single label still apply? If three different finished goods were all packed on a single skid, each would need a separate label. (Each product might contain different compliant materials.)
58. What is the expectation for labeling if the finished product contains components from various board manufacturers? Hypothetically, an order for 10,000 bookcases involves 3 mills and 5 dates of board manufacture (i.e., production). What level of traceability is acceptable? Is it sufficient to list the mills that provide board product for any of those 10,000 bookcases? The label for finished goods only require the fabricator name, production date, and a marking or brief statement to denote that the product complies with the applicable Phase 2 emission standard in section 93120.2 (a) (or that the composite wood products in the finished good were made with no-added formaldehyde (NAF) or ultra-low emitting formaldehyde (ULEF) resins. The fabricator label does not need to include the name of the panel manufacturer. The fabricator needs to keep records of panel purchases to demonstrate that all composite wood products used in the finished good comply with the ATCM. Records on the amount of composite wood used to make finished goods would need to reasonably match the amount of complying composite wood purchased from composite wood product mills.
59. When can a manufacturer of particleboard, hardwood plywood, and medium density fiberboard officially designate their composite wood products as CARB-compliant (or refer to their low-emitting products) on their boards? Manufacturers cannot officially label their products as CARB-compliant, or refer to their product as low-emitting, until they have been approved to do so by a CARB-approved third party certifier and, in the case of products made with NAF or ULEF resins, by the CARB Executive Officer.
60. Is there a “set label” that should be applied on finished goods labels? There is no set requirement or restriction on the label material in the regulation. The regulation requirements on labeling do not require the use of any logo. These provisions are contained in section 93120.7(d)(1), and require that the label include: the name of the fabricator, the date of production and a short statement to indicate Phase 2 emissions are being met in the finished good. For more information on labeling requirements, including example labels, please refer to our enforcement advisory regarding labeling, available at http://www.arb.ca.gov/toxics/compwood/outreach/advisories.htm.
61. We receive bundles of composite wood products such as hardwood plywood, which are broken down to several customers. What labeling requirements do we have? If a group of items are labeled and then divided and distributed separately, each separate item must be labeled with the same information as required on the original label. It would be acceptable if you take the label that was
affixed to the original bundle or shipping pallet, photocopy the label and affix one to each subset created.
62. A final finished product may be composed of numerous small pieces of wood, potentially from various vendors. How much detail is required to document the chain of custody? That is, can chain-of-custody be established for each batch of material used before the different pieces are combined into the final product? Or does each individual piece in each final product need a chain of custody? At a minimum, records must be kept documenting purchases of compliant composite wood products – HWPW, PB, and MDF Where different pieces are combined in a final product, fabricators should be able to demonstrate how many final products were made using the regulated materials, so a determination can be made if an appropriate supply of raw materials was purchased to make the reported amount of final product.
In the case where there are multiple suppliers of MDF, for example, records need to show that an appropriate amount of final goods were made from the amount of MDF purchased for use. It is important that the supplier(s) can be identified. For a given volume of finished goods, fabricators must be able to demonstrate the amount of MDF, etc. that was used, and records showing that enough compliant MDF was purchased to make the amount of final products that were sold.
63. Certain overseas mills are following California’s Proposition 65 and OSHA requirements for formaldehyde warnings on all products containing such. Does this also present additional issues with CARB enforcement? No, that is a separate issue from the composite wood products regulation. The regulation is clear as to how products containing Phase 2 compliant materials need to be labeled, and if there is no label, then we must assume that the product does not contain compliant materials.
64. Must the fabricator’s name be on the product or box, if traceability is apparent through use of visible batch code or other identification? Due to the nature of the import business, many importers and distributors avoid sharing their suppliers with potential competitors. The regulation requires that the fabricator’s name, and the date the finished good was produced, is applied as a stamp, tag, sticker, or bar code on every finished good produced, or on every box containing finished goods, provided that it is destined for sale or supply in California. The wood products industry often uses brand names or other means to conceal trade secrets such as which manufacturer or fabricator makes a certain product. In recognition of this, as an accepted practice, ARB will allow some flexibility in the labeling requirement for manufacturer or fabricator name. It is the intention of the ATCM that the name be included on the label to easily identify the party responsible for the formaldehyde emission characteristics of the board. It is acceptable for a distributor/importer to replace an original label with a label listing their company name as long as all other information required on the original label is retained. It should also be noted that if an importer or distributor replaces a label on a finished good, then they assume the liability for the finished good as a fabricator.
65. What labeling and notification language is acceptable for fabricators of finished goods containing composite wood products? The regulation requires fabricators to clearly label finished goods containing HWPW, PB or MDF. CARB strongly recommends labeling of both the finished good and the box the finished good is contained in. Labels must include, at a minimum, the following information:
a. fabricator’s name,
b. date the finished good was produced, and
c. a statement of compliance to denote that the composite wood product or finished good complies with the ATCM. Finished goods made with all NAF or all ULEF based resins shall be labeled as such.
The intent of the statement must be clear in indicating compliance with the ATCM and should refer to California, or CARB, and include section 93120. For example, a statement of compliance may read “California 93120 Compliant for Formaldehyde.”
- What labeling requirements apply if a finished good only contains NAF products? Products need to be labeled as “NAF” (example: “product was made with NAF resin”)
- What labeling requirements apply if a finished good only contains ULEF products? Products needs to be labeled as “ULEF” (example: “product was made with ULEF resin”)
- What labeling requirements apply if a finished good contains NAF and ULEF products? The label need to indicate that the product was made with “NAF and ULEF resin” (example: “product was made with NAF and ULEF resin”)
- What labeling requirements apply if a finished good contains NAF/ULEF and Phase 2 products? The label should indicate that the finished good contains products that were made with materials that meet Phase 2 emission standard and products containing NAF/ULEF resins (“product contains Phase 2 products and NAF/ULEF products)
fabricators label their finished goods as “CARB-exempt” if they use
products containing NAF/ULEF-based resin? No. NAF/ULEF products are not
exempt; rather they are subject to different requirements (exemption
from third party certification or reduced testing requirements) as
compared to Phase 1/Phase 2 products.
66. Do component parts need to be labeled? Components parts or replacement parts that are sold and/or supplied as individual items to anyone in commerce (individual finished goods, e.g., in a situation where a consumer is buying a replacement part such as a cabinet door or warranty replacement item) are subject to labeling requirements.
Component parts and/or replacement parts, that are supplied to a fabricator (e.g., from a fabricator of component parts), and will be used in a finished good, do not need to be labeled but the invoice or bill of lading must include the statement of compliance to indicate that the shipment of components parts or replacement parts are made of complying composite wood products.
G. No-added Formaldehyde (NAF) and Ultra-low Emitting Formaldehyde (ULEF) Products
67. I make a veneered raised panel door. If the MDF core meets the NAF/ULEF (no-added formaldehyde/ultra-low emitting formaldehyde) standard, but the splices in the veneer are glued with UF, will it still meet the NAF/ULEF standard? The "NAF" and “ULEF” designation applies only to manufactured HWPW-VC, HWPW-CC, PB, or MDF panels and not to finished goods, such as doors.
68. The CARB regulation will drive an increase in use of NAF adhesives. Some of these adhesives emit substances that are irritating, harmful, and/or hazardous to the human body. An example is free MDI radicals - what is being done to address concerns like this? The ATCM is based on emissions performance standards, which does not dictate resins to be used. We cannot predict whether the use of NAF adhesives will increase as a result of the regulation, given the technological advancements with low-emitting urea formaldehyde resins (ULEF). When a manufacturer applies to CARB for certification, we will review the chemical composition of the NAF resin to determine if it qualifies for a NAF designation, we may also seek additional information from the applicant to clarify our assessment of the candidate NAF composite wood product. Furthermore, manufacturing facilities may also be regulated as stationary sources of emissions. The use of a particular resin, such as MDI, may be regulated by the local or state agencies that issue permits to stationary sources or regulate occupational exposure to chemicals.
69. Would a phenolic-formaldehyde (PF) platform (for example PB or MDF core) overlaid with hardwood veneer with PVA glue be considered a NAF product? No. The NAF designation refers to HWPW-VC, HWPW-CC, PB, and MDF panels made entirely with a NAF adhesive (products made with PF resin are not qualified as NAF). However, such composite core plywood could be tested and would probably meet the emissions requirements to be considered a ULEF product.
70. Is there concern that manufactured products using NAF/ULEF adhesives will act as sponges for formaldehyde when stored next to manufactured products using UF adhesives (e.g., Big Box retail storage)? No. We will be able to determine if the NAF/ULEF products were made with the proper resins, and if the retailer has the proper documentation on-site for both the NAF and ULEF products they offer for sale. In addition, the sample preparation conditioning requirements of ASTM D 6007-02 (small chamber) and ASTM E 1333-96(2002) (large chamber) are designed to address contamination by other products, by achieving a steady state emission rate prior to measuring the formaldehyde from the NAF/ULEF product.
71. Will CARB randomly test product from manufacturers that are using NAF/ULEF adhesives that have exemptions from the Executive Officer? Yes. The integrity of the program depends on consumers having certainty that the products meet the low emission standards and there is an effective compliance program.
72. Can a mill that’s been approved to produce NAF/ULEF panels for sale in California also manufacture non-NAF/ULEF panels for non-California use? Mills can choose to produce products not subject to the California standards for non-California customers, but could not label those products as legal for sale or use in California. Moreover, they should inform their customers that if they intend to sell their products to California, they should purchase California compliant composite wood products to make those goods.
73. What are the third party certification requirements for panel manufacturers that produce NAF/ULEF products? Manufacturers of "no-added formaldehyde" (NAF) products have to apply to CARB to be approved as a NAF manufacturer. Emissions data must be included in the application. If the application is approved by CARB, the product manufacturer would be exempt from the TPC requirements for two years, but still subject to field inspection and audits to verify their use of NAF resins. Manufacturers of ultra-low emitting formaldehyde resin (ULEF) products would also have to apply to CARB to be approved as ULEF manufacturer along with providing emissions data with their application. Once the application is approved by CARB, the ULEF manufacturer may be exempt from the TPC requirements for two years or allowed to test their products less frequently; however, they would be subject to field inspection and audits to verify their use of ULEF resins. NAF and ULEF approvals are granted for two-year periods and must be renewed accordingly.
H. Public Health
74. Formaldehyde emissions are significantly lower today compared to say 20 years ago on average. Why regulate composite wood products particularly when most raw board is finished or laminated that encapsulates formaldehyde? Studies show that formaldehyde emissions occur from both laminated and un-laminated boards and that current exposures still result in a public health threat. In our view, until the formaldehyde content of the board is reduced, the health risks from exposure to formaldehyde continue to exist. In the interest of public health protection, action is needed to lower formaldehyde contents from composite wood products, which have been identified as major source of formaldehyde in the context of total daily exposure to the general public.
75. What is the target population you are trying to protect? If it is the end users, wouldn't finished goods be the only products to regulate? Why target raw panels that will be laminated (industrial grade)? The target population is the citizens of California. Because large amounts of formaldehyde are released over time from composite wood products made with UF resins, the best solution for reducing public exposure is to reduce the amount of formaldehyde emitted by composite wood products, which is aligned with the principal of "pollution prevention." In doing this, the amount of formaldehyde emitted in California will be lowered over the useful life of the raw panel or finished product (i.e., decades), regardless of whether the product is laminated or not.
76. What are the specific goals of the proposed regulations and lower formaldehyde emissions? Improved air quality? By what measure will it be improved? Reduced risk of cancer? By what percent? The specific goal of the proposed regulation is to reduce formaldehyde emissions from HWPW, PB, and MDF through the application of Best Available Control Technology (BACT), in consideration of technological feasibility and cost. Improved air quality is a resulting benefit, and implementation of the Phase 2 standards are projected to lead to a reduction in statewide formaldehyde emissions of 500 tons per year. Reduced risk of cancer from formaldehyde exposure is also a resulting benefit, and implementation of the Phase 2 standards is estimated to reduce excess cancer cases per million people from formaldehyde exposure by about 40%.
I. Resin Chemistry
77. In the beginning of this Best Available Control Technology (BACT) assessment, the limit was going to be on "unreacted UF molecules." Now it is formaldehyde as a whole, yet PF is one of your (CARB) recommended alternatives. Is this not a contradiction? It is our understanding that the major portion of formaldehyde emissions from products made with UF resins is "unreacted" formaldehyde. While some formaldehyde may be released from previously bound molecules over time, the amount of "unreacted" formaldehyde is known to be much lower in products made with PF or NAF resins. Because the chemical bonds formed by formaldehyde in PF resins are largely irreversible, we believe that the use of PF resins will result in lower formaldehyde emissions throughout the life of the composite wood product and would be an effective alternative to the use of UF resin and an example of an ULEF resin system. Innovative ULEF resin systems, based on the use of scavengers, can be an effective alternative as well.
78. Does the new standard distinguish between urea-formaldehyde and phenol- formaldehyde or for the sake of the rule are they equally regulated? Under CARB staff's original proposed regulation, they were treated equally as both having added formaldehyde and would not qualify as "no-added formaldehyde" resin systems. However, the final regulation includes staff’s modifications to the original provision and allows ultra-low-emitting formaldehyde-based resins (such as phenol-formaldehyde) to have reduced testing requirements.
J. Third Party Certification (TPC)
79. Who has to be third party certified? Only manufacturers of HWPW-VC, HWPW-CC, PB, MDF and thin MDF are required to be third party certified.
80. What do Third Party Certifiers (TPCs) “certify”? TPCs verify that manufacturers of composite wood panels are capable of complying with the ATCM’s emission standards. TPCs also conduct quarterly inspections and testing, and review routine quality control testing conducted by each mill. Verifications by TPCs apply to specific product types at each mill operated by a manufacturer. A list of certified mills is maintained on CARB’s composite wood products webpage at the following link: http://www.arb.ca.gov/toxics/compwood/tpc/listofmills.htm
It is important to note that just because a mill is listed on CARB’s list of certified mills does not mean that everything made by that mill complies with CARB’s emission standards. For many mills, most of their production is not intended for sale in California and is not CARB compliant.
81. Are Third Party Certifiers (TPCs) required to test finished goods? No.
82. Will CARB supply manufacturers with a list of certified third party testing facilities? We maintain a list of approved third party certifiers on our website. Currently, we have approved of about 40 third party certifiers. For more information on their contact information, please visit our website at: http://www.arb.ca.gov/toxics/compwood/listoftpcs.htm
83. What plans are in place to have certified third party testing facilities internationally? Of the 40 approved TPCs (as of August, 2014), most are providing international services. A list of approved TPCs is available at: http://www.arb.ca.gov/toxics/compwood/listoftpcs.htm.
84. What has CARB done to address international stakeholders with respect to third party certification? CARB approached this issue in three steps. Initially, CARB conducted outreach to major international stakeholders and to the regulated community abroad. Staff traveled to China and Malaysia to conduct site visits to the Chinese consulate and participated in conferences to discuss and explain the CARB ATCM and the standards. CARB’s outreach efforts also include translations of fact sheets, presently available in five languages (Chinese, Spanish, Portuguese, Russian, and Indonesian). The translations of the ATCM text are available in the above listed languages at the following website: http://www.arb.ca.gov/toxics/compwood/outreach/foreign.htm. Second, CARB also put great emphasis on working with international third party certifiers to develop the certification program. Thirdly, important modifications were made to the rule in order to provide consistency compared to other international standards. CARB staff developed and changed the ATCM to allow the use of the secondary test method (small chamber method) to reduce the worldwide need for large chamber testing. In addition, we allowed alternative quality control test methods to provide consistency with existing test methods used for Japanese and European Union composite wood product regulations. CARB also worked closely with the International Wood Products Association and made contacts with its member manufacturers.
85. My company is currently accredited to be a product certifier (e.g, ISO 17065), testing laboratory (e.g., ISO 17025), and inspection body (e.g., ISO 17020), and we have years of experience in inspecting composite wood products mills and testing formaldehyde emissions from panels. The scope of our ISO/IEC 17025 includes ASTM D 6007, but does not include ASTM E 1333. Do we have the qualifications to be a CARB-approved Third Party Certifier? Your company can qualify as a TPC if your secondary method (ASTM D 6007) has been deemed equivalent to the primary method (ASTM E 1333), in accordance with title 17, California Code of Regulations, section 93120.9 and the data is included as part of the TPC application. Unless your ASTM D 6007 chamber is equivalent, it cannot be used to verify panel emission levels, for purposes of the ATCM. If you are in the process of establishing equivalence with an ASTM E 1333 chamber, your application may be submitted, but will be deemed “incomplete”. Please note that the demonstration of equivalence will require you to perform the required comparison testing with an ASTM E 1333 chamber operated by a CARB-approved testing laboratory before an approved Executive Order can be granted. A demonstration of equivalence made with a testing laboratory that has not received CARB-approval will not be accepted as valid, for purposes of the ATCM.
86. Do other states have a similar regulation? We are unaware of any other State having a similar regulation. However, in 2010, the federal Formaldehyde Standards for Composite Wood Products Act was signed into law by President Obama. The Act establishes formaldehyde emission standards for HWPW, PB and MDF sold, supplied, offered for sale or manufactured in the United States. The law requires U.S. EPA to adopt CARB’s formaldehyde emission standards for composite wood products and to promulgate a regulation to implement these new federal standards. The U.S. EPA regulation is expected to be finalized by 2016 and effective by 2017.
87. Are reload warehouses classified as a distribution warehouse or a manufacturing warehouse? Example: rail cars take products to a reload warehouse and trucks distribute products from there. All warehouses are owned by independent third parties and are established as separate business entities from manufacturing companies. Reload warehouses would be considered as distributors who must take reasonable prudent precautions to ensure that compliant products are purchased for resale to California.
88. Is an “installer” of architectural woodwork and miscellaneous cabinetry (e.g., on-site milling and matching, setting up, installing, adjusting, positioning, etc.) responsible for recordkeeping under the ATCM? No. The ATCM does not apply to business entities that only install cabinetry for California consumers, since they are not considered to be a fabricator or a manufacturer. As an “installer,” these business entities only put finished goods into service and are not involved in the fabrication, purchase, or sale of products containing the composite wood products for downstream customers. If an installer uses composite wood products in the act of “installing” finished goods in California, then the installer must use complying composite wood products.
89. Does a retailer need to know what type(s) of composite wood product(s) a given piece of furniture or finished good contains? Yes, to the degree that it satisfies the retailers need to demonstrate “reasonable prudent precautions”. As many components in furniture are made with HWPW, PB or MDF, retailers must work with their suppliers to ensure that the finished goods were made with compliant materials. Retailers must ask for and receive from their suppliers, a statement of compliance that indicates that the finished goods that they are supplied for sale in California were made with composite wood products that comply with applicable California standards.
90. The regulation states that no person shall “supply” any composite wood product which, at the time of sale or manufacture, does not comply with the emission standards. What is meant by “supply”? If a distributor is providing cabinets to a builder or contractor of new homes, the distributor would be “supplying” finished goods to his customer.
91. Are refurbished products regarded as used products? Yes. Refurbished or reconditioned items are not sold as new. Hence, they would fall under “used goods’ and not be covered by the regulation.
92. Is an installer (i.e., closet company), who purchases full-sized laminated panels, cutting them into shelves, edge banding them and trimming their work for installation considered a retailer or fabricator? If a closet company is simply purchasing composite wood products or component parts and then taking them to a consumer and installing shelving/closets, then they would be considered as a retailer. In this case, a retailer is not making a new product, simply installing a pre-fabricated product according to the steps necessary for on-site carpentry, assembly and installation. Retailers need to take reasonable prudent precautions to ensure that they obtain compliant composite wood products, and keep records to demonstrate their products comply with the applicable emission standards
However, if a business exists in which, panels are cut, edge banded, and essentially “new fabricated products” are produced, then that business would be considered as a fabricator. In addition to demonstrating the use of complying composite wood products, fabricators also need to label the finished products. To document their purchases and use of compliant materials to California, fabricators must keep records showing the dates of purchase and suppliers of composite wood products that they used.
93. Can noncompliant composite wood panels and/or finished goods be donated after the expiration of an applicable sell-through period? No. Business entities may not opt for donating their noncompliant inventories. In the ATCM (California Code of Regulations, title 17, Section 93120 (b)), the purpose is stated as “... the purpose of this airborne toxic control measure is to reduce formaldehyde emissions from composite wood products, that are sold, offered for sale, supplied, used, or manufactured for sale in California. By making donations, a business would be “supplying” noncompliant products and potentially exposing the California public to high-emitting and unhealthy products.
94. Are travel goods, including backpacks, luggage, leather goods, business and travel accessories, handbags, business and computer cases etc., that contain small amount of composite wood products subject to the ATCM? Why do I have to use compliant materials if linings and other durable materials fully encapsulates the composite wood products? Under the ATCM, some items such as backpacks, luggage, leather goods, business, and travel accessories, etc., would be considered finished goods if they contain HWPW, PB or MDF. For these products, you would be subject to the regulatory requirements, provided they are sold or supplied to the California market.
The ATCM does not allow exemptions for de minimus use in finished goods, other than those specifically identified for windows and exterior doors (please see questions #51 & #52). The ATCM is an example of pollution prevention because the strict surface formaldehyde emission standards on composite wood panels will necessitate the use of advanced resins systems that will either eliminate or chemically bind formaldehyde, thereby preventing pollution before it occurs. Therefore, we do not view coverings as emissions mitigation. At some point, even covered high-emitting composite wood products will emit into the atmosphere over time as products are worn and damaged. The broad applicability was necessary to ensure that all fabricators of California finished goods would use only certified lower-emitting composite wood products.