by Title VI of TSCA requires manufacturers to switch to low-emission glues in composite core panels or be subject to the same 3rd-party certification as panel producers
COLFAX, N.C. — A March 22, 2024 compliance deadline for the final portion of the federal formaldehyde emissions standards is fast approaching, leaving the furniture industry yet another major compliance issue to address over the next 13 months.
The standard is Title VI of the Toxic Substances Control Act, which regulates formaldehyde emissions in products including hardwood plywood, medium-density fiberboard and particleboard with a wood or bamboo laminated veneer. These types of products are commonly used in case goods and other types of wood furniture or furniture components.
The goal of the standard is to limit consumers’ exposure to formaldehyde emissions, which have been known to cause a variety of ailments including irritation or burning on the skin, and in the nose, throat and respiratory system.
According to the American Home Furnishings Alliance, which has been addressing the formaldehyde issue for the past 20 years or more, the Title VI emissions limits are the same as those identified by the California Air Resources Board that went into full effect in July 2012.
However, the Environmental Protection Agency was charged with developing its own set of regulations to ensure compliance on a national level, not just for products sold into the state of California.
The difference between CARB and Title VI is that CARB has an exemption for fabricators of wood products, such as furniture manufacturers that produce and machine hardwood plywood composite core panels on-site. By some estimates, producing, finishing and using the core panels in finished furniture reduces the formaldehyde emissions by 50%.
But the EPA does not allow for such an exemption, meaning the fabricators or furniture producers would be lumped into the same group as the producers of raw panels under Title VI of TSCA.
So to comply with this last segment of the federal standard, the industry has a couple of options.
One is to convert or move away from traditional resins to a no-added formaldehyde resin or phenol resin for their composite core panels.
Or, if they haven’t done so by March 22, 2024, the fabricators will then be subject to what the AHFA described as record-keeping and third-party certification requirements that are now just applied to the panel producers.
The EPA has given the industry seven years to switch to lower-emitting glues or resins used in the composite panels.
While that may seem like a long time, there have been limited options in the field, which experts dealing with the issue say are not only more costly, but have had some potential quality issues that could compromise the quality of finished furniture. In addition, officials note, there also could be some major altering of the board manufacturing process resulting from the use of the new resins.
The AHFA has been working on a petition for the past seven years seeking another exemption for the fabricators similar to the exemption provided by CARB. The goal was to have it finalized and submitted to the EPA by the end of 2022.
But recently the group put that on hold at least until after an AFHA workshop planned for next week that could provide some major answers and solutions to key issues surrounding Title VI of TSCA.
The workshop is taking place from 8:30 to 4:30 p.m. Feb. 15 at Guilford Technical Community College in Colfax. One of the main agenda items is a panel of major adhesive producers who will discuss new and emerging resin technologies. The panel participants include AkzoNobel Wood Adhesives, Franklin Adhesives & Polymers, H.B. Fuller Company and Hexion Inc.
Also speaking at the event is Robert Courtnage, a head physical scientist in the EPA’s Office of Chemical Safety and Pollution Prevention who will provide an overview of provisions in the federal rule that pertain to laminated product manufacturers and importers — again, known as fabricators.
In addition, Travis Snapp, Joel Oser and Chris Battin, all of Benchmarket International will offer specific actions that fabricators should take to meet the March 2024 deadline.
And Michael Sullivan of law firm Womble Bond Dickinson will discuss supply chain strategies as part of a “comprehensive compliance program.” The AFHA said the event will conclude with a question-and-answer session that offers a chance for the experts to answer any further questions the audience has on this complicated issue.
