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TSCA Imposes Labeling Requirements for Composite Wood Products

Composite wood products are now subject to specific labeling requirements under federal law.

The Formaldehyde Emission Standards for Composite Wood Products Act of 2010 (Act), which added Title VI to the Toxic Substances Control Act (TSCA), established standards for formaldehyde emissions from composite wood products, and essentially adopted the same standards as those imposed by the California Air Resources Board (CARB). The Act also authorized the EPA to issue a final rule enforcing certain measures related to composite wood products. In December 2016, the EPA published a final rule designed to lower exposure to formaldehyde from certain wood products made both inside and outside the United States. The products subject to this rule include hardwood plywood, medium density fiberboard (MDF), thin-MDF, and particleboard.

The final rule contains new labeling requirements for finished goods containing composite wood products that involve a two-stage process. According to the new standards, from June 1, 2018, until March 22, 2019, composite wood products that were sold, supplied, manufactured or imported in the United States required labels identifying such products as CARB ATCM Phase II or complying with TSCA Title VI. This means that labels simply needed to conform to already existing California labeling requirements established by CARB in order to comply with the TSCA final rule.

After March 22, 2019, when the second stage of implementation goes into effect, all composite wood products will be required to be labeled as TSCA Title VI compliant. Therefore, products bearing labels indicating they conform to CARB’s requirements are non-compliant under federal law. However, finished products that are labeled as TSCA Title VI compliant are presumed to conform to standards under California’s CARB Phase II. Nonetheless, good practice may be to place labels on finished goods sold in the state indicating that such goods are compliant with both state and federal regulations.

The new TSCA Title VI labeling rules require manufacturers of finished items that are made of composite wood items to place a label on every finished product or every box that contains a finished product. There are additional requirements for product labels that intend to be both California CARB II compliant and TSCA Title VI compliant. This includes providing a label in English text with the fabricator’s name, the date that the finished product was made, and a statement attesting to compliance.

Grimaldi Law Offices has been advising clients for over 20 years on chemical and product law. For knowledgeable advice and in-depth analysis of your chemical regulatory compliance obligations, contact Grimaldi Law Offices at (415) 463-5186 or email us at [email protected].



Ms. Grimaldi maintains a diverse environmental law practice focusing on chemical and product regulation and litigation defense. Her practice areas include Proposition 65, California's Safer Consumer Products Regulations, California's Rigid Plastic Packaging Container Act and the federal Toxic Substances Control Act. Ms. Grimaldi graduated from the University of California Hastings College of the Law magna cum laude and holds a Bachelor of Science Degree in Bacteriology from University of California, Davis. Prior to attending law school, she worked as a research assistant in laboratories at the University of California, San Francisco Cancer Research Institute and at the University of California, San Francisco School of Medicine.