In the realm of international trade, it’s essential for importers dealing with wood products to understand the Toxic Substance Control Act (TSCA) Title VI, which imposes strict formaldehyde emissions standards on composite wood products. As these regulations affect a wide range of businesses—from manufacturers to retailers—it’s crucial for stakeholders in the supply chain to understand the types of products impacted and the steps importers must take to ensure compliance.
Under TSCA Title VI, the U.S. Environmental Protection Agency (EPA) states that composite wood products must undergo testing and certification to ensure that only compliant products enter the supply chain. This involves certification by an EPA-recognized third-party certifier (TPC), often referred to as an EPA TSCA Title VI TPC. The EPA recognizes three types of composite wood products regulations:
In addition to testing and certification, the regulation imposes recordkeeping, reporting and labeling requirements. All applications and notifications related to the final rule must be submitted through the EPA Central Data Exchange (CDX), ensuring transparency and accountability throughout the process.
Both parties need to work together to ensure compliance. For instance, importers should verify that manufacturers have conducted the necessary testing and certification before importing the products. Additionally, manufacturers should provide the required documentation and labeling to support compliance.
TSCA Title VI impacts various entities within the supply chain, including composite wood panel producers, fabricators, third-party certifiers, importers, distributors and retailers. Here’s a breakdown of the businesses likely to be affected by TSCA Title VI:
Several products are exempt from TSA Title VI, including:
The key steps importers can take to ensure compliance with TSCA Title VI include:
On July 7, 2010, the Formaldehyde Standards for Composite Wood Products Act was enacted into law, becoming Title VI of the Toxic Substances Control Act (TSCA). This legislation was a response to growing concerns about the health impacts of formaldehyde emissions, a common issue with composite wood products used in a variety of consumer goods, including furniture and building materials.
A pivotal moment leading to this legislation occurred in 2007, when the California Air Resources Board (CARB) adopted the Airborne Toxic Control Measure (ATCM) for composite wood products. These standards, which became effective in 2009, were among the strictest in the nation and set stringent limits on formaldehyde emissions.
TSCA Title VI specifically aimed to align national standards with those established by CARB. The CARB standards had been effective in reducing formaldehyde emissions at the state level, and the adoption of these standards at the federal level under TSCA Title VI intended to ensure a uniform national threshold.
The act mandated the EPA to implement regulations that would ensure compliance with the established formaldehyde emission standards. These regulations outline the responsibilities of manufacturers, importers, and distributors of composite wood products, including:
By aligning these standards nationally with California’s rigorous requirements, the regulation aims to provide uniform safety standards across the country, reducing exposure to harmful chemicals and improving indoor air quality.
Navigating the intricacies of TSCA Title VI and its regulations on wood products is vital for maintaining supply chain integrity and ensuring product safety. As these regulatory demands grow increasingly complex, leveraging expert logistics solutions becomes crucial.
At Ascent, we specialize in helping businesses navigate international shipping challenges for wood products, ensuring compliance with not just TSCA Title VI but also other global regulations. We invite you to explore our international freight forwarding solutions to learn how we can support your business needs in this regulated landscape.