TSCA Required for Composite Wood Products starting March 22nd
On March 22, 2019, importers of certain types of composite wood products will need to certify that their imported products comply with the formaldehyde emissions standards under the United States Environmental Protection Agency’s (EPA) Toxic Substances Control Act (TSCA), Title VI.
The TSCA Title VI formaldehyde emissions standards apply to three types of composite wood products:
- Hardwood plywood
- Medium-density fiberboard (MDF)
- Particleboard – whether the product is unfinished panels or incorporated into component parts or finished goods.
The foreign producer must have the products tested and certified by an EPA-recognized 3rd party certifier. The party responsible for brokerage will need to provide a completed TSCA Certificate for each shipment.
The importer’s responsibilities include:
- Certifying at entry that the wood product is compliant with TSCA (or certifying that the product is not subject to TSCA);
- Recordkeeping: For 3 years, the importer must keep an invoice, bill of lading or comparable document that states the product is compliant with TSCA Title VI
- Upon the request of EPA, the importer must be able to make records available to the EPA (within 30 days) identifying the panel producer, the date produced, the supplier and the date the products were purchased. [The importer is not required to maintain this information, but will be required to have the supplier or producer provide the information when requested to do so.]
The U.S. EPA will be hosting two webinars to help companies prepare for these changes. These webinars will occur February 26th and March 6th, 2019.
We strongly encourage our clients to attend one of the seminars.