On 10 December 2016 the U.S. EPA issued Formaldehyde Emission Standards for Composite Wood Products, raising safety and market-access requirements for composite wood made or imported in the United States — the strictest U.S. formaldehyde limits to date. The United States is China’s largest wood-product export market (about USD 20–30 billion a year). The rule is a technical barrier to those exports.
The EPA composite-wood rule is strict in three ways. First, it is mandatory nationwide. Previously only California had formaldehyde limits for composite wood. The Federal Register notice of 10 December 2016 took effect on 10 February 2017 across the United States. Second, the limits are tight: 0.05 ppm for hardwood plywood, 0.09 ppm for particleboard, 0.11 ppm for MDF and 0.13 ppm for thin MDF — stricter than most other jurisdictions. Third, testing, inspection and certification requirements are higher. After 12 December 2017, hardwood plywood, particleboard and MDF made with composite or veneer cores and produced or imported into the U.S. must comply and be certified. After 12 December 2023, laminated products must meet hardwood-plywood test and third-party certification rules. The labs and certification bodies involved must be accredited by an EPA-recognized accreditation body; certification bodies must also apply for EPA recognition.
In the EPA composite-wood technical barrier, accreditation and testing are central. EPA-recognized accreditation bodies must operate to ISO/IEC 17011 and be IAF and ILAC MRA signatories; they and third-party certification bodies must report data through EPA’s Central Data Exchange; bodies outside the United States need a U.S. agent.
CNAS, China’s national accreditation body, is a member of international multilateral recognition arrangements and meets the EPA rule’s requirements for accreditation bodies. After mapping gaps versus EPA requirements, CNAS will, with CNCA approval, apply for EPA recognition and help Chinese composite-wood certification and testing bodies meet the rule, supporting wood-product exports to the United States.
