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TSCA Title VI - Compliance Statement

EPA’s New Composite Wood Formaldehyde Regulation – TSCA Title VI

Conestoga Wood Specialties Compliance Statement

The Toxic Substance Control Act Title VI, or TSCA Title VI, has been finalized with an implementation deadline of June 1, 2018.  As of May 1, 2018, Conestoga is fully compliant with applicable TSCA Title VI requirements.

TSCA Title VI, which is modeled on the California Air Resources Board (CARB) Composite Wood Products formaldehyde regulation, requires mills that produce composite wood products [including medium density fiberboard, (MDF), particleboard (PB), and veneer and composite core plywood] to meet emissions limits for formaldehyde from their products.  TSCA Title VI composite wood product emission limits are the same as those set by the CARB regulation. Both CARB (for California) and TSCA Title VI (for the entire US) require manufacturers that use these products, including Conestoga Wood Specialties, to purchase only compliant materials and meet labeling and recordkeeping requirements. Conestoga has been fully CARB Phase 2 compliant since 2012.

Conestoga has been actively preparing for this regulation for well over a year, and all of Conestoga’s products already meet the TSCA Title VI requirements for formaldehyde emissions. We have developed a robust TSCA Title VI compliance program that includes tracking of materials purchased to the mills they were produced in, regularly reviewing compliance documentation, and communicating compliance with customers. All shipments of products using composite wood materials are labeled as complying with TSCA on the labels, packing slips, and invoices sent from Conestoga.

The TSCA Title VI regulation applies to all manufacturers that utilize composite materials throughout the United States, so it’s critical that our customers have an understanding of this regulation and what is required of their company and their suppliers.  As is the case with CARB, fabricators and manufacturers found to be out of compliance will face substantial financial penalties levied by the EPA.

To learn more about the TSCA Title VI regulation, go to https://www.epa.gov/formaldehyde/formaldehyde-emission-standards-composite-wood-products, or the TSCA resource site at https://www.epa.gov/formaldehyde/resources-and-guidance-materials-translations-formaldehyde-emission-standards-composite.

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