Wood components, products sold or produced in California require labeled shipments.
As of Jan. 1, 2009, any composite wood product produced for sale or use in the state of California must be in compliance with Phase I CARB formaldehyde emission limits. Composite wood panels include particleboard, MDF and hardwood plywood, and the regulation also applies to products made with those materials.

According to the Composite Panel Association, a fabricator is defined as any entity that uses composite wood products to make finished goods. Fabricators include anyone producing component parts for downstream use by other fabricators and those companies producing finished goods. To learn more about the Phases of CARB, see FDM May 2008, pg. 62, "Composite panel industry reacts to CARB ruling."

Under the sell-through provisions, fabricators have until July 1, 2010 to exhaust their inventory of noncompliant panels made before Jan. 1, 2009 and may sell finished goods made with noncompliant panels in California until that date.

Labeling shipments, documentation

When purchasing compliant panels or finished goods, fabricators must take "reasonable prudent precautions" to ensure the products they are buying comply with the rule and are labeled appropriately. The label must include:

1. Fabricator's name
2. Date the finished good was produced
3. Language that clearly indicates the product complies with the applicable Phase 1 or Phase 2
emission limit.

In addition, all invoices or bills of lading must also include a statement of compliance indicating the product meets the Phase 1 and Phase 2 emission limit.

For example, CARB has indicated the following language would be acceptable for the required product label and statement of compliance:

"Contains (particleboard, MDF, hardwood plywood) that complies with CARB (Phase 1, Phase 2) formaldehyde emission standards in CCR 93120.2(a)."

If you're using no-added formaldehyde or ultra-low emitting formaldehyde resins, you can replace the Phase 1/Phase 2 statement on your label and statement of compliance on your invoice with "Contains (particleboard, MDF, hardwood plywood) made with (NAF, ULEF) resins that comply with CARB formaldehyde emission standards in CCR 93120.2(a)."

While CARB does not have a specified standardized label format, the necessary information must be readily identifiable on the box or finished product. The information can appear in separate labels, if they all are clearly visible.

Beyond that, fabricators are required to keep records showing the date of purchases as well as the name of the supplier, and documenting the precautions they have taken to ensure the materials comply with the rule. These records must be kept in electronic or hard copy form for a minimum of two years.

For up-to-date CARB information, Click Here.