Guidance document on the Formaldehyde Emissions from Composite Wood Products Regulation

Health Canada
August 12, 2022

Disclaimer
This document does not in any way supersede or modify the Canadian Environmental Protection Act, 1999 (CEPA, 1999), the Formaldehyde Emissions from Composite Wood Products Regulations or the Directive Concerning Testing for Formaldehyde Emissions or offer any legal interpretation of the Act or the Regulations. In the event of an inconsistency between this document and the Act and the Regulations, the Act and the Regulations take precedence.

On this page

  1. Overview
  2. Scope of the Regulations
  3. Laminated products
  4. Testing
  5. Certification
  6. Non-compliant lots
  7. Labelling
  8. Record keeping and reporting
  9. For more Information
  10. Annex 1. A non-exhaustive list of some commonly used test methods for quality control testing

1. Overview

The purpose of this document is to provide general information on the Formaldehyde Emissions from Composite Wood Products Regulations (the Regulations) established under the authority of CEPA, 1999. Emissions from certain composite wood products are a source of formaldehyde in indoor air. The intended outcome of the Regulations is to help reduce formaldehyde exposure in indoor air and the risk of adverse health impacts associated with this exposure. This document highlights certain sections of the Regulations to provide additional guidance and explanation, however not every section of the Regulations is included.

The Regulations aim to align to the extent possible with the United States (U.S.) Rule, Toxic Substances Control Act, Title VI, Formaldehyde Standards for Composite Wood Products (TSCA Title VI). The U.S. Rule establishes emission limits for certain composite wood products, among other requirements.

2. Scope of the Regulations

The Regulations apply to composite wood products that contain formaldehyde and establish emission limits for the following types of composite wood panels, which tend to be used for indoor applications such as cabinetry, furniture, and trim: hardwood plywood (HWPW), medium-density fibreboard (MDF), thin MDF, particleboard, and laminated products. As per the definitions of HWPW and laminated products, the Regulations apply only to those with a core made of veneer, particleboard, or MDF; they do not apply to HWPW made with other cores such as hardboard or lumber.

The Regulations prohibit the sale, offer for sale, or import of composite wood panels and laminated products that exceed the emission limits. Furthermore, finished goods and component parts must not be sold, offered for sale or imported unless any composite wood panels incorporated into them do not exceed the emission limits.

There are a number of specific uses of composite wood products to which the Regulations do not apply (refer to section 4). For instance, the Regulations do not apply to composite wood products used in most vehicles, vessels, or aircraft. However, composite wood products used in mobile homes, motor homes, and recreational trailers are regulated.

3. Laminated products

Definition

Laminated products are defined in the Regulations as products made by gluing a wood or woody grass veneer to a core or platform composed of particleboard, MDF, veneers or a combination of these materials. To help distinguish laminated products from HWPW, the definition also stipulates that they are made by a manufacturer of component parts or finished goods. Woody veneers glued to cores other than those specified above, such as a lumber core, are excluded from the Regulations. Likewise, the Regulations exclude products composed of the composite wood product cores specified above, to which thin layers of material other than wood veneers are glued. For example, the Regulations would not apply to "laminate flooring" that includes a top layer that has an imprinted, textured image made to look like real wood. "Laminated" kitchen counters, which typically consist of a plastic layer glued to particleboard, would also not be subject to the Regulations. Some products, such as engineered hardwood flooring, composed of a hardwood veneer affixed to a platform, may be subject to the Regulations if the veneer is no thicker than 6.4 mm and is attached to 1 of the platforms mentioned above.

Testing exemptions

The Regulations are intended to align with the U.S. Rule with regard to testing of laminated products. For this reason, the Regulations also exempt from testing laminated products in which the veneer is attached to the core or platform with phenol formaldehyde or no added formaldehyde (NAF) resins. The exemption pertains only to the resin used in the glue line between the veneer and the core or platform and does not apply to the resins used in the core or platform. However, the core or platform must be from a compliant panel with emissions below the applicable limit.

Transition period

The Regulations contain transition periods including one so that laminated products can adapt to the new requirements (refer to section 33). Labelling will be required for all laminated products at the coming into force, as will basic reporting under section 31; however, there is a transition period provided for a number of other requirements. For example, for laminated products using resins other than phenol formaldehyde or NAF to attach the veneer, the testing and third party certification requirements do not apply until 5 years after the Regulations have come into force. Manufacturers of laminated products that use phenol formaldehyde or NAF resins to attach the veneer will continue to be exempt from the testing and certification requirements after that 5-year period, but will become subject to record keeping requirements for the core or platform.

4. Testing

Testing by manufacturers is required so that the applicable composite wood panels and laminated products do not emit formaldehyde above the regulated limits. Two types of testing are used: primary testing and quality control (QC) testing. The primary tests must be carried out four times annually during specific periods by an accredited laboratory, as defined in section 17 of the Regulations. Either the Standard Test Method for Determining Formaldehyde Concentrations in Air and Emission Rates from Wood Products Using a Large Chamber (ASTM E1333), or the Standard Test Method for Determining Formaldehyde Concentrations in Air from Wood Products Using a Small-Scale Chamber (ASTM D6007) may be used to carry out these primary tests. If the ASTM D6007 test method is used, it must first be demonstrated by an accredited lab to be equivalent to the large chamber used in the ASTM E1333. Due to the large chamber and other equipment required for the ASTM E1333 test, as well as the requirement for the testing to be carried out by an accredited laboratory, the primary testing tends to be more precise.

Section 17 of the Regulations states that "any testing to measure formaldehyde emissions" must be performed by an accredited laboratory. Health Canada is exploring options to clarify QC testing requirements.

The QC testing may be conducted using any one of a variety of different test methods. A particular test method for QC testing must be correlated to the ASTM E1333 method prior to use to ensure that the test results consistently relate to the regulated emission limits. Details on how to establish equivalence and correlation of test methods can be found in the Directive concerning testing for formaldehyde emissions (the Directive) published on the CEPA Registry. Annex I provides a non-comprehensive list of test methods used to measure formaldehyde emissions during QC testing.

The testing of a representative sample of composite wood panels or laminated products in a particular production line helps to establish that the formaldehyde emission limits are met. Additional testing, either primary, QC, or both, is required in circumstances where the formaldehyde emissions have likely changed, such as when there are changes in the resin or the process. Furthermore, a declaration of certification is required from the manufacturer before composite wood panels or laminated products may be imported into or sold in Canada.

4.1 Specimen collection and conditioning

Specimens must be selected so that they are as representative as possible of the production lot. Specimens for testing must be selected from within the bundle, where adjacent panels restrict the opportunity for formaldehyde to escape prior to testing. Once selected, the specimens must be handled in accordance with requirements set out in ASTM D6007, including dead-stacking and wrapping air-tight in plastic. Conditioning of the specimen begins within 30 days after the panel or laminated product is manufactured.

The specimens must be in an unfinished state and with no topcoat, and are conditioned as per the temperature (that is, 24 ± 3°C) and humidity (that is, 50 ± 5%) set out in Table 1 of the Directive. Specimens for primary testing are conditioned for 7 days ± 3 hours, while those for QC testing are conditioned for 2 hours ± 15 minutes.

4.2 Frequency of testing

Primary testing must be carried out four times annually during specific periods. The frequency at which QC testing is carried out is based on production. At facilities that manufacture particleboard, MDF or thin-MDF, 1 QC test is required for each product type during each shift (that is, either 8 or 12 hours depending on shift length plus or minus 1 hour). For HWPW and laminated products that tend to have more variable production, the frequency of QC testing is more complex, but translates to about 1 QC test for each 9,290 m2 of product manufactured (see Table 1).

Table 1. Frequency of QC tests for HWPW and laminated products based on weekly and monthly production
Period Per month Per month Per week Per week Per week
Production ≤ 9,290 m2 > 9,290 m2
(≤ 9,290 m2 per week)
>9,290 to <18,581 m2 ≥18,581 to <37,161 m2 ≥ 37,161 m2
Frequency 1 QC test 1 QC test for each 9,290 m2 1 QC test 2 QC tests 4 QC tests

4.3 Reduced-frequency testing

Urea formaldehyde is the most commonly used resin for manufacturing the composite wood products covered by these Regulations. However, it tends to result in higher formaldehyde emissions. In order to encourage the use of other resins that emit less formaldehyde, the Regulations include reduced-frequency testing provisions. This applies to NAF resins as well as to ultra-low emitting-formaldehyde (ULEF) resins.

Table 2. Summary of NAF and ULEF qualification testing
Test type NAF ULEF
Primary tests 1 2
QC tests 13 26
Period 3 months 6 months
Table 3. Summary of NAF and ULEF performance standard limits
Composite wood product NAF: All tests NAF: 90% of QC tests ULEF: All tests ULEF: 90% of QC tests
HWPW 0.05 parts per million (ppm) 0.04 ppm 0.05 ppm 0.05 ppm
Laminated product Not applicable Not applicable 0.05 ppm 0.05 ppm
Particleboard 0.06 ppm 0.04 ppm 0.08 ppm 0.05 ppm
MDF 0.06 ppm 0.04 ppm 0.09 ppm 0.06 ppm
Thin-MDF 0.06 ppm 0.04 ppm 0.11 ppm 0.08 ppm
Table 4. Summary of NAF and ULEF reduced-frequency testing regime
Test type NAF ULEF
Primary tests 1 test every 24 months 1 test every 6 monthsFootnote 1
QC tests No QC testing required 1 QC test per weekFootnote 2
Footnote 4-1

For composite wood products made with a ULEF resin that meet the performance standards limits for NAF resins, 2 primary tests (and no QC tests) are required every 24 months.

Return to footnote 1 referrer

Footnote 4-2

For HWPW and laminated products, the lesser of this testing frequency or that based on regular production apply.

Return to footnote 2 referrer

NAF resins, such as those made from soy, polyvinyl acetate or methylene diisocyanate, contain no formaldehyde as part of the resin cross-linking structure. To qualify for the reduced-frequency testing provisions, panels using the NAF resins must undergo 1 primary test and 13 QC tests over a 3-month period. A third-party certifier (TPC) must verify these tests. All resulting emissions from these tests must be at or below 0.05 ppm to 0.06 ppm, depending on the product, and 90% of all QC tests must be at or below 0.04 ppm.

ULEF resins do contain formaldehyde, but are formulated such that the average formaldehyde emissions are much lower than typical emissions from urea formaldehyde resins. While NAF resins are defined by their composition, ULEF resins are defined strictly based on their emission performance. Phenol formaldehyde is a commonly used example of a ULEF resin; however, even urea formaldehyde can be formulated to meet the lower emissions that define a ULEF resin. Composite wood products made with ULEF resins must undergo double the testing that would be required for NAF resins to qualify for the Regulations' reduced-frequency testing provisions. In other words, 2 primary tests and 26 QC tests over a 6-month period would be required. A TPC must verify these tests. The emissions that must be achieved to qualify for the ULEF reduced-testing incentive are lower than the regulated emission limits, but higher than what is required for NAF resins. However, if composite wood products made with ULEF resins achieve the performance standard limits for NAF resins (as in table 2), the manufacturer will be entitled to a further-reduced-frequency testing regime (that is, 2 primary tests and no QC testing over a 2-year period).

In the case of any change in the manufacturing process or resin that might affect the formaldehyde emissions, such as the temperature, press time, or the amount or formulation of resin used, further testing must be carried out to ensure that the formaldehyde emissions do not exceed the limits that allow the manufacturer to qualify for the reduced-frequency testing regime. For panels made with NAF resins, this testing consists of 1 primary test and 1 QC test, which are verified by a TPC. In the case of composite wood products made with ULEF resins, 1 primary test and 5 QC tests must be carried out and verified by a TPC. If there is a change to the type of resin used, then the reduced-frequency testing regime no longer applies and a manufacturer would have to carry out the steps mentioned above to re-qualify.

Manufacturers of particleboard, MDF and thin-MDF that do not qualify for the NAF or ULEF resin reduced-frequency testing regime, may still qualify for reduced QC testing based on performance. If the 30-panel running average remains 2 standard deviations below the applicable formaldehyde emission limit, the QC test frequency may be reduced from every 8-12 hours to every 24 hours. If the 30-panel running average remains 3 standard deviations below the applicable formaldehyde emission limit, the QC test frequency may be reduced to every 48 hours. Manufacturers may continue to test at these reduced QC test frequencies for as long as they remain qualified.

5. Certification

In addition to composite wood panels and laminated products meeting the testing regime requirements, certification is required before they may be imported into or sold in Canada. Among other things, this certification requires verification from a qualified TPC that the formaldehyde emissions from the particular composite wood product types did not exceed the applicable limit based on at least 5 primary tests and 5 QC tests. Ongoing verification of primary tests by a qualified TPC is also required to maintain certification. Under the Regulations, a person does not apply to the Government to become a TPC. In order to be a TPC, a person must meet the criteria set out in section 18 of the Regulations. For more information on the roles and responsibilities of the TPC, see Third party certifiers: composite wood products containing formaldehyde.

While a qualified TPC may certify the product, the manufacturer of the panels or laminated products is responsible for producing the declaration of certification under the Regulations. If the composite wood product type is already certified under TSCA Title VI, it would meet certification requirements under the Regulations. Under the Regulations, the Government will also accept declarations of certification regarding the reduced-frequency testing certification of panels or laminated products that have qualified and received a NAF or ULEF exemption under TSCA Title VI, as the case may be.

The declaration of certification must contain certain information, but the Regulations do not require a particular format. The declaration of certification must be in either English or French and include, among other things, the civic and postal addresses, telephone number, and if any, the email address of the TPC as well as the name of the TPC's contact person. All this information must be accurate at the time the manufacturer made the declaration. Health Canada recognizes that a TPC's contact person may change from time to time. For this reason, in Health Canada's view, a change in contact person would not result in a compliant declaration of certification becoming invalid. A declaration of certification ceases to be valid for a particular composite wood product type when the formaldehyde emissions resulting from a primary test exceed the applicable limit. In this case, certification may be declared again with at least 1 primary test that is verified by a TPC and that results in emissions below the limit. Certification can also become invalid when a manufacturer does not have a qualified TPC verify the primary and QC tests for that product type. In this case, certification only becomes valid again when a qualified TPC verifies the testing regime for the product type.

The declaration of certification is a key record-keeping requirement that is passed down the chain of commerce from panel manufacturers to finished goods manufacturers to retailers. The intent is not to be able to track which specific panels have been incorporated into an individual finished good, but rather to ensure that any panels incorporated into a finished good product line, from all potential sources, have been certified. This "bundle" of declarations of certification can then be passed down the chain of commerce to retailers, who would keep a library of these declarations of certification.

6. Non-compliant lots

If a primary test or a QC test results in formaldehyde emissions above the applicable limit, then the entire production between this test and the previous test in which the emissions did not exceed the limit is a non-compliant lot. Non-compliant lots are not certified. They must not be sold unless treated to reduce the formaldehyde emissions and must be retested to verify that the emissions following treatment no longer exceed the applicable limit. Non-compliant lots that are not being treated must be disposed. Any method can be used to reduce the formaldehyde emissions, such as treatment with a chemical scavenger like ammonium bisulfite or sodium metabisulfite. Formaldehyde emissions naturally decrease over time and the aging of non-compliant composite wood panels or laminated products is another known method for reducing emissions.

Following treatment, a non-compliant lot must be re-tested. Health Canada recommends that the same test method that determined the lot to be non-compliant in the first place be used for the re-test. However, this is not a requirement in the regulation. One specimen must be selected for the primary test method or 3 specimens from three bundles of the lot must be selected if using the QC test method. The composite wood specimens must be selected randomly as to be representative of the entire lot and they can include panels selected from properly stored samples from that lot that had been set aside by the panel producer for re-test purposes in the event of a failure. If the QC test method is chosen for retesting, then the test results from the 3 specimens is averaged and this average emission value must be below the applicable limit. Whether the primary or QC test methods are used for retesting, these tests must be verified by a qualified TPC.

As there may be a lapse in time between manufacturing a composite wood panel or laminated product and receiving the test results, especially for panels sent to an accredited laboratory for primary testing, it is possible that some composite wood product is sold before being identified as non-compliant. When this occurs, the person who sold the non-compliant panels or laminated products must notify the purchaser within 2 days after the day they become aware of the non-compliance. If the person who sold it is the manufacturer or importer, they must also inform the Minister of the situation in writing within 2 days after the day they become aware of the non-compliance. If the purchaser of a non-compliant lot has not yet sold these panels or laminated product, they must isolate them before either treating the non-compliant product as mentioned above or returning it to the manufacturer for treatment or disposal. If the purchaser of the non-compliant composite wood panel has further sold it down the supply chain, then they are also responsible for passing the notification to the customer of the non-complying lot within 2 days after the day they received the notice. It should be noted that "days" do not include holidays. A manufacturer of finished goods who has already incorporated non-compliant panels or laminated products into those goods by the time they receive the notification, is not required to treat the finished good to reduce emissions or further notify downstream customers.

7. Labelling

Manufacturers and importers must label all applicable composite wood panels and laminated products as well as the finished goods that incorporate them. The label can be in the form of a stamp, tag or sticker and must be securely fastened to the product and clearly visible with legible text. The labels must have a statement that the product complies with the Regulations and contain information that allows the products to be traced back to a particular lot or date of manufacture. Table 5 summarizes the required labelling elements for all composite wood products. For the sake of labelling, the Regulations are referred to as "CANFER". As the key regulatory requirements of emission limits and testing in Canada are aligned with the U.S. Rule, products with a TSCA title VI label will be accepted as long as they meet the bilingual labelling requirements.

7.1 Composite wood panels

Every composite wood panel must be labelled, either individually or in a bundle. If a composite wood panel is not individually labelled, the panel manufacturer, importer, or seller must have a method, such as colour-coded edge markings, that is sufficient to identify the supplier of the panel and to link the product to the proper label information on the bundle. Panels purchased from a manufacturer or importer may be re-sold without the associated label if the label information is made available upon request.

Composite wood panels that are made with no-added-formaldehyde resins, and that qualify for the reduced-frequency testing regime under the Regulations, have the option of including a "NAF" or "no added formaldehyde" statement on their label. Likewise, panels that qualify for the ultra-low-emitting formaldehyde provisions of the Regulations may include that information on their label. These optional labelling statements must be bilingual and include either "SFA" or "sans formaldéhyde ajouté"; or "TFEF" or "à très faibles émissions de formaldéhyde" to accompany the English NAF and ULEF statements respectively.

7.2 Laminated products and finished goods

Manufacturers and importers must either individually label each finished good or have a label on every bundle or box of the finished goods. The name on a finished good label may be the name of the manufacturer, the importer, or the seller. For example, a large retailer may hire a number of different contract manufacturers to produce the same finished good for its product line, which it then labels under its own name.

Table 5. Labelling elements for composite wood panels, laminated products, and finished goods
Requirement status Purpose Composite wood panels Laminated products and finished goodsFootnote 1
Mandatory Identification Name of manufacturer Name of manufacturer, importer or seller
Mandatory Tracking Lot number Date of manufacture
Mandatory Compliance statement
(1 of the following)
  • CANFER compliant / conforme au CANFER
  • TSCA Title VI compliant / conforme au titre VI de la TSCA
  • TSCA Title VI certified / certifié conformément au titre VI de la TSCA
  • CANFER compliant / conforme au CANFER
  • TSCA Title VI compliant / conforme au titre VI de la TSCA
  • TSCA Title VI certified / certifié conformément au titre VI de la TSCA
Mandatory TPC identification Name of TPC (or U.S. EPA number assigned to TPC) Not applicable
Optional Promotional "NAF / SFA" or "no added formaldehyde / sans formaldéhyde ajouté" "NAF / SFA" or "no added formaldehyde / sans formaldéhyde ajouté"
Optional Promotional "ULEF / TFEF" or "ultra-low-emitting formaldehyde / à très faibles émissions de formaldéhyde" "ULEF / TFEF" or "ultra-low-emitting formaldehyde / à très faibles émissions de formaldéhyde"
Footnote 5-1

Finished goods include component parts that are sold separately

Return to footnote 1 referrer

In cases where finished goods incorporate panels that are made with NAF or ULEF resins, or a combination of both, and that qualify for the reduced-testing regimes, these finished good labels may contain a statement to that effect. Finished goods that incorporate panels or laminated products that make up less than or equal to 929 cm2 of its largest surface area, do not need to be labelled. However, the composite wood products contained in these finished goods must still meet the applicable emission limit and are subject to record keeping requirements.

8. Record keeping and reporting

Manufacturers of composite wood products are not required to provide annual reports. However, all manufacturers, importers and sellers of composite wood products must identify themselves to the Minister of the Environment and Climate Change Canada within 60 days of the Regulations coming into force. This self-identification report will help the government establish the regulated community and is only required once, unless the information changes and needs to be updated.

The Regulations do not regulate foreign manufacturers and instead obtain key information through record keeping requirements of importers, sellers and domestic manufacturers. Records must be provided to the Minister of the Environment and Climate Change Canada upon request. Most record keeping pertains to panel and laminated product manufacturers with fewer requirements moving downstream in the supply chain to the sellers of composite wood products. Records must be maintained on-site at the principal place of business in Canada or elsewhere in Canada where the records can be inspected. These records must be kept for a period of 5 years. For some other records that are not necessarily kept within Canada, the manufacturer or importer has 40 days to obtain and provide them to the Minister. For these records, if the information is to be translated from a language other than English or French, the manufacturer or importer has 60 days to provide them to the Minister. A summary of the record keeping requirements is presented in Table 6. For a complete and comprehensive list of record keeping requirements, please refer to the Regulations. It is important to note that a regulated party may have multiple roles, and if this is the case, they must follow the requirements relevant to all of the activities in which they engage. For instance, a company may be both an importer of panels and a manufacturer of finished goods.

Table 6. Record keeping requirements for impacted parties

In this table, the following acronyms are used:

  • M - records to be maintained in Canada at the facility for inspection
  • P - records to be provided within 40 days (or 60 days if translation required)
  • LP - laminated product
  • TPC - third party certifier
  • QC - quality control
  • CWP - composite wood panel
  • n/a - not applicable
Record keeping requirements PanelFootnote 1 manufacturer Test-exempt LP manufacturer Finished goodsFootnote 2 manufacturer PanelFootnote 1 importer Finished goodsFootnote 2 importer Seller
Declaration of certification M MFootnote 3 M M M M
Panel lot number/ LP date of manufacture M n/a n/a P P n/a
Panel/LP- supplier/manufacturer n/a M n/a P P n/a
Non-compliant lot information M n/a M M n/a n/a
Resin information M M n/a n/a n/a n/a
Purchase records n/a M n/a P P n/a
TPC qualifications/last verification M n/a n/a P n/a n/a
Primary test information M n/a n/a P n/a n/a
QC test information M n/a n/a n/a n/a n/a
Manufacturing changes M n/a n/a n/a n/a n/a
Reduced-frequency testing qualification M n/a n/a n/a n/a n/a
Sales information P n/a n/a n/a n/a n/a
Total CWP production P n/a n/a n/a n/a n/a
Footnote 6-1

Panels include laminated products once the relevant provisions come into force

Return to footnote 1 referrer

Footnote 6-2

Finished goods include component parts that are sold separately

Return to footnote 2 referrer

Footnote 6-3

This declaration pertains only to the composite wood panel core or platform

Return to footnote 3 referrer

For testing-exempt laminated products, in other words those that use a NAF or phenol-formaldehyde resin to attach the veneer to the core or platform, the record of certification pertains to the composite wood product core or platform and not to the laminated product as a whole. Likewise, manufacturers and importers of finished goods that incorporate exempt laminated products into the finished goods must maintain the record of certification for the composite wood core or platform used in the laminated product.

While the Minister can request any of these records from the regulated parties, the Regulations also allow purchasers of composite wood panels or laminated products to request information from the manufacturer on the primary tests of the lot they purchased.

9. For more information

Please direct any outstanding questions on the regulations to formaldehyde-formaldehyde@hc-sc.gc.ca.

10. ANNEX I: A non-exhaustive list of some commonly used test methods for quality control testing

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