SGS : Canada Issues Guidance for Formaldehyde Emissions from Composite Wood Products

SG 099.22

Health Canada has published a guideline to assist stakeholders with additional guidance and explanation for formaldehyde emissions from composite wood products.

In July 2021, Canada issued the Formaldehyde Emissions from Composite Wood Products Regulations (SOR 2021-148, the Regulation) to regulate formaldehyde emissions from composite wood panels and laminated products as well as finished goods containing such products (SafeGuardS 97/21).

The Regulation aims to align to the extent possible with the Toxic Substances Control Act, Title VI 'Formaldehyde Standards for Composite Wood Products' in the United States (U.S.) and contains provisions relating to, among other things, formaldehyde emission standards in hardwood plywood (HWPW), medium-density fiberboards (MDF), thin-MDF, particleboards (PB) and laminated products. It also includes third-party certification programs, incentives for products manufactured from ultra-low emitting formaldehyde resins (ULEF) and no added-formaldehyde-based resins (NAF), as well as product labeling, Accreditation Bodies (AB) and Third-Party Certifiers (TPC).

The Regulation will come into force on January 7, 2023, but testing and third-party certification requirements for laminated products will apply from January 7, 2028.

On August 12, 2022, Health Canada announced its guidance document to assist stakeholders to comply with the Regulation. The guideline contains, among other things, important information for economic operators to comply with the law. It:

• Exempts woody veneers glued to cores other than composite wood product cores such as lumber core
• Exempts products composed of composite wood product cores glued to thin layers of material other than wood veneer, e.g.:
• • 'Laminate flooring' that includes a top layer that has an imprinted, textured image made to look like real wood, or
  • 'Laminated kitchen counters,' which typically consist of a plastic layer glued to PB
• Requires primary testing, using ASTM E1333 (large chamber) or ASTM D6007 (small chamber), to be carried out four times annually during specific periods by an accredited laboratory, as well as quality control (QC) testing
• Provides a non-exhaustive list of methods for QC testing (see Table 1 below)
• Details the QC testing frequency based on weekly and monthly production
• Summarizes the criteria for reduced-frequency testing for the use of NAF and ULEF resins
• Emphasizes that certification is a prerequisite for composite wood panels and laminated products prior to importation or sold in Canada
• Indicates the requirement for all manufacturers, importers and sellers of composite wood products self-identify with Minister of the Environment and Climate Change Canada within 60 days of the Regulations coming into force
• Details the record keeping requirements for different economic operators:
• • Panel manufacturers, including those for laminated products
  • Test-exempt laminated product manufacturers
  • Finished goods manufacturers, including those for component parts that are sold separately
  • Panel importers, including those for laminated products
  • Finished goods importers
  • Sellers
• Emphasizes that the label can be in the form of a stamp, tag or sticker and must be securely fastened to the product and clearly visible and legible - products with a TSCA Title VI label will be accepted as long as they meet the bilingual labeling requirements in English and French (see Table 2 below)
• Indicates that every composite wood panel must be labeled, either individually or in a bundle - panel manufacturers, importers or sellers must have a method, such as color-coded edge markings, to link the product to the proper label information on the bundle, if a composite wood panel is not individually labeled
• Specifies that manufacturers and importers of laminated products and finished goods must either individually label each finished good or have a label on every bundle or box of the finished goods
• Reiterates that a label is not required for finished goods that incorporate panels or laminated products with no more than 929 cm² of its largest surface area

Highlights of several of the commonly used methods for quality control testing, as well as labeling elements for composite wood panels, laminated products and finished goods, are summarized in Tables 1 and 2.

Guidance Document on the Formaldehyde Emissions from Composite Wood Products Regulation, August 12, 2022 Annex I: A non-exhaustive list of some commonly used test methods for quality control testing (per text in guidance document)
Standard	Title
ASTM D6007-14	Standard Test Method for Determining Formaldehyde Concentrations in Air from Wood Products using a Small-Scale Chamber
ASTM D5582-14	Standard Test Method for Determining Formaldehyde Levels from Wood Products Using a Desiccator
BS EN ISO 12460-3:2015	Wood-based panels - Determination of formaldehyde release - Part 3: Gas analysis method
BS EN ISO 12460-5:2015	Wood-based panels - Determination of formaldehyde release - Part 5: Extraction method (called the perforator method)
JIS A 1460:2015	Determination of the emission of formaldehyde from building boards - Desiccator method
--	Dynamic Micro-Chamber computer integrated formaldehyde test system, User Manual Copyright 2007 or 2012

Table 1

Guidance Document on the Formaldehyde Emissions from Composite Wood Products Regulation, August 12, 2022 Table 5 'Labeling elements for composite wood panels, laminated products, and finished goods (per text in guidance document)
Composite Wood Panels	Laminated Products and Finished Goods¹
Name of manufacturer Lot number One of the following compliance statements: 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 Name of TPC (or US EPA number assigned to TPC) Optional information: 'NAF/SFA' or 'no added formaldehyde/sans formaldéhyde ajouté 'ULEF /TFEF' or 'ultra-low-emitting formaldehyde/á très faibles émissions de formaldéhyde'	Name of manufacturer, importer or seller Date of manufacture One of the following compliance statements: 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 Optional information: 'NAF/SFA' or 'no added formaldehyde/sans formaldéhyde ajouté 'ULEF/TFEF' or 'ultra-low-emitting formaldehyde/á très faibles émissions de formaldéhyde'
¹Finished goods include component parts that are sold separately

Table 2

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