We inform you that a guide concerning the import of composite wood products into the United States has been issued by the EPA, Environmental Protection Agency.
According to that, effective from June 1st 2018, all composite wood products that are imported into the USA must comply to the standards listed in TSCA Title VI (Toxic Substances Control Act).
TSCA Title VI sets standards on three main categories of products:
- Hardwood plywood;
- MDF
- Particle board
The rule applies to all types of above listed products and all goods containing composite wood parts.
Excluded product list is available here: 
EPA excluded products.pdf
TSCA Title VI imposes Formaldehyde emission standards to reduce human exposure to this substance.
To prove compliance to required standards, suppliers are required to submit their products to a test run by an EPA recognized third party certifier (TPC). TPC list is available here: TPC's for TSCA Title VI Cert.pdf
If standards are met, a compliance certification will be issued by the TPC. Some exceptions are made for articles containing NAF (Non-Added-Formaldehyde based) or ULEF (Ultra-Low-Emitting-Formaldehyde).
Regulation in depth
Effective since June 1st 2018:
- the rule requires that all composite wood products imported into the USA from June 1st 2018 must comply to the standards listed in TSCA Title VI.
- All products imported into the US must be labeled. The label must contain the following data: supplier’s name, production date (month and year) and a standard certification. Download a model here: label.pdf
- Importers must maintain records of all of their requests for 3 years and be able to produce the records to the EPA, if requested, within 30 days of the request. They are responsible for keeping ALL labels and maintaining detailed records of the labels, as well as which shipment and product the label was placed on, who the producer is, the date the product was produced, and the supplier (if different). The Importers/Retailers customers also have the right to the label records and by law they must be able to produce those. All commercial invoices and/or bill of lading must state that the products are TSCA Title VI Compliant.
- All invoices or bill of lading or other comparable documentations must include a declaration signed by the supplier to testify goods compliant to TSCA Title VI.
Effective on 22nd March 2019:
- All importers will be required to supply their customs broker with an Import Certification, under TSCA Section 13 form. This is a physical form that they sign stating their imported product is compliant with the TSCA standard. This form will be needed for all shipments that are to be cleared into the US. Download a model here : TSCA Certification-Single.pdf
In case the above listed requirements are not respected, your shipment operations may be slowed due to further inspections or may not be accepted inside the US territory. The importer could be fined for infringement up to $ 37,500.00.
For further information our US Customs Consultancy team is at complete disposal. You can send your inquiries to consultancy.customs.usa@dbgroup.net
We shall keep you informed about further developments.
D.B. Group
