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Composite Wood Products Regulation Advisory: 11- 01 

EXTENSION OF SELL-THROUGH DATES FOR: 

DISTRIBUTORS, IMPORTERS, FABRICATORS, AND RETAILERS OF FINISHED GOODS 

CONTAINING PHASE 1 HARDWOOD PLYWOOD - VENEER CORE 

AND 

DISTRIBUTORS OF PHASE 1 PARTICLEBOARD AND 

MEDIUM DENSITY FIBERBOARD PANELS 

 

The California Air Resources Board (ARB) is delaying the enforcement of two sell-through dates that 

affect distributors, importers, fabricators, and retailers of finished goods made with Phase 1 hardwood 

plywood - veneer core (HWPW-VC), and distributors of Phase 1 particleboard (PB) and medium 

density fiberboard (MDF) panels. The extension for distributors, importers, fabricators, and retailers 

of finished goods is through June 30, 2012, and affects businesses that use HWPW-VC panels 

(i.e., fabricators) to make finished goods, as well as businesses that distribute or sell these goods in 

California. In addition to the finished goods extension, this advisory also provides an extension for 

distributors of Phase 1 PB and MDF panels through December 31, 2011, aligning this date with the 

sell-through date for panel retailers. The extensions will not change the anticipated emissionreduction benefits, because ARB had expected that these panels and finished goods would have 

already been sold if the economy and turnover of inventories had not slowed. The formaldehyde 

emission standards affecting newly manufactured composite wood products will not be delayed. 

ARB recognizes that many businesses that sell and supply panels and finished goods containing 

composite wood products have been and continue to be adversely affected by the economic 

downturn. Therefore, ARB is providing additional time to allow businesses to deplete their existing 

inventories manufactured before the more stringent Phase 2 emission standards became effective. 

Definitions 

 “Phase 1 PB and MDF panels” means PB and MDF panels manufactured before 

January 1, 2011, that comply with the Phase 1 emission standards specified in ARB’s Airborne 

Toxic Control Measure To Reduce Formaldehyde Emissions From Composite Wood Products 

(the “Regulation”.) 

 “Finished goods” means any good or product, other than a panel, containing HWPW, PB, or 

MDF. Most of these panels are used to make finished goods, such as furniture, cabinets, 

shelving, countertops, flooring, and moldings in homes. 

 “Phase 1 finished goods containing HWPW-VC” means finished goods that contain 

Phase 1 HWPW-VC. 

 “Extension” and “delay in enforcement” means that ARB will not enforce the sell-through 

dates for: 

- Finished goods made with Phase 1 HWPW-VC panels until after June 30, 2012; and 

- Phase 1 PB and MDF panels sold by distributors until after December 31, 2011. 

Regulatory Advisory 

May 2011 
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Background 

Businesses required to comply with the Regulation are: manufacturers, distributors, importers, 

fabricators, and retailers of composite wood product panels and finished goods that contain regulated 

products. The Regulation establishes a phased-in approach to formaldehyde emission standards 

with the most stringent standards going into effect between January 2010 and July 2012. 

To comply with the Regulation, panels must meet the formaldehyde emission standards specified in 

the Regulation and must have been produced by a manufacturer that has been certified by an 

ARB-approved third party certifier. Similarly, panels used to make finished goods must also have 

been certified as complying with the emission standards. 

The Regulation has provisions that allow businesses a limited amount of time to sell or use 

non-compliant composite wood products if those products were manufactured before the effective 

date of each emission standard. This is referred to as the sell-through period. Allowing businesses 

time to sell or use existing inventories is intended to provide a smoother market transition to each 

new emission standard. If a composite wood product was manufactured after an applicable effective 

date, the product must meet the applicable emission standard. 

What other issues should distributors, importers, fabricators, and retailers be aware of? 

Finished goods often contain a combination of different composite wood products. The one-year 

extension will alleviate confusion caused by the current staggered sell-through dates, especially with 

regard to the labeling requirements in the Regulation. 

No extensions have been provided to manufacturers of composite wood product panels. All newly 

manufactured HWPW-VC, PB, and MDF must be Phase 2 compliant at this point in time. All 

hardwood plywood with composite core (HWPW-CC) and thin MDF (MDF with a maximum thickness 

of eight millimeters) currently being manufactured for California must be at least Phase 1 compliant. 

ARB staff has found that manufacturers currently have the capacity to produce ample quantities of 

certified panels to meet the market demand for both Phase 1 and Phase 2 products. 

What are the extended sell-through dates? 

As shown in the following table, the sell-through date is extended until June 30, 2012, for distributors, 

importers, fabricators, and retailers of finished goods containing Phase 1 HWPW-VC. For distributors 

of Phase 1 PB and MDF panels, the sell-through date is extended until December 31, 2011. 
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Phase 1 Sell-through Dates for Distributors, Importers, Fabricators, and Retailers of 

Finished Goods Containing HWPW-VC Panels, and for Distributors of PB and MDF Panels 

 

 Dates Specified 

in Regulation Extended Dates 

Number of Months 

Extended from 

Original Date 

Distributors, 

importers, 

fabricators, and 

retailers of 

finished goods 

containing 

Phase 1 

HWPW-VC 

 

June 30, 2011 June 30, 2012 

 

12 

Distributors of 

Phase 1 PB and 

MDF panels 

May 31, 2011 December 31, 2011 7 

For more information 

The Regulation may be viewed at: http://www.arb.ca.gov/toxics/compwood/compwood.htm. 

Appendix 1 of section 93120.12 of the Regulation sets forth the sell-through provisions. Additional 

information about complying with the Regulation, including staff contacts, fact sheets and 

Frequently Asked Questions, is available on this website.