n an effort to improve public health and safety in Canada, in July 2022, the Canadian government issued the Formaldehyde Emissions from Composite Wood Products Regulations (SOR 2021-148, the Regulation) that are designed to reduce the dangerous levels of formaldehyde emissions from composite wood panels and laminated products and finished goods containing such products.
The Regulation comes into effect on January 7, 2023. It is part of a larger initiative that was put in place to protect the environment and public health by controlling the release of toxic pollutants. Testing and third-party certification requirements for laminated products will come into effect on January 7, 2028.
In light of this, Health Canada recently updated its guidance document to assist manufacturers and other stakeholders in understanding and complying with the Regulation when it comes time for them to start testing their products for formaldehyde emissions. The document provides detailed information about testing procedures, data collection and analysis techniques, recordkeeping requirements, and other reporting needs related to composite wood panels or laminated products.
Exemptions to the Regulation
The guidance document exempts the following from compliance with the new law:
- Woody veneers glued to cores other than composite wood product cores, such as lumber core
- Products composed of composite wood product cores glued to thin layers of material other than wood veneer, such as:
- Laminate flooring that includes a top layer that has an imprinted, textured image made to look like real wood, and
- Laminated kitchen counters, which typically consist of a plastic layer glued to PB
According to the guidance document, preliminary testing using ASTM E1333 (large chamber) or ASTM D6007 (small chamber) is to be carried out four times annually during specific periods by an accredited laboratory, in addition to quality control (QC) testing. The guidance document also details the QC testing frequency based on weekly and monthly production and provides a non-exhaustive list of methods for QC testing (see Table 1 below).
Certification is a prerequisite for importing or selling composite wood panels and laminated products in Canada. This certification requires verification from a qualified third-party certifier (TPC) that the formaldehyde emissions from the particular product types did not exceed the applicable limit based on at least 5 primary and 5 QC tests. Ongoing verification by a qualified TPC is required to maintain certification. For more information on the roles and responsibilities of the TPC, see Third-party certifiers: composite wood products containing formaldehyde.
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 at email@example.com within 60 days of the Regulations coming into effect. 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 guidance document details the recordkeeping requirements for different stakeholders, including:
- 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
Manufacturers and importers must label all applicable composite wood panels, laminated products, and the finished goods that incorporate them. The labels must state 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. Labels can be in the form of a stamp, tag or sticker and must be securely fastened to the product and visible with legible text.
Table 2 below summarizes the required labeling elements for all composite wood products, where the Regulations are referred to as “CANFER” for labelling.
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