The California Air Resource Board (CARB) has issued a notice clarifying its position on the applicability of wood packaging materials (i.e., to pallets and crates) under the Composite Wood Products Airborne Toxic Control Measure (ATCM).
The advisory is designed to provide guidance with labeling requirements for manufacturers, fabricators, importers, distributors and retailers of composite wood products sold in California, according to a release from the Recreation Vehicle Industry Association (RVIA).
The advisory reads, “Since wood packaging may contain composite wood products (i.e., hardwood plywood, medium density fiberboard, and/or particleboard), wood packaging would be ‘finished goods’ subject to the ATCM if one were to take a strict interpretation of the ATCM’s definition of ‘finished goods.’ However, it was not CARB’s intent to regulate wood packaging as ‘finished goods.’
To be consistent with this intent and provide fairness to the regulated community, CARB staff interprets the ATCM as not applying to wood packaging.
These products are not subject to any of the requirements of the ATCM. By ‘wood packaging’ we mean pallets, skids, boxes, crates, and containers used for handling, sorting, storing, shipping, and transporting goods,” CARB stated.
On June 12, 2008, RVIA’s board of directors set an effective date for member manufacturers to begin using wood products that meet CARB’s new formaldehyde emissions level as a mandatory condition of membership.
Effective Jan. 1, 2009, RVIA member manufacturers are required to build units for sale in all 50 states using wood products that comply with the CARB standard’s emission limits. By July 1, 2010, they must use wood that has been certified by an appropriate third party as meeting the CARB standard.