Formaldehyde Emission Standards: CARB P2, TSCA Title VI, E0, ENF Explained
This guide explains four commonly referenced formaldehyde compliance frameworks and emission classifications from the perspective of a manufacturer of PVC and composite building products. It covers what each standard regulates, how the emission limits compare, which test methods apply, and — crucially for PVC wall panel buyers — whether these standards even apply to your product.
This article is informational guidance, not legal or certification advice. Regulatory requirements depend on the product type, destination market and project specification. Always confirm current requirements with the certification body, customs broker and project team.
1. Why Formaldehyde Emission Standards Exist
Formaldehyde is a volatile organic compound (VOC) used in the resins and adhesives that bond composite wood panels together. Urea-formaldehyde (UF) resin, the most common adhesive in particleboard and MDF production, can release free formaldehyde over time — a process that continues well after manufacturing.
Elevated concentrations of formaldehyde in indoor air may be associated with indoor air quality concerns. Regulators in California, the United States, the European Union, Japan and China have each developed formaldehyde emission standards for composite wood products, with the shared goal of limiting exposure in indoor environments.
The key point for building product buyers is this: formaldehyde emission standards target the composite wood panels used in furniture, cabinetry, flooring and wall systems — not all building materials equally. A product made from a material that does not use formaldehyde-based resins may fall outside the scope of these regulations entirely. Understanding which products are regulated, and which are not, is the first step in navigating compliance correctly.
2. The Four Standards at a Glance
| Framework / Grade | Type | Region | Main scope |
|---|---|---|---|
| CARB ATCM Phase II (93120) | Regulation | California, USA | Composite wood products |
| TSCA Title VI (40 CFR Part 770) | Federal regulation | United States | Composite wood products |
| E0 | Emission grade | China / commercial use elsewhere | Wood-based panels |
| ENF (GB/T 39600-2021) | Emission grade | China | Strictest grade (≤0.025 mg/m³); distinct from NAF resin category |
| Concept | What it represents |
|---|---|
| E1 / E0 / ENF | Formaldehyde emission performance grades |
| NAF | No-Added-Formaldehyde — a resin / adhesive category |
| ULEF | Ultra-Low-Emitting Formaldehyde — a resin / product category |
| CARB P2 / TSCA Title VI | US composite wood product regulatory frameworks |
Note: emission grades (E1/E0/ENF) and resin categories (NAF/ULEF) describe different dimensions. A product can carry an ENF emission grade while being produced with various resin systems; “ENF” is not a synonym for a no-added-formaldehyde resin.
All four frameworks primarily target composite wood products — panels made by bonding wood fibres, particles or veneers with adhesives. Products that do not contain composite wood (such as pure PVC panels, metal panels, or glass) may fall outside the scope of these regulations. This does not mean they are exempt from all indoor air quality requirements — it means the specific compliance pathway is different. Formaldehyde compliance (CARB/TSCA/E0/ENF) and broader VOC or indoor-air-quality compliance (for example CDPH, GREENGUARD or FloorScore programs) are related but separate issues; a product outside the TSCA Title VI scope may still be evaluated under a project-specific VOC or indoor air quality standard. See Section 9 for the PVC wall panel discussion.
3. CARB Phase 2 (ATCM 93120): The California Origin
The California Air Resources Board (CARB) adopted the Airborne Toxic Control Measure (ATCM) Section 93120 in April 2007, establishing formaldehyde emission limits for composite wood products sold, supplied, manufactured or used in California. The regulation was implemented in two phases: Phase 1 (P1) served as an interim step, and Phase 2 (P2) set the stricter limits that are now the operative standard.
CARB Phase 2 emission limits
| Composite Wood Product | Emission Limit (ppm) |
|---|---|
| Hardwood plywood (HWPW) — veneer core or composite core | 0.05 |
| Particleboard (PB) | 0.09 |
| Medium-density fibreboard (MDF) | 0.11 |
| Thin MDF (≤ 8 mm thickness) | 0.13 |
The emission standards are expressed in ppm using the ASTM E1333 large-chamber test method; ASTM D6007 may be used as a secondary method where the applicable equivalency requirements are met. The regulation also established a third-party certification (TPC) program: panel producers must be certified by a CARB-approved TPC, with quarterly emission testing and annual audits.
NAF and ULEF exemptions
CARB ATCM recognises two resin categories that qualify for reduced testing frequency or exemption from ongoing certification:
- NAF (No-Added-Formaldehyde) — resins formulated without added formaldehyde as part of the resin cross-linking structure, subject to the applicable regulatory definition and certification requirements.
- ULEF (Ultra-Low-Emitting Formaldehyde) — adhesives that may contain formaldehyde but emit at levels below the CARB P2 limits.
Both designations must be verified by a CARB-approved TPC. A manufacturer cannot self-declare NAF or ULEF status without TPC verification.
Labelling requirements
Each panel or bundle of composite wood products must be labelled with: the manufacturer name, lot or batch number, a compliance marking (Phase 2, ULEF or NAF), and the CARB-assigned TPC number. Importers and fabricators must maintain records and pass compliance information through the supply chain.
4. TSCA Title VI: The Federal Standard
In July 2010, the US Congress passed the Formaldehyde Standards for Composite Wood Products Act, which added Title VI to the Toxic Substances Control Act (TSCA). The US Environmental Protection Agency (EPA) finalised the implementing regulation in December 2016, published as 40 CFR Part 770.
TSCA Title VI adopted emission limits identical to CARB Phase 2 — the same values for HWPW (0.05 ppm), PB (0.09 ppm), MDF (0.11 ppm) and thin MDF (0.13 ppm). The federal rule also aligned many of the certification, labelling and recordkeeping requirements with the California regulation.
Key compliance dates
| Date | Milestone |
|---|---|
| May 22, 2017 | TSCA Title VI rule effective |
| June 1, 2018 | Composite wood products must be certified by an EPA-recognised TPC |
| March 22, 2019 | TSCA Title VI label required; CARB Phase 2 certification alone does not satisfy the federal requirement; import certification begins |
| March 22, 2024 | Non-exempt laminated products must be tested and certified as hardwood plywood |
Who is regulated?
TSCA Title VI applies to the full supply chain: panel producers (manufacturers and importers of composite wood panels), fabricators (manufacturers of finished goods containing composite wood), distributors, retailers and importers. Each entity has specific recordkeeping and labelling obligations.
Products exempt from TSCA Title VI
The regulation explicitly excludes certain products, including: hardboard, structural plywood, structural panels, oriented strand board (OSB), structural composite lumber, glued laminated lumber, prefabricated wood I-joists, finger-jointed lumber, curved plywood, military-specified plywood and wood packaging (pallets, crates). Products that do not contain any composite wood panels are also outside the scope.
5. CARB P2 vs TSCA Title VI: Key Differences
Because TSCA Title VI was modelled on CARB Phase 2 and adopted identical emission limits, the two are often described as “the same standard.” This is true for the emission values themselves, but there are important differences in scope and requirements:
| Aspect | CARB Phase 2 (ATCM 93120) | TSCA Title VI (40 CFR 770) |
|---|---|---|
| Geographic scope | California | All 50 US states (federal) |
| Emission limits | HWPW 0.05, PB 0.09, MDF 0.11, thin MDF 0.13 ppm | Identical to CARB P2 |
| Label required | CARB P2 label (pre-March 2019 transition) | TSCA Title VI label (mandatory since March 2019) |
| Import certification | Not a specific CARB requirement | Importers of regulated composite wood products, component parts and finished goods containing them must comply with the TSCA Title VI import certification requirements |
| Laminated products | Addressed under CARB | Since March 2024, non-exempt laminated products (as defined under TSCA Title VI) must be certified as hardwood plywood |
| TPC recognition | CARB-approved TPCs | EPA-recognised TPCs (many CARB-approved TPCs are also EPA-recognised) |
| NAF / ULEF exemptions | Recognised under CARB ATCM | Recognised under TSCA Title VI with aligned criteria |
For products sold in the US, the operative label since March 2019 is TSCA Title VI, not CARB P2. The emission limits are the same, but the federal rule adds import certification, nationwide scope and the laminated product requirement. Buyers in California may still reference “CARB P2” in specifications because the California standard was the original template, but the compliance documentation should reflect the current TSCA Title VI framework.
6. E0: A Label with Multiple Meanings
“E0” is one of the most frequently encountered — and most frequently misunderstood — formaldehyde emission labels in the building materials trade. The confusion arises because E0 is used in multiple regional contexts with different definitions, test methods and regulatory status.
European E0
In the European system, formaldehyde emission classes for wood-based panels were originally defined as E1 and E2 under EN 13986 (construction wood panels). E1 is the minimum legal requirement for indoor use in most EU member states. E0 is not a harmonized European regulatory grade equivalent to the E1 class under EN 13986; some manufacturers and suppliers use “E0” as a commercial term to indicate emissions below the E1 threshold, but the meaning and test method should always be checked against the supplier’s test report. Although the E1 threshold of 0.124 mg/m³ is used in both the European and Chinese systems, the applicable standards, product scope and regulatory context are not necessarily identical.
Chinese E0 (GB/T 39600-2021)
In China, the national standard GB/T 39600-2021 (“Formaldehyde Release Grading for Wood-Based Panels and Their Products”) defines three grades: E1 (≤ 0.124 mg/m³), E0 (≤ 0.050 mg/m³) and ENF (≤ 0.025 mg/m³), all measured using the 1 m³ climate chamber method. E0 in this context is a defined grade within the Chinese classification system, not a generic label.
Japanese F-four-star (F★★★★)
Japan uses a star rating system under JIS standards. F★★★★ (≤ 0.3 mg/L, JIS A 1460 desiccator method) is the strictest Japanese grade and is sometimes informally equated with E0 or better. However, because the test method (desiccator) and units (mg/L) differ from both the European chamber method and the Chinese climate chamber method, direct numerical comparison is not straightforward.
If a supplier states a product is “E0” without specifying the standard, test method and unit, the claim is ambiguous. It could mean ≤ 0.5 mg/L (desiccator), ≤ 0.050 mg/m³ (climate chamber) or something else entirely. When evaluating an E0 claim, always ask: which standard defines this grade, which test method was used, and in what unit is the result expressed?
7. ENF: The Strictest Grade Under GB/T 39600-2021
ENF is the strictest formaldehyde emission grade defined in the Chinese national standard GB/T 39600-2021, which took effect on 1 October 2021. The ENF limit is ≤ 0.025 mg/m³, measured using the 1 m³ climate chamber method specified in GB 18580-2017.
ENF is the strictest formaldehyde emission grade under GB/T 39600-2021, with a limit of ≤0.025 mg/m³. The ENF grade describes the measured emission performance of the wood-based panel or product; it should not be treated as a direct synonym for a no-added-formaldehyde (NAF) resin formulation. In practice, ENF-grade panels are manufactured primarily for the Chinese domestic market, where consumer demand for ultra-low-emission products has grown significantly since the standard was introduced.
How ENF compares to other standards
| Grade / Standard | Limit | Test Method | Region |
|---|---|---|---|
| ENF (GB/T 39600-2021) | ≤ 0.025 mg/m³ | 1 m³ climate chamber | China |
| E0 (GB/T 39600-2021) | ≤ 0.050 mg/m³ | 1 m³ climate chamber | China |
| E1 (GB 18580-2017, mandatory) | ≤ 0.124 mg/m³ | 1 m³ climate chamber | China |
| E1 (EN 13986 / EN 717-1) | ≤ 0.124 mg/m³ | Chamber (EN 717-1) | Europe |
| CARB P2 / TSCA Title VI (HWPW) | 0.05 ppm | ASTM E1333 large chamber | USA |
| F★★★★ (JIS A 1460) | ≤ 0.3 mg/L | Desiccator | Japan |
Comparing these limits directly is tempting but requires caution: the test methods, chamber sizes, loading ratios, air exchange rates and units all differ. ENF’s 0.025 mg/m³ under the Chinese climate chamber method and CARB P2’s 0.05 ppm under ASTM E1333 are not directly interchangeable without conversion and an understanding of the test-condition differences. What can be said is that ENF represents one of the strictest formaldehyde emission thresholds among the major global classification systems.
It is also worth noting that GB 18580-2017, the mandatory Chinese standard for indoor-use wood-based panels, sets E1 (≤ 0.124 mg/m³) as the minimum legal requirement. E0 and ENF are voluntary classification grades defined in the companion standard GB/T 39600-2021 — they are not mandatory but are widely used in the Chinese market as quality differentiators.
8. Why Test Methods Matter (And Why Numbers Cannot Always Be Compared)
One of the most common sources of confusion in formaldehyde compliance is comparing numbers from different test methods. The same product tested under three different methods may yield three different numerical results, all expressed in different units.
Major test methods at a glance
| Method | Standard | Principle | Unit | Typical Use |
|---|---|---|---|---|
| Large chamber | ASTM E1333 | Product in large chamber, controlled conditions, steady-state measurement | ppm | US composite wood (primary method under CARB/TSCA) |
| Small chamber | ASTM D6007 | Small-scale chamber; recognised as equivalent to E1333 where equivalency requirements are met | ppm | US composite wood (secondary / QC method) |
| Chamber (1 m³) | EN 717-1 / GB 18580-2017 | Small chamber, controlled temperature/humidity/air exchange | mg/m³ | Europe / China |
| Desiccator | JIS A 1460 | Sealed container with water absorber, shorter duration | mg/L | Japan |
| Perforator | EN 120 | Chemical extraction method historically used for certain wood-based panels; applicability depends on the product and the applicable regulatory/standards framework | mg/100g | Europe (where applicable) |
| CDPH chamber | CDPH Standard Method v1.2 | Environmental chamber, multi-day VOC collection | µg/m³ | California / US building-product VOC and indoor-air-quality programs |
CDPH Standard Method v1.2, GREENGUARD, FloorScore and LEED are distinct frameworks: CDPH is a test method, GREENGUARD is a UL environmental product certification program, FloorScore is a flooring-specific indoor air quality certification, and LEED is a green building rating system that may recognise qualifying emissions certifications. They are not the same thing and should not be grouped as one standard.
The practical implication: a formaldehyde result of 0.05 ppm (ASTM E1333) and a result of 0.050 mg/m³ (EN 717-1) may look similar, but they come from different test setups with different chamber volumes, loading ratios and air exchange rates. Treat them as separate data points within their respective standard frameworks, not as directly equivalent values.
When a project specification requires formaldehyde data, identify: (a) which standard and test method the specification references, (b) which edition of the standard applies, and (c) what unit and threshold the project requires. Then request a test report that matches that framework.
9. The PVC Question: Do These Standards Apply to PVC Wall Panels?
This is the question that matters most for buyers sourcing PVC marble wall panels, and the answer is more nuanced than a simple yes or no.
What the regulations cover
CARB Phase 2 and TSCA Title VI regulate formaldehyde emissions from composite wood products: hardwood plywood, particleboard and MDF. The regulation targets these materials because they are bonded with formaldehyde-based resins (primarily urea-formaldehyde) that can release free formaldehyde over time.
What PVC wall panels are
PVC wall panels are extruded from thermoplastic polyvinyl chloride resin. The manufacturing process does not involve wood fibres, particles or veneers bonded with urea-formaldehyde resin. PVC resin is a polymer melt-formed under heat and pressure, not an adhesive-bonded composite. As a result, pure PVC wall panels without any composite wood substrate generally fall outside the scope of CARB P2 and TSCA Title VI.
For a PVC wall panel that contains no composite wood, the appropriate compliance statement is that the product contains no regulated composite wood and therefore is not subject to CARB Phase 2 or TSCA Title VI composite wood formaldehyde emission requirements. This is a material composition statement, not a certification. It means the product falls outside the scope of the regulation — not that it has been “CARB P2 certified.” Suppliers who present a pure PVC panel as “CARB P2 certified” may be conflating scope exemption with active certification, which can confuse buyers and misrepresent the compliance status.
PVC, composite-wood-backed and WPC panels compared
| Requirement | Pure PVC wall panel | PVC + MDF / composite backing | WPC extrusion |
|---|---|---|---|
| Contains regulated composite wood | No | Yes | Not necessarily |
| CARB P2 / TSCA Title VI | Generally outside scope | Potentially applicable | Product-specific |
| Material declaration | Recommended | Important | Recommended |
| Formaldehyde test | Project-dependent | Often relevant | Project-dependent |
| VOC / IAQ testing | Project-dependent | Project-dependent | Project-dependent |
The key question for any panel is whether it contains a regulated composite wood product (hardwood plywood, particleboard or MDF). If it does not, CARB P2 / TSCA Title VI generally does not apply to that component, but the project may still call for a formaldehyde emission test or a broader VOC / indoor-air-quality assessment.
When PVC products may still involve formaldehyde
While the PVC resin itself does not use formaldehyde-based adhesives, some PVC-adjacent products or configurations may still be relevant to formaldehyde compliance:
- WPC (wood-plastic composite) panels — contain wood flour or fibre blended with PVC or other thermoplastics. The presence of wood fibre or wood flour alone does not automatically make a product a regulated composite wood product under TSCA Title VI; the key question is whether the product falls within the regulatory definitions of hardwood plywood, particleboard or MDF, or incorporates one of these regulated composite wood products. Depending on the formulation and adhesive system, formaldehyde emissions may be relevant.
- Composite wood backing or substrate — if a decorative PVC panel is laminated to an MDF or particleboard core, the composite wood component is regulated.
- Installation adhesives — some adhesives used to install wall panels may contain or emit formaldehyde. These are typically regulated under separate VOC content or emission standards, not under CARB P2 / TSCA Title VI.
- Surface coatings and decorative films — some printing inks, lacquers or laminating adhesives may contribute trace formaldehyde, though usually at very low levels.
What buyers should request
For pure PVC wall panels, buyers should request:
- A material composition statement confirming the product does not contain regulated composite wood (HWPW, PB or MDF).
- If the project specification or green building rating system requires formaldehyde emission data regardless of material type, a formaldehyde emission test report from an ISO/IEC 17025 accredited laboratory, using the test method referenced in the project specification (e.g., CDPH Standard Method v1.2, EN 717-1, or ASTM E1333).
- If the product is a WPC panel or incorporates a composite wood component, the appropriate CARB P2 / TSCA Title VI certification documentation for the composite wood element, plus a TPC certification number that can be verified.
For a practical framework on verifying any type of test report — including formaldehyde, fire and VOC reports — see our guide on how to verify a PVC wall panel fire test report. The same verification principles apply: check laboratory accreditation, match the product to the report, confirm the standard version, and verify the data is internally consistent.
10. How to Verify Formaldehyde Compliance
For composite wood products (CARB P2 / TSCA Title VI)
- Check the label: The panel or bundle must be labelled with the manufacturer name, lot number, TPC identification number and a TSCA Title VI compliance statement.
- Verify the TPC: The TPC must be EPA-recognised (for US market) or CARB-approved (for California). EPA maintains a list of recognised TPCs and accreditation bodies.
- Request the TPC certificate: The panel producer should be able to provide their current TPC certification, including the certification scope (which products and which facilities are covered).
- Check NAF / ULEF status: If the product claims NAF or ULEF exemption, verify this is backed by TPC verification, not a self-declaration.
- Maintain records: Importers must keep TPC certification records for at least three years.
For non-composite-wood products (e.g., pure PVC panels)
- Request a material composition statement confirming the product does not contain regulated composite wood (HWPW, PB or MDF).
- If emission data is required by the project specification or green building rating system, request a formaldehyde emission test report from an ISO/IEC 17025 accredited laboratory, using the test method referenced in the specification.
- Verify the laboratory is accredited for the specific test method, not just generally accredited. The accreditation scope should cover the relevant standard (e.g., ASTM E1333, EN 717-1, CDPH Standard Method v1.2).
- Match the product in the report to the product being purchased — same name, thickness, construction and surface treatment.
For WPC or hybrid products
If the product contains both PVC and wood fibre (WPC), or if a PVC decorative surface is laminated to a composite wood core, the compliance pathway depends on the construction:
- If the product contains a regulated composite wood panel (HWPW, PB or MDF), that component must be TSCA Title VI certified.
- If the product is a WPC extrusion that does not use a regulated composite wood panel as a substrate, the CARB P2 / TSCA Title VI composite wood requirements may not apply, but the buyer should still request emission test data if the specification requires it.
- Confirm the specific construction with the supplier and, if in doubt, consult the certification body or a qualified compliance consultant.
11. Common Mistakes to Avoid
1. Presenting a scope exemption as certification
A pure PVC panel that contains no composite wood is not “CARB P2 certified” — it is outside the scope of the regulation. The correct statement is that the product contains no regulated composite wood. Presenting scope exemption as active certification can mislead buyers and create compliance documentation that does not match the product’s actual regulatory status.
2. Using “E0” without specifying the standard
As explained in Section 6, E0 has different definitions in different regional contexts. An E0 claim without a referenced standard, test method and unit is ambiguous. Always specify which classification system the E0 grade comes from (e.g., GB/T 39600-2021, EN 717-1, JIS A 1460).
3. Comparing emission limits across different test methods
0.05 ppm (ASTM E1333) and 0.050 mg/m³ (EN 717-1) are not the same measurement. They come from different test setups with different conditions. Compare results within the same standard framework, and if cross-comparison is necessary, use published correlation studies — not a simple unit conversion.
4. Assuming CARB P2 and TSCA Title VI are fully interchangeable
The emission limits are identical, but the federal rule (TSCA Title VI) adds import certification, nationwide scope and the laminated product requirement. Since March 2019, the TSCA Title VI label is the operative one for the US market. Buyers who still reference “CARB P2” in specifications should ensure the compliance documentation reflects the current TSCA Title VI framework.
5. Forgetting that WPC panels may involve formaldehyde
WPC (wood-plastic composite) panels contain wood flour or fibre. While the primary binder is typically thermoplastic, some formulations may use auxiliary adhesives or additives that could contribute trace formaldehyde. If the project specification requires formaldehyde emission data, request a test report rather than assuming the WPC construction automatically qualifies as “formaldehyde-free.”
6. Overlooking installation materials
A wall panel that itself has negligible formaldehyde emissions can still contribute to indoor air quality concerns if installed with a high-formaldehyde adhesive. If adhesives, primers or sealants are part of the installation, they should also be evaluated for formaldehyde and VOC content under the relevant standards.
Confirming Formaldehyde Compliance for Your Project
Send us your project specification or required formaldehyde standard. We can review the product type and let you know what material composition information, test reports or certification documents are available for the specific Homax Decor product.
Related Guides
- GREENGUARD Gold vs FloorScore: Which VOC Certification Does Your Project Need?
- California Prop 65 Compliance for PVC Wall Panels and Building Materials
- How to Verify a PVC Wall Panel Fire Test Report
- ASTM E84 Class A PVC Wall Panels: What North American Buyers Need to Know
- WPC Wall Panels: Product Range Overview
12. Frequently Asked Questions
What is the difference between CARB Phase 2 and TSCA Title VI?
CARB Phase 2 (ATCM 93120) is a California regulation that set the original formaldehyde emission limits for composite wood products. TSCA Title VI is a federal US regulation (40 CFR Part 770) that adopted identical emission limits and added national-level requirements such as EPA-recognised third-party certification, import certification and labelling. Since March 2019, products sold in the US must carry the TSCA Title VI label. The two standards share the same emission limits but differ in scope: TSCA Title VI applies nationwide, while CARB P2 applies specifically to California and was the template for the federal rule.
Do CARB P2 and TSCA Title VI apply to PVC wall panels?
CARB Phase 2 and TSCA Title VI regulate formaldehyde emissions from composite wood products: hardwood plywood, particleboard and medium-density fibreboard (MDF). PVC wall panels are made from thermoplastic PVC resin and do not contain composite wood panels, so they generally fall outside the scope of these regulations. The correct compliance statement for a PVC wall panel without composite wood is that it contains no regulated composite wood, rather than that it is CARB P2 certified. However, if a PVC product incorporates a composite wood substrate or backing, that component may be subject to the regulation.
What do E0 and ENF mean, and are they the same standard?
E0 and ENF are formaldehyde emission grade labels used in the Chinese national standard system (GB/T 39600-2021), which classifies wood-based panels into E1 (0.124 mg per cubic metre or below), E0 (0.050 mg per cubic metre or below) and ENF (0.025 mg per cubic metre or below). They are not the same: E0 is a low-emission grade, while ENF is the strictest formaldehyde emission grade under GB/T 39600-2021 (≤0.025 mg/m³); it describes measured emission performance and is not a direct synonym for an NAF resin formulation. The term E0 is also used informally in European and Japanese markets, but the definitions and test methods differ across regions, so the label alone does not tell you which standard was applied.
Can formaldehyde emission limits from different standards be directly compared?
Not directly. Different standards use different test methods (large chamber, small chamber, desiccator, perforator), different units (ppm, mg per cubic metre, mg per litre, mg per 100g) and different test conditions (temperature, humidity, loading ratio, air exchange rate). A result expressed in ppm under ASTM E1333 cannot be compared to a result in mg per litre under JIS A 1460 without understanding the conversion factors and test-condition differences. When evaluating a product, identify the specific standard, test method and edition used, and compare results within the same framework.
What is the difference between NAF and ULEF resins?
NAF stands for no-added-formaldehyde-based resins. These are resins formulated without added formaldehyde as part of the resin cross-linking structure, subject to the applicable regulatory definition and certification requirements. ULEF stands for ultra-low-emitting formaldehyde resins, which may contain formaldehyde but emit it at levels below the CARB Phase 2 limits. Both designations are recognised under CARB ATCM and TSCA Title VI and can qualify for reduced testing frequency or exemption from certain certification requirements, subject to the applicable regulations and verification by the certifier.
How do I verify that a product meets CARB P2 or TSCA Title VI requirements?
For composite wood products subject to the regulation, the manufacturer must be certified by an EPA-recognised Third-Party Certifier (TPC). The product label must include the manufacturer name, lot number, TPC identification and compliance statement. Importers should maintain records of the manufacturer TPC certification for at least three years. For products that are not composite wood (such as pure PVC panels), the relevant documentation is typically a material composition statement confirming the absence of regulated composite wood, or a formaldehyde emission test report from an ISO/IEC 17025 accredited laboratory if the project specification requires emission data.
About Homax Decor: CENCHER INDUSTRY SHANGHAI CO., LTD. (brand: Homax Decor) is a manufacturer of PVC marble wall panels, WPC wall panels, and SPC flooring. Formaldehyde compliance documentation for a specific Homax Decor product depends on the product configuration and destination market. Contact us to confirm which documentation applies to your product and project market.
Disclaimer: This article is for informational purposes and does not constitute legal or certification advice. CARB ATCM 93120, TSCA Title VI (40 CFR Part 770), GB 18580-2017, GB/T 39600-2021 and other referenced standards are subject to amendment. Always confirm current requirements with the relevant regulatory authority, certification body and project team before relying on any documentation.
