Guides / Compliance

CARB and TSCA Title VI: What US Buyers Have to Check

July 20, 2026

If your product contains plywood, MDF or particleboard and it is going to the United States, formaldehyde rules apply. They are narrow, they are well defined and they fail in predictable ways. Almost every problem comes from the same misunderstanding: buyers ask the furniture factory whether it is compliant, when compliance lives with the company that made the board.

What is covered and what is not

Covered: hardwood plywood, medium density fibreboard including thin MDF, and particleboard. Also anything built from them, which means most cabinets, most flat pack, most drawer boxes and most cabinet backs.

Not covered: solid wood. A solid rubberwood dining chair is outside the rule entirely. So is a solid acacia butcher block.

The trap is the mixed product, which is most furniture. A solid frame with a plywood panel, a solid top with an MDF underlayer, a hardwood carcass with a particleboard shelf. The composite component pulls the whole product into scope.

Start by writing a bill of materials that names the substrate of every panel in the product. If the factory cannot produce that quickly, it is a sign the panels are bought on price from whoever has stock, which is exactly the situation the rule is designed to catch.

Who holds the certificate

The panel producer is certified by a third party certifier, which audits the mill and tests emissions. That producer issues certificates covering specific product types, grades and thicknesses.

The furniture factory buys certified board and passes the documentation along. It does not create compliance and it cannot certify itself.

So the question is not “are you CARB compliant”. It is three questions.

Which panel supplier do you use for my product? Can I see their current certificate? Does the certificate cover the exact board type, grade and thickness on my bill of materials?

That third question is where certificates quietly fail. A certificate covering 18 mm plywood does not automatically cover the 3 mm back panel, and thin MDF is a separate category in the rule.

Labelling and paperwork

Two things travel with the goods.

The product needs a label or stamp on the finished item or its packaging stating compliance with TSCA Title VI. The exact wording and placement are prescribed, so give the factory the label artwork rather than letting them compose it.

The compliance statement also has to appear on the invoice or bill of lading. This is administrative and it is skipped often enough that it is worth a line in the purchase contract.

Records matter too. Keep the panel certificates for your files, because the obligation to demonstrate compliance sits with the importer even though the certificate belongs to a mill you never dealt with.

The substitution risk

The realistic failure mode is not a factory that lies. It is a factory that runs out of the usual board mid-production and buys a substitute from whoever can deliver that week.

You will not hear about it, because from the factory’s point of view the substitute is the same 18 mm plywood. From the rule’s point of view it is an uncertified board in your product.

Two clauses prevent this. Require written notice and a new certificate before any panel supplier substitution. And require the panel certificate to be supplied with each shipment, referencing that shipment, rather than once at the start of the relationship.

If your volume justifies it, nominate the panel supplier yourself. That is common on cabinet programs and it removes the problem completely.

How this interacts with other markets

The EU does not have an identical rule, but formaldehyde class E1 is a common contractual requirement and some customers ask for E0 or equivalent. The test methods differ from the US ones, so an E1 statement is not a TSCA Title VI certificate and the reverse is also true.

If your product goes to both markets, specify both and expect the panel supplier to hold both. Most mills selling into export markets do.

Practical sequence before a first order

Ask for the bill of materials with substrates named. Ask which panel supplier and get the certificate. Check grade and thickness coverage against your bill of materials. Send the factory the label artwork and the invoice wording. Write the substitution notice clause into the contract. Then require the certificate with each shipment.

That is perhaps two hours of work before a first order and it removes one of the more expensive ways a container gets held.

For the wider compliance picture, including the legality documents that apply regardless of material, see the legality documents guide. If you are still deciding between solid and panel construction, the construction comparison covers the cost and quality trade.

Frequently asked questions

Keep reading

• Legality Documents for Wood Coming Out of Vietnam
• EUDR in Practice for Wood Coming From Vietnam