October 22, 2019

October 21, 2019

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EPA Extends Compliance Deadlines for Formaldehyde Emission Standards in Composite Wood Products

EPA published a final rule in the federal register extending the compliance deadlines in its Formaldehyde Emission Standards for Composite Wood Products as follows:

  • The date for the emission standards, recordkeeping, and labeling provisions has been extended from December 12, 2017 to December 12, 2018;

  • The date for import certification provisions has been extended from December 12, 2018 to March 22, 2019;

  • The date for laminated product producer provisions has been extended from December 12, 2023 to March 22, 2024; and

  • The conclusion of the transition period for CARB Third-Party Certifiers (TPCs) has been extended from December 12, 2018 to March 22, 2019.

This final rule, which takes effect on October 25, 2017, will provide manufacturers with additional time to adjust business processes and record-keeping practices to achieve compliance with the HCHO Rule. Pursuant to a prior final rule that took effect on August 25, 2017, businesses can begin labeling product “TSCA Title VI compliant” as soon as compliance is achieved and need not wait until December 2018 to do so.

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About this Author

Michael J. Sullivan, Womble Carlyle, risk management attorney, cost control lawyer
Managing Partner

Michael Sullivan is Managing Partner in the Atlanta office of Womble Carlyle, a full-service business law firm with more than 530 lawyers in 14 offices throughout the Southeast and Mid-Atlantic United States and in Silicon Valley. Michael is a mass tort and complex commercial litigation attorney with over 30 years of experience representing clients in bet-the-company litigation.  His practice today includes acting as trusted advisor to senior level executives on risk management, cost control and litigation management issues.  In addition to his leadership role in the...

Christa Burger, Womble Carlyle Law Firm, Complex Litigation Attorney

Christa is a young litigator with a broad range of experience defending complex mass tort and business matters, including class actions, contracts, negligence, and products liability claims.  Her practice also involves counseling corporate clients on a variety of marketing and regulatory issues, including product labeling, such as compliance with California’s Proposition 65, public relations, and responding to inquiries from state and federal agencies. 

With respect to litigation, Christa has experience in all stages of case preparation and trial, including offensive and defensive discovery; briefing and motions practice; and evaluating, developing, and preparing fact and expert witnesses for deposition and trial.  Christa has been a member of several trial teams, including Campbell v. R.J. Reynolds (2013) and Haldeman v. R.J. Reynolds (2013), which resulted in judgment for R. J. Reynolds Tobacco Company.  She also has experience with alternative dispute resolution, including mediation and the national arbitration regarding enforcement of the escrow statute against non-participating manufacturers under the Master Settlement Agreement.