Along with other wood products organizations, the Kitchen Cabinet Manufacturers Assn. is actively involved in ensuring that the wood industry is fairly represented when proposed regulations on formaldehyde emissions are adopted by the California Air Resources Board.

On April 26, CARB will vote on its proposed Air Toxics Control Measure (ATCM) on formaldehyde emissions from composite wood products, specifically particleboard, MDF and hardwood plywood. The action date was originally scheduled for January, but was pushed back to allow CARB staff more time to define an enforcement plan and address other issues raised by the California Wood Industry Coalition (CWIC), of which KCMA is an active member.

Among the issues is the feasibility of complying with the low permissible levels for formaldehyde emissions. Under Phase I, which takes effect in 2009, emission standards for particleboard and MDF will drop to 0.18 and 0.21 respectively, while hardwood plywood will be lowered to 0.07 (for veneer core) and 0.09 (composite core). Phase II rates drop significantly, with particleboard (2011) and MDF (2012) lowering to 0.08, and hardwood plywood reducing to 0.03 (veneer core, 2011) and 0.05 (composite core, 2012).

“It is clear that CARB is going to regulate formaldehyde emissions from particleboard, MDF and hardwood plywood. Whether the levels established by the regulation are achievable in the time frame specified remains to be seen,” says C. Richard Titus, executive director of the KCMA.

According to CARB, manufacturing costs to comply with Phase I may be 4 percent higher for particleboard and MDF, and 10 percent higher for hardwood plywood. Based on today’s costs for standard composite panels, compliance with Phase II will be approximately 30 percent higher for particleboard and MDF.

In order to comply with the proposed regulations, cabinet, countertop and furniture manufacturers will need to demonstrate that their products are made from compliant materials through “chain-of-custody” documentation provided to them by their suppliers. The composite wood used in furniture, countertops and cabinetry also will be subject to a “screening” test to validate compliance. Testing of furniture, cabinets and other finished products will not be required, although details of the methodology and test procedures for the “screen” have yet to be defined. As part of its enforcement, CARB says it plans to select items available at retail and check them to verify compliance. Anything constructed with composite wood will be subject to the regulation, regardless of how it is marketed.

“Anyone making or marketing products in California will be subject to the regulation. Other states are expected to follow California’s lead,” Titus says.

In addition to those members manufacturing in California, most KCMA companies have a national distribution market in the state, Titus says.

“California accounts for approximately 10 percent of the U.S. cabinet market, with a value of shipments between $1.3 and $1.7 billion annually. More than 14,000 people are employed in the manufacture of cabinets in California. There are at least 1,100 establishments engaged in the manufacture of wood kitchen cabinets in the state; the vast majority of these establishments employ 20 or fewer employees. Also, there are 60 percent more wood kitchen cabinet manufacturing establishments in California than the next closest state.

“The proposed regulation could have a huge impact on cabinet manufacturing,” he adds.

KCMA has participated in every public meeting to date involving the proposed legislation, including representation at both CWIC and CARB meetings; comments on draft documents; communication with KCMA members regarding CARB proposals and meetings; development of industry data; interaction with CWIC lobbyists and similar activities, says Titus.

For more information about the proposal, visit the CARB Web site at

Cabinets made from particleboard, MDF and hardwood plywood, will face stringent requirements with the passage of CARB’s formaldehyde emissions regulations.

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