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No-Added Formaldehyde (NAF) and Ultra Low Emitting Formaldehyde Resins (ULEF) Option for CARB Compliance

January 1, 2009
The Airborne Toxic Control Measure (ATCM) to control formaldehyde emissions from composite wood products was approved on April 18, 2008, by the Office of Administrative Law. The regulation has been filed with the Secretary of State and is codified into Title 17 of the California Code of Regulations, and is now effective.

In the ATCM, special provisions were provided for manufacturers of hardwood plywood, particleboard, and medium density fiberboard who plan to use no-added formaldehyde (NAF) based resins (section 93120.3(c)) or ultra-low-emitting formaldehyde (ULEF) resins (section 93120.3(d)). NAF based resins are resins formulated with no added formaldehyde as part of the resin cross linking structure, and include resins made from soy, polyvinyl acetate, or methylene diisocyanate. ULEF resins are formaldehyde containing resins formulated such that the formaldehyde emissions from composite wood products are consistently below applicable Phase 2 emission standards.

Manufacturers who plan to use NAF based resins may apply to the Executive Officer of ARB for an exemption from the third party certification requirements in section 93120.3(b). Manufacturers who plan to use ULEF resins may apply to the Executive Officer of ARB for approval to test their products less frequently or for an exemption from the third party certification requirements in section 93120.3(b). The link to the application form for NAF or ULEF product manufacturers is provided below.

If applying for a NAF/ULEF exemption, you will need to contact a CARB approved third party certifier to obtain the necessary data required for a NAF/ULEF application as required in section 93120.3 of the ATCM.