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TSCA Compliance: Composite Wood Products Certification-2004 Monaco Signature


Lee Smith
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I am bringing my 2004 Signature Conquest from Canada to the US.
US Customs has a form that I will need to submit that requires certification as follows:

TITLE VI SECTION 13 COMPOSITE WOOD PRODUCTS
“I certify that all composite wood products in this shipment comply with all applicable rules or
orders under TSCA and that all of the goods are certified and labelled as compliant with TSCA
or any applicable rule or order thereunder.”

I think that this is primarily aimed at formaldehyde.

Here is a link to the form:

PCBUS-Title-VI-Section-13-Composite-Wood-Product-No-Letterhead-2019-03-08-1 (1) (003).pdf

Any help is greatly appreciated.
Thank you,

Lee Smith

 

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Are you sure this applies to the wood in the RV? Seems like it’s speaking of an imported shipment, no? I’ve never heard of this, fellow Canadian 🇨🇦  

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Imports of Certain Composite Wood Products to Require TSCA Certification Title VI

December 17, 2018

 

Beginning March 22, 2019, US imports of regulated composite wood products must be certified and labeled by a third-party as compliant with Title VI of the Toxic Substances Control Act (TSCA). Previously, the goods could be certified under the California Air Resources Board’s (CARB) Airborne Toxic Control Measures (ATCM) phase II emission standards. After the March date, certification to the CARB ATCM phase II criteria is no longer sufficient.

The certification ensures that the goods meet national formaldehyde emission standards per the Environmental Protection Agency’s (EPA) Formaldehyde Standards for Composite Wood Products Act. Composite wood products include hardwood plywood, particleboard, and medium-density fiberboard or finished goods containing the materials, such as furniture, cabinets, picture frames, toys, etc. As found on EPA’s FAQ on the Act, products not covered by the rule include structural, curved, and military-specified plywood; structural panels, oriented strand board, structural composite and finger-jointed lumber, pre-fabricated wood I-joists, hardboard, wood packaging, and other products.

Additionally, after March 22, 2019, importers are responsible for providing a TSCA Section 13 import certification for these products. According to CSMS message #18-000727, the “TSCA Section 13 import certification will be in the form of a positive certification for applicable shipments through the U.S. Customs and Border Protection’s Automated Commercial Environment (ACE).” Upon request, importers must make records documenting compliance available to the EPA within 30 calendar days. If you have questions regarding Title VI or Section 13 of TSCA, please send an email to Deringer’s compliance department.

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Thanks to the good advice above, I called the EPA at the number listed on the certification form:  (202) 554-140, M-F, 8-5, EST.
They promptly answered the phone and said "Does Not Apply" because the RV was pre-owned. Do not file the certification form. They said they get this question a lot. 
They referenced 40 CFR Part 770: 

eCFR :: 40 CFR Part 770 -- Formaldehyde Standards for Composite Wood Products

(c) Subparts B, C, and D of this part do not apply to the following:
(1) Any finished good that has previously been sold or supplied to an end user, an individual or entity that purchased or acquired the finished good in good faith for purposes other than resale. For example, subparts B, C, and D of this part do not apply to antiques or secondhand furniture.

So I have notified my USA Customs Broker to not file the Composite Wood Certification form.

My thanks for your thoughts

Lee Smith

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^^^^^^ What Don and Lee said is 100% the way to handle it, and accurate.

I own an engineering firm that certifies commercial products for sale into every country, including EPA TCSA compliance in the US.

It only applies to manufacturers and “producers” (which is a TCSA and EPA legal term), and you are neither.

You are good to go.

- John

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