How will packing material, such as “dunnage” or “offal” be considered in the ATCM?
Packing material, also referred to as “dunnage”, or “offal” (“dunnage” or “offal” is essentially loose, waste material such as composite wood products that are used for packaging or covering shipments in order to protect cargo from damage during transport) is not considered a finished good and is not appropriate for deconstructive emissions testing. Hence, packing material of this type does not need to comply with the regulation. 15. Does the ATCM apply to rental items such as rental furniture? Furniture that is rented prior to the effective dates of the emission standards is exempt, because such furniture is considered to be “used goods,” which are exempt from the definition of finished goods. At the end of the rental period, the furniture may be sold at any time as used furniture. If a furniture rental company purchases new furniture after the effective dates of the emission standards, for purposes of renting that furniture in California, the new furniture must be made with materials
