How will pallets be considered in the ATCM?
Pallets made prior to 2009, would not be subject to the ATCM. For purposes of the ATCM, pallets are considered finished goods made by a fabricator. Beginning in 2009, pallets made with composite wood products, such as industrial grade hardwood plywood would be subject to the rulemaking in California, and must be made with compliant materials and labeled as being legal for use and sale in California. In addition, any invoices which list the products being transacted must also list the pallet or shipping containers and indicate that all items listed comply with the ATCM. Therefore, pallets made after 2009 would be subject to testing by CARB and the materials used to make pallets must meet applicable standards.
