Would CARB take size, volume or quantity of composite wood products used for finished goods into account?
The regulation does not allow exemptions for de minimus use of the regulated products in finished goods. The regulation applies to all products, (e.g., picture frames, plaques, toys, etc.) containing hardwood plywood, particleboard, or medium density fiberboard, and there is no minimum amount that is exempt. However, the ATCM does include de minimus use exemptions for windows and doors only, see Section 93120.7 (b)(1). 17. Does the ATCM apply to curved or bent plywood? Curved plywood is excluded from the definition of hardwood plywood and is not subject to the ATCM. While CARB staff recognizes that the process of making curved plywood may be similar to industrial grade hardwood plywood, there are important differences, such as the use of a radio frequency curing during the pressing process. Also, CARB does not have emissions data to accurately characterize curved plywood formaldehyde emissions. CARB intends to further evaluate curved plywood in the future to determine whether regulator
