Application for the use of no added formaldehyde (NAF) base resins or ultra low emitting formaldehyde (ULEF) resins is now available through CARB or direct download here.
This application is ONLY for manufacturers using resins in the processing of composite wood product NOT for fabricators of composite wood who use resins in the fabrication of finished goods such as furniture. The application is for those that would like to apply to receive an exemption from testing for using only NAF (no added formaldehyde) base resins OR to receive a either exempt or reduction in testing status for using ULEF (ultra-low emitting formaldehyde) base resins. When asked if there would be any future application or requirement for fabricators or furniture manufacturers using NAF or ULEF resins in the their finished goods, Brent Takemoto, Staff Air Pollution Specialist - Substance Evaluation Section for the CA Air Resource Board replied, "The NAF/ULEF application has no specific relevance to end-product producers, and there is no need for fabricators to fill out the form as they are required to perform formaldehyde emission tests on the products that they make. We will not be publishing further advice or guidelines for filling out the present application form for fabricators. We will not be posting a NAF/ULEF application for fabricators. Fabricators may choose to use these products, and as long as they use compliant materials, keep required records, and label their products accordingly (see section 93120.7 of the final regulation order), they do not need to submit an application to CARB."
However, as a buyer, you should confirm with your suppliers that they have properly confirmed with their supply base that these applications are in process if they use these resins. Also for some of you, your suppliers do manufacture their own composite wood and will be required to apply only if they are seeking a reduction or exemption in testing and are currently using or plan to be using the NAF/ULEF resins to meet the CARB phase 1 or phase 2 requirements. Insist your suppliers switch to these resins and don't let them raise your costs, argue instead that they will be saving all the testing costs for non-compliance. Reduction in testing always translates to a reduction in costs, so the insurance that you will be in full compliance with CARB and the supplier savings of tens of thousands of dollars in testing should more than cover the minor increase in resin cost per board if they can achieve full exemption status. Demand it - NAF resins - going green, means saving green!
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