Compliance Date Extension for Formaldehyde Rule

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Attached is the Direct Final Rule that published on May 24 in the Federal Register regarding the Formaldehyde Wood Rule. The rule allows fifteen days (June 8, 2017) for public comment. If there are substantive adverse comments EPA can pull back the rule for further work.  EPA also submitted a proposed rule to the same effect in case there are adverse comments. The direct final rule will extend the compliance date for recordkeeping (CARB document retrieval system) to March 22, 2018 and subsequently the import certification to March 22, 2019. The laminated products exemption has been extended to March 22, 2024.
 
We are still waiting on the labeling direct final (allowing for labeling prior to the compliance date) and we continue to work with the Agency on a direct final on the non-complying lots provision. Recall this provision relates to the obligations of fabricators and laminators receiving a notification from a panel producer that panels they may have received were part of a lot that failed an emissions test. The provision arguably requires the fabricator (cabinet company) to notify its customers to which it may have shipped finished products containing component parts made from those panels. The fabricator’s notification must inform its customers that those finished products must be isolated; cannot be further distributed; and must either be recalled or treated and retested. This non-complying lots provision appears to be designed with panels and a short supply chain in mind. But it makes no sense when applied to finished goods that may or may not contain component parts from those panels. KCMA has been working with EPA on this issue for many months arguing that the obligation should be  limited to the panel suppliers not the fabricator.   Erik Winchester, Chief of the Fibers & Organics Branch of EPA, in a presentation to the KCMA membership at the spring convention earlier this month announced that the Agency has agreed with KCMA and an FAQ providing clarification would be published soon and posted on the EPA website.

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The Kitchen Cabinet Manufacturers Association is committed to bringing you the most up-to-date…