Overview

Amazon requires all sellers offering products that contain composite wood materials to comply with U.S. Environmental Protection Agency (EPA) formaldehyde emission standards under the Toxic Substances Control Act (TSCA) Title VI. This regulation targets three specific types of composite wood—hardwood plywood, medium-density fiberboard (including thin-MDF), and particleboard—and applies to any finished goods that incorporate these materials. Sellers who fail to meet these requirements risk listing removal, enforcement action, and potential legal liability.

Key Points / What Sellers Need to Know

• Regulated materials — The rule covers three categories of composite wood: hardwood plywood (HWPW), medium-density fiberboard (MDF, including thin-MDF), and particleboard. Any finished product containing these materials falls under the regulation.
• Formaldehyde emission limits — Products containing regulated composite wood must meet EPA emission standards codified at 40 C.F.R. Part 770. These limits restrict the amount of formaldehyde that can off-gas from composite wood panels and the finished goods that contain them.
• Labeling is mandatory — Every product containing regulated composite wood must be individually labeled in accordance with EPA regulations. Products that lack proper labeling are prohibited from sale on Amazon.
• Non-compliant products are prohibited — Amazon explicitly prohibits the listing and sale of products containing regulated composite wood that do not meet EPA formaldehyde emission standards.
• Federal law applies — These requirements stem from the Formaldehyde Standards for Composite Wood Products Act (15 U.S.C. § 2697), which is a federal statute. Sellers must also comply with any applicable state laws, such as the California Air Resources Board (CARB) standards that preceded the federal rule.

Regulatory Background

The EPA's formaldehyde emission standards for composite wood products were established under TSCA Title VI, which Congress enacted in 2010 as part of the Formaldehyde Standards for Composite Wood Products Act. The rule sets maximum emission levels for hardwood plywood, MDF, and particleboard, and requires that these panels be tested and certified by EPA-recognized third-party certifiers before they can be sold in the United States. The implementing regulations are found at 40 C.F.R. Part 770, which also establishes chain-of-custody documentation requirements, quality control testing protocols, and labeling mandates that flow through the supply chain from panel manufacturers to fabricators, importers, distributors, and retailers—including online marketplace sellers.