Would structural plywood that is a “downfall” (products that do not meet all the required properties of PS1 or PS2 structural plywood) be exempt from the ATCM?
No, structural plywood “downfall” is not exempt from the requirements of the ATCM. From a formaldehyde emissions standpoint, it is likely that downfall is also a low emitting product, but from an enforcement perspective, the sale and supply of uncertified and unmarked structural plywood products to California creates an unenforceable situation since downfall products are not labeled and unverifiable. As a side note, downfall products may be used for packaging applications (e.g., for use in making pallets, crates, boxes, etc.) which are not subject to the requirements of the ATCM (see FAQ #13). 25. Is hardboard, made to standards other than ANSI A 135.4-2004, subject to the ATCM? Similar to PS 1 and PS 2 structural plywood, we recognize that hardboard is made in other parts of the world to comply with standards established for region-specific needs. CARB staff continues to evaluate international standards and have determined at this time that hardboard complying with European EN 13986 s
