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WDMA Raises Concerns with Proposed Canadian Formaldehyde Regulations

Posted By Window and Door Manufacturers Association, Tuesday, September 17, 2019
[WASHINGTON, DC] - On September 12, WDMA submitted comments to Canadian officials in response to proposed new Canadian regulations for formaldehyde emissions from composite wood products that were jointly proposed by the Department of Health and the Department of the Environment. As with the U.S. EPA regulations for formaldehyde (TSCA Title VI), the intent of the proposed regulations is to reduce potential risks associated with exposure to formaldehyde emissions in composite wood products. In addition, the proposed Canadian regulations are intended to be consistent with the U.S regulations to help ensure a level playing field among Canadian and U.S. manufacturers of composite wood products covered by the respective U.S. and Canadian regulations.
After a review of the proposed regulations in relation to TSCA Title VI, WDMA has raised significant concerns with proposed Canadian provisions that are not consistent with TSCA Title VI. Those include provisions for labeling and recordkeeping, as well as requirements for highly detailed reports on a manufacturer’s production and sale of composite wood products covered by the regulations to be submitted to the Canadian government on an annual basis.
More specifically, WDMA’s comments address inconsistencies with the form, content and placement of labels, record keeping requirements that would necessitate U.S. manufacturers who do not have facilities in Canada to establish a Canadian presence, and unclear applicability of the annual reporting requirements.
“These discrepancies, if left unaddressed, have the potential to create disruption in both the U.S. and Canadian supply chains and marketplaces,” said Michael O’Brien, WDMA president and CEO. “We support the intent of the proposed regulations, but they should not result in undue compliance costs and administration burdens for manufacturers of composite wood products, especially for architectural wood door manufacturers.”
There is no specific timeline for finalizing the regulations, but they will become effective six months after publication of the final regulations in the Canada Gazette. Canada currently has voluntary standards for formaldehyde emissions from composite wood products that most manufacturers comply with, but no mandatory regulations as in the U.S.

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