Guides / Compliance

CARB P2 and TSCA Title VI for Vietnam Plywood

September 21, 2026

Formaldehyde paperwork is where a first plywood import into the United States usually stalls. The panels arrive, the broker asks for the certification, and the mill sends a scan that covers a different product line.

This is what the rules ask for, in the order a buyer meets them.

What the rules cover

Two rules, same numbers. CARB Phase 2 is the California measure. TSCA Title VI is the federal rule that applies across the United States and was written to match it. Both set emission limits on composite wood panels:

Product	Limit
Hardwood plywood	0.05 ppm
Particleboard	0.09 ppm
MDF	0.11 ppm
Thin MDF	0.13 ppm

They cover the bare panel and the finished goods built from it, so a cabinet or a piece of furniture crossing the border carries the same obligation as a pallet of sheets. Structural panels made to the softwood plywood standards sit outside the rule. Most of what Vietnam exports for interior use does not.

Certification is done by a third party, not the mill

A mill cannot certify itself. Panels have to be certified by a third party certifier that is recognised for this rule, and that certifier audits the factory and tests panels on a schedule.

Three questions settle whether a certificate is worth anything:

1. Does it name this factory, at this address?
2. Is the issuing body a certifier recognised for TSCA Title VI?
3. Does it cover the product line your order runs on?

The third one catches most problems. A factory can hold certification for the line that presses furniture panels and run your order on a line that is not covered, without anybody lying to you. Ask which line your order will be pressed on and whether the certificate covers it.

There are lower testing routes for panels made with no added formaldehyde resins, usually written NAF, and for ultra low emitting resins, written ULEF. They still go through the certifier. They are not a way around it.

What has to be on the panel

Labels are the part buyers forget until the container is open. Panels or bundles are labelled by the producer, and the label carries the producer name, the lot number, the certifier number and a statement that the product complies. A panel with no label is a problem at the door, not a detail to fix later.

Ask for a photograph of the actual label from your production batch before shipment. It takes the mill five minutes and it is the cheapest check in this whole process.

What you keep on file

Importers keep records that connect the shipment to the certification, normally for three years, and the import declaration at entry states that the goods comply. Your customs broker handles the declaration. You hold the certificates, the labels, the invoices and the lot numbers so that the chain can be reconstructed if anyone asks.

Set the file up before the first container, not after. It is a folder per shipment with five things in it: the certificate, the label photo, the packing list with lot numbers, the invoice and the test report if you asked for one.

Veneer origin sits next to this, and it is a different question

Formaldehyde certification says nothing about duty. Where the face and core veneer came from is a separate line of enquiry, and it has been the subject of US trade cases: hardwood plywood assembled in Vietnam from Chinese inputs has been examined, and found in some cases to fall inside the orders that apply to Chinese hardwood plywood.

That is not a reason to avoid Vietnam. It is a reason to ask, in writing, where the veneer comes from, and to keep the answer with the rest of the file. The scope of these cases changes, and your customs broker has the current version for your product and your port. Nothing on this page is legal advice.

The checklist before you place the order

• Which rule your buyer or your own sale requires, CARB P2 or TSCA Title VI or both
• The certificate: factory name, certifier, scope, expiry
• Which production line the order runs on, and whether the certificate covers it
• A photo of the label from your batch
• Origin of face veneer and core veneer, in writing
• Who keeps which records, and for how long
• Whether a test report on the production batch is included or extra

Seven lines. Send them with the specification and the mills that cannot meet them will take themselves out of the running, which saves everybody a round of samples. The rest of what belongs in a plywood enquiry is in what your enquiry has to say.

For the formaldehyde, legal timber and duty rules of the other markets, see our guide to plywood import requirements.

See also: TSCA Title VI for plywood for the limit, certifier chain, label fields and importer records in order.

Frequently asked questions

Keep reading

• Formaldehyde Tests for Plywood: Chamber vs Desiccator
• Fire Retardant Plywood: Grades, Test Methods and Honest Claims