CARB P2 Certified Pine Plywood from Brazil: What US Importers Need to Know

If you import composite wood products into the United States — including plywood, MDF, or particleboard — CARB Phase 2 (CARB P2) compliance is a legal requirement, not an option. This guide explains what CARB P2 means for Brazilian pine plywood and what documentation you need with every shipment.

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What is CARB P2?

CARB stands for the California Air Resources Board. Its Airborne Toxic Control Measure (ATCM) for composite wood products limits formaldehyde emissions. Although originally a California regulation, ATCM has been effectively adopted at the federal level through the Formaldehyde Standards for Composite Wood Products Act (TSCA Title VI), enforced by the EPA.

CARB Phase 2 sets the strictest emission limits:

Product type	CARB P2 emission limit
Hardwood plywood — veneer core	0.05 ppm
Hardwood plywood — composite core	0.05 ppm
Medium Density Fibreboard (MDF)	0.11 ppm (standard)
Particleboard	0.09 ppm

All composite wood products imported into the US must comply, regardless of whether they are sold in California or another state.

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How Brazilian pine plywood achieves CARB P2 compliance

CARB P2 certification requires four elements:

1. Approved adhesive/resin — typically ultra-low-emitting formaldehyde (ULEF) resins or no-added-formaldehyde (NAF) adhesives
2. Third-party certification (TPC) — an EPA-approved third-party certifier tests products and audits manufacturers on an ongoing basis
3. Labelling — all CARB P2 product must carry the certification stamp with the TPC identifier
4. Chain of custody — importers must be able to trace the product back to the certified mill

Our Brazilian pine plywood suppliers are certified by TSCA/CARB P2-approved certifiers including Bureau Veritas, SGS, and INTERTEK.

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What documents to request with every shipment

Document	What it confirms
CARB P2 / TSCA Title VI compliance certificate	TPC name, certificate number, covered product categories
Mill-specific CARB certificate	The production facility is certified
Third-party test reports	Emission levels from accredited lab
Packing list with CARB P2 marking	Batch shipped matches certified specification

Retain all compliance documentation for a minimum of 3 years — the retention period required under TSCA Title VI.

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Common compliance mistakes to avoid

• Ordering by grade only, without confirming CARB P2 certification
• Accepting supplier declaration without verifying the TPC certificate number at the EPA database
• Buying from an uncertified mill and assuming certification transfers with the product
• Failing to verify the certificate covers plywood specifically (not just MDF or particleboard)
• Not retaining documentation for the required 3-year period

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How to verify a CARB P2 certificate

1. Get the TPC certificate number from your supplier's CARB compliance certificate
2. Search the EPA TSCA Title VI database at epa.gov/tsca-wood to verify the certificate is current and the mill name matches
3. Confirm the product category (hardwood plywood, softwood plywood, MDF etc.) is explicitly covered

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Related reading

CDX Plywood Specifications · T1-11 Siding Specifications · How to Verify FSC Certification from Brazil · Plywood Grades Explained · Pine Plywood

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