California 93120 Phase 2 sets stricter limits on formaldehyde in wood products sold in the state

California Code of Regulations Title 24, Section 93120 Phase 2 is a formaldehyde emission standard that applies to composite wood products — plywood, particleboard, medium-density fiberboard (MDF), and hardwood plywood veneer — sold or manufactured in California. Phase 2, which took effect January 1, 2020, lowered the allowable formaldehyde emissions from the Phase 1 limit of 0.13 parts per million (ppm) to 0.05 ppm for most products and 0.03 ppm for certain laminated products.

This means manufacturers and distributors selling wood-based furniture, cabinets, flooring underlayment, and building materials in California must test their products and document compliance. If you are buying furniture or building materials in California, products labeled as 93120 Phase 2 compliant have met this lower threshold. If you are a manufacturer, distributor, or retailer, you need to understand what compliance requires and how to document it.

Key Takeaways

  • Phase 2 compliance applies to composite wood products sold in California, regardless of where they are manufactured.
  • Compliant products must emit no more than 0.05 ppm formaldehyde (0.03 ppm for laminated products) as verified by third-party testing.
  • Manufacturers and distributors must keep test reports and provide them to retailers; retailers must keep documentation available for inspection.
  • Products must be labeled or accompanied by documentation stating they meet 93120 Phase 2 standards.
  • Non-compliant products cannot be sold in California, and violations can result in civil penalties and product seizure.

Who must comply with 93120 Phase 2

Any manufacturer or distributor selling composite wood products in California must comply, even if the product is made outside the state. This includes large furniture retailers, small cabinet shops, flooring distributors, and online sellers shipping to California addresses. The regulation applies to the finished product — a desk, cabinet, or sheet of plywood — not just raw materials.

Retailers are responsible for ensuring their suppliers provide compliant products and documentation. You do not need to test products yourself if you are a retailer, but you must keep records showing your suppliers' compliance documentation and be able to produce those records if the California Department of Resources Recycling and Recovery (CalRecycle) or a local air quality district conducts an inspection.

How products are tested and certified for Phase 2 compliance

Testing must be performed by a laboratory accredited under the Composite Wood Products (CWP) Accreditation Program or an equivalent program recognized by California. The lab measures formaldehyde emissions using the test method specified in the regulation — typically the chamber method or perforator method — and issues a test report with the results.

A single test result is valid for that specific product formulation and batch. If a manufacturer changes the resin, glue, or production process, a new test is required. Manufacturers typically test representative samples from production runs and keep test reports on file for at least five years. The test report must show the product name, the emission level in ppm, the test date, the laboratory name and accreditation number, and the test method used.

Third-party certification programs — such as those run by NSF International, SCS Global Services, or Underwriters Laboratories (UL) — also issue compliance certifications. These programs conduct their own testing and audits and issue certificates that manufacturers can use to demonstrate compliance. A product with a valid third-party certification certificate does not require a separate test report from the manufacturer.

Documentation and labeling requirements

Manufacturers must provide documentation to distributors and retailers showing that the product meets Phase 2 limits. This documentation can be a test report, a certification certificate, or a written declaration from the manufacturer stating the emission level and the basis for that claim (test report number, certification program, or other evidence).

Products must be labeled or accompanied by a document stating they comply with California 93120 Phase 2. The label or document must be visible to the buyer or available at the point of sale. For example, a sheet of plywood might have a stamp on the edge; a piece of furniture might have a tag attached or a document in the box; an online retailer might display the compliance statement on the product page.

Retailers must keep copies of all compliance documentation from their suppliers and make those records available for inspection by CalRecycle or local air quality officials. If you cannot produce documentation showing a product is compliant, you may be required to remove it from sale.

What happens if a product does not meet Phase 2 standards

Non-compliant products cannot be sold in California. If CalRecycle or a local air quality district discovers a product that does not meet the standard, the product can be seized and destroyed. The manufacturer or distributor may face civil penalties, which can range from hundreds to thousands of dollars per violation, depending on the severity and whether the violation was intentional.

Retailers who knowingly sell non-compliant products can also be held liable. If you are a retailer and discover that a supplier has provided non-compliant products, you should stop selling them when ready, notify the supplier, and keep records of the action you took. If you are a manufacturer or distributor and discover a compliance problem, you should notify your customers and work with CalRecycle to determine the appropriate remedy.

How Phase 2 differs from Phase 1 and federal standards

Phase 1 of California 93120, which was in effect from 2009 to 2019, set the formaldehyde limit at 0.13 ppm. Phase 2 lowered that limit to 0.05 ppm (and 0.03 ppm for laminated products), making California's standard stricter than the federal standard under the Formaldehyde Standards for Composite Wood Products rule, which allows up to 0.13 ppm.

This means a product that is compliant with federal law may not be compliant with California law. If you are selling in California, you must meet the California standard, not just the federal standard. Other states have adopted similar or identical standards to California's Phase 2 limit, so compliance with 93120 Phase 2 often means compliance with multiple state markets.

Where to find compliance documentation for products you are buying

If you are purchasing furniture or building materials in California, ask the retailer or manufacturer for documentation showing Phase 2 compliance. Reputable manufacturers and retailers will have this information readily available. You can also contact the manufacturer directly and request a test report or certification certificate for the specific product you are interested in.

If a retailer cannot provide documentation, that is a red flag. You can report non-compliant products to CalRecycle or your local air quality management district. CalRecycle maintains a list of accredited testing laboratories and certification programs on its website, which you can use to verify that a test report or certificate is legitimate.

Frequently Asked Questions

Does Phase 2 explore to solid wood furniture or only composite wood?

Phase 2 applies only to composite wood products — plywood, particleboard, MDF, and hardwood plywood veneer. Solid wood furniture is not subject to the standard. However, if a piece of furniture contains composite wood components (such as a plywood back or particleboard shelves), those components must be compliant.

What if I bought furniture before Phase 2 took effect?

Phase 2 compliance is required for products sold after January 1, 2020. Products manufactured and sold before that date are not subject to Phase 2. If you own older furniture, it may not meet the current standard, but you are not required to replace it.

Can I import composite wood products from another country and sell them in California?

Yes, but they must meet Phase 2 standards. The regulation applies to any composite wood product sold in California, regardless of origin. You will need test reports or certification documentation from the manufacturer showing compliance with the 0.05 ppm limit (or 0.03 ppm for laminated products).

Who do I contact if I suspect a product is not compliant?

You can report non-compliant products to CalRecycle's Compliance and Enforcement Program or to your local air quality management district. Provide the product name, manufacturer, retailer, and any documentation you have. CalRecycle will investigate and take appropriate action.

Does Phase 2 compliance cost more?

Compliant products may cost slightly more because manufacturers must invest in lower-formaldehyde resins and testing, but the price difference is typically small. Many manufacturers have already absorbed the cost of compliance into their standard pricing, so you may not see a significant difference at the point of sale.