Hello all! I’m back and you know that one topic which will always draw me back to the blogosphere—formaldehyde!
This time it’s the Canadian regulation, CANFER. That stands for the CANadian Formaldehyde Emissions Regulation. Effective on January 7, the regulation in large parts mirrors TSCA Title VI. Unfortunately it does have some unique traits of its own, which we’ll get into.
But first, it does have one key provision that much of the industry probably needs to note. Everyone who is doing business in Canada in composite wood products needs to register before March 8. That’s everyone–manufacturers and importers, distributors and retailers and importers. Big boxes and little boxes, factories and workshops—if you are making a composite wood product or selling a product that contains a composite wood composite, you need to specifically register with the government. Yes, that’s for all products: flooring and cabinets and furniture and picture frames, etc., and all regulated panel materials, plywood, particleboard, and MDF.
I don’t think the government really knows what they are asking with this, but they have asked it very directly and clearly in section 31 of the rule:
Now the good news is that you can do it quickly by email: firstname.lastname@example.org.
The government clearly takes this seriously. The opening of the rule itself says that a company is not allowed to business in Canada without registering:
5 A person must not import, sell or offer for sale a composite wood product that contains formaldehyde unless…
(c) the person provides the information set out in section 31 to the Minister in accordance with that section.
As a note, I’ve been asked numerous times why a company should be required to register. I also have been asked if another registration (like a business registration or an importer registration) would work.
So of course I certainly don’t understand all the government’s thinking with this rule, but I believe they are trying to create a mailing list for distributing information. They have been sending out information for several years, but most companies still don’t know much about CANFER. I think they need a more focused mailing list and they can’t comb through all the other government databases to find impacted companies. So they want everyone to identify themselves. I think that’s the main reason, certainly right now. So no, don’t count on the government knowing you handle these products—as they’ve required by law, register now. It’s just one email!
More on CANFER in later blogs! If you want to study on your own in advance, check out:
Elizabeth Baldwin is Environmental Compliance Officer for Metropolitan Hardwood Floors. In her 25 plus year career in the wood industry has visited over 70 countries and hundreds of facilities of all sizes and types. She describes herself as a “jack of all wood trades.” Familiar with jungles of all sorts–having camped out along the Amazon and walked the halls of Congress–she blogs for the NWFA on both environmental and regulatory issues for educational and informational purposes only. Her blog is not intended and should not be construed as legal advice. Persons seeking legal advice on compliance with CARB, TSCA, the U.S. Lacey Act or any other law, regulation, or compliance requirement/claim should consult with the regulatory agency directly and/or a qualified legal professional.