CARB Compliance

Hardwood Bargains sells only engineered wood flooring products that are CARB-compliant or – if they are not subject to CARB – that use low-VOC glues and meet CARB limits for formaldehyde emissions.

The issue of indoor air quality (IAQ) gained attention in the 1980s with the identification of sick building syndrome, a combination of ailments associated with an individual’s place of work or residence. Its causes are frequently tied to the off-gassing of volatile organic compounds (VOCs) — chemical compounds that vaporize and enter the atmosphere under normal conditions — from some building materials. One of the main VOCs implicated in unhealthy indoor air quality is formaldehyde.

CARB is a regulation whose goal is to reduce public exposure to formaldehyde. It establishes strict emission performance standards on various types of composite wood products, including some types of engineered wood flooring. In addition, CARB requires that all finished goods destined for sale in California use composite wood products tested and certified as compliant at the mill that makes them.


Indoor Air Quality & Formaldehyde

Poor indoor air quality comes from flaws in the heating, ventilation, and air conditioning (HVAC) systems but is also attributed to contaminants produced by the out-gassing of volatile organic compounds (VOCs) from some building materials. These are chemical compounds that vaporize and enter the atmosphere under normal conditions. One of the main VOCs implicated in unhealthy indoor air quality is formaldehyde.

Formaldehyde is a chemical compound made up of carbon, hydrogen, and oxygen that is everywhere. For example, it occurs naturally at low levels in bread, trees, and the human body. Such formaldehyde is “bound up” in the matter of which it is a part and poses no risk to human health.

Formaldehyde can pose health risks when it occurs in a gaseous form in high concentrations in an indoor environment where it can be breathed. Gaseous formaldehyde is a common indoor air pollutant and exists at some level of concentration in virtually all homes and buildings. As a gas, it is colorless, has a strong smell, and is released into the air from various sources. These include the combustion of fossil fuels, tobacco smoke, fireplaces, wood-burning stoves, and a wide variety of home products–including engineered wood flooring (and other composite wood products) that use adhesives that off-gas formaldehyde.



Generally, formaldehyde has no observable health effects when air concentrations are below 1.0 ppm. However, respiratory irritation and other health effects begin when air concentrations exceed 3.0-5.0 ppm.

Reactions to formaldehyde vary. Some people have no reactions, while others have severe and potentially life-threatening responses to exposure. The effects of breathing formaldehyde can include nose and throat irritation, a burning sensation in the eyes, wheezing, breathing difficulty, insomnia, anorexia, and loss of libido. In addition, formaldehyde can trigger asthma symptoms in those with asthma, and sensitive individuals may experience fatigue, headache, and nausea from exposure.

Finally, formaldehyde is a known carcinogen: the International Agency for Research on Cancer reclassified formaldehyde from “probably carcinogenic to humans” to “carcinogenic to humans” in 2004.


EPA, CARB & Wood Flooring


Because formaldehyde occurs in nature – even outdoor air has low levels of formaldehyde (about .03 ppm) – and is part of the chemical composition of the wood itself, there is no such thing as a formaldehyde-free wood flooring product. There are, however, engineered wood flooring products whose adhesive system contains no or very low levels of added formaldehyde. They, therefore, do not off-gas formaldehyde at dangerous levels and comply with EPA/CARB requirements.



The Composite Wood Products Regulation was established in 2009 by the California Air Resources Board, a public agency in the state of California (confusingly, the regulation is referred to as CARB, i.e., the acronym CARB agency that created it). 

Its goal is to reduce public exposure to formaldehyde. The Air Resources Board evaluated formaldehyde exposure in California and found that one of the significant sources of exposure is from inhalation of formaldehyde emitted from composite wood products containing urea-formaldehyde resins.

In 2017, the EPA finalized a new rule – the Formaldehyde Standards for Composite Wood Products Act, which added Title VI to the Toxic Substances Control Act (TSCA) – that extends CARB requirements to all 50 states.

CARB and the EPA regulation reduce exposure to formaldehyde through the establishment of strict emission performance standards on particleboard, medium-density fiberboard (MDF), heavy-density fiberboard (HDF), and hardwood plywood (collectively known as composite wood products). In addition, they require that composite wood products, including those used in some types of engineered wood flooring, be tested and certified as compliant at the mill that makes them. The CARB regulation was introduced in two phases: CARB 1 came first and had higher emissions limits than CARB 2.

California now has the strictest formaldehyde emissions laws for wood products on Earth. For composite wood products to be sold legally in California, they must meet standards that only a few years ago were seen only with rigorous independent green product certifications.



Only engineered wood flooring that is constructed like plywood (i.e., made up of multiple layers of veneer) OR whose format incorporates composite wood products such as hardwood plywood or Heavy Density Fiberboard (HDF) must meet CARB regulations. Generally, composite wood products constitute the underlying platform to which the visible wood wear layer is affixed when used to make flooring.


Flooring products that are subject to CARB regulations include:

  • Engineered wood or bamboo flooring that has a multilayer hardwood plywood platform (e.g., Baltic Birch)

  • Engineered wood, cork, or laminate flooring that has a High-Density Fiberboard (HDF) platform

  • Multi-ply wood flooring that is made up of multiple layers of veneer and thus resembles plywood in its construction


Flooring products that are NOT subject to CARB regulations include:

  • Solid wood flooring

  • Solid “traditional” bamboo flooring (made entirely of laminated pieces of bamboo)

  • Solid “Strand” bamboo flooring (made of bamboo fibers mixed with phenol-formaldehyde resins)

  • Solid, densified poplar flooring

  • Solid cork tiles

  • Engineered wood and bamboo flooring that has a solid lumber core (commonly known as 3-ply)


For engineered wood flooring products not subject to CARB, Galleher is careful only to source and sell products that meet CARB 2 formaldehyde emissions standards.

Companies that make wood flooring containing composite wood products must label their flooring or their boxes of flooring as having been made with certified compliant composite wood products to keep records to verify that they have purchased compliant products and inform distributors and retailers that their flooring is compliant.

Most wood flooring manufacturers are not required to be certified under CARB. Instead, they are required to make their flooring using certified composite wood products when these products are used at all. The resulting flooring product is considered CARB 

compliant and labeled as such, but only the substrate is “certified.”



CARB provides special provisions for manufacturers of composite wood products that use no-added formaldehyde (NAF) or ultra-low-emitting formaldehyde (ULEF) resins. NAF-based resins are formulated with no added formaldehyde as part of the resin cross-linking structure. ULEF resins are formaldehyde-containing resins formulated such that the formaldehyde emissions from composite wood products are consistently below applicable Phase 2 emission standards.

Manufacturers who demonstrate the use of NAF resins can receive an exemption from CARB requirements, and such manufacturers are “CARB exempt.” In addition, manufacturers who use ULEF resins can apply for approval to have their products tested less frequently or for an exemption.


FloorScore Certification

FloorScore provides expanded assurance for people concerned about IAQ. To get certified under the FloorScore standard, products are tested by independent labs which verify that they meet emission limits for 35 individual VOCs (including formaldehyde) specified by the California Standard Method for VOC Emissions Testing and Evaluation Standard Method V1.2, otherwise known as CA Section 01350.