Layer one, emissions: TSCA Title VI federalised the CARB Phase 2 limits, so the two names now describe one regime with identical numbers, and compliance flows up from the panel mill. Every composite panel in the product carries certification from an EPA-recognised third-party certifier, the TPC; the furniture maker's job is to buy certified board, keep the mill records, label accordingly and back the import certification statement made at entry. The recurring failure is not exotic: uncertified or mixed board sneaking into a run, which is why the specification names TPC-certified panels and the file keeps the mill certificates per batch. European E1 is not the same thing: close in spirit, not interchangeable in paperwork, and US entries run on TSCA documentation.
Layer two, wood identity: the Lacey Act declaration, filed as PPQ 505, lists the scientific name and country of harvest for the wood in the shipment, and the scope explicitly includes composite materials, so MDF and particleboard declare their species content too. Getting species data for composite panels means asking the mill, which is another reason integrated, certified panel suppliers anchor a US-ready chain. False or missing declarations are a federal offence with penalties that have reached famous case law, so the declaration is prepared with the commercial documents, not improvised at the broker's desk.
Layer three, stability and product safety: the STURDY Act made ASTM F2057-23 mandatory for free-standing clothing storage units at least 27 inches tall and 30 pounds, dressers and wardrobes foremost, with testing that simulates a 60-pound child, open-drawer conditions and carpet placement, warning labels, anti-tip anchoring hardware and a General Certificate of Conformity; children's furniture adds third-party testing and a Children's Product Certificate. California adds Proposition 65 warnings where listed substances apply and the TB 117-2013 fire pair covered in our fire-standards guide. None of this is negotiable at the port; all of it is cheap at the drawing stage.
One regime, two names
CARB Phase 2 and TSCA Title VI carry identical formaldehyde numbers, with CARB as the Californian origin and TSCA the federal rule; suppliers advertising CARB P2 board are describing the right chemistry, and the US entry still documents under TSCA with TPC certificates behind it.
The Lacey trap on composites
PPQ 505 covers MDF and particleboard species content, which surprises exporters who thought declarations were a solid-wood affair; mills that publish species and origin data make the form routine, and mills that cannot are a US-market disqualifier.
STURDY is a design gate, not a sticker
Interlocks, anchor hardware, weighted-drawer stability and labels are engineered before tooling; a dresser that fails F2057-23 cannot be papered into compliance, and marketplaces now ask for the GCC up front.