I-10 Compliance Clarifications

Products Containing Composite or Engineered Wood

Composite wood products, or products that contain composite wood, are required to provide additional VOC emissions documentation to an Approved Product Emissions Standard or Conformant Certification to meet the requirements of this Imperative in the Living Building Challenge and receive a listed compliant pathway on the product’s Declare label. Otherwise, the product Declare label will display: “Not Compliant”. Documentation and certifications that demonstrate low formaldehyde emissions, such as CARB ASTM and/or TSCA Title VI Compliance or BIFMA X7.1 testing, must be supplemented by additional documentation demonstrating CDPH / Approved Products Emission Standards Compliance for the purposes of the Living Building Challenge.

Structural Members – Composite or Engineered Wood

Structural members made of composite or engineered wood are not required to demonstrate compliance to the above; the CDPH Standard excludes structural material. Manufacturers of these products that pursue a Declare label for the product will see their label read “Not Applicable” for this LBC criterion. Project teams pursuing LBC are provided the following clarification:

*“Project teams are advised that while structural material is not subject to the requirements of CDPH, depending on where they are used, composite structural members could influence the results of the indoor air quality test, which references formaldehyde and a number of other VOCs. In addition, for projects pursuing I-13 Red List, ingredients requirements remain applicable, including those related to formaldehyde.” – LBC Materials Petal Handbook

With respect to composite or engineered structural wood, prioritizing products that meet applicable standards identified in APA Technical Note J330D will best-position projects for compliance with formaldehyde-related requirements within LBC. The Technical Note lists USA and Canadian production specifications for structural wood and compares the formaldehyde emissions to other international specifications and formaldehyde emissions thresholds for these products.”

Inherently Non-Emitting Substances

Products that are considered inherently non-emitting sources of VOCs and have no integral organic-based surface coatings, binders, or sealants, are not required to demonstrate compliance to CDPH limits on VOC emissions. These products include stone, ceramic, powder-coated metals, plated or anodized metal, glass, concrete, clay brick, certified organic fabrics and upholstery, and unfinished or untreated solid wood.