CARB P2 is the California rule; TSCA Title VI is the federal rule that largely mirrors it. Both require a test report naming the board grade and method, plus a chain of custody from panel to finished cabinet. The claim usually fails on paperwork, not on the board.
CARB P2 is the California rule; TSCA Title VI is federal.
A valid report names grade, method, result, lab and date.
Chain of custody links panel to cabinet.
Hold a report plus a per-shipment declaration.
Keep records at least three years.
1. The two rules
CARB P2 comes from California and sets limits for composite wood. TSCA Title VI is the federal rule and largely mirrors it. For a supplier, meeting CARB P2 usually satisfies TSCA Title VI in substance; for a buyer, the difference is in the paperwork and the scope.
2. CARB P2 vs TSCA Title VI
| Item | CARB P2 | TSCA Title VI |
|---|---|---|
| Level | California | Federal |
| Scope | Composite wood | Composite wood |
| Limit basis | Phase 2 | Mirrors phase 2 |
| Paperwork | Report and declaration | Report and declaration |
| Enforcement | State | Federal |
The numeric limits are revised from time to time. Check the current version for the project, and do not rely on a number remembered from an old report.
3. Scope
Scope covers panels, doors and carcasses, including MDF, particleboard and plywood. Solid wood is generally out of scope, but a composite core with a veneer face is in scope. A cabinet can be partly in and partly out, which is why the report has to name each board.
4. A valid report
A valid report names the board grade, the method, the result, the laboratory and the date. It should also link to the batch or the supplier invoice. A report that names only the factory is a claim about the factory, not the board.
5. Chain of custody
Chain of custody is the trail from the panel supplier to the finished cabinet. Without it, a report proves a panel was compliant, not that the cabinet uses that panel. Ask for the panel invoice and the production record that links it to the order.
6. Declarations per shipment
Most buyers hold the underlying report on file and take a declaration per shipment that ties the goods to the report. The declaration should name the order, the board grade and the report reference. The compliance documents guide shows where it sits in the pack.
7. Verifying a supplier claim
Verify at three points: the quote, the pre-shipment inspection and the arrival documents. At each point, check the report reference against the order. A claim that cannot be traced to a report is a risk, not a compliance position.
8. Common mistakes
Three mistakes recur: accepting a factory certificate as a board report, missing the chain of custody, and relying on an old report after a board change. Each is avoidable by asking for the report reference and the panel invoice at the same time.
9. A checklist before you commit
Before you sign, confirm six things: the board grade, the hardware model, the finish system, the packing standard, the inspection scope and the payment schedule. Each should be in writing, not in a call. The quote checklist turns the six into a one-page comparison.
10. Common mistakes
The most common mistake is comparing a factory price with a landed cost. The second is leaving the inspection out of the budget. The third is paying the balance before the inspection is signed off. Each is avoidable with a written scope and a pre-shipment inspection.
11. How to measure the room
Measure each wall at three points, top, middle and bottom, and use the smallest. Walls are rarely square, and a 10 mm bow over three metres changes the filler. Measure the ceiling at each corner and note sockets, radiators and soil pipes before drawing. A measured survey saves more time than a faster drawing, and the measuring guide has a printable sheet.
Frequently asked questions
What is CARB P2?
CARB P2 is the California Air Resources Board phase 2 limit for composite wood products. It applies to panels used in cabinets sold in California and is widely adopted across the US market.
Does TSCA Title VI replace CARB P2?
No. TSCA Title VI is the federal rule and largely mirrors CARB P2. In practice a product that meets CARB P2 usually meets TSCA Title VI, but the paperwork must show both.
What does a valid test report include?
The board grade, the test method, the result, the laboratory and the date. It should also link to the batch or the supplier invoice.
What is chain of custody?
The trail from the panel supplier to the finished cabinet. Without it, a test report proves a panel was compliant, not that the cabinet uses it.
Do I need a certificate per shipment?
Usually a report plus a declaration per shipment, with the underlying report on file. The declaration ties the shipment to the report.
How long should records be kept?
At least three years. US rules and buyers can ask after clearance, and an insurer may ask after a claim.
