🇺🇸 US Compliance · Formaldehyde · SPC & LVT · 2026
CARB2 & TSCA Title VI for SPC Flooring: What US Importers Actually Need
Buyers and big-box procurement teams routinely ask vinyl suppliers for “CARB2 compliance.” The honest answer surprises most importers — and it works in your favour. Here is exactly how the federal formaldehyde rule applies to rigid SPC and LVT, where it genuinely bites, and the documentation you should actually be collecting.
Short answer
Pure SPC and rigid LVT contain no regulated composite wood — no hardwood plywood, particleboard or MDF — so they generally fall outside the TSCA Title VI and CARB ATCM Phase 2 composite-wood scope. That is a compliance advantage over laminate and engineered-wood flooring, which do carry the formaldehyde-certification burden.
Last reviewed June 2026 · General information, not legal or customs advice — confirm with your customs broker and a qualified consultant.
What the rule actually regulates
TSCA Title VI & CARB ATCM Phase 2 — a composite-wood rule
Both standards exist to limit formaldehyde emissions from composite wood. They are set at identical emission levels; since March 2019 the federal TSCA Title VI label is the operative one nationwide, and CARB ATCM 93120 Phase 2 was the California template it was built from.
The regulated panels are hardwood plywood (HWPW), particleboard (PB), and medium-density fiberboard (MDF, including thin MDF) — plus finished goods that contain those panels. Formaldehyde is the target because it off-gasses from the urea-formaldehyde resins used to bond wood fibres. A product with no wood-resin panel has nothing for the rule to measure.
Reference · the regulated limits
Formaldehyde emission limits — composite wood panels
These are the panel limits the rule enforces. They are shown here for context: a rigid SPC core is never tested against them, because it is not one of these panels.
| Regulated panel | Emission limit (ppm) |
|---|
| Hardwood plywood (HWPW) | 0.05 |
| Particleboard (PB) | 0.09 |
| Medium-density fiberboard (MDF) | 0.11 |
| Thin MDF (≤ 8 mm) | 0.13 |
Limits per CARB ATCM 93120 Phase 2 / EPA TSCA Title VI (40 CFR 770), in parts per million. SPC and rigid LVT have no plywood, particleboard or MDF layer, so they are not measured under this scheme.
Where it applies — and where it doesn’t — across flooring
✓ Generally OUT of scope
→SPC (Stone Plastic Composite) — rigid PVC + limestone core, IXPE backing. No composite wood panel.
→Rigid / click LVT — PVC core, no wood panel.
→Dryback & loose-lay LVT — flexible PVC, no wood panel.
These are not “CARB2 certified” because the standard does not regulate them — there is no wood panel to test. The correct statement is that they contain no regulated composite wood and add no formaldehyde.
⚠ IN scope (wood core present)
→Laminate flooring — HDF/MDF core. Squarely a composite-wood finished good.
→Engineered wood — plywood core; producers are “laminated product” fabricators under the rule.
→WPC with wood flour — if a regulated wood panel is used, it can fall in scope.
If you also source these categories, they need TSCA Title VI-certified core material and the matching compliance records. This is a real reason buyers prefer SPC.
The practical part
What to collect instead — and what Ecoflors provides
Even when a product is out of scope, US importers, distributors and retailers must take “reasonable prudent precautions” — in practice, holding a supplier statement on file. And big-box and spec buyers often require formaldehyde/indoor-air documentation as a blanket purchasing rule. So the goal is not a CARB2 panel certificate (which doesn’t exist for vinyl) — it is the right alternative evidence:
Statement of Compliance
Non-applicability + NAF
A signed statement that the product contains no regulated composite wood (HWPW/PB/MDF) and no added urea-formaldehyde — satisfying your “reasonable prudent precautions” file for TSCA Title VI.
FloorScore
SCS-FS-05154
Tests indoor-air emissions to the CDPH (California 01350) method, which includes a formaldehyde criterion. This is the certification that actually addresses the concern CARB2 covers for wood — and it applies to vinyl.
GREENGUARD Gold
135464-420 (SPC)
A stricter indoor-air standard built for schools and healthcare, with its own formaldehyde emission criterion. Accepted for LEED v4 and WELL v2 — the documents US specifiers actually request.
Importer FAQ
CARB2 & TSCA Title VI questions for vinyl buyers
Is SPC flooring CARB2 / TSCA Title VI certified?
Strictly speaking, no — and that is the correct answer. CARB ATCM Phase 2 and TSCA Title VI regulate composite wood (hardwood plywood, particleboard, MDF). Rigid SPC and LVT contain none of these, so there is no panel to certify and the product sits outside the rule’s scope. What Ecoflors provides instead is a statement that the product contains no regulated composite wood and no added formaldehyde, backed by FloorScore and GREENGUARD Gold — which test the indoor-air emissions the standard is concerned with.
Then why do buyers keep asking for “CARB2 compliance” on vinyl?
Because procurement teams often apply one formaldehyde checklist to every flooring category, and many suppliers reinforce the confusion by loosely claiming “CARB2 compliant.” The accurate position is stronger for you as a buyer: SPC has no formaldehyde-emitting wood core to begin with. Asking for a statement of non-applicability plus FloorScore/GREENGUARD gives your file everything a CARB2 line item was trying to achieve.
Which flooring products ARE regulated by TSCA Title VI?
Flooring that contains a regulated wood panel: laminate (HDF/MDF core), engineered wood (plywood core), and any WPC that uses a regulated wood-composite panel. Producers of these are treated as fabricators of laminated products and must use TSCA Title VI-certified core material with the matching records. If your range mixes vinyl and laminate, the laminate lines are the ones that need the certificate.
What documentation should I keep on file as a US importer?
For vinyl: a supplier statement of compliance (no regulated composite wood / no added formaldehyde), plus FloorScore (SCS-FS-05154) and GREENGUARD Gold certificates. Holding these satisfies the “reasonable prudent precautions” expectation and answers the indoor-air questions specifiers and big-box buyers raise. See our
FloorScore vs GREENGUARD guide for which to lead with.
Does being out of scope mean SPC has high formaldehyde?
No — the opposite. SPC is out of scope precisely because it has no urea-formaldehyde wood resin to off-gas. The formaldehyde concern that drove the composite-wood rule simply isn’t present in a PVC + limestone core. FloorScore and GREENGUARD Gold testing confirm the low indoor-air emission profile for the product as a whole.
How does this fit with import tariffs on SPC?
They are separate issues — compliance documents don’t change duty. For the 2026 tariff picture (5.3% MFN + 25% Section 301 + 10% Section 122, with no AD/CVD on vinyl), see our
SPC tariff guide — Section 301 + 122. Together, the tariff page and this page cover the two questions every US importer asks before a first order.
Factory-direct · Full document pack
Get the compliance pack with your quote.
Tell us your product, thickness and target market. Within one business day we send the FOB price, the statement of compliance (no regulated composite wood / no added formaldehyde), and the FloorScore and GREENGUARD Gold certificates — so your procurement file is complete before the first container ships.
HS Code 3918.10 · FOB Ningbo / Shanghai · MOQ 800 sqm / SKU
FloorScore SCS-FS-05154 · GREENGUARD Gold · CE EN 14041 · factory-direct from Changzhou, China since 2017
Disclaimer: General information for SPC/LVT importers, not legal, customs, or regulatory advice. TSCA Title VI (40 CFR 770) and CARB ATCM 93120 Phase 2 regulate formaldehyde from composite wood products (hardwood plywood, particleboard, MDF) and finished goods containing them; scope determinations depend on a product’s actual construction. Confirm your specific products and obligations with a qualified compliance consultant and your customs broker. Reviewed June 2026.
