The US buyer wants CARB / TSCA Title VI: Prop 65 and CE will not fill composite-wood formaldehyde

Bottom line:

When a US buyer asks for CARB / TSCA, EPA covers hardwood plywood, particleboard, MDF and finished goods that contain them. They must be certified and labeled under TSCA Title VI. After 22 March 2019, an old CARB-only label will not do for imports.
Prop 65, CE and a children’s CPC each stay in their own box. Opening the store does not issue the label.
Certification follows the body quote. There is no official US-dollar price.

The inquiry says: “Need CARB certificate / TSCA Title VI / formaldehyde free.” Sales staples a Prop 65 warning, a furniture CE and a two-year-old Chinese “CARB Phase 2” letter. The buyer replies that the panel has no EPA-recognized TPC number. The shop floor asks whether to buy another California certificate or print a no-formaldehyde mark on the carton.

How the California warning is written sits on Prop 65. The children’s certificate sits on CPSIA. Food and cosmetics sit on FDA. This page only splits the composite-wood formaldehyde box: who certifies the panel, how the finished good is labeled, and how it stays apart from the others.

1. The paper they want sits on the panel and the cabinet

Title VI covers three panels — hardwood plywood, particleboard, MDF — and component parts and finished goods that contain them. The panel producer certifies through an EPA-recognized third-party certifier. The panel or bundle label names the producer, the lot, the TPC number and a Title VI statement. The fabricator labels the finished good: name, production month and year, Title VI statement.

What they say	What it is	Issued with a Hong Kong store?
CARB certificate	Usually Title VI panel certification and the finished-good label; the California ATCM is a separate state rule	No. An old Phase 2 PDF will not match post-2019 imports
TSCA Title VI	The federal formaldehyde rule: certification, labels, importer records	No. Opening the store does not make you the importer
Prop 65	A California warning	It will not fill a TPC number
CE / CPC	EU conformity, a US children’s certificate	Neither writes the panel-formaldehyde box

Ask first whether this unit contains a regulated composite panel. On solid-wood furniture or an all-metal rack, a spoken “CARB” often means Prop 65 or the buyer’s own substance list. Retitling a panel report for an all-textile sofa produces the next email asking for the foam.

2. The label sits on this lot, not on “our factory passed”

The TPC number belongs to the panel producer and that lot. A new mill, a new resin or a new contract factory will not take the old label. The importer must keep, for three years, a bill of lading or invoice with a written compliance statement, and be able to name the panel producer and production date within thirty days if EPA asks.

A Hong Kong company can be the seller. The US importer is the party who certifies the import and keeps the records. Opening the store does not name an importer and does not sign for them.

Certification and testing follow the body and the panel type. There is no site-wide official US-dollar price. Do not lock an “official CARB fee” into the unit price.

3. Prop 65, CE and a CPC will not fill this box

Prop 65 answers whether California wants a warning. That is that page. A warning can be on and the panel still needs a Title VI label.

CE is EU conformity. A children’s CPC is issued by the US importer from third-party tests. That is the CPSIA page. Neither fills an EPA TPC number.

Writing “formaldehyde free / CARB certified” on a showcase while the cabinet has no matching label will be screenshotted back at you.

4. How the inquiry can be answered

They write	A usable reply	Do not write
Send CARB / TSCA certificate.	Regulated composite wood and finished goods imported into the United States are certified and labeled under Title VI. We will provide the panel-certification summary and finished-good label information for this lot. The importer keeps the records. Prop 65 stays separate.	Retitle a two-year-old CARB Phase 2 or a CE.
You have Prop 65, so formaldehyde is done.	Prop 65 is a warning. Title VI is panel certification and the label. Two boxes.	A California paper means the whole chemicals pack.
Put CARB certified / formaldehyde free on your store.	Without a matching panel certification and finished-good label, the showcase will not say certified or formaldehyde free.	Write it first so inquiries convert.
How much is the official CARB fee?	There is no site-wide official US-dollar price. Bodies quote by panel type. Opening the store does not include it.	Lock an “official certification fee” into the unit price.

Do not write “CARB passed” or “formaldehyde free” on a showcase. You can say the seller is a Hong Kong company, that goods containing regulated composite wood are labeled under Title VI, and that this stays apart from Prop 65 and CE.

5. If you already replied “we have CARB”

Tell sales the same day: prices that say “certified / formaldehyde free” stop.
Open this US order: is there a regulated panel, do they want the panel certification or the finished-good label, and who is the importer.
Keep Prop 65, CE and the CPC as their own files. Do not merge and retitle.
Match the panel lot and the fabrication month. Do not hand the master account to an intermediary to “make a certificate.”
If the goods are already moving: send the matching label information. Do not invent a TPC number.

The membership still buys the file and the showcases. Wire it to ALIBABA.COM HONG KONG LIMITED. Corpable does not act as the importer or certify to EPA. What customs asks for follows their process that day. Do not write a penalty figure into the contract.

Questions teams actually ask

Is a CARB certificate something you buy from California?

No. California has the ATCM. The federal rule is EPA’s TSCA Title VI. Composite wood and finished goods imported into the United States after 22 March 2019 must be certified and labeled under Title VI. An old “CARB Phase 2” intermediary PDF will not do.

If we have a Prop 65 warning, is formaldehyde done?

No. Prop 65 is a California warning law. That is that page. Title VI is formaldehyde from composite wood, plus labels and records. A warning can be on the carton while the panel still has no EPA-recognized TPC number.

If the furniture plant has a “whole factory CARB pass,” will it cover every cabinet?

Panels are certified by the panel producer through an EPA-recognized third-party certifier. The finished-good label names the fabricator, the production month and year, and a Title VI statement. A new panel lot or a new contract factory will not take the old label.

Does opening Alibaba.com on a Hong Kong company already give us TSCA?

No. The membership buys showcases. It does not issue a Title VI label and it does not make the US importer keep records. A Hong Kong letterhead will not fill an EPA TPC number.

May the showcase say “CARB passed / formaldehyde free”?

Not without a matching panel certification and finished-good label. Testing and certification follow the body quote. There is no site-wide official US-dollar price. Writing “certified” will be screenshotted back when they ask for label photos.

Can Corpable file CARB for us, or guarantee a US clearance?

No. An advisor can sit with you on whether they want the panel certification or the finished-good label. We do not act as the importer, certify to EPA or promise customs. Membership still wires to ALIBABA.COM HONG KONG LIMITED.