VOC Emissions Standards for Flooring: California 01350 and CARB Reference

Volatile organic compound (VOC) emissions standards govern the chemical off-gassing limits allowable in flooring materials and adhesives used in occupied buildings. Two frameworks dominate procurement and specification decisions in the US market: the California Department of Public Health's Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions from Indoor Sources Using Environmental Chambers (CDPH SM v1.2, commonly called "California 01350") and the California Air Resources Board (CARB) Airborne Toxic Control Measure (ATCM) for composite wood products. Understanding where each applies, how they are measured, and how they interact is essential for flooring contractors, specifiers, and building owners operating in regulated or certification-seeking environments.

Definition and scope

California 01350 is a test method developed by the California Department of Public Health (CDPH) that sets maximum allowable concentrations of specific VOCs emitted from products used in schools and offices. It covers flooring materials including carpet, resilient flooring, wood flooring, and associated adhesives and coatings. Products are tested in environmental chambers under standardized temperature and humidity conditions, and emission factors are modeled against a reference office or classroom scenario. A product "complies with Section 01350" when its modeled VOC concentrations fall below the threshold limits specified in the CDPH Standard Method.

CARB ATCM for Composite Wood Products — codified at California Code of Regulations Title 17, §93120 et seq. — is a separate regulatory instrument targeting formaldehyde emissions specifically from composite wood panels such as hardwood plywood, medium-density fiberboard (MDF), and particleboard. Because engineered wood flooring, laminate, and certain subfloor assemblies incorporate these panels, CARB Phase 2 formaldehyde limits apply directly to large segments of the flooring product market.

The scope distinction is material: California 01350 is a voluntary test method adopted by specification programs (LEED, CHPS, and public school procurement standards), while CARB ATCM is a mandatory regulation enforceable by the California Air Resources Board with civil penalties under California Health and Safety Code §39674. Products sold into California's composite wood market must carry documentation of CARB-compliant resin systems or third-party certification from a CARB-approved testing laboratory.

How it works

California 01350 — testing and modeling process:

Chamber conditioning: Product samples are placed in a stainless-steel environmental chamber at 23°C, 50% relative humidity, and an air-change rate specified by the standard.
Emission measurement: Air samples are collected at 24 hours and at a defined second interval (typically 96 hours or 14 days depending on the protocol version), then analyzed for target compounds using gas chromatography/mass spectrometry (GC/MS).
Exposure modeling: Measured emission rates are input into a single-zone mass balance model representing either a standard office (250 ft²) or classroom (1,000 ft²) to calculate predicted steady-state air concentrations.
Threshold comparison: Modeled concentrations are compared against the chemical-specific reference exposure levels (RELs) established by CDPH, based on chronic and acute toxicity data from the California Office of Environmental Health Hazard Assessment (OEHHA).
Compliance determination: Compliance is issued per product and per scenario (office or classroom). A product passing the classroom scenario is considered the more stringent outcome.

CARB composite wood — regulatory mechanism:

CARB Phase 2 limits are expressed as maximum formaldehyde emission concentrations in parts per million (ppm). For MDF, the Phase 2 limit is 0.11 ppm (CARB Title 17, §93120.2); for hardwood plywood with composite cores, the limit is 0.05 ppm; for particleboard, 0.09 ppm. Manufacturers must use qualifying resin systems (typically ultra-low-emitting formaldehyde or ULEF resins) or obtain third-party certification from a CARB-approved certifier. Distributors and fabricators in the supply chain bear co-compliance obligations.

Common scenarios

Commercial and institutional procurement: Public school construction and renovation projects in California typically require products that meet California 01350 for any flooring installed in occupied spaces. The Collaborative for High Performance Schools (CHPS) criteria reference 01350 compliance as a prerequisite for material credits.

Green building certification: LEED v4 and v4.1 under the Materials and Resources (MR) and Indoor Environmental Quality (EQ) credits require flooring products to comply with CDPH SM v1.2, or equivalent, for projects pursuing certification. Products must be documented with a test report from an accredited third-party laboratory.

Engineered and laminate flooring sales into California: Any laminate or engineered wood flooring product sold in California and containing MDF, particleboard, or composite core materials must be CARB Phase 2 compliant. Retailers and distributors who sell non-compliant product face enforcement actions under CARB's supply-chain liability structure.

Multi-state projects: Outside California, states including Washington and Oregon have adopted or referenced CARB-equivalent formaldehyde standards. The federal Formaldehyde Standards for Composite Wood Products Act (TSCA Title VI) — administered by the EPA — harmonized national formaldehyde emission limits with CARB Phase 2 levels, making CARB Phase 2 the effective national baseline for composite wood products sold in the US after December 2022.

Flooring contractors and specifiers working across multiple jurisdictions can reference the flooring listings on this directory to identify suppliers and contractors with documented compliance capabilities. The flooring directory purpose and scope page describes how the directory is structured by product type and service category.

Decision boundaries

Not all flooring products or projects trigger these standards equally. The following classification matrix identifies when each framework applies:

Condition	California 01350 applies?	CARB ATCM applies?
Solid hardwood flooring, no composite core	Yes (adhesives/coatings)	No
Laminate flooring with MDF core	Yes	Yes
Engineered wood with hardwood plywood core	Yes	Yes (0.05 ppm limit)
Carpet with adhesive	Yes (adhesive)	No
Resilient vinyl or LVT (no composite wood)	Yes	No
Concrete subfloor sealers	Yes	No

Voluntary vs. mandatory distinction: California 01350 compliance is legally mandatory only when written into a public contract specification, a building permit condition, or a lease covenant requiring it. CARB ATCM compliance is mandatory by regulation for any composite wood product sold, offered for sale, supplied, or manufactured for sale in California — regardless of project type or voluntary program participation.

Third-party certification requirement: CARB-compliant composite wood products must be certified by a CARB-approved third-party certifier (TPC). The CARB-approved TPC list is maintained at the California Air Resources Board composite wood page. Self-declaration of CARB compliance is not accepted; chain-of-custody documentation must accompany product through the supply chain.

Federal preemption and TSCA Title VI interaction: For manufacturers and importers operating nationally, TSCA Title VI (40 CFR Part 770) establishes emission limits, laminated product provisions, and third-party certification requirements that parallel California's structure. California retains the authority to enforce its own ATCM for products sold within the state, meaning dual compliance documentation is standard practice for national distribution.

Professionals seeking contractor or supplier references with documented VOC compliance credentials can use how to use this flooring resource to navigate directory listings by compliance scope and product category.

References

📜 1 regulatory citation referenced · 🔍 Monitored by ANA Regulatory Watch · View update log