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February 17, 2021

Berkeley Analytical Tests Wood Products by EN 16516 for Compliance with New German Formaldehyde Emission Ordinance

What are the allowed formaldehyde emission rates from wood products in Germany?

January 2021 marked the first anniversary for the implementation of the German “Ordinance on bans and restrictions on placing on the market and on the delivery of certain substances, mixtures and products according to the Chemicals Act (Chemicals Prohibition Ordinance – ChemVerbotsV)". If you haven’t heard, Germany effectively established lower limits for the emissions of formaldehyde from coated and uncoated wood-based materials and defined a new test method for demonstrating compliance to these requirements. EN 16516 is the new reference method for the required testing and has been amended to include specific conditions for measuring formaldehyde emissions from wood-based materials. EN 717-1 is still allowed as an additional test method. Germany says that the acceptance criterion is still the indoor air guideline of 100 ppb (120 µg/m3) formaldehyde concentration in chamber air; but that the measured chamber concentration by EN 717-1 needs to be multiplied by a correction factor of two to account for a general decrease in building ventilation rates. In practical terms this is just another way of saying that the allowed emission concentration has, in fact, been reduced by a factor of two to 50 ppb (60 µg/m3) as measured by EN 717-1.

How do the two test methods for formaldehyde emissions in Germany compare?

The two test procedures allowed under the German Prohibition of Chemicals Ordinance are compared in Table 1. EN 16516, as amended, is the primary method. EN 717-1 is still allowed, but the maximum allowed formaldehyde concentration is effectively lowered by a factor of two. The main difference between the two methods is the specified area-specific airflow rate. Due to the lower air change rate and the higher loading factor, the area-specific airflow rate for EN 16516 is 3.6 times lower than the value for EN 717-1, i.e., the dilution airflow rate per unit area of material is 3.6 times lower. Since formaldehyde emissions are strongly influenced by mass transfer resistance, formaldehyde emissions from the same board will be lower in the EN 16516 test. The net result is that the maximum allowed formaldehyde emission factor by the EN 16516 procedure is about a factor of two lower than the acceptable emission factor using the EN 717-1 procedure with an allowed concentration of one-half the previous value of 100 ppb, i.e., 60 µg/m3.

Table 1. Comparison of allowed German test methods for formaldehyde emissions from wood products

Test Parameter
 Test Method
EN 16516 amended EN 717-1
Temperature (oC) 23 ± 1 23 ± 0.5
Relative humidity (%) 50 ± 5 45 ± 3
Duration (days) 28 Days to steady state
Air change rate (h-1) 0.5 ± 0.015 1.0 ± 0.05
Loading factor (m2/m3) 1.8 1.0 ± 0.2
Unsealed edges to surface area (m-1) 1.5 1.5
Area-specific airflow rate (m/h) 0.28 1.0
Maximum allowed conc (µg/m3) 120 120/2 = 60
Maximum allowed area-specific emission rate (µg/m2-h) 33.3 60


Will composite wood that complies with EPA TSCA Title VI for hardwood plywood also comply with the German ordinance?

In Table 2, the amended EN 16516 is compared to ASTM D6007, the U.S. Secondary test method for the U.S. EPA TSCA Title VI and CARB ATCM formaldehyde regulations. The area-specific airflow rate for EN 16516 is about a factor of four lower than for the reference method, ASTM D6007 in this case. If a sample tested by ASTM D6007 is tested by EN 16516, we expect that the area-specific emission rate will decrease by about a factor of two due to the difference in mass transfer resistance. The two-degree Celsius temperature difference also will lower the emission rate. Thus, from the comparison of the emission factors in Table 2, it’s probable that hardwood plywood and other composite woods that are in compliance with EPA TSCA Title VI for the hardwood plywood category will also be in compliance with the new German ordinance.

Table 2. Comparison of amended EN 16516 with ASTM D6007 for formaldehyde emissions from wood products

Test Parameter
 Test Method
EN 16516 amended ASTM D6007
Temperature (oC) 23 ± 1 25 ± 1
Relative humidity (%) 50 ± 5 50 ± 4
Duration (days) 28 7 + 1 = 8
Air change rate (h-1) 0.5 ± 0.015 na
Loading factor (m2/m3) 1.8 na
Area-specific airflow rate (m/h) 0.28 1.173
Maximum allowed conc (µg/m3) 120 61
Area-specific emission rate (µg/m2-h) 33.3 72


Berkeley Analytical can help companies meet the formaldehyde testing requirements in the new German ordinance

Companies that are exporting wood-based products to Germany and to a number of other EU countries need to test these products for compliance with the formaldehyde emission requirements in the German Prohibition on Chemicals Ordinance. The scope of this ordinance is broader than the formaldehyde regulations in the U.S. The ordinance applies to all coated and uncoated wood-based materials such as chipboard blockboard, fiberboard, and veneer products. Additionally, furniture containing wood-based materials must also meet these requirements. If wood-based products meet the requirements by themselves, no further testing of coated products is required. However, if coatings are applied to wood products that don’t comply, the assemblies must be tested in their coated state. It’s important to note that, unlike in the U.S., the German Prohibition on Chemicals Ordinance does not require third-party certification for formaldehyde testing of wood products.

Berkeley Analytical is ready to assist companies with meeting the formaldehyde testing requirements in the German ordinance. Berkeley Analytical is an ISO/IEC 17025 accredited test laboratory with EN 16516 in the scope of its accreditation. In addition, Berkeley Analytical is highly experienced with measuring emissions of formaldehyde from all types of composite wood products by ASTM D6007 and by other test methods such as CDPH Standard Method V1.2. Contact us today to get a quote.

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