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New Rules for Formaldehyde in IEQc4.4

LEED Interpretation #10250, issued January 1, 2013 and applicable to all LEED 2009 projects, as well NC-v2.2 and other systems, now allows for the use of urea in combination with melamine formaldehyde (MF) in certain circumstances.
Brent Ehrlich
February 21, 2013

Editor's Update: As expected, LEED Interpretation #10250 was revisited by USGBC in its 4/1/13 release. This article has been updated to address that revision. 

Composite wood products made with added urea formaldehyde (UF) are one of the few products that LEED has consistently banned under its longstanding IEQc4.4: Low-emitting Materials credit. However, LEED Interpretation #10250, issued January 1, 2013 (revised April 1, 2013) and applicable to all LEED 2009 projects, as well NC-v2.2 and other systems, now allows for the use of urea in combination with melamine formaldehyde (MF) in certain circumstances. The Interpretation was meant to clarify longstanding questions about the use of MF resins. Products that use MF resins without any urea are allowed, per the original credit language. However, many MF-containing products have a urea component. The Interpretation addresses those products as follows: 

• Urea, when used as part of a melamine-urea-formaldehyde (MUF) resin or as a formaldehyde “scavenger,” is allowed as long as the composite wood product meets California Air Resource Board (CARB) Airborne Toxic Control Measure (ATCM) 93120 requirements for ultra-low-emitting formaldehyde resins (ULEF).

Note that in the original January 1, 2013 Interpretation composite wood products that used urea as a scavenger were not allowed, even if they met ULEF requirements. The April 1, 2013 revision reversed that decision.

According to André Verville, research and technical director at Uniboard, maker of ULEF melamine particleboard and other composite wood products. Urea itself “scavenges” leftover free formaldehyde from the MF reaction and converts it into another form, which should actually reduce formaldehyde emissions from the product, he explained, when compared with MF resins that don’t use urea scavengers.  Verville said that pure MF products could have up to three times the emissions of those using the scavenger.

The chemistry of these resins is complicated, and there have been concerns that formaldehyde could be released over time from products using urea as a scavenger—particularly in hot, humid climates. But the ULEF performance-based policy requiring emissions testing was later deemed sufficient enough to address these concerns. Design teams looking to avoid all formaldehyde from MUF composite wood products should look to those made using polyurethane resins.

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May 22, 2014 - 1:35 pm

I have a sub that just submitted documentation for Particle board that is "Third party certified (California ARB approve TPC-1) to comply with CCR 93120.2 (CARB Composite Wood ATCM). Also conforms to Formaldehyde emission requirements for particleboard in ANSI A208.1-2009." It is also "Eco-Certified" - on the eco certified website it says that it will help acheive LEED credit for IEQc4.4 - all this to say that it does not contain any NAUF commentary. I think I will push back and have the sub request NAUF documentation unless I am missing something and some of the items mentioned above demonstrate compliance. Thoughts?

June 8, 2017 - 4:15 pm

Hi Jennifer,

Pardon my tardiness and for any confusion the older article caused. I have updated it to reflect the April 1, 2013 revision.

That article was originally written because of the confusion over urea being used to scavenge excess formaldehyde in melamine formaldehyde composite wood products, but because of this I think it introduced some confusion of its own.

As noted in the comments, the required ppm to meet ULEF criteria varies depending on the composite wood product (as it did for CARB Phases 1&2). For particleboard, the ULEF target is 0.05 ppm (90% of the tests have to be <0.05 ppm) and the max/cap is 0.08. For MDF it is 0.06 ppm target/0.09 ppm cap. Manufacturers can also get a ULEF exemption if their products test consistently at a target 0.04 ppm, with a max of 0.06 ppm for both particleboard and MDF. So if you find a product with that ULEF exemption they have demonstrated those lower emissions (which also saves the manufacturer $ through reduced testing and paperwork requirements).

It looks as though you have found what you are looking for (and that old CARB link was no help), but if you want specifics, all the CARB/ULEF nuances can be found here https://www.arb.ca.gov/regact/2007/compwood07/fro-final.pdf. The CARB table is on page 7 and the ULEF table is on page 12.

Hope this is still useful!


June 8, 2017 - 3:36 pm

Thank you Dawn,

Ok, so for LEED V4 purposes the requirement is to simply be CARB ULEF or NAF. The specific limits of which are:

hardwood: 0.05 ppm
particleboard and MDF: 0.06 ppm

June 8, 2017 - 2:34 pm

hmmm.....when I click through to the federal register site it says "this page no longer exists".... Perhaps a Trump Admin deletion. :(

June 7, 2017 - 6:04 pm

The ULEF target and cap are different depending on the type of composite wood product. The particulars are shown in Table 2 of the regulation Section 93120.3 (d) (1) Special provisions for manufacturers of hardwood plywood, particleboard and MDF with ULEF resins.
There is also a ULEF cap value of 0.05 ppm for HWPW and 0.06 ppm for PB, MDF if manufacturers are applying for a ULEF Exemption. This link will take you to the ARB page where you can download the final regulation. This info is found on pg 11-12. https://www.arb.ca.gov/toxics/compwood/compwood.htm
I hope this is helpful.

June 7, 2017 - 5:43 pm

Hi Dawn,

Thanks for you reply. My questions has to do with the specifics of the CARB Language. In the CARB documentation, the definition of ULEF is not singular but particular to the medium (plywood, mdf, partcileboard) I was curious if there was push back from GBCi to this level of detail or if the ULEF of 0.05 (Brent specifies above) stands for all mediums....

June 7, 2017 - 5:36 pm

Hello Jennifer - USGBC posted some allowable credit substitutions so that LEED 2009 projects may utilize LEED v4 credits. Here's the link to that info http://www.usgbc.org/articles/new-leed-v4-credit-substitutions-2009-proj...
Scroll down the page and for BD+C projects (ID+C and Retail also) they will allow Low-Emitting Materials credit support to substitute for LEED 2009 IEQc4.4. Specifically, they mention the Composite Wood Evaluation. For clarification, products that meet this new criteria must utilize CARB approved ULEF or NAF resins (not just CARB Phase 2 certified).

April 20, 2017 - 10:27 am

It would be great to get a definitive answer to this important question! Nick, Emily any updates on how it worked out to GBCI? I am seeing much conflicting info on various pieces.

The first - The precise definition of ULEF...Brent states - 0.05ppm...Another source has it at 0.09ppm... the table on page 7 of this CARB doc: www.arb.ca.gov/regact/2007/compwood07/fro-final.pdf tells me that is depends on whether it is particle board, mdf, or plywood... Is this table the definitive source that other are using?

The second - is a long struggle to find a EU cabinet manufacturer that can meet IEQ4.4....I have been working with Poliform and they appear to have figured out a complaint substrate, the IDROLEB PB panel: http://www.grupposaviola.com/wp-content/uploads/GR-06-Grezzo-IDROLEB-Rev... Has anyone else used this to LEED credit success?

October 20, 2015 - 5:09 pm

Emily, I never got a response. You could try submitting a question to the USGBC, but would potentially have to wait weeks for an answer. You could also ask the contractor to submit a letter from the USGBC confirming that their product meets the 2009 NC credit requirements.

October 20, 2015 - 4:58 pm

Any response for Nick's question above? We just had this come through for a product on our project, too. The subcontractor is claiming it is compliant b/c it passed CARB, but we aren't convinced for a 2009 NC project.

August 13, 2014 - 4:05 pm

On the LEED V4 low emitting materials page, the credit language seems to have relaxed to include ULEF per the CARB code. Can someone confirm if this language would retroactively apply to 2009 projects?


Composite Wood Evaluation. Composite wood, as defined by the California Air Resources Board, Airborne Toxic Measure to Reduce Formaldehyde Emissions from Composite Wood Products Regulation, must be documented to have low formaldehyde emissions that meet the California Air Resources Board ATCM for formaldehyde requirements for ultra-low-emitting formaldehyde (ULEF) resins or no added formaldehyde resins.

May 22, 2014 - 3:11 pm

Erika, I checked with Brent, our expert here on composite wood, and we think your instincts are right—the product may comply with LEED, but the documentation isn't enough to show it.

March 6, 2013 - 10:12 am

We are not pursuing IEQc4.4 for our project. However, the contractor has stated that we may be able to add it. For solid core wood doors and some products with composite woods as minor components we are receiving certifications that the wood products comply with CARB Phase 2 standards. I've researched this a little and so far have not found any answers.

If we do pursue the credit and this is the level compliance for products being submitted, does it comply with the IEQc4.4 requirement?

If we don't pursue the credit and these products have this level of compliance, does it affect any other credit we may be pursuing?

March 6, 2013 - 11:02 am

Thanks for the speedy response. Your first answer is what I thought and the second has been noted to the Contractor. Thanks for your help.


March 6, 2013 - 10:39 am

Joel, we'd need more information on the resins in your products to be able to answer the first question—see Brent's breakdown above.

For your second question, not directly, but theoretically it could affect IEQc3.2, and those products will have a bearing on MRc4, MRc7, and others.