I am looking for some clarification pertaining to the VOC and emissions requirements for Casework and Millwork. 

We are in the process of reviewing a bathroom counter assembly.  The counter is Silestone, but it has supports made out of Plywood laminated with a high-pressure decorative laminate (HPL).  Please note that the lamination occurs off-site. 

I initially categorized the HPL as composite wood, and asked for ULEF/NAUF documentation.  The manufacturer has responded stating that HPL is not a composite wood product, and as such the ULEF/NAUF requirements do not apply. 

Table 5 states the following:  

Products with composite woods constituting all or portion of product (e.g., countertops, cabinetry with composite wood cores and internal components) must be constructed with composite wood documented to have low formaldehyde emissions (compliant to CARB ATCM limits for no added formaldehyde or ultra-low formaldehyde emitting or its equivalent). Materials with no defined category under ATCM must follow requirements for particleboard. Built-in cabinetry constructed of inherently nonemitting materials (e.g., metal with factory-applied powder coating or plating) are eligible for credit without testing.

The bolded sentence seems to apply, thus requiring the ULEF/NAUF documentation.   In my interpretation, this would also apply for the Silestone counter, which is not a wood product, but is part of an assembly with composite wood.   Do you agree?

Do you think the ULEF/NAUF documentation is required for these elements (HPL & Silestone)?