Office Furniture Certifications: GREENGUARD & REACH

GREENGUARD, CARB/TSCA Title VI, Prop 65 and REACH are four different instruments, not four versions of one certificate. GREENGUARD is a UL product-emissions certification for indoor air. CARB ATCM 93120 and TSCA Title VI cap formaldehyde from composite wood panels. Prop 65 is a California warning law. REACH is the EU chemicals regulation. Each one requires different evidence.

GREENGUARD and GREENGUARD Gold: two tiers, one test standard

UL Solutions runs GREENGUARD under the UL 2818 standard. A finished product — a chair, a desk, a storage unit — is placed in a controlled environmental chamber and tested for volatile organic compound (VOC) emissions, including formaldehyde, over a defined exposure period.

There are two tiers. GREENGUARD is the base level for low-emitting products. GREENGUARD Gold applies stricter limits and additional criteria; it grew out of the former Children & Schools program. Either tier is accepted evidence in LEED low-emitting materials credits and WELL air features.

The listing matters as much as the certificate. Certified products appear in UL SPOT, UL’s public product database; check the exact model, expiry date and listing status before the claim goes into a specification.

GREENGUARD covers emissions only: nothing about durability, structural safety or chemical content.

CARB ATCM 93120 and TSCA Title VI: the composite wood rule

CARB approved its formaldehyde regulation for composite wood on April 26, 2007; it is now codified at 17 CCR §93120 et seq. It covers hardwood plywood, particleboard, medium-density fiberboard (MDF) and thin MDF, plus finished goods made with them — desks, storage, tables — sold, supplied, used or manufactured for sale in California.

TSCA Title VI (40 CFR Part 770) applies equivalent emission limits across the United States, with compliance phased in from 2017. For an importer this is the more relevant rule: the importer of record is responsible for what it brings in.

Both programs rely on third-party certification, not a one-time test. Panel producers work with an approved third-party certifier, label their panels and stay under audit; testing continues through the production year and certification is renewed. NAF and ULEF products take an exempt route, but still need approval and documentation.

The common mistake is treating this as a chair certificate. It is a panel-level certification: the mill holds the CARB executive order or the third-party certifier’s documentation, and the furniture maker has to show chain of custody, panel labels and purchase records for the panels it used. “CARB P2 panels” is a material specification, not a finished-product certificate. Ask for the mill’s documentation and panel labels.

Prop 65: a warning law with no certificate

California’s Safe Drinking Water and Toxic Enforcement Act of 1986, known as Proposition 65, is administered by the Office of Environmental Health Hazard Assessment (OEHHA). It requires a clear and reasonable warning before exposing anyone in California to a listed chemical — the list runs to more than 850 substances and is updated regularly.

A warning is not required if exposure stays below the applicable threshold: the No Significant Risk Level (NSRL) for cancer, or the Maximum Allowable Dose Level (MADL) for reproductive harm. Enforcement comes from the California Attorney General and from private plaintiffs, who must give a 60-day notice; civil penalties can reach $2,500 per violation per day.

For furniture, typical exposures are formaldehyde from panels and adhesives, wood dust, toluene diisocyanate in foam, lead in coatings and PVC, and phthalates in flexible PVC parts.

There is no “Prop 65 certificate”. Compliance is a documented decision: either a warning on the product and packaging, or an exposure assessment showing why no warning is needed.

REACH: SVHC, Annex XVII and SCIP

REACH (Regulation (EC) No 1907/2006) is the EU chemicals framework. It applies to articles — an office chair is an article — and creates several separate duties, which is why no single “REACH certificate” exists.

SVHC disclosure (Article 33). If an article contains a Candidate List substance above 0.1% by weight, the supplier must give the recipient enough information for safe use; consumers can ask and must get an answer within 45 days. The Candidate List is updated twice a year.
SCIP notification. Since January 5, 2021, EU suppliers of articles containing Candidate List substances above 0.1% must notify ECHA’s SCIP database and pass the SCIP number down the supply chain.
Annex XVII restrictions. These limit or ban specific substances in articles, including certain flame retardants, phthalates and CMR substances in textiles.
Registration and authorization apply mainly to substances and mixtures, not finished furniture.

For furniture, a REACH package is a set of declarations: SVHC content by article, the SCIP number, and Annex XVII conformity. Safety data sheets are the wrong document for an article.

The matrix: 5 credentials, 3 markets

Credential	Main market	What it regulates	Document to request	Renewal and maintenance
GREENGUARD / GREENGUARD Gold	US and Canada; accepted elsewhere	VOC emissions from the finished product, including formaldehyde	UL certificate, UL SPOT listing, model coverage list	Time-limited; re-testing and surveillance; check expiry and listing status
CARB ATCM 93120	California	Formaldehyde from composite wood panels and finished goods	Panel mill’s CARB executive order or TPC certificate, labels, purchase records	Ongoing testing, third-party audits, periodic re-certification
TSCA Title VI	United States, including imports	The same panel formaldehyde limits, federally	TPC certificate from the panel producer, importer records, labels	Continuing quality-control testing and third-party audits
Prop 65	California	Warning for listed chemicals above exposure thresholds	Warning text or a no-warning exposure assessment	No expiry; re-check when formulas or the list change
REACH	EU and EEA	SVHC information, SCIP notification, Annex XVII restrictions	SVHC declaration, SCIP number, Annex XVII conformity statement	No expiry; re-check with each Candidate List update, twice a year

Five shortcuts that cost money later

A certificate is not a test report. Reports carry sample details, methods and measured values. Keep both.
Coverage is not company-wide. Documents cover defined models, panel types or configurations; change the foam, fabric or board supplier and the evidence may not apply.
“CARB P2 certified chairs” is shorthand. The certification belongs to the panel mill; the chair is compliant only if its panels trace to a certified mill.
“Prop 65 certificate” does not exist. Ask for the warning text or the exposure assessment.
“REACH compliant” is not one line on a spec sheet. It is a set of duties, and an SVHC declaration without a SCIP number is incomplete for EU supply.

An ISO 9001 certificate belongs here too: it certifies a management system, not a chair’s emissions or structural performance.

What to request from a supplier

A document matrix mapped to the destination market, showing who holds which certificate.
The GREENGUARD certificate and UL SPOT entry, with the covered model list, if low emissions is claimed.
For every composite-wood part: panel mill, panel type and grade, certifier documentation and labels.
Prop 65 warning text, or the exposure assessment behind a no-warning decision, for California-bound goods.
SVHC declaration and SCIP number for EU shipments.
Expiry dates and document versions for everything above.

FAQ

Is GREENGUARD Gold the same as GREENGUARD?

No. Both use UL 2818, but Gold applies stricter emission limits and additional criteria. Specify the tier by name and verify the model on UL SPOT, not a brochure logo.

Does a CARB certificate cover the finished chair?

No. Both CARB ATCM 93120 and TSCA Title VI certify panel producers and their products. For a chair, the evidence is the mill’s documentation plus the maker’s records showing those panels went into that product.

Can a product be “Prop 65 certified”?

No. Prop 65 is a warning requirement, not a certification program. A compliant product either carries a compliant warning or has an exposure assessment showing no warning is required.

Is a REACH certificate required for furniture?

No such certificate exists. For EU supply, expect an SVHC declaration by article, a SCIP number where the 0.1% threshold is exceeded, and a statement of Annex XVII conformity.

Do these certifications expire?

GREENGUARD is time-limited and maintained through re-testing; the certificate and listing show current status. CARB and TSCA certification stays valid through continuing testing and audits. Prop 65 and REACH have no certificate to expire — refresh the declarations when formulations or the underlying lists change.

What do I need for a US project versus an EU project?

For the US: CARB or TSCA Title VI panel documentation, GREENGUARD if indoor-air credits apply, and a Prop 65 position for California. For the EU: the REACH package — SVHC declaration, SCIP number, Annex XVII statement — plus EN 1335 reports for seating.

Sources

UL Solutions, GREENGUARD certification: https://www.ul.com/services/ul-greenguard-certification (accessed November 4, 2026)
UL SPOT product database: https://spot.ul.com/ (accessed November 4, 2026)
CARB, Composite Wood Products ATCM and third-party certification: https://ww2.arb.ca.gov/our-work/programs/composite-wood-products-program and https://ww2.arb.ca.gov/resources/documents/third-party-certification-program (accessed November 4, 2026)
US EPA, formaldehyde emission standards for composite wood products: https://www.epa.gov/formaldehyde/formaldehyde-emission-standards-composite-wood-products (accessed November 4, 2026)
40 CFR 770.10, formaldehyde emission standards: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-R/part-770/subpart-C/section-770.10 (accessed November 4, 2026)
OEHHA, Proposition 65: https://oehha.ca.gov/proposition-65 (accessed November 4, 2026)
ECHA, Candidate List of SVHCs: https://echa.europa.eu/candidate-list-table (accessed November 4, 2026)
ECHA, SCIP database: https://echa.europa.eu/scip (accessed November 4, 2026)
EUR-Lex, Regulation (EC) No 1907/2006 (REACH): https://eur-lex.europa.eu/eli/reg/2006/1907/oj (accessed November 4, 2026)

For the full list of standards and schemes Wenyi references — ISO 9001:2015, ISO 14001:2015, ISO 45001:2018, GREENGUARD Gold for selected products, CARB P2 / TSCA Title VI panels and BIFMA-aligned testing — see our certifications page. Panel and emission documentation follows the product through desks and workspaces, and our team can assemble the document set for your destination market with the quotation.

Last updated: November 2026

Office Furniture Certifications Explained: GREENGUARD, CARB/TSCA, Prop 65 and REACH