Compliance guidance. Read on 7 November 2026 from Regulation (EU) 2023/1464, a Defra memorandum, BREEAM manuals and BSI listings. The standards themselves were not read. Limits and credits depend on the scheme and version, so check the current text and your assessor or adviser. This is guidance, not legal or technical advice. It says nothing about any product or partner workshop: ask each supplier for its test report.

At a glance

YardstickWhat it isNumber as readWhere it comes from
Panel class (E1, E05, no added formaldehyde)A class the panel maker declares under the panel standard, tested by chamber method.Not quoted: the standards were not read.BS EN 13986:2004+A1:2015; BS EN 717-1:2004
REACH Entry 77, furniture and wood-based articlesA legal limit on formaldehyde released under chamber conditions.0.062 mg/m³ (0.080 for other articles), for articles placed on the market after 6 Aug 2026Reg (EU) 2023/1464, Entry 77(1)(a)
Entry 77 test conditionsHow the chamber test is run.23 ± 0.5 °C, 45 ± 3 % RH, loading 1 m²/m³, 1 air change per hour, to steady state, not over 28 daysEntry 77, Appendix 14
BREEAM product limit, wood-based (baseline)Formaldehyde, TVOC and carcinogens after 28 days in a chamber.Formaldehyde 0.06 mg/m³ (MDF 0.08); TVOC 1.0; Cat 1A/1B 0.001International NC V6 Table 17
BREEAM exemplary levelThe stricter level for extra credits.Formaldehyde 0.01; TVOC 0.3; TSVOC 0.1; Cat 1A/1B 0.001 mg/m³International NC V6 Table 18
BREEAM room air test, before occupationMeasured in the finished room, not on a product.Formaldehyde 100 µg/m³ (30 min); TVOC 300 µg/m³ (8 h)International NC V6 criteria 12, 14; UK 2014 manual
Paint VOC content (a content figure, not an emission)Grams of VOC per litre of product.Matt interior walls 10 g/L; glossy 40 g/LInternational NC V6 Table 19
Furniture and laboratory in BREEAMWhether the VOC credit covers furniture; who may test.Furniture out of scope; ISO/IEC 17025 laboratoryInternational NC V6 CN3.10, CN3.3

mg/m³ is milligrams per cubic metre; 100 µg/m³ is 0.1 mg/m³. A chamber result on a product and a room air result are different tests: do not compare them directly. BREEAM figures are from the International V6 manual unless stated; the UK manual for your project may differ.

Three yardsticks, three different questions

A panel class (E1, E05, “no added formaldehyde”) is a label the panel maker declares. For wood-based panels it comes from the panel standard BS EN 13986 and its chamber test, BS EN 717-1. It says how the panel was classed. It is not a statement about the finished piece, and it does not name a legal limit.

A legal limit is a number a product must not exceed to be sold. Entry 77 of the EU REACH restriction list sets one for formaldehyde released from furniture and wood-based articles. It is written as a chamber result, not as a class, so the word “E1” does not prove it.

A scheme credit is a client or assessor requirement. BREEAM asks for product emission limits tested after 28 days in a chamber, and then an air test in the finished room before occupation. Which numbers apply depends on the scheme and the version, and a project may also have its own indoor-air brief.

The practical rule: write down which of the three you mean. “E1” alone, “low VOC” alone and “BREEAM compliant” alone are all too loose to price or check.

Three yardsticks behind low emissionThree columns: a panel class, a legal limit and a green-building credit, each answering a different question.PANEL CLASSE1, E05 or noadded formaldehydeSet by the panelstandard, testedin a chamberAsk for: the declarationLEGAL LIMITREACH Entry 770.062 mg/m³ forfurniture andwood-based articlesEU and N. Ireland,after 6 Aug 2026Ask for: a chamber resultSCHEME CREDITBREEAM Hea 02 / 04product limits after28 days in a chamber,then a room airtest beforeoccupationAsk for: the scheme versionThree questions. One test report rarely answers all three.
Three different yardsticks that are all called low emission. Original drawing by Make Bespoke Studio.

Commission Regulation (EU) 2023/1464, published 17 July 2023, adds Entry 77 to Annex XVII of REACH. Articles may not be placed on the market after 6 August 2026 if formaldehyde released under the Appendix 14 test conditions exceeds 0.062 mg/m³ for furniture and wood-based articles, or 0.080 mg/m³ for other articles. That date has now passed. The text read has no transitional period for articles after it.

Appendix 14 sets a reference chamber: 23 °C, 45 per cent relative humidity, a loading of 1 m² of product per m³ (or the loading factors in EN 16516 where that default is clearly unrealistic), one air change an hour, measured at least twice daily until a steady value, and in any case for no more than 28 days. Other conditions are allowed only if a scientifically valid correlation with the reference is shown.

Exclusions in the text: articles used only outdoors; construction articles used only outside the building shell and vapour barrier; articles for exclusively industrial or professional use unless they expose the general public; second-hand articles; articles where the formaldehyde is only naturally present in the materials; and products covered by other named rules (entry 72 articles, biocides, medical devices, protective equipment, food-contact articles).

Where it applies. The Defra memorandum of 11 January 2024 says the restriction applies in the EU and, through the Windsor Framework, in Northern Ireland. We found no equivalent in Great Britain: HSE opened a UK REACH call for evidence in 2023 as the first step towards a risk management options analysis, and the page shows no outcome. UK makers selling into the EU or Northern Ireland are caught. Whether it reaches architectural joinery or built-in work as well as free-standing furniture is not settled by anything we read: see the notes below.

Published numbers on one axisFormaldehyde numbers in mg per cubic metre, each labelled with what it measures.00.020.040.060.080.10.12mg/m³0.01BREEAM exemplary,chamber, 28 days0.06BREEAM baseline,most wood-based0.062 REACH Entry 77furniture, wood-based(chamber, Appendix 14)0.08BREEAM baseline, MDF;REACH, other articles0.1 room air test30 min average, afterfit-out: not a panel test
The published numbers on one axis. Chamber results on products and a room air test are different measurements. Original drawing by Make Bespoke Studio.

What BREEAM asks for

The International New Construction V6 manual (SD250, 1 December 2021) sets product emission limits in a chamber after 28 days. For wood-based products, including wood flooring, the baseline is formaldehyde at or below 0.06 mg/m³ (0.08 for MDF), TVOC at or below 1.0 and Category 1A and 1B carcinogens at or below 0.001. Interior paints and coatings, flooring, wall and ceiling products and interior adhesives and sealants have their own lines. For one credit, at least four of the five product types must comply (fewer where fewer are used). The exemplary level is stricter: 0.01 for formaldehyde and 0.3 for TVOC.

Evidence. Laboratories must be accredited to ISO/IEC 17025 for the sampling and analysis. A manufacturer’s declaration is accepted if an accredited laboratory did the testing, or if the product contains no formaldehyde or VOC-emitting substances. After construction and before occupation the room is tested: formaldehyde at or below 100 µg/m³ averaged over 30 minutes and TVOC at or below 300 µg/m³ over 8 hours.

Furniture. The same manual says the VOC credits do not extend to furnishings. A client may still ask for emission evidence for furniture, and Entry 77 covers it for the EU market.

Version. The older UK 2014 manual (SD5076 issue 5, 2016) used a different route for wood panels: a class E1 declaration to BS EN 13986, or a chamber result at 0.1 mg/m³. A September 2025 notice from a testing institute says the chapter was renumbered from Hea 02 to Hea 04 in the International and UK versions of 2025, with the product requirements unchanged. We did not read the UK V6 or V7 manuals. So always quote the manual, version and credit number that your assessor is working to.

Finishes, adhesives and veneered panels

Two different numbers appear on a finish data sheet. VOC content is grams of volatile compound per litre of the product as supplied, and it is what limits such as the BREEAM paint table (for example 10 g/L for matt interior wall paint) are written in. Emission is what the dried finish gives off into a test chamber over days, in mg/m³. A low content figure does not by itself give a low emission result, so ask which one the data sheet shows.

The reference method for chamber testing of construction products is BS EN 16516:2017+A1:2020. BSI lists it as current, and as covering volatile and semi-volatile organic compounds and very volatile aldehydes. It describes how to test; the limits come from the regulation or scheme. The BREEAM V6 table still cites the earlier technical specification, CEN/TS 16516:2013, which BSI lists as replaced, so ask your assessor which edition they accept.

A veneered or lacquered panel is a board, a glue line and a finish. Ask for the board result and the finish system’s data, and ask the maker to say in writing whether the finished panel was tested. Do not assume the board’s class covers the finished surface. For the boards themselves see MDF decoded and finishes on timber joinery.

Evidence to ask for

Ask for the evidence at tender, before the board or finish is chosen, because changing it later is a substitution: see the substitution register. Sustainability documents beyond emissions are on sustainability documents a tender will ask for, and for timber origin see FSC and PEFC.

Ask forIt should showWarning sign
Test reportLaboratory name; test standard and its edition; the product tested (board type, thickness, finish); chamber conditions; result with its unit; date.A one-line “E1” badge, a data sheet with no report behind it, or a result with no unit.
Laboratory accreditationThat the laboratory is accredited to ISO/IEC 17025 for formaldehyde and VOC sampling and analysis, and the accreditation body.A company that tests in-house with no accreditation stated.
Match to the productThat the report covers the board, thickness range and finish you are buying, and the production period or batch.A report for a different board, or years old, with the supplier or resin since changed.
Class or limit, in writingWhich yardstick the supplier claims to meet: the panel class, Entry 77, or the scheme credit, and the version.“Low emission” with no figure or standard.
Finish systemFor each coating or adhesive: VOC content in g/L and, where the scheme asks, a chamber result at 28 days.A content figure offered as an emission result.
“No added formaldehyde”What the claim covers (resin only, or the whole board) and what test supports it.A claim read as “zero”. Wood itself contains some formaldehyde.

Make Bespoke Studio coordinates manufacture through partner workshops. This page does not say that any partner’s panels or finishes meet any limit: the evidence for each project is requested from the workshop concerned and recorded against the schedule.

Specification wording

Paste into your schedule or specification and replace anything in [square brackets] with your own figures. Wording is a starting point: your specification governs.

Wood-based panels and cores
Wood-based panels, veneered panels and cores used in [item / package] shall be supported by a formaldehyde emission test report from a laboratory accredited to ISO/IEC 17025 for formaldehyde sampling and analysis, tested to [BS EN 717-1 / BS EN 16516 / ISO 16000-9, edition to be confirmed], stating the board type and thickness, the chamber conditions and the result in mg/m³. The result shall not exceed [0.062 mg/m³ / the figure in the project indoor air brief]. A class declaration (for example E1) without a test report is not accepted as evidence of this limit.
Finishes and adhesives
For each coating, lacquer, oil and adhesive used in [item], the supplier states the VOC content in g/L as supplied and, where [BREEAM Hea [02 / 04], version [ ]] applies, a chamber emission result at 28 days to [standard and edition] from an ISO/IEC 17025 accredited laboratory. The finishing system as applied (primer, coats, adhesive) is named in the sample approval record.
Match to the supply
Test evidence relates to the board type, thickness range and finish supplied, and to a production period of not more than [24] months before order. A change of board manufacturer, resin system or finish requires new evidence and approval on substitution register [ref] before the item is ordered.
Goods for the EU or Northern Ireland
For items to be placed on the market in the EU or Northern Ireland after 6 August 2026, the supplier confirms in writing that furniture and wood-based articles do not exceed the Entry 77 limit of Regulation (EU) 2023/1464 under the Appendix 14 conditions, and provides the test evidence.

Terms used on this page

Formaldehyde class E1
A class that a wood-based panel maker declares for formaldehyde released from the panel, under the panel standard and a chamber test. The class is not the same thing as the EU legal limit, which is written as a chamber result.
VOC
Volatile organic compounds: gases released from paints, lacquers, adhesives and boards. Content (g/L of the product) and emission (mg/m³ in a test chamber) are different measures.

All specification and delivery terms

Standards and sources

Questions we are asked

Is E1 enough?

Not on its own. E1 is a panel class declared under the panel standard. The EU limit for furniture and wood-based articles is written as a chamber result of 0.062 mg/m³, so ask for a test report or a written statement against that figure. For a BREEAM project, ask which manual and version applies, because older UK manuals accepted an E1 declaration and the current International V6 table uses chamber limits.

Does the EU formaldehyde limit apply to a project in Great Britain?

Not as far as we found. The limit applies in the EU and in Northern Ireland. We saw no Great Britain equivalent, and HSE’s 2023 call for evidence shows no outcome. It does apply to goods a UK workshop sells into the EU or Northern Ireland, so ask where the item will be placed on the market.

Does low-VOC paint make a low-emission panel?

No. VOC content of a paint (grams per litre) is a different figure from the emission of a finished board in a chamber. Ask for each, and for the finish system as applied.

Is furniture covered by BREEAM Hea 02?

The International V6 manual says the VOC credits do not extend to furnishings. Other schemes and client briefs may ask for evidence anyway, and the EU limit covers furniture. Ask what the brief actually requires.

Which laboratory should do the test?

The BREEAM V6 manual asks for a laboratory accredited to ISO/IEC 17025 for formaldehyde and VOC sampling and analysis. Ask for the accreditation scope as well as the report.

Does “no added formaldehyde” mean none is released?

No. Wood contains some formaldehyde naturally, and the EU restriction text exempts articles where it is only naturally present in the materials. The claim means no formaldehyde-based resin was added. Ask what it covers and what test supports it.

Download the factsheet

A two-page A4 PDF with the yardsticks table, the evidence checklist and paste-in clauses for panels, finishes and goods going to the EU, to keep with your project file.

Factsheet TL-SPE-34 v1.0 (PDF)