On July 6, 2026, the U.S. Environmental Protection Agency (EPA) published a final rule amending the National Emission Standards for Hazardous Air Pollutants (NESHAP) applicable to the Plywood and Composite Wood Products (PCWP) source category. The amended rule marks a significant regulatory development for the forest products industry, resolving longstanding litigation and administrative proceedings while introducing new maximum achievable control technology (MACT) requirements that will materially affect compliance obligations for covered facilities.
The final rule addresses the 2007 partial remand and vacatur of EPA's 2004 NESHAP for this source category and responds to a petition for reconsideration of the Agency's 2020 residual risk and technology review. In doing so, EPA has revisited the regulatory framework governing hazardous air pollutant (HAP) emissions from plywood, composite wood, and kiln-dried lumber operations, updating both numerical emission limits and associated work practice standards to reflect current control technologies and risk considerations.
Under the amended rule, MACT emission limits and work practices now apply to a broad range of pollutants, including total HAPs, non-mercury HAP metals, mercury, hydrogen chloride, polycyclic aromatic hydrocarbons (PAHs), dioxin and furan compounds, and methylene diphenyl diisocyanate (MDI). This expanded pollutant coverage reflects EPA's effort to more comprehensively regulate the range of emissions produced during wood drying, pressing, and finishing operations, and will require covered facilities to reassess emissions inventories, monitoring protocols, and control equipment performance.
The rule reaches approximately 219 existing major-source facilities nationwide. Of these, 93 are PCWP facilities, and 126 are kiln-dried lumber facilities. Operators in both segments should evaluate the applicability of the new limits and work practices to each affected emissions unit, and should begin compliance planning promptly given the technical complexity of demonstrating conformance with MACT-based standards.
Affected facilities should also consider recordkeeping, reporting, and initial performance testing obligations, as well as the potential need to revise Title V operating permits. Early engagement with environmental counsel and technical consultants can help identify compliance gaps, mitigate enforcement risk, and inform capital planning decisions tied to control technology upgrades.
This update is provided for general informational purposes only. Clients with facilities potentially subject to the amended NESHAP should seek tailored legal advice regarding their specific circumstances and compliance obligations.