Personal Communication with KCMA. 2010. Conversation between Richard
Titus (Kitchen Cabinet Manufacturers Association) and Abt Associates
Inc. regarding written questions about FSCWPA Impacts. October 28, 2010.
 Matt LaPenta spoke with Bill Perdue on 11.02.2010.

Number of Fabricators

What percentage of furniture manufacturers would you estimate use
composite wood products (hardwood plywood, particleboard, or medium
density fiberboard) in their products? 

Hundreds of fabricators worldwide.  There are many offshore fabricators.
 90% of wood-based furniture manufacturers use composite wood products. 
Wood based furniture is the lion’s share of the market.  For Home
furnishings 80% of furniture is wood based.  

Of these manufacturers, what percentage would you estimate produce at
least some product lines that are CARB compliant because they use CARB
certified panels or component parts and follow the CARB recordkeeping
and labeling requirements?

All are complying with CARB.  All are following recordkeeping and
labeling requirements.  This is true for AHFA members and non-members.
Sources of non-compliant product are not available.

Do the manufacturers that are producing CARB compliant product lines
also carry product lines for sale outside of California that are not
CARB compliant?  If, so what percentage of production volume would you
estimate are product lines that are not compliant with CARB because they
do not use CARB certified panels or component parts or do not follow the
CARB recordkeeping and labeling requirements?

No – separate inventory would be too difficult. 

Impact of Labeling Requirements

A national regulation of composite wood products could potentially
require manufacturers that use composite wood materials to put a label
on every separate item that gets produced and shipped out.  Given this,
could you estimate the average number of labels that would be needed
annually for each manufacturer that uses composite wood materials?

All products have a manufacturing label with product number and SKU. 
CARB compliance is also indicated on this label.  This system works well
because manufacturers use the existing labels. Labels are on the boxes
and the products.  There are millions of labels.

If labels were required for each shipment of products instead of each
individual item, about how may items would be included in a typical
shipment? 

This would not work for furniture.  Lot labeling would make it harder to
track it back to the board manufacturer.  AHFA says lot labeling of
panels makes it harder for the fabricators because it makes their
recordkeeping more difficult. .

Number of Wood Veneer “Laminator Product”  Manufacturers

The recent federal legislation uses the term laminated product to mean a
finished good (such as a custom panel, cabinet, window, door, or piece
of furniture) that is produced by affixing a wood veneer to a purchased
platform.  How many of your members would you say produce such laminated
products by affixing wood veneer themselves?  Please do not include
other types of laminates (such as high pressure laminates, thermally
fused papers, vinyl films, decorative foils, or polypropylene films) in
your answer.

All domestic manufacturers do this.  There are about 250 domestic
manufacturers who are laminators.  

For those manufacturers that would be classified as wood veneer
laminators, how common is it for these manufacturers to also fabricate
products using purchased panels that were already finished with a wood
veneer or other decorative finish?

Common. Laminators would also use purchased panels.

What percentage of the production of wood veneer laminated products are
produced using formaldehyde-based resins to affix wood veneers to
purchased platforms?

Some use cold press PVA.  Typically use UF.

If wood veneer laminators using UF resins were to switch to a lower
emission resin, what would be the likely resin choice?

Not sure. Dictated by market.

Of those wood veneer laminators that use no-added formaldehyde resins,
what are the most common adhesives used? 

Not sure. Dictated by market.

If wood veneer laminators were subject to the same third party testing
requirements as CARB, about how many different product types would need
to be third party certified for a typical manufacturer?

Not sure.  Would be a burden but not as many products as a custom panel
manufacturer.

General comments

Worlds largest home furniture association

450 members

Represents all levels of supply chain

International and domestic members

Was @ table with CARB

Was active with Klobuchar

Has engaged with EPA

Performance questions associated with CARB 2 resins.  More boards seem
to have mold problems.

