United States International Trade Commission

Investigation No. 332-487

USITC Publication 4032

August 2008

Wood Flooring and 

Hardwood Plywood: 

Competitive Conditions 

Affecting the U.S. 

Industries
Address all communications to 

Secretary to the Commission 

United States International Trade Commission 

Washington, DC 20436

U.S. International Trade Commission

Director, Office of Industries

Karen Laney-Cummings

Director of Operations

Robert A. Rogowsky

COMMISSIONERS 

 

Shara L. Aranoff, Chairman 

Daniel R. Pearson, Vice Chairman 

Deanna Tanner Okun 

Charlotte R. Lane 

Irving A. Williamson 

Dean A. Pinkert
U.S. International Trade Commission

Washington, DC 20436 

www.usitc.gov

Publication 4032 August 2008

Wood Flooring and Hardwood Plywood: 

Competitive Conditions Affecting the U.S. 

Industries

Investigation No. 332-487
This report was prepared principally by the Office of Industries

Project Leaders

Fred Forstall and David Ingersoll

Gail Burns, Vincent DeSapio, Cindy Foreso, Vincent Honnold, Cathy Jabara,

Alan Treat, and Jeremy Wise

Primary Reviewers

Laura Bloodgood and Marinos Tsigas

Administrative Support

Diane Bennett and Sharon Greenfield

Special Assistance

Kimberlie Freund, David Lundy, Laura Polly, Karl Tsuji, and Karen Taylor

Under the direction of

Robert Carr, Chief

Natural Resources and Metals Division
i

ABSTRACT

Although U.S. production, consumption, and trade of wood flooring and hardwood plywood

increased significantly during the 2002–07 period, the domestic industries faced increasing

competition from imports. In the midst of growing markets for both wood flooring and

hardwood plywood, U.S. wood flooring producers generally increased shipments, capacity,

and exports more than U.S. hardwood plywood producers. During the period, the value of

U.S. imports doubled, and their share of the U.S. markets increased from one-third to nearly

one-half in 2007. Factors contributing to the rise in imports included shifting U.S. market

preferences and reportedly, the increased market power of wholesale distributors and large

retailers whose greater logistical capabilities make them more able to source imported

products. In addition, higher input costs in the United States, mainly for raw material and

labor, put upward pressure on U.S. product prices at the same time that lower input costs,

mainly for labor, in competitor supplier countries (other than Canada) put downward

pressure on finished product prices and contributed to the rise in the import share of the U.S.

market. Although there are a number of significant foreign suppliers, during the 2002-07

period China became the largest supplier of wood flooring and hardwood plywood and the

most significant competitor to the U.S. industry in the U.S. markets for hardwood plywood

and engineered wood flooring. Chinese producers took advantage of domestic plantation

wood resources and relatively low wage rates to achieve low overall production costs, and

as its currency was effectively pegged to the U.S. dollar for most of the period, China was

able to increase exports to the United States and to increase its market share, partly at the

expense of other foreign suppliers.

iii

CONTENTS

Page

Abstract ................................................................. i

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix

Chapter 1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

Background and purpose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

Production coverage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2

Product descriptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2

Wood flooring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2

Hardwood plywood . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-3

Tariff classification and treatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-3

Industry and trade data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-5

Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-7

Report organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-8

Chapter 2. Global Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

Global production . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

Raw materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

Wood flooring and hardwood plywood . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3

Global trade . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5

Illegal logging and trade . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-9

Definitions of illegal logging . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-10

Estimated rates of illegal logging in production and exports . . . . . . . . . . . . . . . . . . . 2-11

Economic effects of illegal logging . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-13

Actions to address illegal logging and trade . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-13

European Union . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-14

Japan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-14

United States . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-15

Certification and sustainable forest management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-17

Chapter 3. United States . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

Raw materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2

Solid wood flooring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4

Engineered wood flooring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-5

Hardwood plywood . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-5
iv

CONTENTS–Continued

Page

Trade . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-6

U.S. imports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-6

U.S. exports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8

Wood flooring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8

Industry structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8

Solid wood flooring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-10

Engineered wood flooring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-12

U.S. market for wood flooring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-14

U.S. Market trends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-15

Channels of distribution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-17

Prices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-19

Hardwood plywood . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20

U.S. industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20

Capacity, shipments, consumption, and trade . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-22

Cost of goods sold . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-24

U.S. market for hardwood plywood . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-24

Channels of distribution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-26

Product trends in hardwood plywood . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-27

Prices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-29

Chapter 4. China . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1

Industry structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1

Hardwood plywood . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1

Wood flooring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-3

Raw material supply . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4

China’s raw material imports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-5

Development of domestic plantation resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-10

Production, trade, and consumption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-12

Hardwood plywood . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-12

Wood flooring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-15

Capital costs and investment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-17

Production costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-18

Raw material costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-18

Labor costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-20

Transportation and other costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-20

Marketing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-21

Pricing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-22

Government programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-24

Trade policies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-24

Other polices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-26

Foreign government programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-27
v

CONTENTS–Continued

Page

Chapter 5. Other Foreign Suppliers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1

Industry structure and capacity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1

Brazil . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2

Canada . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3

Indonesia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-4

Malaysia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-5

Russia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-5

Raw material supply . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-6

Brazil . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-6

Canada . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-6

Indonesia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-6

Malaysia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-7

Russia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-8

Log production, trade and consumption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-8

Production, trade, and consumption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-10

Production costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-18

Raw material costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-19

Labor costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-19

Marketing practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-21

Prices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-22

Government programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-24

Chapter 6. Competitiveness Conditions in the 

U.S. Market . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1

Factors affecting competitive position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-2

Demand factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-2

Markets for products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-2

Exports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-7

Supply factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-7

Raw materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-7

Cost of production . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-8

Industry structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-11

Channels of distribution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-11

Exchange rates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-11

Pricing and marketing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-11

Government programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-17
vi

CONTENTS–Continued

Page

Bibliography . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Biblio-1

Appendices

A. Request letter and letter amending the schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1

B. Federal Register notice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1

C. HTS descriptions and tariff information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-1

D. Hearing list of participants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-1

E. Summary of view of interested parties . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-1

Tables

2.1. Global production of hardwood saw logs and veneer logs: 2002–06 . . . . . . . . . . . . . . . . . . 2-3

2.2. Estimated global production of hardwood plywood . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5

2.3. Reported exports of wood flooring and hardwood plywood . . . . . . . . . . . . . . . . . . . . . . . . . 2-9

2.4. Estimated rates of suspicious industrial roundwood harvest . . . . . . . . . . . . . . . . . . . . . . . . . 2-12

2.5. Estimated rates of suspicious trade . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-12

3.1. U.S. production, trade, and consumption of hardwood logs, 2002–07 . . . . . . . . . . . . . . . . . 3-3

3.2. U.S. production, trade, and consumption of hardwood lumber, 2002–07 . . . . . . . . . . . . . . . 3-3

3.3. Estimated combined U.S. imports of wood flooring and hardwood plywood, 2002–07 . . . . 3-7

3.4. Estimated combined U.S. exports of wood flooring and hardwood plywood, 2002–07 . . . . 3-9

3.5. U.S. solid and engineered wood flooring: shipments, consumption, and trade, 2002–07 . . . 3-11

3.6. U.S. wood flooring producers: Average cost of goods sold, 2002–07 . . . . . . . . . . . . . . . . . . 3-13

3.7. U.S. floor covering market sales, 2002–06 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-16

3.8. U.S. hardwood plywood: shipments consumption, and trade, 2002–07 . . . . . . . . . . . . . . . . 3-23

3.9. U.S. hardwood plywood producers: Average cost of goods sold, 2002–07 . . . . . . . . . . . . . 3-24

3.10. Hardwood plywood: Shares of U.S. shipments and imports, by thickness, 2002–06

and January–June 2006 and 2007 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-28

4.1. China’s total hardwood log imports, 2002–07 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6

4.2. China imports of lumber, 2002–07 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-8

4.3. China veneer imports, 2002–07 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-9

4.4. China’s hardwood plywood: production, trade, and consumption, 2002–06 . . . . . . . . . . . . . 4-13

4.5. China plywood exports, 2002–06 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-14

4.6. China wood flooring production, 2002–07 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-16

4.7. China solid wood flooring exports, 2002–06 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-17

4.8. Examples of manufacturing costs for hardwood plywood and wood flooring producers in 

in China . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-19

4.9. Listed export prices for various plywood production, February 2008 . . . . . . . . . . . . . . . . . . 4-22

4.10. Listed wholesale domestic prices for Chinese domestic and imported solid wood 

flooring products, February 2008 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-23
vii

CONTENTS–Continued

Page

4.11. Changes to trade preference programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-25

5.1. Foreign supplier countries: Sawmills, plywood mills, and other wood product producers 

number of firms and installed capacity (1,000 cubic meters) . . . . . . . . . . . . . . . . . . . . . . . . 5-2

5.2. Foreign supplier countries: Forest resources, 2005 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-7

5.3. Foreign supplier countries: Hardwood log production, trade, and consumption, 2002-06 . . 5-9

5.4. Foreign supplier countries: Hardwood plywood production, trade, and 

consumption 2002–06 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-11

5.5. Foreign supplier countries: Exports and imports of plywood and wood flooring, 2002–06 . 5-12

5.6. Foreign supplier countries: Share of exports of hardwood plywood and wood flooring 

by market, 2002–06 (%) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-15

6.1. Exchange rates: Units of foreign currency per U.S. dollar, 2002–06 . . . . . . . . . . . . . . . . . . 6-13

Figures

ES.1. U.S. shipments, consumption, imports, and exports of wood flooring and 

hardwood plywood, 2002–07 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix

ES.2. U.S. imports of wood flooring and hardwood plywood, 2002–07 . . . . . . . . . . . . . . . . . . . . xi

1.1. Raw material production flows for wood flooring and hardwood plywood . . . . . . . . . . . . . 1-4

2.1. Nonconiferous industrial roundwood: Major trade flows, (million $), 2006 . . . . . . . . . . . . 2-4

2.2. Reported global imports of wood flooring and hardwood plywood, 2002 and 2006 . . . . . . 2-6

2.3. Reported global exports of wood flooring and hardwood plywood, 2002 and 2006 . . . . . . 2-7

2.4. Hardwood plywood and wood flooring: Major trade flows, 2006 . . . . . . . . . . . . . . . . . . . . 2-8

3.1. U.S. composite lumber prices in dollars per thousand board feet, 2002–06 . . . . . . . . . . . . 3-5

3.2. Major distribution channels for wood flooring and hardwood plywood . . . . . . . . . . . . . . . 3-18

3.3. U.S. composite oak strip flooring prices, 2002–06 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-21

3.4. U.S. solid wood flooring prices, 2002–06, and January–June 2007 . . . . . . . . . . . . . . . . . . . 3-21

3.5. U.S. hardwood plywood prices, 2002–06 and January–June 2007 . . . . . . . . . . . . . . . . . . . 3-30

5.1. Malaysia: Nominal log prices, 2002–07 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-20

5.2. Thin plywood: Indonesia and Malaysia nominal 2.7 mm plywood prices, 2002–07 . . . . . . 5-23

5.3. Plywood: Indonesia and Malaysia nominal 3 mm plywood prices, 2002–07 . . . . . . . . . . . 5-23

5.4. Thick plywood: Brazil, Indonesia, and Malaysia nominal plywood prices, 2002–07 . . . . . 5-24

6.1. U.S. shipments, consumption, imports, and exports of wood flooring and 

hardwood plywood, 2002–07 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-3

6.2. Housing starts, manufactures housing shipments, and RV shipments, 2002–07 . . . . . . . . . 6-3

6.3. U.S. shipments, consumption, imports, and exports of wood flooring, 2002–07 . . . . . . . . . 6-5

6.4. U.S. shipments, consumption, imports, and exports of engineered 

wood flooring, 2002–07 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-5

6.5. U.S. shipments, consumption, imports, and exports of hardwood plywood, 2002–07 . . . . 6-7

6.6. U.S. and Malaysian logs: Trends in indexed prices, 2002–06 . . . . . . . . . . . . . . . . . . . . . . . 6-10

6.7. Indexed hardwood plywood, solid and engineered wood flooring producer prices, 

averaged selected grades, and PPI for single-unit residential construction inputs 

and materials, 2002–06 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-14
viii

CONTENTS–Continued

Page

6.8. Indexed hardwood plywood and solid and engineered wood flooring prices 

deflated by hardwood lumber PPI, 2002–06 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-15

6.9. Hardwood plywood: Domestic producer price and Chinese import prices,

selected grades, 2002–06 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-15

6.10. Hardwood plywood: Indexed U.S., Malaysian, and Brazilian prices, 2002–06 . . . . . . . . . . 6-16
ix

Executive Summary

The value of U.S. production, consumption, and trade of wood flooring and hardwood

plywood all increased during the 2002–07 period. However, in the midst of a rapidly growing

market, the domestic industries faced increasing competition in the U.S. market from rising

imports. As imports rose from $1.2 billion in 2002 to $2.7 billion in 2006 before falling back

to $2.4 billion in 2007, the share of the U.S. market held by imports rose from about one-third

in 2002 to nearly one-half by 2007 (figure ES.1). This increase in market share indicates a

possible decline in the competitive position of the U.S. industries, particularly vis-à-vis the

Chinese industries, which are now the largest foreign suppliers of these products and the most

significant competitors to the U.S. industry in the U.S. markets for hardwood plywood and

engineered wood flooring.

This report responds to a request by the Senate Finance Committee for information on and

analysis of the trends and new developments in the global wood flooring and hardwood

plywood industries that have affected the competitive position of the U.S. industries in the

U.S. market. The report covers four major areas: (1) an overview of the U.S. market; (2) a

description of the U.S. industries and the principal foreign industries supplying the U.S.

market; (3) an examination of U.S. trade patterns and the factors affecting trade patterns; and

(4) an analysis of the factors affecting the competitive position of U.S. producers and the

principal foreign suppliers in the U.S. market.

0

1000

2000

3000

4000

5000

6000

2002 2003 2004 2005 2006 2007

$ millions

Shipments Consumption Imports Exports

FIGURE ES.1 U.S. shipments, consumption, imports, and exports of wood flooring and 

hardwood plywood, 2002–07

Source: Compiled from U.S. producers and importers questionnaires.
x

Major Findings

Key factors affecting the competitive position of the U.S. wood flooring and hardwood

plywood industries in the U.S. market during the period 2002–07 include the following:

U.S. Consumption of Wood Flooring and Hardwood Plywood Grew Rapidly 

U.S. consumption of these products rose from $3.5 billion in 2002 to $5.6 billion in 2006

before declining to $5.2 billion in 2007. Consumption of solid wood flooring, engineered

wood flooring, and hardwood plywood increased by 41 percent, 100 percent, and 35 percent,

respectively during this period. Growing U.S. markets over most of the period for new

residential housing and remodeling and consumer preferences for wood flooring over other

types of flooring drove the strong increase in demand for both solid and engineered wood

flooring. The strong housing market also contributed to the increase in demand for hardwood

plywood in certain end-use segments (e.g., cabinetry and fixtures manufacturing). However,

declining demand in other end uses (e.g., furniture manufacturing) moderated growth of

overall U.S. consumption of hardwood plywood. In the U.S. housing market, a slowdown,

which began in 2006, caused declines in consumption and production in 2007 of both wood

flooring and hardwood plywood. 

U.S. Production of Wood Flooring Increased Significantly While Production

of Hardwood Plywood Remained Unchanged 

The performances of the U.S. industries for wood flooring and hardwood plywood were

markedly different over the period. Domestic flooring producers were able to significantly

increase shipments, capacity, and exports. In contrast, hardwood plywood producers did not

significantly increase shipments, capacity, or exports. U.S. shipments of solid and engineered

wood flooring posted an average annual increase of 6 percent during the period, increasing

from $1.5 billion in 2002 to almost $2.2 billion in 2004, and exceeded $2 billion for the

balance of the period. By contrast, U.S. shipments of hardwood plywood posted an average

annual increase of only 1 percent during the period, increasing from $913 million in 2002 to

almost $990 million in 2005, before falling to $939 million in 2007.

U.S. Imports Increased Faster Than U.S. Production

U.S. imports of wood flooring and hardwood plywood rose from $1.2 billion in 2002 to $2.7

billion in 2006 before declining to $2.5 billion in 2007. Imports of solid wood flooring,

engineered wood flooring, and hardwood plywood increased by 140 percent, 350 percent, and

67 percent, respectively. The six largest global suppliers (Brazil, Canada, China, Indonesia,

Malaysia, and Russia) are also the largest suppliers of wood flooring and hardwood plywood

to the U.S. market (figure ES.2). Imports from Brazil, China, and Malaysia were substantially

higher in 2007 than in 2002, while imports from Canada and Russia remained unchanged, and

imports from Indonesia were lower.
xi

Changes in U.S. Market Preferences Benefitted Imports More Than Domestic

Production

A significant shift in U.S. market preferences toward products such as prefinished wood

flooring, exotic species for solid wood flooring, and engineered wood flooring largely

benefitted foreign suppliers who were able to respond to increased U.S. demand. U.S.

producers of wood flooring and hardwood plywood increased their imports of finished

products either to broaden product lines or supplement domestic production. U.S. producers

also increased their imports of platforms (intermediate inputs) for engineered wood flooring

and hardwood plywood to lower production costs. The reportedly increasing market power

of large domestic retailers, coupled with their logistical ability to source products overseas,

contributed to the further erosion of the domestic market share of the U.S. wood flooring and

hardwood plywood industries and may also have put downward pressure on U.S. producers’

prices.

China Emerged as a Major Global Competitor and Supplier to the U.S.

Market

Despite an expanding domestic market, the rapid growth of Chinese production and exports

moved China from a net importer to a large net exporter of engineered wood flooring and

hardwood plywood. China accounted for most of the growth in U.S. imports during the

2002–07 period, increasing steadily at an average annual rate of 37 percent. China is the

largest hardwood plywood producer in the world and a significant producer of wood flooring.
xii

Despite paying relatively high prices for many imported raw materials, Chinese hardwood

plywood and engineered wood flooring producers have been able to take advantage of

domestic plantation wood resources which provide a large portion of the material for the

veneer cores and relatively low wage rates to achieve lower overall production costs as

compared with U.S. manufacturers. Recently, the Chinese government attempted to temper

export growth, conserve resources, and address trade frictions by reducing or eliminating

value-added tax export rebates and other benefits to the wood flooring and plywood industries

such as preferential tax breaks for foreign invested enterprises.

Global Trade in Wood Flooring and Hardwood Plywood Increased by 80

Percent, Outpacing Trade in Other Wood Products

Global trade increased at an average annual rate of 12 percent during the 2002–06 period. The

United States and the six leading foreign suppliers to the U.S. market account for more than

three-fourths of global exports of wood flooring and hardwood plywood. Brazil, Canada,

Indonesia, Malaysia, and Russia produce substantial surpluses of wood flooring and plywood

products and are export oriented. Moreover, Indonesia and Malaysia each produce

approximately three times more plywood than the United States. However, producers in all

five countries are facing increasing competition from China and have lost market share to

China in the United States and other major global markets.

Changes in Exchange Rates Yielded Uneven Effects

The declining U.S. dollar did not affect the major U.S. suppliers’ currencies equally. The

value of the Brazilian real, the Canadian dollar, the Indonesian rupiah, and the Russian ruble

have risen relative to the U.S. dollar faster than the Malaysian ringgit and Chinese yuan,

giving Malaysia and China a definite advantage vis-à-vis the other suppliers to the U.S.

market. However, for a supplier such as China, which relies heavily on imported raw

materials, the declining U.S. dollar has also raised the U.S. dollar cost of imported logs and

lumber (the majority of which come from non-U.S. sources), thus mitigating some of the

advantage that China has when selling its final products into the U.S. market. This decline has

also benefitted U.S. exports, particularly to Canada. U.S. producers increased exports of wood

flooring products at an average annual rate of 16 percent by quantity and by 17 percent by

value. U.S. exports of hardwood plywood were mixed with the value of exports increasing

at an average annual rate of 4 percent even as quantities exported fell.
xiii

Illegal Logging Increases the Supply and Reduces the Cost of Raw Materials

and Has Contributed to Increased Production and Consumption of Wood

Flooring and Hardwood Plywood

In addition to providing a possible cost advantage to those who use illegal logs in the

manufacture of wood products, illegal logging has a negative effect on prices for all wood

products by increasing the supply of wood products on global markets. The effect of illegal

logging on U.S. prices, however, has been relatively small. Major studies have estimated that

although illegal logging decreases world prices by 5–16 percent, it has only caused a decrease

in U.S. prices of 2–4 percent. Major exporters have implemented measures designed to

control and conserve forest resources and to retain those resources for their domestic

producers, with varying degrees of success. Major importers of forest products, such as the

United States, the European Union, and Japan, have also implemented policies or are

developing policies to address illegal logging.

 1

 On March 6, 2007, the Senate Committee on Finance (Committee) requested that the U.S. International

Trade Commission (Commission) prepare a report under section 332(g) of the Tariff Act of 1930 (19 U.S.C.

1332(g)) that provides information on the competitive conditions that affected the U.S. wood flooring and

hardwood plywood industries during the 2002–06 period. A copy of the request letter is included in app. A,

along with a copy of the Committee’s March 10, 2008, letter amending the schedule of the investigation.

App. B includes the Commission’s notice of institution and notice to reschedule the public hearing, which

were published in the Federal Register. 

1-1

CHAPTER 1

Introduction 

Background and Purpose

The United States is one of the world’s leading producers and consumers of wood flooring

and hardwood plywood, and is an important participant in the increasingly globalized market

for these products. Although U.S. exports of wood flooring and hardwood plywood have

risen in recent years, the U.S. industries manufacturing these products depend primarily on

the domestic market for sales. Consequently, the 105 percent increase in the value (nominal)

of U.S. imports of wood flooring and hardwood plywood during 2002–07 and the resulting

48 percent share (by value) of the U.S. market now held by imports have raised concern in

the U.S. industries. Although there are a number of significant foreign suppliers to the U.S.

market, the inroads in the U.S. market share made by Chinese products are particularly

noteworthy. China is now the largest U.S. supplier of wood flooring and hardwood plywood

products and the most significant U.S. competitor in the hardwood plywood and engineered

wood flooring segments of the domestic market.

This report was prepared in response to a request by the Senate Committee on Finance

(Committee) regarding competitive conditions affecting the U.S. wood flooring and

hardwood plywood industries.1

 The report addresses, to the extent possible, the following

elements of the Committee’s request:

• An overview of the U.S. markets for solid and engineered wood flooring (both

unfinished and factory-finished products) and hardwood plywood;

• A description of the U.S. industries for wood flooring and hardwood plywood and

the industries in the principal countries (including Canada, China, Brazil, Indonesia,

Malaysia, and Russia) supplying the U.S. market, including trends in production,

capacity, employment, and consumption; 

• An examination of U.S. trade patterns and the factors affecting trade patterns,

including tariffs and other border measures;

• An analysis of the factors affecting the competitive position of U.S. producers and

the principal foreign suppliers to the U.S. market, including raw materials, illegal
 2

 Fillets of solid wood may be substituted for veneer in the core of engineered wood flooring.

 3

 Some wood flooring is finished by infusing it with acrylic to increase the hardness and resistance to

wear and damage of the floor. Catalina Research, Inc., Wood Flooring, November 2005, 44.

1-2

logging, technological capabilities, labor practices, environmental policies,

government programs, and substitutes for wood flooring and hardwood plywood;

and

• Views of industry, homebuilders, importers, and other interested parties on

developments in the supply of and the demand for wood flooring and hardwood

plywood, including the effect of imports and substitutes for each product.

Product Coverage 

Product Descriptions

Wood Flooring 

Wood flooring, including both solid wood flooring and engineered wood flooring, is one

segment of the $24 billion U.S. market for floor coverings; other segments include carpet

and rugs, resilient flooring (e.g., vinyl and rubber flooring), ceramic floor tiles, and laminate

flooring. U.S. demand for wood flooring is closely tied to U.S. residential housing

construction and remodeling, which account for the vast majority of sales.

Although wood flooring is predominantly made from hardwood species, softwood species

are occasionally used; therefore, this report will use the terms “wood flooring” or “wood

floors.” Solid wood flooring is typically milled from a solid piece of lumber and shaped to

impart the characteristic tongue and groove to the edges and/or ends. Solid wood flooring

is typically made in thicknesses of 3/4 inches or 5/16 inches and can be made from a wide

variety of temperate and tropical hardwoods. 

Engineered wood flooring is typically assembled into panels (like plywood) with 3–10 layers

of wood veneer with the grain of adjacent plies perpendicular.2

 Once assembled, “boards”

are shaped to impart tongues and grooves to the edges in the same fashion as solid wood

flooring. Engineered wood flooring ranges from 1/4 inch to 3/4 inch thick, and the top (i.e.,

wear) layer ranges from 1/16 inch to 1/6 inch thick. Due to its multi-ply construction,

engineered wood flooring is more dimensionally stable than solid wood flooring and thus

can be installed in areas that were previously considered unsuitable for wood floors (e.g.,

directly over concrete slabs and in basements).

Both solid and engineered wood floors are sold as either unfinished or prefinished (i.e.,

factory finished) products. Prefinishing generally facilitates installation and increases

durability.3
 4

 Veneer (i.e., peeler) logs are higher in value than logs used for lumber because they are relatively large,

straight, and free of defects and/or large knots. To prepare them for peeling, they are debarked, cut to length,

and soaked in steam and/or hot water to soften the wood fibers.

 5

 To make rotary veneer, a log is spun on a lathe as a long (parallel) knife is held against it, producing a

continuous piece of veneer in a manner analogous to unrolling paper towels. A guillotine cuts the veneer

across its width to create panel-sized pieces.

 6

 To make sliced veneer, logs are sawn into half logs or quarter logs to create a flat surface, across which

a knife is drawn. In contrast to rotary cut veneer, which is cut into panel-sized pieces, the relatively narrow

leaves of sliced veneer must be spliced together to form panel-sized pieces. 

 7

 The production of plywood cores (i.e., platforms or blanks) is sometimes an intermediate step in the

production of finished hardwood plywood. U.S. hardwood plywood producers may use domestic or imported

platforms in the production of finished hardwood plywood. Under the Harmonized Tariff Schedule (HTS),

plywood cores are generally classified in the same subheadings as finished hardwood plywood.

1-3

Hardwood Plywood 

U.S. demand for hardwood plywood is principally derived from demand for cabinets,

furniture, store fixtures, recreational vehicles, and manufactured homes as well as U.S.

residential housing construction and remodeling. Because products made with hardwood

plywood are meant to be seen, the appearance of plywood is often a defining feature.

A plywood panel is formed by applying glue to face, back, and core veneers that are then

stacked on one another alternating the direction of the grain of each ply. The resulting

sandwich has a face ply, a back ply and a core consisting of an odd number of plies (three

or more) depending on the thickness of the veneer and the desired thickness of the finished

product. Plywood production generally begins by either peeling or slicing a log into thin

sheets.4

 Rotary (peeled) veneer5 is less expensive than sliced veneer and is used for core

material, as well as faces and backs, whereas sliced veneer 6

 is used as face veneer in highvalue end uses (e.g., wall paneling, furniture). Other types of panels, such as particleboard

or medium-density fiberboard (MDF), are sometimes used for cores, either alone or in

combination with veneer, and U.S. producers in the Pacific Northwest and Brazilian

producers often use softwood veneer for core material.7

 A paper, vinyl, or melamine layer

may be used instead of veneer for the back of a panel. Figure 1.1 summarizes the flow of raw

materials and inputs for wood flooring and hardwood plywood.

Tariff Classification and Treatment 

Wood flooring and hardwood plywood are classified in chapter 44 (wood and articles of

wood; wood charcoal) of the Harmonized Tariff Schedule of the United States (HTS).

Generally, these products do not have distinct tariff or statistical categories assigned to them

and are classified in several subheadings within HTS headings 4409, 4412, and 4418, based

on characteristics such as species of wood, construction, and finish. Hardwood plywood is

classified in heading 4412 (plywood, veneered panels, or similar laminated wood); more

detailed classification depends on the species of wood used for the face and back of the

panel, the type of core (e.g., veneer, solid, particleboard, MDF), and the construction of the

panel. Wood flooring is also classified based on its characteristics, and may be classified in

headings 4409 (wood continuously shaped along any of its edges, ends or faces), 4412 (see
1-4
 8

 Certain imports of those wood flooring and hardwood plywood products that are not normally free of

duty may be free of duty under the various bilateral U.S. free trade agreements or other U.S. trade preference

programs (e.g., GSP, AGOA, CBTPA, ATPA). For more specific information on tariff classifications and

duty rates, see app. C.

 9

 Global trade data for wood flooring and hardwood plywood based on the World Customs Organization's

(WCO) Harmonized System (HS) also reflect the overlap in classification between engineered wood flooring

and hardwood plywood. Amendments to the HS in 2007 further complicate analysis of global trade. Due to

reclassification of some flooring and plywood products, 2007 trade statistics do not correspond directly to

data from earlier years. Those amendments were made as a part of the normal WCO 5-year review.

 10 U.S. trade data are generally reported in either cubic meters or square meters depending on the

particular product.

 11 Possible causes for the reporting discrepancies include differences in classification or units of measure,

errors in data collection and compilation, inconsistent conversions, and/or illegal trade. 

 12 The seven HS subheadings are 4409.20, 4412.13, 4412.14, 4412.22, 4412.23, 4412.29, and 4418.30.

1-5

above), or 4418 (builders’ joinery and carpentry of wood). Although engineered wood

flooring is generally more heavily processed than hardwood plywood, it is essentially

plywood and is classified as such in the HTS. 

Depending on the particular subheading, wood flooring and hardwood plywood imports

enter the United States at normal trade relations duty rates ranging from zero to 8 percent;

special rates of duty may also apply to wood flooring and hardwood plywood under certain

trade preference programs or free trade agreements.8

 From 2002 to 2006, the annual average

duty paid on U.S. imports of wood flooring and hardwood plywood was 2.4–2.9 percent.

Industry and Trade Data

Official trade statistics do not permit precise and product-specific estimates of global trade

flows of wood flooring and hardwood plywood. This is due to the classification issues noted

above (overlapping classification or classification in basket categories);9

 differing units of

measure (e.g., cubic meters, square meters, metric tons);10 and differences between the export

data reported by one country and the corresponding import data reported by its trading

partner.11 Because of the overlap in classification between engineered wood flooring and

hardwood plywood, the trend in global trade is discussed collectively both in the global

overview in chapter 2 and in the section in chapter 3 on major foreign suppliers to the U.S.

market. The global trade data shown in chapter 2 are based on official national statistics as

compiled and reported by Global Trade Information Services, and are the aggregate of seven

6-digit HS subheadings that are believed to include most wood flooring and hardwood

plywood trade.12 Although this grouping may not include all wood flooring and hardwood

plywood and may contain other wood products, it is believed that the observed trend in

global trade for this group closely approximates the actual trend for wood flooring and

hardwood plywood.

With respect to different units of measure, reported quantities of wood flooring and

hardwood plywood trade were converted to a common unit of measure (square meters) using

conversion factors obtained from industry sources. Also, apparent errors in reported

quantities were analyzed and, when possible, corrected by using the corresponding data from

the partner country.

The product-specific estimates of U.S. trade of wood flooring and hardwood plywood used

in Chapter 3 were based on producer and importer questionnaires, in combination with

official U.S. trade statistics and importers of record data.
 13 Other uses for hardwood lumber include furniture, millwork, cabinets, railroad ties, and pallets.

1-6

Comprehensive global production data for wood flooring and hardwood plywood are not

generally available. The estimates of global hardwood plywood production discussed in

chapter 2 were based on a number of sources, including the Food and Agriculture

Organization of the United Nations (FAO), the International Tropical Timber Organization

(ITTO), and the European Federation of the Plywood Industry. Production of wood flooring

is more difficult to assess. Because solid wood flooring is one of many end uses for

hardwood lumber, it is likely that available estimates of global hardwood lumber production

mask the trend in production of wood flooring.13

The estimates of U.S. annual shipments of wood flooring and hardwood plywood shown

in chapter 3 are based on questionnaire data. For both products, estimates were adjusted

to account for the shipments of known non-responding U.S. producers. Industry statistics

were also used to estimate U.S. shipments. Partial-year shipment data for 2006 and 2007

were gathered from the Commission’s questionnaires and form the basis of the estimates

of 2007 U.S. shipments.

The U.S. producer and importer questionnaires solicited a broad range of information that

was intended to help characterize the U.S. markets for wood flooring and hardwood

plywood. However, the Commission is prevented from reporting certain data (e.g.,

employment and pricing), even in summarized form, in order to avoid disclosure of

confidential business information. Although the Commission received a relatively large

number of questionnaire responses, not all producers and importers reported information for

all questions or across all pricing products and/or countries. Therefore, the actual responses

for particular questions were more limited, and in several instances, the data reported by

larger firms accounted for a prohibitively large portion of the total. In general, when

confidentiality issues occur, the report discusses only general trends or presents information

in an indexed form (e.g., pricing data) to prevent disclosure of confidential information.
 14 Includes responses by firms that indicated they were neither importers nor domestic producers. 

 15 The questionnaires also solicited information for the first half of 2007, in addition to the 2002–06

period. Data are aggregated in this report so as not to reveal the operations of any one company. 

1-7

Approach 

A principal goal of this report is to identify and analyze the factors affecting the conditions

of competition in the U.S. market between the U.S. wood flooring and hardwood plywood

industries and major foreign suppliers. The factors noted in the Committee’s letter include

raw materials, illegal logging, technological capabilities, labor practices, environmental

policies, government programs, and substitutes for wood flooring and hardwood plywood.

Various economic factors, such as production costs, exchange rates, and pricing and

marketing practices, also contribute to the competitive position of U.S. and foreign

industries. Additional factors include firm concentration in production and distribution, the

degree of horizontal and vertical integration, product differentiation, and consumer tastes and

preferences. Data related to these factors are presented where available, but because

sufficient data do not exist, not all these factors can be quantified, particularly for foreign

industries. Therefore, market shares and prices in the United States, which can be estimated,

are used as key indicators of industry performance in this study. Other competitive factors

are assessed qualitatively to the extent possible. 

The main data-gathering instruments for this investigation were two questionnaires

developed by Commission staff. One questionnaire was designed to be completed by firms

in the United States that produce wood flooring and hardwood plywood; the other was

designed to be completed by firms that import wood flooring and hardwood plywood into

the United States. Both questionnaires were designed to gather quantitative and qualitative

information. To address the elements of the request letter, the questionnaires asked for

information on trends in U.S. production of wood flooring and hardwood plywood as well

as production costs, investment, prices, trade in raw materials, timber legality and

certification, and competition. In addition, the questionnaires gathered information on

imports of wood flooring and hardwood plywood and competitive factors such as channels

of distribution and the substitutability of imported flooring and plywood products for

domestic products. Finally, both the importer and producer questionnaires sought detailed

information about the HTS subheadings used by importers for their U.S. imports and by

producers for their U.S. exports of wood flooring and hardwood plywood. That information

was used to develop estimates of U.S. trade, market size, and market shares for wood

flooring and hardwood plywood.

The Commission developed a list of 280 companies believed to be producers of wood

flooring and hardwood plywood and 160 companies believed to be importers of wood

flooring and hardwood plywood. Copies of both questionnaires were mailed to all 440

companies, because some producers are also importers of these products. Over 200

questionnaire responses were received by the Commission.14 Of those, 66 importer

questionnaires and 75 producer questionnaires were compiled and analyzed to assess specific

trends and issues related to factors of competitiveness during the 2002–06 period.15

As part of this investigation, the Commission held a public hearing on October 3, 2007. The

information gathered at the hearing and from the questionnaire responses was supplemented

by written submissions provided to the Commission by interested parties; academic and trade

literature, including reports from numerous government and nongovernment organizations;
1-8

and interviews of industry representatives. Field visits were also made to manufacturing

facilities and organizations in North Carolina, Oregon, Pennsylvania, Virginia, Washington,

and China.

Report Organization 

Chapter 2 provides an overview of trends in global production, consumption, and trade

patterns for wood flooring and hardwood plywood. Country profiles are presented for the

United States in chapter 3, for China in chapter 4, and for the other major foreign suppliers

to the United States (Brazil, Canada, Indonesia, Malaysia, and Russia) in Chapter 5. Each

profile presents information about production, the structure and organization of the

industries, trade, consumption, raw materials (logs, lumber, and veneer), supply

chain/marketing channels, pricing, and other key attributes and factors affecting each

industry. Chapter 6 provides an analysis of the principal factors affecting the competitive

position of the U.S. industries and foreign supplier industries competing in the U.S. market.

Appendices to this report contain the request letter and amending letter from the Committee

(appendix A), Federal Register notices (appendix B), HTS descriptions and tariff

information (appendix C), a list of witnesses that appeared at the Commission’s public

hearing (appendix D), and summaries of views of interested parties (appendix E).
 1

 Industrial roundwood includes all industrial wood in the rough (logs, saw logs and veneer logs,

pulpwood and chips, poles, piling, etc.) but does not include fuelwood.

2-1

CHAPTER 2

Global Overview

The production and consumption of forest products have long been concentrated in the

world’s most developed economies. About two-thirds of industrial roundwood1

 has

traditionally been produced in North America and Europe. With that supply of raw material,

those same regions have been the major producers of downstream wood and paper products.

However, this traditional pattern is changing. Growth in the production of wood products,

in general, and wood flooring and hardwood plywood in particular, is shifting to developing

economies, especially to China. Although global production figures for certain hardwood

products are not readily available, and trade flows for these products are difficult to track,

data suggest that global trade is increasing at a faster rate than global production. New

sources of raw materials, new products, and low tariff barriers in the major markets for forest

products have all contributed to changing trade patterns.

The United States and the six largest foreign suppliers to the U.S. market account for about

three-fifths of the global production of the basic raw materials (hardwood saw logs and

veneer logs) used for the manufacture of wood flooring and hardwood plywood. The United

States and these suppliers also account for more than one-half of global exports of all wood

products and over three-fourths of global exports of wood flooring and hardwood plywood.

Industry observers generally believe that illegal logging, which increases the supply and

reduces the costs of raw materials, has contributed to increased consumption of wood

products and has furthered the destruction of natural forests, particularly in the tropics.

Much of the effort to reduce global forest degradation by combating illegal logging and

illicit trade in forest products and increasing the amount of certified sustainable timber and

forest products is being undertaken by these seven major producing countries. Major

producers and exporters have implemented measures designed to control and conserve forest

resources and to retain those resources for domestic producers in order to increase

downstream returns. The major importers of forest products—the United States, the EU, and

Japan—also have implemented or are developing policies to address the conservation of

forest resources.

Global Production

Raw Materials 

Because forest products industries have historically depended upon local supplies of suitable

raw material from existing natural forests, the largest global suppliers of wood flooring and
 2

 FAO data are supplied by reporting countries. Data supplied by some producing countries have been

challenged by other countries, as well as certain environmental groups. Comparable data from the

International Tropical Timber Organization (ITTO) are not comprehensive globally.

 3

 Softwoods typically predominate in natural forests at higher latitudes, and hardwoods predominate in

natural forests at lower latitudes. Countries may supplement harvests from natural forests by establishing tree

plantations, but the choice of species to be planted is still constrained by geographic and/or silvicultural

factors. 

 4

 Most of China’s natural forests are in remote, mountainous regions; others have been over-harvested or

converted to other land uses. Chan, “How Much Risk?” January 18–20, 2006; and Zhang, “China’s

Plantation Program,” January 18–20, 2006.

2-2

hardwood plywood also tend to be large producers of the hardwood logs from which the

products are made (table 2.1). According to the United Nations Food and Agricultural

Organization (FAO), during the 2002–06 period, the United States and the six major

suppliers of wood flooring and hardwood plywood to the U.S. market collectively accounted

for over 60 percent of global production of hardwood saw logs and hardwood veneer logs.2

While production of these basic raw materials in the United States and China was essentially

constant over the period, Brazil, Malaysia, Canada, and Russia each increased production

by more than 20 percent. Global production of hardwood logs grew at an average annual rate

of 1 percent during the 2002–06 period.

Geography and climate are key determinants of the types of trees that grow in the natural

forests in particular countries.3

 Located in the middle latitudes of the Northern Hemisphere,

U.S. forests are well endowed with both hardwoods and softwoods. To date, the United

States is the largest global producer of hardwood logs. Brazil, Indonesia, and Malaysia have

large areas of tropical forests and are large producers of various species of tropical hardwood

logs. Russian and Canadian forests are primarily softwood but are nevertheless large enough

to have significant quantities of hardwood logs as well. Desirable indigenous species may

confer a competitive advantage with respect to the production of wood flooring and

hardwood plywood. For example, Russian birch and Indonesian or Malaysian lauan are in

demand for hardwood plywood, and Brazilian exotic tropical species are in demand for

flooring. China is not well endowed with natural forests,4

 but recently established poplar

plantations provide an important supply of core veneer for China’s plywood and engineered

wood flooring industries.

Trade in hardwood logs and veneer is typically limited to higher-value species that are

intended for such end uses as furniture, flooring, cabinets, and paneling. Trade in lowervalue species is generally restricted to relatively short, cross-border moves, for instance

between Canada and the United States, between Russia and China, or within Europe. The

higher-value raw material is generally used for solid wood flooring, or for face veneer for

plywood, or engineered wood flooring, and the lower-value logs are generally used as core
 5

 Global trade statistics are not available separately for hardwood saw logs and veneer logs.

 6 Annual Report, 2006–2007, European Federation of the Plywood Industry, June 28, 2007, various pages.

Commission staff estimates of global hardwood plywood production are based on data from FAO, ITTO, and

the European Federation of the Plywood Industry.

2-3

TABLE 2.1 Global production of hardwood saw logs and veneer logs, 2002–06 (Millions of cubic meters)

Country 2002 2003 2004 2005 2006 

United States 61.6 55.8 61.5 61.0 61.4 

EU 27 28.0 31.0 31.0 28.0 29.0 

Brazil 19.6 22.4 20.9 24.7 24.9 

Malaysia 17.9 21.5 23.7 23.0 21.7 

Indonesia 26.5 26.0 26.0 24.2 21.6 

Canada 15.6 16.1 17.3 19.8 19.8 

China 18.3 18.6 18.7 18.7 18.7 

Russia 13.0 13.2 13.3 14.9 15.6 

Subtotal 201.2 204.5 212.3 214.5 212.5 

Other 72.6 72.7 77.5 77.6 78.8 

Total 273.8 277.2 289.7 292.2 291.3 

Source: FAOSTAT Forestry Database.

material. The major global trade flows for non-coniferous (i.e., hardwood) industrial

roundwood, which includes hardwood logs, are presented in figure 2.1.5

Wood Flooring and Hardwood Plywood

Strong global demand spurred increased production of both wood flooring and hardwood

plywood during the 2002–06 period. Although data are not available for global wood

flooring production, it is believed that production increased substantially, largely in response

to robust residential and commercial construction activity in the major consuming markets

(e.g., the United States, the EU, and China). The United States, the EU, China, Indonesia,

Malaysia, and Brazil are believed to be among the top global producers of wood flooring.

Global production of hardwood plywood increased at an estimated average annual rate of

8 percent during the period, due in part to strong demand for hardwood plywood for nonstructural construction purposes, as well as for furniture manufacturing.6

 In each year of the

period, the United States and the six major suppliers to the U.S. market accounted for more

than three-fourths of global production of hardwood plywood (table 2.2). However, the shift

in global production of hardwood plywood toward developing economies is demonstrated

by the fact that Brazil, China, India, Malaysia, and Russia accounted for virtually all the

growth in global production over the period.
2-4

FIGURE 2.1 Non-coniferous industrial roundwood: Major trade flows, (million $), 2006

109

291

414 414

272

235

LEGEND

Major exportersMajor importers

Source: GTIS, Global Trade Atlas Database.
 7

 These trade figures are based on import and export data reported by countries to Global Trade

Information Services, Inc. Tracking global trade flows for these products is problematic. Regardless of the

statistical source, major differences exist between data reported by importing and exporting countries. Some

of the causes for the discrepancies include differences in classification and units of measure, errors in data

collection and compilation, and inconsistent conversions. Illegal harvesting and trade may contribute to

additional discrepancies. Goetzl, “Discrepancies in Foreign Trade Data,” 2005.

 8

 Although this grouping contains other wood products as well, it is believed that the observed trends in

global trade for this grouping closely match the actual trends for wood flooring and hardwood plywood.

Owing to the overlap in HS classifications between engineered wood flooring and hardwood plywood, it is

not possible to determine separate global trade flows for these products.

2-5

TABLE 2.2 Estimated global production of hardwood plywood (1,000 cubic meters)

Country 2002 2003 2004 2005 2006

China 9,720 17,990 17,960 21,530 23,360 

Indonesia 6,550 6,111 4,514 4,534 6,111 

Malaysia 4,341 4,771 4,734 5,006 5,072 

Russia 1,675 1,820 2,066 2,352 2,390 

India 1,600 1,760 1,936 2,130 2,312 

United States 1,855 1,855 1,855 1,844 1,786 

EU 27 1,611 1,580 1,689 1,677 1,712 

Brazil 1,100 1,220 1,380 1,305 1,387 

Japan 1,132 1,131 919 963 1,009 

Taiwan 500 550 650 650 717 

Canada 300 300 300 302 293 

Subtotal 25,741 30,621 29,643 30,360 32,647 

Other 3,503 3,602 4,034 4,093 4,061 

Total 33,887 42,690 42,038 46,385 50,210 

Source: Estimated by Commission staff based on data from the FAOSTAT Forestry Database, ITTO annual reports,

and FEIC Annual Report 2006–07.

Global Trade

Both supply and demand factors spurred global trade in forest products during the 2002–06

period. Production capacity moved from the large consuming countries to countries with

lower costs of production for wood and paper products, and the establishment of fastgrowing plantations added new sources of both softwoods and hardwoods in some countries.

Also, the development of new products, such as engineered wood flooring and prefinished

flooring, and the demand for new, exotic species in both flooring and plywood products

contributed to this changing trade pattern.

Trade in wood flooring and hardwood plywood increased at a faster pace than trade in other

wood products, growing from a 12 percent share in 2002 to a 15 percent share of global

wood products trade in 2006.7

 Global imports of wood flooring and hardwood plywood

increased steadily during the 2002–06 period at an average annual increase of 12 percent,

from $6.1 billion to $11.0 billion (figure 2.2).8

 Global demand for imported wood flooring

and hardwood plywood products is highly concentrated; the top three import markets (the

United States, the EU, and Japan) collectively accounted for 73 percent of global imports in

2006. Japan, previously the largest importer of wood flooring and hardwood plywood, was

overtaken by the United States in 2004 and the EU in 2005, as U.S. and European imports

expanded at faster rates (16 and 17 percent, respectively) than Japan’s imports (7 percent).
 Annual Report, 2006–2007, European Federation of the Plywood Industry, June 28, 2007, various 9

pages.

2-6

imports expanded at faster rates (16 and 17 percent, respectively) than Japan’s imports (7

percent). Japan's more moderate growth was due, in part, to the relatively slow growth of

the Japanese housing market during the 2002–06 by historically low interest rates, European

residential construction, for both new and renovations reportedly began a strong upward

trend in 2004. In addition to the trend in residential construction, European demand for 9

wood flooring is increasing relative to other types of flooring. Consumption of engineered

solid wood flooring reportedly accelerated during the last five years, and by 2006, European
 During the 2002–06 period, Japanese housing starts increased at an average annual rate of 2 percent. 

10

Yasushi Okamoto, editor of Japan Lumber Journal, e-mail message to Commission staff, February 18, 2008.

 Ibid. 11

 Ibid. 12

2-7

consumption of wood flooring was approximately 114 million square meters or period.10

Driven 5.5 percent of the total flooring market. European plywood consumption by 11

quantity increased during the period at an estimated average annual rate of 4 percent.

12

The top three exporters of wood flooring and hardwood plywood (China, Malaysia, and

Indonesia) accounted for about two-thirds of global exports (by value) during 2002 (figure

2.3). Chinese exports posted the largest gain among all supplier countries from 2002 to

2006, increasing steadily at an average annual rate of 37 percent during the period, and

accounted for almost one-half of the increase in global exports. In 2006, China overtook

Malaysia to become the largest global supplier. Malaysian exports increased steadily at an

average annual rate of 13 percent, while Indonesian exports peaked in 2004. Brazilian and

Russian exports grew at an average annual rate of 15 percent, while Canadian exports

expanded much more slowly (3 percent) during the period. The major global trade flows for

hardwood plywood and wood flooring are presented in figure 2.4.
2-8

FIGUR E 2.4 H ardwood plyw ood and wood flooring: Major trade flows, (m illion $), 2006

So urce: GTIS , Glo bal Trad e Atlas Da ta base .

353

1,084

206

247

212

232

369

284

823

1,267

304

LEGE ND

M a jo r exp ortersM a jo r imp orters
 13 Analysis of the quantities of global exports of wood flooring and hardwood plywood is made more

difficult because quantity data for the HS subheadings that include wood flooring and hardwood plywood are

reported in different units of measure (meters, square meters, cubic meters, metric tons, and kilograms) or are

not reported at all. This gives rise to apparent errors in reporting that are difficult to detect and correct or

convert to a common unit of measure. Most data for these products are reported in cubic meters, square

meters, or metric tons. Quantities reported in metric tons or square meters have been converted to cubic

meters using average weights and thicknesses; quantities reported in meters were not included. Industry

officials believe that the estimated trends closely match the actual trends.

2-9

The quantity of global exports of wood flooring and hardwood plywood expanded at a

somewhat slower rate than the dollar value of such exports during the 2002–06 period, due

in part to the declining value of the U.S. dollar.13 The top three exporters (China, Malaysia,

and Indonesia) accounted for 60 percent or more of the volume of global exports during the

period (table 2.3). Again, Chinese exports of wood flooring and hardwood plywood posted

the largest gain of any country, increasing steadily at an average annual rate of 43 percent

in quantity terms. The quantity of Russian exports also increased rapidly, at an average

annual rate of 22 percent. Quantities of exports from Malaysia, Brazil, and Canada increased

at much more modest rates, and shipments from Indonesia actually declined by an average

annual rate of 9 percent. The United States is the eighth–largest exporter of wood flooring

and hardwood plywood. Reported U.S. exports increased at an average annual rate of 12

percent, to $325 million, during 2002–06 and benefitted from favorable exchange rates,

especially later in the period. 

TABLE 2.3 Reported exports of wood flooring and hardwood plywood 

Country 2002 2003 2004 2005 2006 aCAGR

Thousand cubic meters %

China 1,530 2,393 4,702 5,830 9,032 43

Malaysia 4,003 4,371 4,372 4,562 5,855 8

Indonesia 6,157 7,327 6,320 4,608 3,919 -9

Brazil 1,163 1,169 2,033 1,357 1,372 3

Russia 1,012 920 1,405 1,817 2,751 22

United States 365 423 508 743 1,168 26

Canada 514 532 555 599 562 2

Other 4,798 6,080 5,656 4,300 4,231 6

Total 19,451 23,216 25,552 23,816 28,890 8

Source: GTIS, Global Trade Atlas Database.

a

Compound annual growth rate.

Illegal Logging and Trade 

Despite national forestry laws that restrict logging and establish requirements for sustainable

harvesting, illegal logging remains a significant contributor to degradation of the world’s

remaining natural forests. According to the FAO, regions with developed economies and

temperate forests generally have stable or increasing forest area, while regions with
 14 FAO, State of the World’s Forests 2007, 2007, viii. The causes of deforestation vary by location and

include logging for raw material for wood and paper products, conversion of forested lands to crop land or

cattle grazing land, and the felling of trees for firewood or to be turned into charcoal. Most deforestation in

the tropics is caused by conversion to other land uses rather than by logging.

 15 Examples of trade disruptions include import and export bans on logs and sawn timber in producing

countries and government procurement policies aimed at reducing illegal logging. Some industry observers

also consider certain activities of private sector entities that object to imports of some wood products to be

disrupting market access.

 16 FAO, “Governments Making Progress in Curbing Illegal Logging,” December 5, 2005, 1. For a

comprehensive look at the extent of illegal logging, the environmental and other damages associated with it,

and the attempts by governments, NGOs, and others to curtail the practice, see Chatham House of London,

http://www.illegal-logging.info/.

 17 OECD, Environmental Outlook, 2001.

 18 World Resources Institute Web site http://www.wre-ltd.com/marketPDFs/IllegalLogging (accessed June

5, 2007).

 19 World Bank, Strengthening Forest Law Enforcement and Governance, August 2006, 2.

 20 However, there is nearly universal agreement that some tree species warrant protection, and they are

specifically listed in the Appendices to the Convention on International Trade in Endangered Species of Wild

Fauna and Flora (CITES). For instance, Brazilian rosewood is listed in app. I, which prohibits commercial

trade, and big-leaf mahogany is listed in app. II, which tightly controls trade.

 21 Miller, Taylor, and White, Keeping it Legal, July 2006, 11–12.

 22 Turner, Katz, and Buongiorno, Implications for the New Zealand Wood Products Sector, July 2007, i.

2-10

developing economies and tropical forests continue to lose forest area.14 In addition to

environmental effects, illegal logging is believed to be disrupting trade,15 creating

unsustainable economic development, and causing lost revenue for national governments and

local communities.16

In 2001, the OECD estimated that approximately 10 percent of the global trade in forest

products was derived from illegally harvested or traded wood.17 The World Resources

Institute has estimated that illegal logging represents about 8–10 percent of global wood

products production, and that about 17 percent of plywood production and as much as 23

percent of exported plywood is likely to be manufactured from illegally acquired logs.18 The

World Bank estimated the annual global value of losses from illegal logging on public land

at more than $10 billion and the losses of royalties at an additional $5 billion.19

Definitions of Illegal Logging

Efforts to address illegal logging are hampered by the lack of a universally accepted

definition of illegal logging, other than the notion that it includes logging that violates

national forestry laws.20 Government agencies tend to focus on whether timber harvests are

officially sanctioned and whether traded raw material and products carry valid documents.21

Definitions used by nongovernmental organizations (NGOs) often incorporate other issues

such as the awarding of logging concessions, sustainable forest management, compliance

with labor and environmental laws and regulations, proper collection of taxes, royalties and

fees, and an absence of corruption. The differences between governmental and NGO

definitions may help explain some of the variation found in assessments of the extent of

illegal logging.22
 23 Seneca Creek Associates and Wood Resources International, “Illegal”Logging and Global Wood

Markets, November 2004, 4. 

 24 Contreras-Hermosilla, Doornbosch, and Lodge, The Economics of Illegal Logging and Associated

Trade, January 2007, 17.

 25 Goetzl, “Discrepancies in Foreign Trade Data,” 2005, i.

 26 Seneca Creek Associates and Wood Resources International, “Illegal”Logging and Global Wood

Markets, November 2004, 11–13.

2-11

The most commonly cited definition of illegal logging addresses many of the issues noted.

Under this definition, illegal logging includes harvesting without authority in designated

parks or forest reserves, harvesting in excess of concession permit limits, avoiding royalty

payments or taxes, and violating international trading rules and agreements.23

Estimated Rates of Illegal Logging in Production and Exports 

It is often difficult to determine the origin of logs and, thus, the legality of those logs and the

downstream wood products. As noted by the OECD, reported figures for illegal logging are

imprecise and subject to debate, and the amount of illegal wood entering markets is

particularly difficult to estimate given the imperfect monitoring and statistical systems that

exist in many countries. Raw material is available from many different suppliers and is then

turned into wood and paper products by firms that may use a mix of legal and illegal

material. Raw materials and downstream products are sold in domestic and international

markets where further mixing may occur.24

Assessing the extent of illegal logging is made more difficult by inadequacies in the statistics

for forests and wood processing industries. Official estimates of timber harvests and

production of wood products are often questionable. There are also inconsistencies in

statistical information produced by agencies and other entities that monitor logging and

inconsistencies in the reporting of exports and imports of logs and wood products.25

Two comprehensive studies of the economic impact of illegal logging examined the

available assessments of the extent of illegal logging and arrived at similar estimates of

suspicious harvests and trade across the various countries. The first study, completed in 2004

by Seneca Creek and Associates for the American Forest and Paper Association, examined

the ranges of estimates provided by governments, NGOs, and other sources, and sought to

estimate the effect of illegal logging on the U.S. forest products industry. Seneca Creek

arrived at estimates of suspicious harvests for 2002 for the producers covered by this study

that ranged from 5 percent of harvested wood for Malaysia to 60 percent for Indonesia. In

a study conducted for the New Zealand Ministry of Forestry, Alphametric (a consultancy)

produced nearly identical estimates of suspicious harvests for the high-risk countries.26 The

only difference in their assessments was a slightly higher estimate for Brazil by Alphametric

(table 2.4).

These two groups also provided estimates of the percentage of suspicious exports of raw

materials (and imports in the case of China) commonly used to produce wood flooring and

hardwood plywood, as well as for plywood itself (table 2.5). The estimates from the
2-12

TABLE 2.4 Estimated rates of suspicious industrial roundwood harvests

Country aAlphametric bSeneca Creek

%

Low Most Likely High Ranges Assumed

Brazil 13 19 25 20–90 15

China 20 30 40 30 30

Indonesia 50 60 80 70–80 60

Malaysia 3 5 35 35 5

Russia 10 18 40 20–50 15–20

a

Turner, Katz, and Buongiorno, Implications for the New Zealand Wood Products Sector, July 2007, ii. These

percentages include both hardwood and softwood. Harvests from natural forests in Brazil, Indonesia, and Malaysia

are predominantly hardwood. b

Seneca Creek and Associates and Wood Resources International, “Illegal” Logging and Global Wood Markets,

November 2004, 11–13. The ranges represent figures reported by various authors and organizations, and the

assumed figures are those used in their analysis of the impacts on the U.S. industry.

TABLE 2.5 Estimated rates of suspicious trade

% of Exports

Country aAlphametric bSeneca Creek

Low Most Likely High Hardwoods

Brazil Roundwood exports 13 19 25 1

Sawnwood exports 13 19 25 15

Plywood exports 13 19 25 15

China Roundwood imports 21 32 29 31

Sawnwood imports 12 18 31 31

Plywood imports 37 56 74 31

Roundwood exports 21 32 39 30

Sawnwood exports 21 32 39 31

Plywood exports 17 25 39 31

Indonesia Roundwood exports 100 100 100 100

Sawnwood exports 55 65 86 65

Plywood exports 37 55 85 55

Malaysia Roundwood exports 7 10 35 10

Sawnwood exports 3 5 35 12

Plywood exports 3 5 35 12

Russia Roundwood exports 10 25 40 25

Sawnwood exports 10 16 40 30

Plywood exports 10 16 40 20

a

Turner, Katz, and Buongiorno, Implications for the New Zealand Wood Products Sector, July 2007, 25. b

Seneca Creek and Associates and Wood Resources International, “Illegal” Logging and Global Wood Markets,

November 2004, 18.
 27 Ibid., ES-3.

 28 Ibid., ES-1.

 29 Contreras-Hermosilla, Doornbosch, and Lodge, The Economics of Illegal Logging, January 2007, 20.

 30 Ibid., 4.

 31 Seneca Creek Associates and Wood Resources International, “Illegal”Logging and Global Wood

Markets, November 2004, ES-2.

2-13

two studies are similar. Seneca Creek estimated that illegal forest activity represents 5–10

percent of global industrial roundwood production. Seneca Creek estimated the rate for

softwood at 4 percent, but the rate for hardwood, the raw material of interest to this study,

at 15 percent.27 Seneca Creek also estimated that as much as 23 percent of hardwood lumber

and 30 percent of hardwood plywood could be traced to suspiciously produced roundwood.28

Alphametric also estimated similar higher rates for hardwood products.

Economic Effects of Illegal Logging 

Illegal logging increases the supply of wood on the market, putting downward pressure on

prices and encouraging consumption. Although the price of illegal logs may be equal to that

of legal logs in some markets, traders can often sell illegal logs at lower prices by avoiding

costs such as fees and taxes. Export prices would likely rise if all log production and exports

were legal. However, these higher prices could lead to increased incentives for illegal

logging.29

The price differential between legal and illegal logs depends on the end use of the logs, e.g.,

whether they are for fuel wood or for industrial products.30 Illegal logs are reportedly

generally of higher quality and may therefore flow to higher-value uses and draw higher

prices. These higher-value products include high-quality sawnwood, which may then be

made into solid wood flooring, as well as face veneers for use in higher-end hardwood

plywood or engineered wood flooring.

In addition to providing a possible cost advantage to those who use illegal logs in the

manufacture of wood products, illegal logging has a negative effect on prices for all wood

products. Seneca Creek estimated that illegal logging results in decreased world prices by

7–16 percent and U.S. prices by 2–4 percent.31 Alphametric estimated that illegal logging

causes global prices to decline 5–7 percent. Although these studies do not provide direct

links between illegally logged material and specific production or exports of wood flooring

and hardwood plywood, there is little evidence to suggest that price impacts for these

products would lie outside those estimates. However, since the model simulations performed

by Seneca Creek did not distinguish between softwood and hardwood, the price effects for

hardwood products may be higher.

Actions to Address Illegal Logging and Trade

Over the past decade, a number of initiatives have been undertaken to address illegal logging

and associated trade. The Convention on the International Trade in Endangered Species

(CITES) is the major multilateral environmental agreement that regulates trade in threatened
 32 Saunders, “EU FLEGT,” undated (accessed June 22, 2007), 3.

 33 EC, “Council Conclusions,” December 31, 2003.

 34 EU, Forest Law Enforcement, Governance and Trade, May 21, 2003.

 35 Saunders, “EU FLEGT,” undated, (accessed June 22, 2007). 

 36 For further information, see http://www.illegal-logging.info/presentations/200706/Lopez-Casero.ppt.

 37 For further information, see http://www.profrest.net/cpet.

2-14

and endangered species, including trade in forest products. In addition to that convention,

to which the United States and the six major foreign suppliers are signatories, the foreign

suppliers have their own efforts underway to reduce illegal logging. Those efforts are briefly

outlined below and are more fully addressed in the respective country sections in chapters

3, 4, and 5. 

European Union

In the EU, the debate over the extent to which consumer countries contribute to forest

degradation by driving the demand for timber and wood products has been especially strong

and has led to policy changes at the EU Commission level and in member states. The EU is

a major importer of logs, sawn timber, and wood products, including substantial imports

from countries identified as high risk for illegal logging and related trade.32 In 2003, the EU

adopted the Forest Law Enforcement, Governance and Trade (FLEGT) action plan with the

aim of developing supply-side measures that provide assistance to producer countries that

export to the EU and demand-side measures to reduce EU imports of illegally logged

timber.33 The FLEGT action plan’s key elements include voluntary partnership agreements

(VPAs) between producer countries and the EU on timber licensing; the adoption of policies

for procurement of timber from legal sources; the promotion of private sector initiatives such

as codes of conduct; and the exercise of due diligence by export credit agencies and financial

institutions when funding logging projects.34 Forest products legally produced in VPA

partner countries will be licensed, and only licensed products from these partner countries

will be allowed access to the EU. Thus far, the EU has not yet concluded any VPAs.

However, several member states are in discussions with individual producer countries on

possible VPAs, including Malaysia and Indonesia.35 On the demand side, several EU

countries are implementing public procurement policies requiring the purchase of legal forest

products. Thus far, six member states have adopted such policies, with the United Kingdom

the furthest along.

Japan

Japan imports large volumes of timber and wood products, particularly from tropical

countries. During 2006, the government of Japan announced changes to its public

procurement policy concerning wood-based products, including the requirement that all

wood-based products procured on behalf of the national government be certified as being

legal.36 The policy does not require independent verification of legality and does not address

sustainability. Certification schemes that are currently accepted as certifying legality under

the public procurement policy in the United Kingdom are reportedly likely also to be

accepted in Japan.37
 38 USAID, “Initiative Against Illegal Logging,” May 20, 2004, 1.

 39 White House, “President’s Initiative Against Illegal Logging,” undated (accessed February 6, 2008). 

 40 USTR, “USTR Schwab and Indonesian Trade and Forest Ministers,” November 16, 2006.

 41 Japan, China, and Korea, major consumers of Indonesia’s wood exports, have each signed an MOU

with Indonesia. Indonesia also signed an MOU with the United Kingdom to address the trade in illegal

timber between the two countries.

 42 USTR, “International Cooperation in Preventing and Combating Illicit International Trafficking in

Forest Products,” December 15, 2007, 2.

2-15

United States 

President’s Initiative Against Illegal Logging 

Begun in 2003, the President’s Initiative Against Illegal Logging (PIAIL) is intended to

assist developing countries in their efforts to combat illegal logging, including the sale and

export of illegally harvested timber, and in fighting corruption in the forest sector. The

PIAIL focuses on three regions—the Congo Basin, the Amazon Basin and Central America,

and South and Southeast Asia.38 PIAIL emphasizes four key strategies: (1) capacity building

to strengthen legal regimes and enforcement of laws affecting forest management, especially

those aimed at illegal logging; (2) enhancing community involvement in forest governance

and related wildlife issues; (3) transferring technology to improve capabilities to monitor

forest activity and conditions as well as compliance with laws; and (4) promoting good

business practices, transparent markets and legal trade, including in–country capacity to

implement obligations under CITES.39

Indonesia 

In November 2006, the United States and Indonesia signed a memorandum of understanding

(MOU)40 that is designed to promote forest conservation by combating illegal logging and

associated trade and to help ensure that Indonesia's legally produced timber and wood

products continue to have access to markets in the United States and elsewhere.41 The MOU

prescribes bilateral consultations and actions to promote transparent timber markets and trade

in legally produced timber products, enhanced cooperation on forest law enforcement

affecting trade in timber, and partnerships with nongovernmental entities. In support of this

MOU, the United States and Indonesia co-sponsored the forest products resolution at the

April 2007 UN Commission on Crime Prevention and Criminal Justice.42

China

In December 2007, the United States and China signed an MOU under which the two

countries agreed to immediately begin sharing information on shipments of timber, step up

law enforcement against illegal activity, and encourage private sector partnerships to

promote sustainable forest management. The United States and China plan to negotiate a

detailed bilateral agreement. China recently has signed other timber protection agreements,
 43 Ibid., 1.

 44 Ibid.

 45 16 U.S.C. 3371 et seq.

 46 16 U.S.C. 3373.

2-16

including agreements and memoranda with Russia on joint forest products industries

development, forest fire prevention, and nature reserve protection.43

Peru

The recently ratified Peru Trade Promotion Agreement (PTPA) between the United States

and Peru includes new and innovative provisions on combating illegal logging. The PTPA

environment chapter includes a first-ever annex on forest sector governance that recognizes

the environmental and economic consequences of trade associated with illegal logging and

illegal trade in wildlife, and provides for concrete steps that the parties will take to enhance

forest sector governance in Peru and promote legal trade in timber products. Under a separate

partnership, the United States is helping Peru and Colombia to monitor and verify the

management of forests under logging concessions, including facilitating the sharing of

technologies and approaches for increased forest transparency in the Amazon Basin.44

Food, Conservation, and Energy Act of 2008

On May 22, 2008, Congress passed the Food, Conservation, and Energy Act of 2008 (Public

Law No. 110-234). Section 8204 of the Food, Conservation, and Energy Act amended the

Lacey Act Amendments of 198145 (Lacey Act or Act) to extend the Act to imports of wood

and wood products harvested from illegal sources. Originally enacted in 1900 to protect

wildlife, the Lacey Act was amended in 1981 to include prohibitions on importation or

spread of potentially dangerous non-native plants. The 2008 amendment expands the

definition of the term “plant” or “plants” in the Lacey Act to include “trees from either

natural or planted forest stands”; defines the word “taken” to include, with respect to a plant,

“harvested, cut, logged, or removed”; and expands the list of acts prohibited to include plants

“taken, possessed, transported, or sold without the payment of appropriate royalties, taxes,

or stumpage fees required for the plant by any law or regulation of any State or any foreign

law.” The 2008 amendment also requires any person importing a plant into the United States

to file an “import declaration” that states the scientific name of the plant, the value and

quantity of the importation, and the country of origin of the plant. The Lacey Act provides

for civil and criminal penalties in the case of violations of the Act.46
 47 ITTO defines sustainable forest management (SFM) as “the process of managing forests to achieve one

or more clearly specified objectives of management with regard to the production of a continuous flow of

desired forest products and services without undue reduction of its inherent values and future productivity

and without undue undesirable effects on the physical and social environment.” ITTO, “Sustainable Forest

Management,” undated (accessed November 7, 2006).

 48 FAO, State of the World’s Forests 2007, 2007, 94.

 49 PEFC, “About PEFC,” undated (accessed February 14, 2008).

 50 FSC, “More Than 100 Million Hectares,” April 3, 2008, 3.

 51 The SFI and FSC have provisions for chain-of-custody tracking and certification. Given the number of

small land holdings in the United States, chain-of-custody and certification for hardwood producers may be

more challenging in the United States than in other countries.

2-17

Certification and Sustainable Forest Management 

Forest product industries around the world have adopted various certification standards for

sustainable forest management, usually as the result of the combined efforts of industry,

NGOs, and other interested groups, and often with government support.47 Certified

sustainably managed forests reportedly account for only about seven percent of the global

forest area, with the majority of certified area consisting of plantations rather than native

forests.48 National and international programs certify individual land holders, companies, and

national, state, or community forests. Typically, private organizations and third-party

auditors accredited by the certification programs determine program compliance. Exporting

countries, particularly those in the tropics, have sometimes viewed certification programs as

trade barriers because of their potential impact on market access for forest products.

The three most widely adopted international certification schemes—PEFC (originally Pan

European Forest Certification, now Program for the Endorsement of Forest Certification);

Forest Stewardship Council (FSC); and Sustainable Forestry Initiative (SFI)—account for

nearly 80 percent of all certified forest land. The PEFC, adopted by both European and nonEuropean countries, covers 23 independent national forest certification systems through

mutual recognition and accounts for more than 200 million hectares (494 million acres).49 As

of September 2007, the FSC had certified areas in 76 countries covering about 91 million

hectares (225 million acres). Of the major international programs, the FSC currently

accounts for the largest portion of certified forest area in the developing countries; these

forest areas account for about 20 percent of total FSC-certified forest area. One-third of FSCcertified tropical forests are commercial plantations, and the other two-thirds are natural

forests.50 The SFI, which is in the United States and Canada, began as a voluntary selfregulatory program promoted by the AF&PA. The SFI currently has certified about 61

million hectares (151 million acres).51

Several national certification program standards exist, particularly in the major suppliers

covered by this report. The Canadian Standard Association (CSA) Sustainable Forest

Management Program (CAN/CSA Z809) is the leading certification program in Canada.

Other national systems include the Malaysian Timber Certification Council, CERFLOR in

Brazil, and Lembaga Ekolabel Indonesia.

The vast majority of certified forest area is still in developed countries, and the demand for

certified products is concentrated in the major markets of Europe and the United States. In
2-18

developing markets, domestic demand for certified products is much more limited, but

several of these countries are substantial suppliers of hardwood products such as flooring and

plywood to Europe and the United States, and are thus interested in having their products for

international markets differentiated by certification. While certification does not appear to

guarantee price premiums, it seems to be a growing requirement in international markets. 
 1

 The basic elements of the manufacturing processes for these products have remained unchanged for

many years, and the equipment (e.g., lathes, molders, and presses) used in their manufacture are the same or

very similar among most major competitors. Nevertheless, U.S. mills are relatively advanced with respect to

several aspects of the manufacturing process such as the size and speed of manufacturing equipment, the

level of automation, and process control systems.

3-1

CHAPTER 3

United States 

Robust U.S. markets for new residential housing and residential remodeling for most of the

period and favorable marketing trends vis-à-vis other types of flooring drove apparent U.S.

consumption for wood flooring upward. In response, U.S. production capacity and

production for both solid wood flooring and engineered wood flooring expanded during

much of the 2002–07 period. The strong U.S. housing market also favorably influenced

demand for hardwood plywood in certain end uses, but declining demand in other end uses

moderated the overall growth of U.S. consumption of hardwood plywood. Contrary to the

upward trend that U.S. producers of wood flooring enjoyed, U.S. production capacity for

hardwood plywood remained relatively flat, and the quantity of U.S. production actually

declined during the period.

U.S. imports of wood flooring and hardwood plywood grew rapidly during 2002–07. The

six major global suppliers of these products identified in chapter 2 (Brazil, Canada, China,

Indonesia, Malaysia, and Russia) are also the largest suppliers of wood flooring and

hardwood plywood to the U.S. market. U.S. imports from China grew at a much faster pace

than imports from other countries during the 2002–06 period; China became the largest

supplier to the U.S. market in 2004. Estimates of product-specific trade indicate that imports

have a significant presence in the U.S. markets for wood flooring and hardwood plywood,

and import penetration for both products increased steadily during the period. U.S. exports

of wood flooring and hardwood plywood were relatively small compared to imports, and

mainly went to the NAFTA partners. 

The United States is well endowed with native hardwood resources, which supply most of

the raw materials for the large and technically capable U.S. industries manufacturing wood

flooring and hardwood plywood.1

 However, despite the abundance of U.S. hardwood

resources, U.S. manufacturers generally experienced higher costs for and, in some cases,

decreased availability of raw materials during the 2002–07 period. This was due to sawmill

shutdowns and high demand for the specific types of raw material typically used by U.S.

manufacturers. During the 2002–07 period, there were no U.S. Government programs that

directly benefitted the U.S. manufacturers of wood flooring and hardwood plywood.
 2

 The Commission received 65 usable producer questionnaires and 66 usable importer questionnaires. The

reported data from these questionnaires represent an estimated 72–76 percent of total U.S. shipments of

wood flooring, 85–93 percent of U.S. shipments of hardwood plywood, and 35–43 percent of U.S. imports of

the combined products.

 3

 U.S. timberlands (i.e., those available for timber production) are forest lands minus lands reserved for

other uses (e.g., national parks and wilderness areas). USDA Forest Service, “Forest Inventory and Analysis

National Program,” Table 1, undated (accessed May 9, 2008).

 4

 Geography influences the composition of forests; softwoods (e.g., pine, spruce, and fir) dominate in

upper latitudes and hardwoods (e.g., oak, maple, and poplar) dominate in lower latitudes. Being located in

middle latitudes, the United States is well-endowed with both native softwood and hardwood forests.

 5

 Buchanan, “What in the World Happened to Red Oak?” June 2005.

 6

 An industry source noted, however, a recent shift in demand toward U.S. hardwood logs, rather than

lumber in offshore markets. Industry official, telephone interview by Commission staff, May 8, 2008.

3-2

This chapter presents information on the U.S. industries and markets for these products, and

much of the information presented in the chapter is based on the questionnaire responses of

U.S. producers and importers.2

 The first section of the chapter pertains to raw materials and

provides general information about U.S. hardwood resources, which are the principal raw

materials for wood flooring and hardwood plywood, and information specific to each

product. The second section discusses trends in U.S. trade with the major foreign suppliers

and foreign markets for the combined products, as it is not possible to determine productspecific trade flows across the spectrum of supplier and market countries. The final two

sections provide specific information about the U.S. wood flooring and hardwood plywood

industries. Within the wood flooring section, separate discussions of solid and engineered

wood flooring are presented to the extent that information and data are available.

Raw Materials

The United States has approximately 304 million hectares (751 million acres) of forest land,

of which 68 percent (208 million hectares, or 514 million acres) is available for timber

production.3

 Well endowed with indigenous hardwoods, the United States is the leading

global producer of hardwood logs, the basic raw materials for wood flooring and hardwood

plywood (see table 2.3).4

 U.S. manufacturers reported that the domestic resource base

provides them with a competitive advantage over most other producers of wood flooring and

hardwood plywood. 

During the 2002–06 period, the supply of U.S. logs was relatively stable with the exception

of 2003, when production was reportedly hampered by wet weather (table 3.1).5

 U.S. log

imports fluctuated during the 2002–06 period but declined subsequent to the collapse of the

housing market in 2006. In general, however, apparent U.S. log consumption depends

heavily on domestic logs; imported logs accounted for only 3–5 percent of consumption in

each year of the period. There were no clear patterns in U.S. exports of hardwood logs

during the 2002–06 period, but they consistently accounted for only 3 to 4 percent of

production.6
 7

 The top five producing states (Pennsylvania, Tennessee, Virginia, West Virginia, and North Carolina)

accounted for 38 percent of U.S. hardwood lumber production in 2006. While more than a dozen species are

used for hardwood lumber, red and white oak (Quercus spp.) and yellow poplar (Liriodendron tulipifera),

account for about 40 percent of U.S. production. USDOC, Census Bureau, Lumber Production and Mill

Stocks: 2006, July 2007, 4–6.

 8

 Hardwood lumber consumption for flooring reportedly increased by about 10 percent from 2002 through

2005 but declined in 2006. Hardwood Publishing, Annual Forecast 2007, 2007, 17; and Armas, “Sawmills

Pressured as Furniture Plants Go Abroad,” September 15, 2007.

 9

 Even countries with large supplies of hardwood, such as Brazil, are reportedly beginning to import more

U.S. logs and lumber. The constrained supply of domestic raw materials noted by Brazilian manufacturers in

part explains this trend. Hardwood Review Global, “World Wide Lumber Demand Is Up,” May 2006, 1;

Hardwood Review Global, “Overseas Markets Take on Increased Importance,” August 2006, 1; Tropical

Timber Market Report, “Brazil Raises Intake of U.S. Timber,” March 2008; and USITC hearing transcript,

October 3, 2008, 222–24.

3-3

TABLE 3.1 U.S. production, trade, and consumption of hardwood logs, 2002–07

Item 2002 2003 2004 2005 2006 2007

Thousand of cubic meters

Production 61,605 55,801 61,468 60,958 61,358 a

61,637

Imports 3,368 2,322 2,088 3,235 2,690 1,910

Exports 2,270 2,165 2,147 2,369 1,950 1,997

Consumption 62,703 55,958 61,409 61,824 62,098 61,550

Imports/consumption (percent) 5.4 4.1 3.4 5.2 4.3 3.1

Exports/production (percent) 3.7 3.9 3.5 3.9 3.2 3.2

Source: Compiled from FAOSTAT Forestry Database and official statistics of the U.S. Department of Commerce.

a

USITC estimate based on prior year trend. 

With respect to U.S. hardwood lumber, most is milled in the eastern United States, which

accounted for 96 percent or more of annual U.S. production during the period.7

 U.S.

production remained flat at about 25–26 million cubic meters (table 3.2). Likewise, U.S.

consumption of hardwood lumber remained relatively flat during the 2002–06 period, as

decreasing demand related to some end uses (e.g., furniture and pallets) generally offset

increasing demand from other end use sectors (e.g., cabinets, flooring, and railroad ties).8

Imports increased steadily until 2005 and subsequently declined. U.S. exports of hardwood

lumber generally increased during the 2002–06 period, in part due to favorable exchange

rates and to a general tightening of global hardwood supplies, especially in Russia,

Indonesia, and Malaysia.9

TABLE 3.2 U.S. production, trade, and consumption of hardwood lumber, 2002–07

Item 2002 2003 2004 2005 2006 2007

Thousands of cubic meters

Production 26,203 24,724 26,055 26,288 25,977 26,183

Imports 1,538 1,585 1,819 1,894 1,632 1,230

Exports 2,767 2,739 3,013 3,010 3,123 2,745

Consumption 24,974 23,570 24,861 25,172 24,486 24,668

Imports/consumption (percent) 6.2 6.7 7.3 7.5 6.7 5.0

Exports/production (percent) 10.6 11.1 11.6 11.4 12.0 10.5

Source: Compiled from official trade statistics of the U.S. Department of Commerce and USDOC, Census Bureau,

Lumber Production and Mill Stocks: 2006, July 2007.
 10 Hardwood Market Report, “2006: The Year at a Glance,” 2007, 18; and Buchanan, “What in the World

Happened to Red Oak?” June 2005.

 11 Logs accounted for the remaining balance of U.S. producers’ purchases. 

3-4

The average U.S. prices for red and white oak lumber (the most important species with

respect to wood flooring) increased from 2002 until the third quarter of 2004 due to the

continued strength in the housing and remodeling markets (figure 3.1). However, several

factors contributed to the subsequent decrease in prices, which began in August 2004.

Reportedly, the supply of available lumber increased as U.S. production recovered from a

period of difficult logging conditions caused by inclement weather. Also, demand decreased

in part due to the contraction of the U.S. furniture industry, a shift away from oak as a

preferred species for cabinets, trim, and moldings, and a seasonal slump in export demand

during the last half of 2004.10

Solid Wood Flooring 

Most U.S. solid flooring manufacturers purchase lumber as opposed to logs; hardwood

lumber on average accounted for 96 percent of wood purchases by responding U.S.

producers in 2006.11 U.S. solid wood flooring producers reported no changes in purchasing

patterns during the period except in the case of production growth or the development of new

products. In 2006, 97 percent of wood purchased by responding producers came from U.S.

sources, with only trace amounts from Canada, South America, and Asia, indicating that U.S.

producers are not heavily reliant on exotic species of wood.

Although U.S. hardwood resources remain abundant, several solid wood flooring firms

reported decreased availability of lumber or longer hauls for lumber during the 2002–06

period. The principal reason cited was U.S. hardwood sawmill closures in the wake of

declining demand for lumber by U.S. furniture manufacturers. Furniture is a significant end

use for high-grade lumber (i.e., clear, defect free lumber), which typically constitutes about

45 percent of the production of U.S. hardwood sawmills. Declining demand for high-grade

lumber reportedly constrained total U.S. hardwood lumber production, with the result that

U.S. sawmills were unable to meet demand for the lower grades of hardwood lumber, which

flooring producers normally use. The impact of tight supplies of low-grade lumber was

exacerbated by strong demand for low-grade lumber from other end uses (e.g., railroad ties).

Other factors contributing to decreased availability of raw materials included forest fires,

harvesting restrictions on federal lands, scarcity of certain species or types of wood such as

black walnut (Juglans nigra) or antique lumber (i.e., previously used lumber removed from

old buildings), and increased export demand.
 12 Also known as blanks or cores, platforms are plywood cores to which a face ply will be affixed during

further manufacturing of engineered wood flooring or hardwood plywood.

3-5

Engineered Wood Flooring

In 2006, veneer accounted for 78 percent of raw material purchases by responding U.S.

manufacturers of engineered wood flooring, logs accounted for 14 percent, and platforms12

accounted for 8 percent. Purchasing patterns were generally stable, with only one firm

reporting nonacquisition-related changes. As with solid wood flooring, U.S. manufacturers

of engineered wood flooring are largely reliant on U.S. raw materials. In 2006, responding

U.S. manufacturers purchased 92 percent of their wood from domestic sources. Asian-Pacific

sources accounted for about 5 percent, and trace amounts came from other countries. U.S.

manufacturers of engineered wood flooring generally did not report difficulties with respect

to raw material supply. In fact, one U.S. manufacturer noted that it had idled its own veneer

mill because the firm could purchase veneer from other sources less expensively than it

could make it. Another firm stated that it had had to force price reductions on its raw

material suppliers in order to remain competitive in its markets against offshore flooring

imports.

Hardwood Plywood 

With respect to responding U.S. manufacturers of hardwood plywood, veneer accounted for

64 percent of wood purchases in 2006, platforms accounted for 21 percent, and logs

accounted for 15 percent. Several firms noted increasing purchases of platforms during the

2002–06 period. U.S. plywood manufacturers rely mostly on domestic raw materials; in

0

100

200

300

400

500

600

700

800

2002 2003 2004 2005 2006

 $ per thousand board feet

Red oak White oak

FIGURE 3.1 U.S composite lumber prices in dollars per thousand board feet, 2002–06

Source: Hardwood Publishing Co.
 13 On average, softwoods account for approximately 11 percent of U.S. industry expenditures for wood

fiber. USDOC, Census Bureau, Hardwood Veneer and Plywood Manufacturing: 2002, September 2004, 9.

 14 From 2002 to 2007, U.S. exports of yellow poplar logs increased at an average annual rate of 11

percent, and export unit value increased from $257 per cubic meter to $276 per cubic meter.

 15 Convention on International Trade in Endangered Species of Wild Fauna and Flora. See also Chapter 2,

footnote 20 on page 2-15.

3-6

2006, responding U.S. firms purchased 72 percent of their wood from domestic sources and

19 percent from Canadian sources. South American, Asian, and African sources supplied the

balance (9 percent). Yellow poplar is an important species for cores for eastern U.S.

producers, while West Coast firms typically use softwood veneer for cores.13

U.S. hardwood plywood producers echoed solid wood flooring firms’ concerns about

decreased availability of raw materials. Reportedly, the decline in the number of U.S.

furniture manufacturers also adversely affected the supply of veneer to U.S. manufacturers

because there is no longer a significant domestic market for furniture-grade veneer. Other

hardwood plywood producers noted that harvesting restrictions on federal lands and

increasing exports had raised prices or decreased the availability of raw materials.14 Several

producers also noted that the elevation of mahogany (Swietenia macrophylla) to CITES

appendix II,15 which had the effect of restricting trade in that species, limited the availability

of mahogany veneer.

Trade 

This section discusses trends in U.S. trade with the major foreign suppliers and foreign

markets for the combined products. Separate aggregate estimates of U.S. trade for each

product are provided later in the sections for wood flooring and hardwood plywood.

U.S. Imports 

The estimated values and quantities of U.S. imports of wood flooring and hardwood

plywood increased at overall average annual rates of 16 percent and 6 percent, respectively

during the 2002–07 period (table 3.3). Steady, rapid growth of U.S. imports characterized

the period from 2002 to 2006. However, the downturn in the U.S. housing market, which

began in the second half of 2006, slowed U.S. imports. The values and quantities of U.S.

imports from all major suppliers declined in 2007, and total U.S. imports decreased by 6

percent (by value) in 2007.

The six major global suppliers noted in chapter 2 (China, Canada, Indonesia, Malaysia,

Brazil, and Russia) are also the largest suppliers of wood flooring and hardwood plywood

to the U.S. market. The most notable trend during the 2002–07 period was the growth of

U.S. imports from China, which in both value and quantity terms grew at average annual

rates very near or exceeding 50 percent. China became the largest supplier to the U.S. market

in 2004, and China’s import market share among all foreign suppliers to the U.S. market

increased from 10 percent (by value) of the total in 2002 to 47 percent in 2007. In

comparison, the trends for the other foreign suppliers to the U.S. market were more modest

during the period, posting generally small to moderate overall gains by value but overall

declines by quantity.
3-7

TABLE 3.3 Estimated combined U.S. imports of wood flooring and hardwood plywood, 2002–07

Country 2002 2003 2004 2005 2006 2007

a

CAGR

2002–07

Thousands of $ %

China 117,675 205,754 551,220 808,093 1,166,025 1,144,519 57.6

Canada 258,749 297,759 335,702 342,521 319,172 283,022 1.8

Indonesia 226,767 209,318 237,434 215,055 224,152 206,072 -1.9

Malaysia 135,129 125,117 213,231 183,913 222,161 193,633 7.5

Brazil 96,749 129,642 226,640 224,606 205,900 189,545 14.4

Russia 121,770 111,201 165,019 160,174 127,917 121,592 0.0

Subtotal 956,839 1,078,791 1,729,246 1,934,362 2,265,327 2,138,383 17.4

All Other 190,786 212,283 286,515 289,587 318,101 277,824 7.8

Total 1,147,625 1,291,074 2,015,761 2,223,949 2,583,428 2,416,207 16.1

b

Thousands of square feet

China 255,414 405,043 1,178,224 1,566,484 2,054,451 1,782,587 47.5

Canada 388,262 413,351 442,618 503,546 466,533 285,581 -6.0

Indonesia 559,574 468,044 449,667 374,320 339,069 250,192 -14.9

Malaysia 385,573 357,614 519,892 413,916 445,090 345,614 -2.2

Brazil 293,903 362,095 449,271 289,544 235,004 176,678 -9.7

Russia 350,189 321,274 428,014 355,112 295,561 197,840 -10.8

Subtotal 2,232,915 2,327,420 3,467,686 3,502,922 3,835,709 3,038,492 6.4

All Other 307,833 303,947 349,417 342,550 358,926 366,669 3.6

Total 2,540,748 2,631,367 3,817,103 3,845,473 4,194,635 3,405,160 6.0

$ per square foot 

China 0.46 0.51 0.47 0.52 0.57 0.64 6.9

Canada 0.67 0.72 0.76 0.68 0.68 0.99 8.3

Indonesia 0.41 0.45 0.53 0.57 0.66 0.82 15.2

Malaysia 0.35 0.35 0.41 0.44 0.50 0.56 9.8

Brazil 0.33 0.36 0.50 0.78 0.88 1.07 26.7

Russia 0.35 0.35 0.39 0.45 0.43 0.61 12.1

Subtotal 0.43 0.46 0.50 0.55 0.59 0.70 10.4

All Other 0.62 0.70 0.82 0.85 0.89 0.76 4.1

Total 0.45 0.49 0.53 0.58 0.62 0.71 9.5

Source: Compiled from official statistics of the U.S. Department of Commerce. 

Note: Data shown reflect the changes to the HTS that occurred in 2007. The 2002–06 data include trade

in subheadings 4409.10, 4409.20, 4412.13, 4412.14, 4412.19.5050, 4412.22, 4412.23, 4412.29, and

4418.30. The 2007 data include trade in subheadings 4409.10, 4409.29, 4412.31, 4412.32,

4412.39.5050, 4412.94, 4412.99, 4418.71, 4418.72, and 4418.79. Totals may not add due to rounding.

 a

Compound annual growth rate.

 b

Imports reported in cubic meters were converted to square measure based on an estimated average

thickness of 13 mm.
 16 A total of 51 U.S. flooring firms submitted questionnaires to the Commission, of which 42 make solid

flooring, 5 make engineered flooring, and 4 make both. Analysis of the list of U.S. producers developed for

this investigation indicated that there are approximately 80 solid flooring firms and 24 engineered flooring

firms that did not submit questionnaires.

 17 Catalina Research Inc., Wood Flooring, November 2005, 10.

 18 Over 60 percent of responding U.S. wood flooring producers reported increased capacity. 

3-8

U.S. Exports

The value of U.S. exports of wood flooring and hardwood plywood increased steadily, at an

average annual rate of almost 12 percent during 2002–07 (table 3.4). The quantity of U.S.

exports peaked in 2004. U.S. manufacturers are primarily focused on the U.S. market, and

U.S. exports were small relative to imports, ranging from as little as 5 percent (by quantity)

to 8 percent of U.S. imports. During the period, U.S. producers benefitted from generally

favorable exchange rates. Most U.S. exports went to the NAFTA partners, whose markets

are easily accessible to U.S. producers. Canada alone accounted for over 60 percent of U.S.

exports (by value) in each year of the period. The top three markets for U.S. exports, Canada,

Mexico, and China, accounted for 80 percent or more of U.S. exports in each year of the

period.

Wood Flooring 

Industry Structure 

There are approximately 155 manufacturers of wood flooring in the United States. In 2006,

the five largest firms accounted for almost 60 percent of total U.S. production. The largest

firms typically make other types of flooring or floor coverings in addition to wood flooring.

In general, there are fewer and somewhat larger manufacturers of engineered wood flooring,

whereas solid wood flooring manufacturers are much smaller but more numerous. In 2006,

there were approximately 33 manufacturers of engineered wood flooring, and the average

annual shipments of responding firms was over 27 million square feet. In the same year,

there were approximately 126 U.S. manufacturers of solid wood flooring, and the average

annual shipments of responding firms was 9.5 million square feet.16 Industry analysts report

that during the 2002–06 period, U.S. manufacturers responded to the strong U.S. market for

wood flooring by investing in new plants and capacity.17 This observation is confirmed by

questionnaire data, which indicate that the capacity of responding U.S. wood flooring

producers increased during the 2002–06 period at an average annual rate of almost 10

percent.18

During the 2002–06 period, there were a number of acquisitions in the U.S. wood flooring

industry. For instance, in 2006 Armstrong increased its U.S. manufacturing capacity and

obtained new brands by acquiring engineered wood flooring manufacturer Capella
 19 Armstrong Industries, “Armstrong Announces Investments in Hardwood Flooring,” March 15, 2006.

 20 Wood Digest, “Mohawk Industries, Inc. Announces Purchase of Wood Flooring Assets,” June 26, 2007.

 21 Anderson, “Shaw Industries Agrees to Acquire the Anderson Family of Companies,” September 14,

2007.

3-9

TABLE 3.4 Estimated combined U.S. exports of wood flooring and hardwood plywood, 2002–07

Country 2002 2003 2004 2005 2006 2007

a

CAGR

2002–07

Thousands of $ %

Canada 92,073 110,704 113,841 113,396 123,966 139,985 8.7

Mexico 15,126 11,473 18,281 19,931 18,942 39,214 21.0

China 1,321 2,707 2,896 5,122 9,442 10,277 50.7

Subtotal 108,520 124,884 135,018 138,449 152,350 189,476 11.8

All other 19,400 24,554 27,025 34,583 31,954 38,051 14.4

Total 127,920 149,438 162,043 173,032 184,304 227,527 12.2 b

Thousands of square feet %

Canada 107,813 125,059 144,963 135,246 135,109 124,351 2.9

Mexico 33,238 27,982 49,019 44,752 28,713 73,548 17.2

China 2,075 7,235 8,858 9,784 5,495 6,055 23.9

Subtotal 143,126 160,275 202,840 189,782 169,318 203,953 7.3

All other 24,947 48,466 48,519 55,886 30,237 29,906 3.7

Total 168,073 208,742 251,359 245,668 199,555 233,859 6.8

$ per square foot %

Canada 0.85 0.89 0.79 0.84 0.92 1.13 5.7

Mexico 0.46 0.41 0.37 0.45 0.66 0.53 3.2

China 0.64 0.37 0.33 0.52 1.72 1.70 21.7

Subtotal 0.76 0.78 0.67 0.73 0.90 0.93 4.1

All other 0.78 0.51 0.56 0.62 1.06 1.27 10.3

Total 0.76 0.72 0.64 0.70 0.92 0.97 5.0

Source: Compiled from official statistics of the U.S. Department of Commerce.

Note: Data shown reflect the changes to the HTS that occurred in 2007. The 2002–06 data include trade in

subheadings 4409.10, 4409.20, 4412.13, 4412.14,4412.22, 4412.23, 4412.29, and 4418.30. The 2007 data

include trade in subheadings 4409.10, 4409.29, 4412.31, 4412.32, 4412.94, 4412.99, 4418.71, 4418.72, and

4418.79. Totals may not add due to rounding.

 a

Compound annual growth rate.

 b

Exports reported in cubic meters were converted to square measure based on an estimated average

thickness of 13 mm.

Engineered Wood and solid wood flooring manufacturer HomerWood.19 Two notable

acquisitions occurred in 2007. Reportedly seeking increased participation in the U.S. wood

flooring market, U.S. flooring firm, Mohawk, purchased the wood flooring assets of

Columbia Forest Products,20 and U.S. firm, Shaw Industries acquired Anderson.21

Large U.S. flooring firms often manufacture other types of flooring such as vinyl flooring

or carpet. Smaller U.S. wood flooring firms often make other wood products in addition to

wood flooring, such as hardwood lumber, stair treads, and moldings, as well as certain

products made from the byproducts of flooring manufacture such as fuel pellets, fire logs,

and animal bedding. 
 22 Miller, “Mannington Floors the Competition with Product Diversity,” April 2007, 48.

 23 Estimates of capacity utilization are based on the reported production and capacity of responding solid

wood flooring producers. Most reporting firms calculated capacity on the basis of one shift per day and five

days per week.

 24 Reported shipments from producer questionnaires were adjusted to account for the shipments of

nonresponding U.S. producers. Most responding U.S. wood flooring producers reported that there was no

particular seasonality to their shipments of wood flooring, although on average the shipments of responding

firms in 2006 were somewhat larger in the third quarter and less in the fourth quarter.

 25 Industry sources indicate that U.S. shipments of solid wood flooring decreased in 2006, after a record

year in 2005. Hardwood Market Report, “2006: The Year at a Glance,” 2007, 68. 

 26 U.S. solid wood flooring imports from Brazil, a major supplier to the U.S. market, declined in 2007

primarily because of the decline in the U.S. housing market. Brazilian flooring manufacturers noted

additional factors in the decline including higher European demand for Brazilian wood flooring, increasing

consumption in Brazil, and timber supply constraints in Brazil. USITC hearing transcript, October 3, 2007,

222–24.

3-10

The level of vertical integration of individual U.S. flooring plants varies. Although some

plants are vertically integrated, other plants perform just one step of the manufacturing

process. For example, with respect to engineered wood flooring, separate plants may perform

veneer production, panel production, and flooring production.22

Solid Wood Flooring

The production capacity of responding U.S. solid wood flooring producers increased at an

average annual rate of 9 percent during the 2002–06 period but declined slightly thereafter,

coincident with the market downturn. The capacity utilization of responding firms increased

from 91 percent in 2002 to 93 percent in 2004 but declined thereafter to 81 percent.23 The

average annual capacity of responding solid wood flooring firms increased from 31 million

square feet in 2002 to 38 million square feet in 2006, with some smaller firms reporting

annual capacities of less than 100,000 square feet. Because of differing size and degree of

plant integration, the required capital expenditure for new capacity varied widely, from less

than $1 million to over $100 million. The average capital expenditure for larger firms was

$46 million, while the average for smaller firms was about $3.5 million. During the 2002–06

period, employment of production workers by responding U.S. solid wood flooring

manufacturers increased at an average annual rate of about 3 percent, but in 2007 reported

employment declined to below 2002 levels. 

U.S. shipments of solid wood flooring posted an overall gain during the 2002–07 period,

increasing at an average annual rate of 6 percent.24 The estimated value of U.S. shipments

peaked at over $1.5 billion in 2004 (table 3.5).25 Although the estimated quantity of U.S.

shipments continued to increase through 2006, both the value and quantity of U.S. shipments

of solid wood flooring declined in 2007 in response to the slowdown in U.S. housing.

During the 2002–07 period, imports of wood flooring increased significantly, as did import

penetration; imports of engineered wood flooring increased more quickly than solid wood

flooring. U.S. imports of solid wood flooring increased rapidly through 2005, and import

penetration had almost doubled by 2006 (table 3.5). However, with a decline in U.S.

demand, imports and import penetration declined in 2007.26 Reported direct imports of
3-11

TABLE 3.5 U.S. solid and engineered wood flooring: Shipments, consumption, and trade, 2002–07

Estimated aCAGR

Item 2002 2003 2004 2005 2006 2007 2002–07

Millions of $ %

Solid wood flooring:

U.S. shipments 1,104 1,284 1,561 1,520 1,493 1,412 5.1

Imports 190 296 496 605 597 460 19.4

Exports 90 104 147 135 160 169 13.5

Consumption 1,204 1,475 1,910 1,990 1,930 1,703 7.2

Imports/consumption (percent) 15.8 20.1 26.0 30.4 30.9 27.0

Exports/shipments (percent) 8.1 8.1 9.4 8.9 10.7 12.0

Millions of square feet 

U.S. shipments 516 552 613 627 631 613 3.5

Imports 152 229 350 407 370 263 11.6

Exports 49 55 68 62 71 72 8.3

Consumption 619 726 895 973 930 804 5.5

Imports/consumption (percent) 24.6 31.5 39.1 41.9 39.8 32.8

Exports/shipments (percent) 9.4 9.9 11.0 9.9 11.2 11.8

Millions of $

Engineered wood flooring:

U.S. shipments 427 485 621 662 675 613 7.5

Imports 115 142 249 367 537 518 35.2

Exports 28 19 29 25 25 84 24.5

Consumption 514 608 842 1,004 1,187 1,047 15.3

Imports/consumption (percent) 22.3 23.4 29.6 36.6 45.3 49.5

Exports/shipments (percent) 6.6 3.9 4.7 3.8 3.7 13.7

Millions of square feet

U.S. shipments 179 193 245 251 258 243 6.3

Imports 86 88 136 204 377 244 23.3

Exports 50 32 82 61 45 137 22.2

Consumption 215 250 299 395 590 350 10.3

Imports/consumption (percent) 39.9 35.3 45.5 51.8 63.9 69.6

Exports/shipments (percent) 28.0 16.4 33.4 24.2 17.4 56.3

Millions of $

Total wood flooring:

U.S. shipments 1,531 1,768 2,182 2,182 2,168 2,025 5.8

Imports 305 438 746 972 1,135 978 26.3

Exports 118 123 176 160 185 253 16.5

Consumption 1,718 2,083 2,752 2,994 3,117 2,750 9.9

Imports/consumption (percent) 17.7 21.0 27.1 32.5 36.4 35.6

Exports/shipments (percent) 7.7 7.0 8.1 7.3 8.6 12.5

Millions of square feet 

U.S. shipments 695 745 858 878 889 856 4.2

Imports 238 317 486 612 748 507 16.3

Exports 99 86 149 123 116 209 16.2

Consumption 834 976 1,195 1,367 1,521 1,154 6.7

Imports/consumption (percent) 28.5 32.5 40.7 44.7 49.2 44.0

Exports/shipments (percent) 14.2 11.6 17.4 14.0 13.0 24.5

Source: Compiled from producer questionnaires and official statistics of the U.S. Department of Commerce.

 a

Compound annual growth rate.
 27 These data and those reported in subsequent sections for engineered wood flooring and hardwood

plywood only reflect imports for which U.S. manufacturers were the importers of record and do not include

foreign products that they may have purchased through importers.

 28 Specific wage data for the wood flooring and hardwood plywood industries are unavailable. However,

data for average hourly earnings of production workers in the U.S. wood products manufacturing sector

indicate that wage rate increases were relatively moderate during the 2002–06 period, with hourly earnings

increasing at an average annual rate of about 2 percent, from $12.33 per hour in 2002 to $13.67 per hour in

2007. USDOL, BLS, “Average Hourly Earnings of Production Workers,” undated (accessed June 12, 2008).

3-12

solid wood flooring by U.S. wood flooring manufacturers increased during the period but

accounted for less than 3 percent of total U.S. imports of solid wood flooring in each year

of the period.27

Traditionally, U.S. manufacturers of most forest products, including solid wood flooring,

have focused primarily on the relatively large domestic U.S. market and have had a limited

presence in export markets. Nonetheless, with favorable exchange rates, U.S. exports

increased steadily throughout the period, rising from 8 percent of shipments in 2002 to 12

percent in 2007.

With the strong U.S. housing market and favorable demand trends, apparent U.S.

consumption of solid wood flooring, both by value and quantity, climbed steadily during the

2002–06 period, at average annual rates of 13 and 11 percent respectively, but declined in

2007 subsequent to the market downturn. Growth in solid flooring consumption was

somewhat less than that for engineered wood flooring, in part because engineered wood

flooring can be used in areas of a home not suitable for solid flooring.

Raw material is the biggest component of the cost of goods sold for U.S. solid wood flooring

producers, accounting for over 60 percent of the total costs. The average cost of goods sold

increased from $2.10 per square foot in 2002 to $2.25 per square foot in 2004, before

declining to $2.15 per square foot in 2006 (table 3.6). Consistent with the peak in U.S.

lumber prices in 2004, the reported average industry cost of raw material likewise peaked

in 2004 at 66 percent of total cost. Direct labor as a percent of total cost of goods sold

increased steadily over the period, increasing from 15 percent to 17 percent of total cost of

goods sold.28 Other costs (e.g., energy, administration) ranged from 19 percent to 24 percent

of total cost of goods sold and generally decreased during the 2002–06 period.

Engineered Wood Flooring 

The annual capacity of responding U.S. producers of engineered wood flooring increased

steadily during the 2002–07 period at an average annual rate of more than 10 percent, but

unlike solid wood flooring, engineered wood flooring capacity continued to expand in 2007.

The reported average capacity of U.S. engineered wood flooring firms increased from 32

million square feet in 2002 to over 41 million square feet in 2006. Estimated capacity

utilization increased from 82 percent in 2002 to 95 percent in 2004 and declined to 84
 29 Estimated capacity utilization for the first half of 2007 was 80 percent. Responding U.S. engineered

wood flooring firms typically calculate plant capacity based on two or three shifts per day.

3-13

TABLE 3.6 U.S. wood flooring producers: Average cost of goods sold, 2002–07

Item 2002 2003 2004 2005 2006 2007

$ per square foot

Solid wood flooring:

Raw material 1.29 1.31 1.49 1.33 1.36 1.36

Direct labor 0.31 0.31 0.34 0.35 0.36 0.36

Other factory costs 0.50 0.48 0.43 0.41 0.43 0.43

Total 2.10 2.10 2.26 2.09 2.15 2.15

%

Raw material 61.4 62.4 65.9 63.6 63.3 63.3

Direct labor 14.8 14.8 15.0 16.7 16.7 16.7

Other factory costs 23.8 22.9 19.0 19.6 20.0 20.0

Total 100.0 100.0 100.0 100.0 100.0 100.0

$ per square foot

Engineered wood flooring:

Raw material 0.97 0.97 0.91 1.10 1.03 1.03

Direct labor 0.27 0.28 0.27 0.30 0.30 0.28

Other factory costs 0.55 0.56 0.44 0.49 0.54 0.59

Total 1.79 1.81 1.62 1.89 1.87 1.90

%

Raw material 54.2 53.6 56.2 58.2 55.1 54.2

Direct labor 15.1 15.5 16.7 15.9 16.0 14.7

Other factory costs 30.7 30.9 27.2 25.9 28.9 31.1

Total 100.0 100.0 100.0 100.0 100.0 100.0

Source: Compiled from U.S. producer and importer questionnaires.

Note: Percentages may not add due to rounding.

percent in 2006.29 The average reported capital expenditure for new engineered wood

flooring capacity was $38 million. As with solid flooring, the expenditure for new capacity

varied widely, depending on plant size and the degree of vertical integration. The number

of production workers reported by U.S. engineered wood flooring firms increased at an

average annual rate of 10 percent during the 2002–06 period. However, compared with the

solid wood flooring industry, the subsequent decline in production workers among U.S.

manufacturers of engineered flooring was relatively small.

During the 2002–07 period, the value of estimated U.S. shipments of engineered wood

flooring grew at an average annual rate of 7 percent, slightly faster than that of solid flooring

shipments, and accounted for an increasing percentage of total U.S. wood flooring shipments

(table 3.5). Both the value and quantity of U.S. shipments of engineered wood flooring

increased steadily from 2002 to 2006, before declining in 2007. 

Estimated U.S. imports of engineered wood flooring also increased at a faster rate than

imports of solid wood flooring, and import penetration for engineered wood flooring was

somewhat higher than for solid wood flooring (table 3.5). Direct imports of engineered wood

flooring by U.S. producers as a percent of total imports also grew quickly, from a relatively

small amount in 2002 to almost 10 percent in 2004, but declined in 2007, largely in response

to the housing downturn. Estimated U.S. exports of engineered wood flooring exhibited no

clear patterns during the 2002–07 period, but nonetheless accounted for less than 10 percent

of shipments in each year until 2007.
 30 Floor Covering Weekly, “Statistical Report ‘05,” July 17–31, 2006, 28.

 31 Catalina Research Inc., Wood Flooring, November 2005, 3.

 32 In 1991, the U.S. housing market began a period of steady expansion that continued until 2005. During

that period, housing starts increased in all but two years (1995 and 2000), increasing at an overall average

annual rate of 5.2 percent. USDOC, Census Bureau, “New Privately Owned Housing Units Started,” undated

3-14

Reflecting the favorable trend in demand relative to solid wood flooring, estimated U.S.

consumption of engineered wood flooring grew more rapidly than that for solid flooring

during the 2002–06 period, and engineered wood flooring as a percentage (by value) of total

U.S. wood flooring consumption increased from 30 to 38 percent (table 3.5). Nonetheless,

U.S. consumption of engineered wood flooring decreased 9 percent by value and 6 percent

by quantity in 2007. 

Raw material is also the largest component of the cost of goods sold for engineered wood

flooring, but it accounts for a smaller percentage than it does for solid flooring (table 3.6).

During the 2002–06 period, the average cost of goods sold for U.S. engineered wood

flooring producers increased from $1.79 per square foot in 2002 to $1.89 per square foot in

2005 and remained flat thereafter. The average cost of raw material increased steadily to

peak at 58 percent of total cost in 2005. Direct labor as a percent of total cost of goods sold

increased steadily but remained in the 15–17 percent range during the period.

Most responding U.S. wood flooring producers reported that production can be adjusted

relatively easily only in the short term, within the limits of raw material supply and their

existing employees’ capacity to work overtime. Several producers noted that longer-term

changes would likely be constrained by the availability of additional labor and/or supplies

of logs or lumber. This was a special concern of solid wood flooring manufacturers, 40

percent of which indicated that production could not be easily expanded or contracted. For

readily available species, these manufacturers reported that additional supplies of logs would

take a minimum of 18 months to procure and that additional supplies of lumber would take

at least 13–18 weeks. New supplies of less readily available species could take longer to

procure. Because they typically run their plants close to maximum capacity, some

manufacturers of engineered flooring noted that significant capital expenditures would be

necessary to expand production much beyond 10–15 percent. 

Although U.S. shipments of wood flooring grew during the 2002–06 period, the

questionnaire data suggest that further expansion of solid wood flooring production may

actually have been constrained by the relatively long lead time necessary to secure new

supplies of logs and lumber, despite the relative abundance of the underlying resource. Also,

major capital investment may have been necessary for further expansion of engineered wood

flooring production. 

U.S. Market for Wood Flooring

Unlike hardwood plywood, wood flooring is a finished or semi-finished product with a

specific end use. Demand is driven by U.S. residential housing construction and remodeling,

which reportedly account for over 80 percent of U.S. wood flooring sales.30 For most of the

period, the U.S. market for wood flooring benefitted from a rising U.S. housing market,

which was driven by low mortgage rates, rising personal incomes, and favorable

demographics.31 Annual U.S. housing starts increased steadily, from 1.7 million starts in

2002 to a peak of 2.1 million starts in 2005.32 Strong housing demand also resulted in
(accessed May 2, 2008).

 33 Catalina Research Inc., Wood Flooring, November 2005, 3, 59, 84.

 34 USDOC, Census Bureau, “New Privately Owned Housing Units Started,” undated (accessed May 2,

2008).

 35 Laminate flooring was introduced to the U.S. market in the mid 1990s and consists of (1) a top wear

layer to resist abrasion, (2) a decorative paper layer, (3) a core layer of high-density fiberboard for structural

integrity, and (4) a stabilizing bottom layer. The paper layer is printed with photo designs to mimic the

surface of natural materials. U.S. sales of laminate flooring have grown rapidly and are expected to continue

to grow due to strong sales in residential remodeling, where its advantages are durability and easy

installation (i.e., locking tongue and groove technology) and maintenance. Despite the fact that it is often

printed to simulate wood flooring, major U.S. flooring firms have laminate flooring in their product lines and

do not regard it as a substitute for wood flooring. Laminate flooring is considered a floor covering rather than

flooring and is priced between vinyl on the low end and wood flooring on the upper end. While the prices of

both wood flooring and laminate have fallen, their relative positions are the same, although the gap has

narrowed. USITC hearing transcript, October 3, 2007, 180–182; Floor Covering Weekly, “Statistical Report

‘06,” July 23–30, 2007, 1; and Miller, “Mannington Floors the Competition with Product Diversity,” April

2007, 48.

 36 Floor Covering Weekly, “Statistical Report ‘05,” July 17–31, 2006, 8; and Catalina Research Inc.,

Wood Flooring, November 2005, 1.

 37 Catalina Research Inc., Wood Flooring, November 2005, 22.

 38 Most of the U.S. producers and importers that expressed opinions in their questionnaire responses felt

that U.S. and foreign wood flooring were interchangeable. However, U.S. importers pointed out that they

typically import flooring of desirable exotic species that do not grow in U.S. forests. U.S. producers

contended that the exotic flooring nevertheless takes a share of the U.S. market that otherwise would likely

have been supplied by flooring of U.S. species. USITC, hearing transcript, October 3, 2007, 170 and 214;

and Catalina Research Inc., Wood Flooring, November 2005, 1, 32–33.

 39 USITC hearing transcript, October 3, 2007, 217–219

3-15

vigorous sales of existing homes, with buyers often undertaking remodeling projects.33 The

trend in the U.S. residential housing market toward use of more upscale building materials,

such as wood flooring, was also significant. Late in the period, the housing market slowed,

however, with annual housing starts decreasing to 1.8 million in 2006 and to 1.4 million in

2007.34

Substitutes for wood flooring (i.e., other types of flooring and flooring coverings) include

carpet and rugs, resilient flooring (e.g., vinyl and rubber flooring), ceramic floor tiles, and

laminate flooring.35 With strong housing demand, U.S. sales of all flooring rose to $24 billion

in 2005 at the peak of the market (table 3.7). During the 2002–06 period, wood flooring

continued a slow but steady upward trend relative to other types of flooring, despite the

average price for wood flooring far exceeding most other flooring choices.36 The share of

U.S. flooring sales accounted for by wood flooring increased from 10 percent to 11 percent

by value and from 3 percent to 4 percent by quantity during the 2002–06 period.37

U.S. Market Trends

U.S. consumer tastes are trending away from domestic species and traditional appearance

toward flooring of exotic (i.e., nonnative) species or nontraditional materials (e.g., bamboo),

and toward a more rustic appearance (e.g., hand-scraped floors or reclaimed floors).38

Brazilian manufacturers, who are major suppliers of exotic wood flooring, assert that

Brazilian wood flooring is generally sold at the high-end of the U.S. market due to its high

density and resistance to wear and that they rely primarily on species (e.g., jatoba, ipé,

cumaru, tigerwood, and santos mahogany) that typically grow only in Brazil.39 Also, wider

width (i.e., plank) flooring has gained popularity at the expense of strip flooring, which is
 40 Hardwood Market Report, 2006: The Year at a Glance, 2007, 18. 

 41 Questionnaire data indicated that in 2006, 64 percent of U.S. solid flooring production was strip, 30

percent was plank, 5 percent was wide plank, and parquet accounted for less than 1 percent. With respect to

engineered wood flooring, strip accounted for 38 percent, plank accounted for 46 percent, wide plank

accounted for 16 percent, and parquet accounted for less than 1 percent.

 42 The market niches identified by responding U.S. producers include products such as high-end, custom,

and designer flooring, parquet flooring, sports flooring, and reclaimed floors, as well as market segments

such as the market for second homes (i.e., houses not intended as primary residences), particular regional

markets, and sales to floor covering retailers.

3-16

TABLE 3.7 U.S. Floor covering market sales: 2002–06

Segment 2002 2003 2004 2005 2006

a

CAGR

2002–06

Millions of $ %

Carpet and rugs 13,030 13,820 14,440 15,350 15,060 3.7

Wood flooring 1,959 2,151 2,398 2,590 2,583 7.2

Ceramic flooring 2,360 2,540 2,860 3,070 3,170 7.7

Resilient flooring 1,960 1,786 1,820 1,820 1,700 -3.5

Laminate flooring 910 1,206 1,408 1,503 1,508 13.5

Total 20,219 21,503 22,926 24,333 24,021 4.4

Billions of square feet 

Carpet and rugs 17.98 19.48 19.16 19.38 17.98 0.0

Wood flooring 0.87 0.93 0.99 1.15 1.03 4.3

Ceramic flooring 2.64 2.81 3.14 3.26 3.30 5.7

Resilient flooring 3.64 3.60 3.84 3.84 3.26 -2.7

Laminate flooring 0.68 0.94 1.12 1.26 1.30 17.6

Total 25.81 27.76 28.25 28.89 26.87 1.0

 $ per square foot

Carpet and rugs 0.72 0.71 0.75 0.79 0.84 3.7

Wood flooring 2.25 2.31 2.42 2.25 2.51 2.7

Ceramic flooring 0.89 0.90 0.91 0.94 0.96 1.8

Resilient flooring 0.54 0.50 0.47 0.47 0.52 -0.8

Laminate flooring 1.34 1.28 1.26 1.19 1.16 -3.5

Total 0.78 0.77 0.81 0.84 0.89 3.4

Source: Floor Covering Weekly, "Statistical Report '06," July 23–30, 2007,10.

 a

Compound annual growth rate

now regarded as a commodity item.40 Questionnaire responses of U.S. producers and

importers confirm the growth of plank flooring and show that in 2006, plank flooring

(including wide plank flooring) accounted for 35 percent of U.S. solid flooring production

and 62 percent of U.S. engineered wood flooring production.41 There was also a trend toward

thicker flooring. With respect to solid wood flooring, for instance, 3/4s of an inch remained

the dominant thickness and this type of flooring increased as a percentage of both U.S.

shipments and imports during the period. Trends in consumer preference have expanded the

range of wood flooring that U.S. flooring firms must offer, and many of the market niches

identified by responding wood flooring producers depend on U.S. demand for high-end

flooring.42 The desire for high quality flooring is reflected in the responses of both U.S.

producers and importers, who generally agree that factors other than price are frequently

significant in U.S. sales of wood flooring. Responding U.S. wood flooring manufacturers

rated product quality as the most influential factor with respect to their sales of wood

flooring, and many noted factors such as high quality, craftsmanship, and consistency as
 43 Other factors identified by producers as sources of competitive advantage included characteristics of the

firms themselves (e.g., tradition of product innovation, family ownership, brand, and longevity in the

market), product attributes (e.g., dimensions, wear layers, color, and finishes) and manufacturing (e.g.,

custom work, grading, precise tolerances, and moisture control).

 44 U.S. producers identified lead times, on-time delivery, proximity to customers, and raw materials as

sources of competitive advantage. U.S. customers may require special services such as just-in-time

inventories and warehousing, promotional literature and displays, and/or cooperative advertising, small

orders and/or less-than-truckload shipments, job-site deliveries, technical assistance, sales support, and

special packaging.

 45 Floor Covering Weekly, “Statistical Report ‘05,” July 17–31, 2006, 8; and Catalina Research Inc.,

Wood Flooring, November 2005, 5.

 46 Catalina Research Inc., Wood Flooring, November 2005, 5.

 47 Reportedly, logistical considerations make imports of unfinished flooring from Asia impractical, so

most of what is imported from Asia is prefinished, engineered flooring. Wahlgren, “Worldly Vision,”

April/May 2007, 73.

3-17

sources of competitive advantage.43 Service was rated the next most influential factor by

responding firms, followed by business relationships.44 Product availability and price were

regarded as the least influential factors with respect to wood flooring sales.

U.S. consumption of engineered wood flooring grew more quickly than that of solid wood

flooring during the 2002–06 period, because engineered wood flooring can be used in places

(e.g., directly over slabs and in basements) not suited for solid flooring, has more consistent

raw material availability, and has improved features (e.g., locking tongues and grooves) that

facilitate do-it-yourself remodeling projects.45 Questionnaire respondents noted that

customers are starting to ask specifically for engineered wood flooring as opposed to solid

wood flooring.

There is also a trend in the U.S. market toward prefinished flooring, which is generally easier

to install than unfinished flooring,46 and U.S. producers are continuing to develop harder

finishes (e.g., acrylic impregnated floors) to increase resistance to wear. U.S. producer

questionnaire data reveal that during the 2002–06 period, 99 percent of U.S. engineered

production and about two-thirds of U.S. solid production were prefinished. U.S. wood

flooring imports are also largely prefinished, although the percentages of prefinished flooring

in reported imports was somewhat less than for U.S. production. Importer questionnaires

indicate that during the 2002–06 period, about 90 percent of engineered flooring imports and

approximately 54 percent of solid flooring imports were prefinished.47

Most of the U.S. market trends during the 2002–06 period were positive for U.S. producers

of wood flooring in that either the market itself and/or opportunities for increased value

added (i.e., prefinishing) were growing. However, these trends very likely did not benefit all

U.S. producers equally, as the more numerous and relatively small U.S. producers of

traditional unfinished solid wood flooring were less able than manufacturers of engineered

wood flooring to take advantage of the favorable market trends.

Channels of Distribution

Sales of wood flooring in the U.S. market typically follow either a one-step path directly

from the manufacturer to the end user or a two-step path from the manufacturer through a

distributor to the end user (figure 3.2). Most domestic and imported wood flooring is sold

through the two-step distribution process. In 2006, U.S. manufacturers reported that about

75 percent of U.S. wood flooring production was sold to wholesale distributors, whereas on
3-18

FIGURE 3.2 Major distribution channels for wood flooring and hardwood plywood

Source: IWPA, USITC analysis

Note: Solid lines represent flows of U.S. products, and dashed lines represent flows of imported products. Dotted 

lines represent minor flows. 

U.S. flooring installers,

builders, & homeowners

U.S. building material and

flooring retailers

U.S. manufacturers of

cabinets, furniture, fixtures,

RVs and mfg. homes

U.S. wholesale distributors

U.S. importers

U.S. manufacturers

Overseas manufacturers

Foreign logs,

lumber & veneer

U.S. logs,

lumber & veneer

Hardwood plywood

& wood flooring

Hardwood plywood

& wood flooring

Exports
 48 Catalina Research Inc., Wood Flooring, November 2005, 62.

 49 Wood flooring importers typically work through distributors to develop sales in the U.S. market. Ibid.,

65.

 50 Floor Covering Weekly, “Statistical Report ‘05,” July 17–31, 2006, 12.

 51 The duration of sales contracts reportedly ranges from as little as 10 days to 2 years. When used,

however, they do not always fix price and quantity. Of those producers reporting the use of contracts, about

one-half indicated that price was subject to renegotiation during the term of the contract.

 52 Wahlgren, “Worldly Vision,” April/May 2007, 72.

3-19

average, 55 percent of U.S. imports were sold through wholesale distributors. Most U.S.

producers’ direct sales (one-step path) went to retail building materials dealers, with the

small remainder split between home builders, flooring retailers, flooring installers, and

homeowners. In contrast, direct sales of U.S. imports were most often sold to flooring

retailers, home builders, and flooring installers. 

Retail wood flooring sales reportedly outpaced overall U.S. wood flooring sales due to the

growing importance of the residential remodeling market,48 but sales through distributors

increased as well, driven by increased wood flooring imports.49 The Internet has become a

key retail medium for wood flooring, especially for the “new breed” of discount flooring

retailer (e.g., Lumber Liquidators) that is now competing with retail building materials

dealers.50

Prices

About one-half of U.S. producers reported that prices of solid and engineered wood flooring

were determined through negotiations on a transaction-by-transaction basis, while price lists

were the most important factor for the other half. In general, the use of contracts, either long

or short term, is limited. Of the responding U.S. producers, nearly all noted that spot sales

accounted for 100 percent of their sales.51

Fifty-eight percent of the responding U.S. producers reported that prices were generally

quoted f.o.b. mill or warehouse. Thirty-five percent reported that they quoted prices on a

delivered basis, and the balance reported quoting prices either f.o.b. or delivered based on

customer preference. As in other industries, U.S. manufacturers typically offer some sort of

discount based on either volume or prompt payment, with sales terms generally ranging from

10 to 40 days.

For solid wood flooring, reported average lead times ranged from one day to four weeks for

orders shipped from inventory, with most producers averaging one week or less. Reported

average lead times ranged from 1 to 12 weeks for sales produced to order, with most

producers averaging 4 weeks or less. For engineered wood flooring, reported average lead

times ranged from 3 to 14 days for orders shipped from inventory and from 1 to 8 weeks for

sales produced to order.

Prices for all types of wood flooring in the U.S. market are reported to be generally

cyclical.52 According industry sources, in 2002, average weekly U.S. prices for traditional

unfinished, oak strip flooring were at low ebb following the last slowdown in the U.S.

economy (figure 3.3). Strip flooring prices, driven by the strong demand for residential

housing construction, gradually increased to a high point in mid-2004. By early 2005, the

subsequent decline took prices to levels comparable to 2002. The decline was, in part,

attributed to increased production from North American producers, increasing imports, and
 53 Industry official, e-mail message to Commission staff, April 21, 2008.

 54 Commission questionnaires solicited price information for four solid wood flooring products and five

engineered flooring products. Solid products included three oak strip flooring products, and a broad product

category for solid flooring of exotic (i.e., nondomestic) species. Engineered products included a

hand-scraped product and a sawn face product in addition to products with oak and exotic faces.

 55 The number of reporting firms for these products was not sufficient to allow prices to be reported

directly.

 56 The limited number of responding producers and importers also prevents the direct release of these

pricing data. Most reported prices for engineered wood flooring were for prefinished three inch oak with a

face ply greater than 1 mm thick, flooring with a hand-scraped face (various species), and flooring of exotic

species with few reports for prefinished three inch oak with a face ply less than 1 mm thick and flooring with

a sawn face.

 57 Additionally, there are an estimated 90 U.S. establishments engaged in the manufacture of hardwood

veneer. USDOC, Census Bureau, Hardwood Veneer and Plywood Manufacturing: 2002, September 2004, 5.

 58 Industry official, interview by Commission staff, Eugene, OR, August 17, 2007.

 59 The share of U.S. production accounted for by eastern plants ranged between 50 and 53 percent during

the 2002–06 period. HPVA, Hardwood Stock Panels, Annual Statistical Report for Calendar Year 2004,

2005, 41 and 71; and HPVA, Hardwood Stock Panels, Annual Statistical Report for Calendar Year 2006,

2007, 45 and 75.

3-20

weakening U.S. demand for unfinished, oak strip flooring relative to exotic, plank, and

prefinished flooring.53

Average annual prices collected from U.S. producer questionnaires for three solid oak strip

flooring products generally track weekly industry data during the period (figure 3.4).54

Responding U.S. importers reported very few prices for the traditional oak strip flooring

products. Most reported import prices were for solid wood flooring of exotic species, either

from Brazil or China.55 In general, reported prices of engineered wood flooring declined

during the period.56

Hardwood Plywood

U.S. Industry 

There are approximately 24 manufacturers of hardwood plywood in the United States.57 As

with wood flooring, a small number of firms account for the bulk of production; in 2006, the

five largest companies accounted for over three-quarters (by quantity) of U.S. production of

hardwood plywood. The U.S. industry was established on the West Coast in the mid-1960s.58

Later, plants were built in the East to take advantage the vast regional hardwood resource,

and, with a few exceptions, most U.S. hardwood plywood plants are located either in the

Southeast or the Pacific Northwest. Industry statistics indicate that during the 2002–06 period,

U.S. production of hardwood plywood was relatively evenly split between eastern and

western plants.59 In 2006, the average annual production capacity of responding hardwood

plywood firms was 87 million square feet, although some producers reported annual

production capacity of less than 100,000 square feet. Hardwood plywood producers also 
3-21
 60 Industry official, interview by Commission staff, Old Fort, NC, July 18, 2007.

 61 U.S. producers do not think that shipments are particularly seasonal, although, on average, reported

shipments in 2006 were somewhat larger in the first quarter and smaller in the fourth quarter. Summer is

reported to be a period of slow sales because many small cabinet shops, which are often not air-conditioned,

tend to close for vacation during the hot summer months. Industry official, interview by Commission staff,

Old Fort, NC, July 18, 2007.

3-22

manufacture other types of wood products including veneer, doors, particleboard, and other

products made with hardwood plywood.

In general, the U.S. manufacturing process from log to finished product is somewhat

fragmented, and the level of vertical integration among U.S. firms varies. For example, some

firms assemble the plywood panels with purchased veneer, while others have integrated

veneer production, particularly for veneers to be used for cores, and may even have integrated

log supply from company-owned woodlands. With respect to the production of sliced veneer,

which is typically used for faces and backs, some firms specialize in slicing the veneer, while

others specialize in the splicing (i.e., edge gluing) of sliced veneer into panel-sized pieces.60

U.S. producers identified all aspects of the manufacturing process as potential sources of

competitive advantage over other manufacturers. With respect to raw materials, their certified

timberlands were regarded by one responding firm to be a competitive advantage. Various

product attributes were noted as being advantageous, including product quality, specialty

panels, custom sizes and finishes, prefinishing, thin panels, and a broad product line. Various

aspects of the manufacturing process were noted, such as vertical integration, sanding,

adhesives, and proprietary grading. Small minimum orders, short lead times, and the ability

to mix shipments of plywood with other products were noted as important factors in choosing

a supplier. Special services sometimes required by plywood customers in the U.S. market

include blueprint matching, assembling components, special packaging, product or plant

engineering support, and logistics support.

Capacity, Shipments, Trade, and Consumption 

The total annual capacity of responding U.S. hardwood plywood firms increased at an average

annual rate of 3 percent during the 2002–07 period, but the average annual capacity of

responding firms decreased from about 100 million square feet to 87 million square feet.

Estimated capacity utilization for responding producers was 78 percent in 2002 and 77

percent during 2003–04. In 2005, capacity utilization decreased to about 70 percent, where

it remained for the rest of the period. The reported capital expenditures for new production

capacity was $2–50 million and averaged $13 million or $0.26 per square foot of capacity in

2006.

The trend in employment of production workers was generally down during the period.

Reported employment of production workers increased by 1 percent in 2003 but subsequently

declined during 2003–07 at an average annual rate of about 2 percent.

The total value of U.S. hardwood plywood shipments increased very slowly during the

2002–07 period, advancing at an average annual rate of about 1 percent (table 3.8).61 On a
 62 Industry data show that the decline was not confined to a particular region. Production in both the East

and Pacific Northwest decreased. HPVA, Hardwood Stock Panels, Annual Statistical Report for Calendar

Year 2004, 2005, 41 and 71; and HPVA, Hardwood Stock Panels, Annual Statistical Report for Calendar

Year 2006, 2007, 45 and 75.

 63 HTS statistical codes break out U.S. imports of door skins, 3.6 mm or less plywood of dimensions

suitable for flush (i.e., flat surface) doors for interior use. During the 2002–06 period, U.S. imports of door

skins accounted for 8–11 percent of the square foot quantities of annual U.S. imports of hardwood plywood.

Based on producer and importer questionnaire responses, the average thickness of U.S. imports of hardwood

plywood ranged from one-tenth inch (2.5 mm) to one-eighth inch (3 mm), less than the thickness of most

U.S. hardwood plywood production during the 2002–06 period.

3-23

quantity basis, however, U.S. shipments actually declined, dropping each year between 2002

and 2007, with the largest year-over-year declines coming after 2005.62

Estimated U.S. trade in hardwood plywood is shown in table 3.8. The value of U.S. imports

of hardwood plywood increased steadily from 2002 to 2006, and although imports declined

slightly in 2007, the value of U.S. imports increased at an average annual rate of 11 percent

during the period. Some U.S. producers actively sought opportunities to control costs by

importing hardwood plywood, either as finished product or as raw material (i.e., platforms)

for their own production process. Direct imports of hardwood plywood by U.S. producers as

a percent of total imports by value remained in the 7–9 percent range between 2002 and 2006,

but subsequently declined in 2007. 

TABLE 3.8 U.S. hardwood plywood: shipments, consumption, and trade, 2002–07

Estimated aCAGR

Item 2002 2003 2004 2005 2006 2007 2002–07

Millions of $ %

U.S. shipments 913 885 961 990 987 939 0.5

Imports 904 908 1,354 1,332 1,550 1,506 10.7

Exports 28 48 44 47 52 33 3.7

Consumption 1,790 1,745 2,270 2,275 2,484 2,412 6.1

Imports/consumption (percent) 50.5 52.0 59.6 58.6 62.4 62.5 NA

Exports/production (percent) 3.0 5.4 4.6 4.8 5.3 3.5 NA

Millions of square feet

U.S. shipments 1,079 1,064 1,061 1,026 951 890 -3.8

Imports 2,531 2,449 3,496 3,423 3,697 3,091 4.1

Exports 64 85 42 53 42 27 -15.8

Consumption 3,546 3,428 4,515 4,397 4,607 3,954 2.2

Imports/consumption (percent) 71.4 71.4 77.4 77.9 80.3 78.2 NA

Exports/production (percent) 5.9 8.0 4.0 5.2 4.4 3.1 NA

Source: Compiled from producer questionnaires and official statistics of the U.S. Department of Commerce.

a

Compound annual growth rate.

Estimated import penetration (by value) increased from 51 percent in 2002 to 62 percent in

2007. Import penetration by quantity increased from 71 percent in 2002 to 80 percent in 2006.

Import penetration by quantity is somewhat larger because imports are, on average, somewhat

thinner than domestic production, leading to lower prices on a unit basis. In part, this is

because of demand for imports of thin plywood for RVs and manufactured homes.63 During
 64 HPVA, Hardwood Stock Panels, Annual Statistical Report for Calendar Year 2004, 2005, 41and 71,

and HPVA, Hardwood Stock Panels, Annual Statistical Report for Calendar Year 2006, 2007, 45 and 75.

3-24

the 2002–06 period, the strong U.S. housing market favorably influenced demand for

hardwood plywood in certain end uses (e.g., cabinets), but declining demand in other

segments (e.g., furniture) moderated growth of U.S. consumption of hardwood plywood. The

value and quantity of U.S. consumption increased at average annual rates of 7 percent and 5

percent, respectively, during the 2002–06 period. In 2006, U.S. consumption of hardwood

plywood totaled $2.5 billion, or 4.0 billion square feet (table 3.9). U.S. consumption of

hardwood plywood decreased 3 percent by value and 14 percent by quantity in 2007.

TABLE 3.9 U.S. Hardwood plywood producers: Average cost of goods sold, 2002–07

Item 2002 2003 2004 2005 2006 2007

$ per square foot

Hardwood plywood

Raw material 0.57 0.58 0.61 0.64 0.70 0.73

Direct labor 0.10 0.09 0.10 0.10 0.11 0.11

Other factory costs 0.09 0.09 0.09 0.11 0.12 0.12

Total 0.75 0.77 0.80 0.85 0.93 0.96

%

Raw material 75.0 76.3 76.3 75.3 75.3 76.0

Direct labor 13.2 11.8 12.5 11.8 11.8 11.5

Other factory costs 11.8 11.8 11.3 12.9 12.9 12.5

Total 100.0 100.0 100.0 100.0 100.0 100.0

Source: Compiled from U.S. producer questionnaires.

Note: Values and percentages may not add due to rounding.

Cost of Goods Sold

Against the backdrop of flat or declining U.S. production during the 2002–06 period, the

average cost of goods sold for responding U.S. hardwood plywood producers increased

steadily, from $0.75 per square foot in 2002 to $0.93 per square foot in 2006, and was

estimated to have increased further in 2007 (table 3.9). The percentages of the cost of goods

sold accounted for by raw materials, direct labor, and other costs remained relatively stable

during the period for U.S. hardwood plywood firms. Raw material is an even larger cost

component for hardwood plywood than it is for wood flooring, accounting for 76–77 percent

of the total; the remainder of the cost of goods sold is fairly evenly split between direct labor

and other costs. 

U.S. Market for Hardwood Plywood

In their questionnaire responses, U.S. hardwood plywood manufacturers described the

conditions in the U.S. hardwood plywood market during the 2002–07 period as being very

competitive. Unlike wood flooring, hardwood plywood is generally an intermediate product

that is used to manufacture a variety of other items. It is typically used for nonstructural

purposes, and appearance is often a defining feature. Major end uses for U.S. hardwood

plywood are cabinets, furniture, and store fixtures.64
 65 Ibid.

 66 Hardwood Review Weekly, “North American Kitchen Cabinet Manufacturing,” May 25, 2007, 21; and

Hardwood Market Report, 2006: The Year at a Glance, 2007, 18.

 67 HPVA, Hardwood Stock Panels, Annual Statistical Report for Calendar Year 2004, 2005, 41 and 71;

and HPVA, Hardwood Stock Panels, Annual Statistical Report for Calendar Year 2006, 2007, 45 and 75.

 68 Demand from the office furniture and dormitory furniture segments has remained steady. Industry

officials, interviews by Commission staff, Portland, OR, August 16, 2007, and Eugene, OR, August 17,

2007.

 69 HPVA, Hardwood Stock Panels, Annual Statistical Report for Calendar Year 2004, 2005, 41, 71; and

HPVA, Hardwood Stock Panels, Annual Statistical Report for Calendar Year 2006, 2007, 45 and 75.

 70 Manufactured homes consist of one or more units on a permanent chassis that are transported to the site

on wheels and usually remain on temporary foundations. USITC, Conditions of Competition in the U.S.

Market for Wood Structural Building Components, 2003.

 71 The top thin plywood products are 2.7 mm (1/8 inch) and 3.4 mm (3/16 inch) 3-ply panels. Industry

officials, interviews by Commission staff, Portland, OR, August, 13, 2007, and Alexandria, VA, May 11,

2007.

 72 Because veneer as thin as 0.01 inch (0.25 mm) is used, thin plywood is made using a wet process, in

which the face and back veneers are laid up and pressed without prior drying. Because more labor is required

to handle thin veneers, it is not cost effective for U.S. producers to make thin plywood. Smooth, knot-free

lauan (Shorea spp.) logs from Indonesia or Malaysia are well suited for thin plywood and give those

countries a competitive advantage. U.S. RV manufacturers use thin lauan plywood for its strength, light

3-25

U.S. industry statistics indicate that shipments to both cabinet and fixture manufacturers

increased during the period. Cabinet manufacturers, which make stock or custom kitchen

cabinets and bathroom vanities, reportedly account for over one-half of U.S. hardwood

plywood consumption. Benefitting from strong residential housing construction, the U.S.

cabinet industry grew steadily during the 2002–06 period at an average annual rate of 5

percent. This spurred an increase in the quantity of direct shipments to the U.S. cabinet

industry from U.S. hardwood plywood manufacturers; shipments grew at an average annual

rate of 6 percent and accounted for almost one-half of direct sales by the U.S. industry in

2006.65 As with wood flooring, consumer preference with respect to species is changing; hard

maple and cherry have reportedly surpassed red oak as the preferred species for cabinets in

the U.S. market.66

Because cabinet installation often involves custom or semi-custom manufacturing, the U.S.

cabinet market has reportedly been somewhat more resistant to import competition than other

segments of the U.S. plywood market. However, U.S. producers have recently perceived a

loss of sales of cabinet components and parts, as some U.S. cabinet manufacturers have

switched some of their purchases to imports. Direct domestic shipments to U.S. manufacturers

of store fixtures, which accounted for about 7 percent of direct sales in 2006, also increased

during the 2002–06 period.67

In contrast to the cabinets and fixtures segments of the market, demand for hardwood

plywood from the declining U.S. furniture industry decreased during the 2002–06 period,

particularly in the U.S. residential furniture and contract furniture (i.e., furniture for the

hospitality industry) segments.68 Industry statistics indicate that direct shipments of U.S.

hardwood plywood to U.S. furniture manufacturers declined at an average annual rate of 13

percent during the period of investigation.69 Direct shipments to retail building materials

dealers also declined during the 2002–06 period. U.S. manufacturers report that some major

retail building materials dealers have begun to purchase imported plywood, as have some

large distributors of building products.

.

The U.S. manufactured home70 and recreational vehicle (RV) industries also use hardwood

plywood, particularly thin plywood (i.e., less than 1/4 inch thick).71 The U.S. industry

generally does not compete in this segment of U.S. demand.72 Commission estimates of
weight, and flexibility, which allows it to conform to interior contours. It is usually laminated with printed

paper for interior applications or with fiber glass and aluminum for exterior walls. IWPA, “Innovation

Continues to Drive the RV Industry,” 2005, 52–53; and industry officials, interviews by Commission staff,

Dillard, OR, August 15, 2007, and Portland, OR, August, 13–14, 2007.

 73 RVIA, “Historical Glance: RV Wholesale Shipments,” undated (accessed May 20, 2008); USDOC,

Census Bureau, “Cost & Size Comparisons For New Manufactured Homes,” undated (accessed May 20,

2008); Dickerhoof, Panel Product Usage in Mobile Home Production, 1978, 5; and RV industry official,

telephone interview by Commission staff, May 20, 2008.

 74 U.S. RV shipments increased from 311,000 in 2002 to 390,500 in 2006 but declined to 353,400 in 2007.

Annual U.S. shipments of manufactured homes decreased steadily from 168,500 units in 2002 to 117,300

units in 2006. A small increase in 2005 notwithstanding, shipments have decreased steadily from a maximum

of 373,100 in 1998. RVIA, “Historical Glance: RV Wholesale Shipments,” and “RV Shipments and Sales

Data,” undated (accessed August 9, 2008); and USDOC, Census Bureau, “Shipments of New Manufactured

Homes: 1959–2006,” undated (accessed May 8, 2008). 

 75 Industry official, interview by Commission staff, Old Fort, NC, July 18, 2007.

 76 Market niches identified by responding producers included architectural woodwork, RVs and boats, and

“green” building materials. 

3-26

demand in this segment indicate that demand declined at an average annual rate of about 3

percent from 812 million square feet in 2002 to 730 million square feet in 2006.73 Increasing

consumption attributable to relatively strong U.S. RV sales during the 2002–07 period did not

offset decreasing consumption attributable to declining sales of manufactured homes.74

Channels of Distribution

Similar to wood flooring, hardwood plywood can go through various, often circuitous,

channels of distribution to reach end users, with some sales involving multiple distributors

and products changing hands several times (figure 3.2). Most hardwood plywood, whether

U.S. production or imports, is sold through a two-step distribution channel through a

wholesale distributor to the end user, rather than a one-step distribution channel directly from

the manufacturer to the end user. In 2006, responding U.S. producers and importers reported

that 70 percent of U.S. production and 55 percent of U.S. imports were sold through

wholesale distributors. Industry sources report that much of what is distributed through

wholesale distributors is in turn sold to and used by small U.S. cabinet shops.75

According to U.S. producer questionnaires, in 2006, cabinet manufacturers were the largest

market for one-step (i.e., direct) sales, accounting for 16 percent of total reported U.S. sales.

Retail building materials dealers accounted for 6 percent, furniture manufacturers accounted

for 4 percent, and fixture manufacturers accounted for 2 percent of total sales in 2006. Trace

amounts were sold to manufactured home firms, flooring manufacturers, and for architectural

millwork.76 Generally, direct sales of U.S. imports were more likely to go to retail building

material dealers than to cabinet manufacturers.

U.S.-made hardwood plywood was less interchangeable with imports than U.S.-made wood

flooring because of the wider diversity of end uses for hardwood plywood. Nevertheless,

hardwood plywood from U.S. and foreign sources was generally regarded by both producers

and importers to be somewhat interchangeable. Producer questionnaire responses indicate

that, as with wood flooring, product quality is a significant factor in purchasing decisions for

U.S. hardwood plywood. Responding U.S. manufacturers rated product quality and service

equally as being highly influential for their sales of hardwood plywood, and one producer

suggested that the high end of the U.S. market was increasing in “architectural

sophistication.” Price and business relationships were regarded as the next most influential,

and product availability was regarded as less influential than the other factors.
 One U.S. producer noted that the market for A-grade plywood remained steady during the 2002–06 77

period but that the market for B-grade panels was been eroded by competition from imported C-grade panels.

 The current industry standard grades were consolidated in the mid-1980s by the HPVA. This traditional 78

marketing approach emphasized selling the “entire log.” Typically, an effort would be made to create special

panels for large customers, while residual production went to other customers. Some U.S. firms noted a

decreasing reliance on the traditional marketing approach based on standard HPVA grades in favor of

proprietary grades (i.e., company-specific brands or grades). In their view, the standard grades have been

“commoditized” or are deficient because they allow wide quality variation within grades and do not consider

all defects or features of veneer that influence appearance and customer appeal. Reportedly, this trend started

before the increase in imports but accelerated as imports increased. The use of proprietary brands does not

imply the use of higher-value or higher-quality veneers. Industry officials, telephone interviews by

Commission staff, January 31, 2008; and industry officials, interview by Commission staff, Alexandria, VA,

September 24, 2007.

3-28

sophistication.” Price and business relationships were regarded as the next most influential,

and product availability was regarded as less influential than the other factors.

Product Trends in Hardwood Plywood

U.S. production of hardwood plywood is trending toward thinner panels, as manufacturers

and other consumers of hardwood plywood reduce costs. The traditional 3/4 inch panel still

accounted for most U.S. shipments, but as a percent of total U.S. shipments, it declined from

65 percent to 54 percent during the 2002–06 period, while the percentages of thinner panels

generally increased (table 3.10). In contrast, 3/4 inch plywood accounted for only about onefourth of reported U.S. imports.

In 2006, architectural grades (i.e., grades AA, A, and B) accounted for 66 percent of reported

U.S. shipments, and both U.S. producers and importers suggest that U.S. production trended

toward higher grades during the 2002–06 period, as U.S. imports increased. Imports of high- 77

grade plywood are limited; in their questionnaire responses, very few U.S. importers reported

any imports of architectural grade plywood. Rather, U.S. imports are mostly lower-grade

panels (i.e., grades C and D), and importers claim that U.S. production is now confined to a

narrow range of grades that no longer includes “utility plywood.”78
 79 Industry official, interview by Commission staff, Washington, DC, May 3, 2007.

3-28

TABLE 3.10 Hardwood Plywood: Shares of U.S. shipments and imports, by thickness, 2002–06,

January–June 2006, and January–June 2007

Jan.-June Jan.-June

Thickness 2002 2003 2004 2005 2006 2006 2007

% of U.S. shipments

1/4" (5.2 mm) and less 18 18 20 21 22 22 22

3/8" (9.0 mm) 2 3 4 5 4 4 3

1/2" (12.0 mm) 11 12 12 13 13 13 13

5/8" (15.0 mm) 2 2 2 3 4 3 3

3/4" (18.0 mm) 65 62 58 55 54 54 56

1" (24.2 mm) and thicker 111112 2

Other 1 1 1 2 2 2 2

Total 100 100 100 100 100 100 100

% of U.S. imports

1/4" (5.2 mm) and less 32 35 36 37 35 35 35

3/8" (9.0 mm) 3 2 2 2 2 2 2

1/2" (12.0 mm) 15 15 15 13 14 14 14

5/8" (15.0 mm) 6 6 6 6 6 6 6

3/4" (18.0 mm) 22 24 25 26 26 26 26

1" (24.2 mm) and thicker 622222 3

Other 16 16 14 14 15 15 15

Total 100 100 100 100 100 100 100

Source: Compiled from U.S. producer and importer questionnaires.

The use of alternative cores (e.g., particleboard or MDF) by the U.S. industry is increasing,

although veneer cores still predominate.79 According to questionnaire data, in 2006,

approximately 69 percent of reported U.S. shipments had veneer cores. MDF and

particleboard cores accounted for 20 percent and 10 percent, respectively, of U.S. shipments,

and lumber (i.e., solid) cores accounted for the remainder. Several U.S. producers reported

that the use of alternative cores grew in the U.S. market, as end users sought lower-cost

alternatives and as U.S. production of low-grade plywood decreased.

U.S. production of prefinished plywood has increased relative to unfinished plywood.

According to U.S. producer questionnaire responses, the level of prefinished plywood

increased steadily, from 7 percent to 14 percent of reported U.S. plywood shipments during

the 2002–06 period. In comparison, the reported percentage of prefinished imports of

hardwood plywood exhibited no clear pattern, ranging from 1 to 8 percent of reported imports

during the 2002–06 period, and may be further evidence of the limited participation of

imports in high-end segments of the U.S. market.

Most U.S. plywood producers noted a growing awareness during the 2002–06 period of

environmental issues among their customers, who are also concerned with manufacturing

environmentally responsible products. Growing environmental awareness was evident in

formaldehyde emissions reductions and increasing air quality standards, increased fiber

sourcing standards (e.g., FSC standards), and increased demand for green building products

(i.e., products certified by the Leadership in Energy and Environmental Design (LEED) Green

Building Rating SystemTM).
 80 USITC hearing transcript, October 3, 2007, 33–36; and Hamler, “Plywood Gets a Makeover,” July

2007, 48.

 81 The CARB standards take effect in 2009 and are more stringent than existing HUD standards for

formaldehyde emissions in manufactured homes. The current HUD standard is 0.3 parts per million (ppm),

whereas CARB phase 1 levels are 0.08 ppm for hardwood plywood, 0.18 ppm for particleboard, and 0.21

ppm for MDF. Phase 2 levels are 0.05, 0.09, and 0.11 ppm, respectively. Hamler, “Plywood Gets a

Makeover,” July 2007, 49.

 82 Industry official, interview by Commission staff, Medford, OR, August 15, 2008.

 83 Hamler, “Plywood Gets a Makeover,” July 2007, 48–49.

 84 Some large foreign producers already make low-emitting panels for other markets (e.g., Japan), but

reportedly, it will be more difficult for smaller Chinese producers to comply because they often use air dried

veneer, which requires more adhesive to maintain adequate bonds. USITC, hearing transcript, October 3,

2007, 33–34 and 43; and Hamler, “Plywood Gets a Makeover,” July 2007, 48.

 85 Commission questionnaires solicited prices for 10 hardwood plywood products: five birch face, two oak

face, and two maple face panels of various grades in addition to one thin panel of various face species. All

other price data received from U.S. producers and importers were insufficient to permit public disclosure.

3-29

A significant environmental issue with respect to hardwood plywood is the off-gassing of urea

formaldehyde, a component of the adhesives used to make hardwood plywood that has been

shown to impact air quality.80 Regulation of formaldehyde was not a competitive factor during

the 2002–07 period because regulatory standards for formaldehyde emissions heretofore

existed only for plywood used in the construction of manufactured homes. However, recent

regulations promulgated by the California Air Resources Board (CARB) are expected to

increase the impact of formaldehyde content on the U.S. market. In April 2007, CARB

adopted stringent control measures to reduce formaldehyde emissions from composite wood

products (e.g., plywood, particleboard, and MDF) and the products made from them (e.g.,

furniture, cabinets).81 Large U.S. producers have already, or are in the process of, developing

formaldehyde-free and low-emitting adhesives.82 Although the new adhesives are typically

more expensive, industry analysts nevertheless expect that the CARB regulations will

ultimately lead to low-emission products becoming the standard for the entire U.S. market

because California is a relatively large portion of the U.S. market.83 This issue is a major

concern for U.S. manufacturers, which contend that U.S. imports are not being held even to

the current federal emissions standard for manufactured homes and that some imported

plywood has been shown to have emissions many times the allowable level. It is expected that

the testing and certification required by the new standard will, at least temporarily,

disadvantage some foreign producers in the California market.84

Prices

Sufficient questionnaire responses were received from U.S. producers to allow prices to be

reported for three hardwood plywood products: birch, grade B-4, 1/4 inch; birch, grade B-2,

1/2 inch; and birch, grade D-3, 3/4 inch.85 Average annual prices for these products are shown

in figure 3.5. The average reported prices for 1/4 inch B-4 birch declined at an average annual

rate of 3 percent during the 2002–06 period. Reported prices of the other products increased

at average annual rates of 3–4 percent.
3-30
 1

 International Wood Markets Group, The China Book, part 2, 2006, 76; and Rutton and Hock, “Reviving

Tropical Plywood,” May 2004, 25.

4-1

CHAPTER 4

China

China is the largest hardwood plywood producer and the largest wood flooring market in the

world. China’s highly fragmented hardwood plywood and wood flooring industries have

grown significantly in recent years, largely in response to booming domestic demand.

However, production has outpaced consumption, resulting in significant export growth.

Many small Chinese hardwood plywood and wood flooring producers are not competitive

in either domestic markets or export markets because of low levels of technology, inadequate

technical expertise, poor or inconsistent product quality, and/or a lack of innovative designs.

However, increased domestic and foreign investment—particularly from Taiwan and other

southeast Asian countries—and imported advanced technology from the United States,

Japan, and Europe have contributed to improved product quality and capacity expansion in

recent years.

Despite paying relatively high prices for their raw materials, many Chinese producers enjoy

low overall production costs because of low wage rates and the relatively high labor content

within these industries. However, rising raw material costs, as well as increasing energy,

labor, and transportation costs, have negatively impacted the competitive position of some

Chinese manufacturers and resulted in curtailed production or closure of some facilities,

particularly those making solid wood flooring.

In addition, government policies such as the processing trade preference program and the

value-added tax (VAT) export rebate that had encouraged the development of China’s wood

processing industries and favored exports have been revised in recent years. Reductions in

VAT export rebates have reduced the incentive to export, thereby favoring companies that

focus on the domestic market.

Industry Structure

Hardwood Plywood 

China’s hardwood plywood industry is highly fragmented, with thousands of privately

owned enterprises ranging from workshops and small-scale companies to relatively large

manufacturers. Overall, there are 5,000–6,000 hardwood plywood producers, most of which

are small “cottage” mills with an annual production capacity of less than 2,000 cubic meters

(m3

).1 Many of these cottage mills reportedly specialize in log peeling and veneer production

to supply veneer to plywood producers and, as a result, the actual number of plywood

producers may be somewhat smaller. Around 200 plywood producers reportedly have an

annual production capacity of more than 20,000 m3

, while around a dozen have an annual
 2

 International Wood Markets Group, The China Book, part 2, 2006, 77.

 3

 Average annual production capacity estimates for U.S. hardwood plywood producers are based on

responses to the Commission’s producer questionnaires, and were converted to cubic meters assuming an

average thickness of 14 millimeters.

 4

 Qian, “China’s Wood Based Panel,” April 22–25, 2007; and International Wood Markets Group, The

China Book, part 2, 2006, 76.

 5

 Rutton and Hock, “Reviving Tropical Plywood,” May 2004, 25.

 6

 International Wood Markets Group, The China Book, part 2, 2006, 80.

 7

 Ibid.

 8

 Ibid.

 9

 Xiufang, Cheng, and Canby, China’s Forest Product Exports, 2005, 5; TFT, China Wood Products

Supply Chain Analysis, March 2007, 9; and International Wood Markets Group, The China Book, part 2,

2006, 81.

 10 Xiufang, Cheng, and Canby, China’s Forest Product Exports, 2005, 5.

 11 USDA, FAS, Chinese Wood Usage Continues Rapid Growth, July 11, 2007, 16; and International

Wood Markets Group, The China Book, 2006, part 2, 74.

4-2

production capacity greater than 100,000 m3.

2

 In comparison, the average reported plant size

in the United States is approximately 87,000 m3

.

3

 Overall, the average annual production

capacity of Chinese plywood producers is reportedly less than 4,500 m3

 each, or about 5

percent of reporting U.S. producers’ average annual production capacity. China’s total

annual plywood production capacity is estimated to be 25–30 million m3

, of which 85

percent is hardwood.4

Medium-sized mills, whose annual production capacity ranges from approximately

2,000–10,000 m3

, reportedly account for 30 percent of China’s total plywood capacity. These

mills may purchase veneers from domestic cottage mills or from larger mills, or may import

them. Larger plywood mills, with an annual production capacity greater than 10,000 m3

, may

be vertically integrated, peeling domestic or imported logs and then gluing and pressing the

veneer layers to manufacture plywood. However, these mills may also purchase domestic

poplar veneer used as core material from cottage mills, which reportedly can supply quality

materials at a competitive price.5

 Some larger mills may also possess their own plantation

resources.

According to one industry estimate, the top 20 plywood producers have annual production

capacities ranging from 80,000 m3

 to 300,000 m3 and are export oriented, having exported

over 60 percent of their production in 2004, the latest year for which data are available.6

 In

comparison, China’s overall plywood industry exported 20 percent of production that year.7

Although China’s export-oriented plywood producers are significantly larger than the

average Chinese plywood mill, they account for only about 10 percent of China’s total

plywood production, yet 30 percent of China’s total plywood exports.8

Much of China’s hardwood plywood industry is located near tree plantations in the southern

and southeastern provinces of Jiangsu, Zhejiang, Fujian, and Guangdong.9

 Important

plywood production centers in northern China include Shandong and Hebei provinces.10

Access to log imports through major ports and to domestic plantation logs such as poplar

(Populus spp.) and eucalyptus (Eucalyptus spp.), as well as access to log and veneer

wholesale centers, equipment and material suppliers, low-cost skilled labor, and favorable

transportation infrastructure have contributed to the development of industry clusters in these

regions.11

Pizhou in Jiangsu province is one of the most important plywood production and export

centers in China. With a total plywood production capacity of 8 million m3

, approximately
 12 International Wood Markets Group, “China’s ‘City of Plywood,’” November 2007.

 13 Ibid.

 14 Ibid.

 15 Ibid.

 16 International Wood Markets Group, The China Book, part 2, 2006, 158–59. Laminated flooring is the

largest flooring industry segment in terms of production volume. However, laminated flooring is not the

focus of this study.

 17 Ibid., 175.

 18 Average annual production estimates for U.S. solid wood flooring producers are based on responses to

the Commission’s producer questionnaires, and were converted to cubic meters assuming an average

thickness of approximately 18 millimeters.

 19 International Wood Markets Group, The China Book, part 2, 2006, 149.

 20 Includes employees engaged in laminated flooring production. ITTO, Tropical Timber Market Report,

September 16–30, 2006.

 21 International Wood Markets Group, The China Book, part 2, 2006, 168.

4-3

3,000 mills are engaged in plywood production or raw material supply in Pizhou and

consume over 10 million m3

 of domestic poplar plantation logs and almost 3 million m3 of

imported logs and veneer annually.12 Reportedly, 335 mills produce finished plywood, while

the remainder are engaged in veneer production for both plywood and engineered wood

flooring.13 Of the 335 mills, 48 have production capacity reportedly exceeding 50,000 m3

 per

year, while two producers have an annual production capacity greater than 100,000 m3

.

14 In

2006, total plywood exports from Pizhou reached 3.2 million m3

, or approximately 40

percent of total Chinese plywood exports that year.15 Major export markets include the

United States, the EU, and Japan.

Wood Flooring

Similar in structure to the plywood industry, the solid wood flooring industry is highly

fragmented, with 5,000–6,000 producers, most of which are small in scale.16 The average

annual production of solid wood flooring producers is estimated to be 1,000 m3

, although

larger mills reportedly produce 2,000–10,000 m3

 annually.17 In comparison, the average

annual production of U.S. solid wood flooring producers is approximately 8,700 m3

, almost

nine times larger than that of the average Chinese mill.18 There are reportedly around 100

larger-scale solid wood flooring mills that account for about 40 percent of China’s solid

wood flooring production.19 Overall, there are about one million employees engaged in wood

flooring production, distribution, and service activities.20

In contrast to the abundance of small-scale solid wood flooring producers, the engineered

wood flooring industry in China is relatively more concentrated. In 2005, there were

estimated to be around 100 Chinese engineered wood flooring producers.21
 22 Ibid., 177.

 23 Average annual production estimates for U.S. engineered wood flooring producers are based on

responses to the Commission’s producer questionnaires, and were converted to cubic meters assuming an

average thickness of 13 millimeters.

 24 International Wood Markets Group, The China Book, part 2, 2006, 168.

 25 Ibid., 159.

 26 Ibid., 169; and USITC hearing transcript, October 3, 2007, 233.

 27 Industry official, interview by Commission staff, China, February 21, 2008. Bamboo flooring is an

engineered flooring product that is manufactured from strips split longitudinally from bamboo stalks.

Bamboo flooring producers may purchase bamboo raw materials from cooperatives that process bamboo

stalks into strips, which are further processed and glued together to form the basis of an engineered bamboo

flooring product. Some bamboo flooring producers also produce engineered wood flooring.

 28 International Wood Markets Group, The China Book, part 2, 2006, 171; and industry official, interview

by Commission staff, China, February 21, 2008.

 29 ITTO, Tropical Timber Market Report, March 1–15, 2007, 8; and USITC hearing transcript, October 3,

2007, 178.

 30 White, et al., China and the Global Market for Forest Products, March 2006, 6.

4-4

Annual production reportedly ranges from 5,000 m3 for smaller engineered flooring mills,

which is comparable in size to the average Chinese plywood mill, to 15,000 m3

 for large

ones.22 In comparison, the reported average plant size in the United States is almost 50,000

m3

, substantially larger than the average Chinese engineered wood flooring producer.23 The

10 largest engineered flooring producers are estimated to account for 50 percent of

engineered wood flooring production in China.24

Overall, the wood flooring industry—comprising both solid and engineered wood

flooring—is concentrated in the southern coastal provinces of Guangdong, Zhejiang, and

Jiangsu, as well as Shanghai municipality, although important production centers are also

located in Yunnan in the south and Liaoning and Heilongjiang in the north.25 Engineered

wood flooring tends to be produced in the same regions as plywood. The manufacturing

processes of the two products are similar and certain plywood producers have expanded their

product offerings to include engineered wood flooring.26

The bamboo flooring industry is a comparatively small segment of China’s overall wood

flooring industry. There are an estimated 100–200 bamboo flooring producers, although

many of them may only be semi-finished producers processing bamboo stalks into bamboo

strips, which are in turn assembled into flooring by flooring mills.27

Following improvements in product quality in the late-1990s, bamboo flooring has

reportedly increased in popularity in China because of its hardness and durability,

particularly in commercial flooring applications.28 In export markets such as the United

States, bamboo flooring is increasingly viewed as “green,” which contributes to its cachet

as an environmentally sustainable flooring product.29

Raw Material Supply

In recent years, China’s rapid economic growth has led to growing domestic consumption

of wood products that has outpaced the supply of domestic wood resources.30 As a result,

China’s wood-processing industries rely heavily on imported raw materials. China is the

largest importer of hardwood logs and lumber in the world, accounting for 36 percent of the
 31 GTIS, Global Trade Atlas Database (accessed June 11, 2008). Hardwood logs are included in the

following HS subheadings: 4403.49, 4403.91, and 4403.99. Hardwood lumber is included in the following

HS subheadings: 4407.21, 4407.22, 4407.25, 4407.26, 4407.27, 4407.28, 4407.29, 4407.91, 4407.92,

4407.93, 4407.94, 4407.95, and 4407.99.

 32 TFT, China Wood Products Supply Chain Analysis, March 2007, 2.

 33 Weiming, et al., Russian Logs in China, 2007, 1. Figure includes both softwood and hardwood species.

 34 Xiufang, Cheng, and Canby, China’s Forest Product Exports, 2005, 5.

 35 International Wood Markets Group, The China Book, part 2, 2006, 162.

 36 TFT, China Wood Products Supply Chain Analysis, March 2007, 7.

4-5

value of global hardwood log imports and 14 percent of the value of global hardwood lumber

imports in 2006.31 Logging restrictions implemented in 1998 through China's National Forest

Protection Program (NFPP) to protect domestic natural forests, and a subsequent elimination

of import duties on logs and lumber, contributed to increasing raw material imports,

particularly imported logs and lumber for higher-end or export-oriented products.32 By 2004,

imports of logs and lumber accounted for almost 36 percent of China’s total raw material

supply.33 In recent years, domestic poplar plantations have also become an important source

of core material for plywood and engineered wood flooring.

Generally, China’s plywood industry uses poplar from fast-growing high-yield (FGHY)

domestic plantations for core veneers, but is dependent upon imports of temperate and

tropical wood species to produce face and back veneers.34 The engineered wood flooring

industry typically uses imported temperate or tropical species to produce face veneers, and

domestic softwood and hardwood species, including plantation wood, as core material. The

solid wood flooring industry reportedly relies on imports of temperate and tropical hardwood

logs and lumber for 90 percent of its raw material.35 China’s abundance of domestic bamboo

resources provide raw material for its bamboo flooring and other bamboo products.

China’s Raw Material Imports

China is the world’s largest importer of hardwood logs and lumber, obtaining significant

hardwood imports from all major global supply sources noted in chapter 2. Hardwood logs,

particularly high-value tropical logs, as well as temperate hardwood species, are processed

into veneer to produce plywood and engineered wood flooring. Hardwood lumber is used

to produce solid wood flooring. Chinese policies such as the NFPP that curb domestic timber

production, coupled with an expansion of production capacity in China’s wood processing

industries in response to surging economic growth, growing domestic housing demand, and

increased demand for wood-based products, have resulted in significant import growth in

recent years. Growing demand for raw materials, particularly for tropical logs, increasing

transportation costs and freight charges, and global supply shortages have contributed to

increased prices for hardwood logs, lumber, and veneer.

China’s hardwood log imports increased by 65 percent to 13.3 million m3

 from 2002 to

2007. Russia is the largest hardwood log supplier to China, accounting for almost one third

of China’s hardwood log imports in 2007, up from 12 percent in 2002 (table 4.1). Common

species from Russia used in the production of hardwood plywood and wood flooring include

birch (Betula spp.) and larch (Larix spp.), which is a softwood often used as core material.36
4-6

TABLE 4.1 China’s total hardwood log imports, 2002–07

Change CAGR

Country 2002 2003 2004 2005 2006 2007 2002–07 2002–07

Quantity (thousand cubic meters) %

United States 61 75 118 155 179 225 269.6 29.9

Top 5 suppliers:

Russia 961 1,784 2,201 2,898 3,681 4,326 350.1 35.1

Papua New 

Guinea 1,128 1,378 1,314 1,835 2,064 2,341 107.5 15.7

Malaysia 2,121 2,924 2,721 1,856 1,412 1,331 -37.2 -8.9

Gabon 1,087 940 633 802 958 1,150 5.8 1.1

Solomon 

Islands 163 283 450 650 775 1,049 544.8 45.2

All others 2,522 2,708 2,627 2,657 3,041 2,867 13.7 2.6

Total 8,043 10,091 10,063 10,852 12,110 13,289 65.2 10.6

Value in thousand $

United States 27,751 40,753 65,802 91,011 108,547

 128,504

363.1 35.9

Top 5 suppliers:

Russia 106,020 190,748 255,465 345,627 413,938 559,853 428.1 39.5

Papua New 

Guinea 123,214 154,873 169,353 270,514 345,246 414,744 236.6 27.5

Malaysia 243,035 395,422 416,997 268,405 226,852 249,027 2.5 0.5

Gabon 184,808 205,745 165,901 228,566 291,346 395,576 114.0 16.4

Solomon 

Islands 18,173 32,546 57,891 96,071 124,716 181,900 900.9 58.5

All others 347,675 422,632 461,518 510,770 650,440 918,724 164.2 21.5

Total 1,050,676 1,442,719 1,592,927 1,810,964 2,161,086 2,848,328 171.1 22.1

$ per cubic meter

United States 455 541 557 588 606 570 25.3 4.6

Top 5 suppliers:

Russia 110 107 116 119 112 129 17.3 3.2

Papua New 

Guinea 109 112 129 147 167 177 62.2 10.2

Malaysia 115 135 153 145 161 187 63.3 10.3

Gabon 170 219 262 285 304 344 102.4 15.1

Solomon 

Islands 112 115 129 148 161 173 55.2 9.2

All others 138 156 176 192 214 320 132.4 18.4

Total 131 143 158 167 178 214 64.1 10.4

Source: GTIS, Global Trade Atlas Database (accessed March 12, 2008).

Note: Includes HS subheadings 4403.91, 4403.49, 4403.91, and 4403.99.

Factors that have contributed to increased Russia-China trade include the following: (1)

increased harvesting of Siberian timber; (2) Russia’s relatively easy overland access to China

through border gateway towns such as Manzhouli (Inner Mongolia) and Suifenhe

(Heilongjiang); (3) Chinese government investment in transportation infrastructure; (4)

Chinese encouragement of border trade by reducing import-related taxes and duties; and (5)
 37 Weiming, et al., Russian Logs in China, 2007, 1; and USITC, Staff Paper: The Effects of Increasing

Chinese Demand on Global Commodity Markets, 2006, 4-22.

 38 TFT, China Wood Products Supply Chain Analysis, March 2007, 7.

 39 For further discussion on China’s import shift from intermediate products to primary raw materials in

forest products trade, see USITC, Staff Report: The Effects of Increasing Chinese Demand on Global

Commodity Markets, 2006, 4-1; and Canby, et al., Forest Products Trade Between China and Africa,

February 2008, 10.

 40 AFX News, “Carlyle to Invest 27.5 mln,” May 11, 2006. A&W (Shanghai) Wood Co. Ltd., a solid and

engineered flooring producer, acquired a natural forest tract in Brazil to secure long-term timber resources,

becoming the first Chinese company to do so in a foreign country.

4-7

favorable Chinese re-export policies for processed logs.37 Although Chinese hardwood log

imports from the United States increased by 270 percent to 225,000 m3

 during the 2002–07

period, U.S. hardwood logs, including species such as oak and cherry, never accounted for

more than 1.7 percent of China’s total hardwood log imports.

Most of China's tropical log imports come from Southeast Asia and West Africa, and include

species such as meranti (Shorea spp.), bintangor (Calophyllum spp.), and red canarium

(Canarium schweinfurthii) from Southeast Asia, as well as okoumé (Aucoumea klaineana)

from West Africa.38 Nine countries—Malaysia, Burma, Papua New Guinea, Indonesia,

Gabon, Equatorial Guinea, Congo, Cameroon, and the Central African Republic—accounted

for almost 98 percent of China’s tropical log imports during the 2002–07 period. Although

harvest restrictions, declining log availability, log export bans (particularly from Indonesia)

to support domestic wood processing, and environmental pressures associated with

deforestation and illegal logging have impacted tropical log supplies from many of China’s

principal suppliers, Chinese imports from Southeast Asia and West Africa nevertheless

increased overall. In Africa, declining tropical log supplies from Gabon were offset by

increased supplies from Equatorial Guinea and Congo. Likewise in Southeast Asia, declining

tropical log shipments from Indonesia were offset by increased shipments from Burma and

Papua New Guinea.

Although hardwood log imports increased from 2002 to 2007, Chinese hardwood lumber and

veneer imports decreased, reflecting in part a shift from imports of intermediate products to

primary raw materials.39 Despite declining lumber and veneer import volumes, import values

increased during the period because of rising prices in dollar terms. Overall imports of

lumber declined by 12 percent to 3.7 million m3

 during the period, led by substantially

falling lumber shipments from Indonesia and, to a lesser extent, Malaysia (table 4.2).

Increasing import volumes from the United States and Brazil helped to partially offset the

declining import volumes from Malaysia and Indonesia. Reportedly, over one-half of

Brazil’s lumber exports to China are destined for wood flooring producer A&W (Shanghai)

Wood Co. Ltd., a Chinese solid and engineered wood flooring producer that acquired natural

forest resources in Brazil amid a global supply shortfall in 2004.40
4-8

TABLE 4.2 China imports of lumber, 2002–07

Country 2002 2003 2004 2005 2006 2007

Change

2002–07

CAGR

2002–07

Thousand metric tons %

Top 5 suppliers:

United States 592 620 716 801 952 997 68.4 11.0

Thailand 591 671 835 762 706 694 17.5 3.3

Malaysia 474 436 429 474 376 310 -34.6 -8.2

Burma 183 191 200 276 175 259 41.7 7.2

Brazil 132 200 291 267 323 258 95.7 14.4

All other 2,232 1,977 1,820 1,502 1,419 1,176 -47.3 -12.0

Total 4,203 4,133 4,291 4,082 3,952 3,695 -12.1 -2.5

Value in thousand $

Top 5 suppliers:

United States 165,559 180,640 210,113 257,242 330,338 350,875 111.9 16.2

Thailand 111,743 135,233 175,991 172,505 179,104 196,816 76.1 12.0

Malaysia 98,998 87,864 7,332 106,845 100,215 82,193 -17.0 -3.7

Burma 37,917 34,967 36,082 60,869 36,498 46,638 23.0 4.2

Brazil 63,231 105,839 144,584 160,812 199,264 167,591 165.0 21.5

All other 510,232 435,142 439,585 428,670 459,760 406,168 -20.4 -4.5

Total 987,680 979,685 1,093,687 1,186,942 1,305,178 1,250,281 26.6 4.8

$ per cubic meter

Top 5 suppliers:

United States 280 291 293 321 347 352 25.9 4.7

Thailand 189 201 211 226 254 284 49.8 8.4

Malaysia 209 201 204 225 267 265 27.0 4.9

Burma 207 183 180 221 209 180 -13.2 -2.8

Brazil 480 443 497 602 616 650 35.4 6.3

All others 229 220 241 285 324 345 51.0 8.6

Total 235 237 255 291 330 338 44.0 7.6

Source: GTIS, Global Trade Atlas Database (accessed March 12, 2008).

Note: Includes subheadings 4407.21, 4407.22, 4407.25, 4407.26, 4407.27, 4407.28, 4407.29, 4407.91, 4407.92,

4407.93, 4407.94, 4407.95, and 4407.99.
 41 On July 29, 2008, the President signed legislation that requires the Secretary of State, in consultation

with the Secretary of Commerce and other appropriate Federal officials, to submit to Congress, within a year

of enactment, a report on Burma's timber trade. The reporting requirement is set out in section 12 of the

Burma Democracy Promotion Act of 2007 (Public Law 110-286). The report is to include information

relating to U.S. imports made from wood from Burma, statistics about Burma's timber trade, and information

about the chains of custody of wood products from Burma; illegalities, abuses, or corruption in the Burmese

timber sector; and a description of the consumer and commercial applications unique to Burmese hardwoods. 

The report must also include recommendations regarding the following: (1) alternatives to Burmese

hardwoods for commercial applications; (2) strategies for encouraging sustainable management of timber in

locations that compete with Burmese hardwoods; (3) the U.S. and international customs documents and

declarations that would need to be kept and compiled to establish the chain of custody for products made

from Burmese woods; and (4) strategies for strengthening the capacity of Burmese civil society to monitor

and report on trade in timber and other extractive industries.

 42 USDA, FAS, Chinese Wood Usage Continues Rapid Growth, July 11, 2007, 4.

 43 Does not include the logging quota for bamboo. Any unused portion of the logging quota for plantation

timber may be carried over to the following year. Ibid.

 44 Ibid.

 45 International Wood Markets Group, “Chinese Domestic Timber Harvest is Growing,” November 2007.

 46 International Wood Markets Group, “China’s ‘City of Plywood’,” November 2007.

 47 The remainder of China’s plantations include protective forests (i.e., to mitigate soil erosion), economic

or agricultural plantations such as orchards, fuelwood, and other forest cover. International Wood Markets

Group, “Chinese Domestic Timber Harvest is Growing,” November 2007; and International Wood Markets

Group, The China Book, part 1, 2006, 20–21. The State Forest Administration (SFA) of China releases a

National Forest Resource Report every five years. The Sixth National Forest Resource Report, covering

1999–2003, was released in 2005. One hectare equals approximately 2.5 acres.

4-9

Chinese veneer imports declined by 38 percent to 94,300 metric tons from 2002 to 2007,

although the value of veneer imports increased, resulting in a 148 percent increase in average

unit values during the period (table 4.3). Imports from China’s largest import

suppliers—Malaysia, the United States, and Indonesia—all declined, and were only slightly

offset by increased veneer imports from Burma.41

Development of Domestic Plantation Resources

In recent years, the Chinese government has emphasized the development of plantation

resources as an alternative to domestic natural forest resources and as a way to reduce the

reliance of China’s wood processing industries on imports of raw materials. Plantation

timber, particularly FGHY species such as poplar, have increasingly replaced natural forests

as the major domestic wood resource in China.42 Under China’s 11th five-year plan

(2006–2010), plantation timber is intended to account for 63 percent of China’s 248 million

m3

 logging quota.43 In contrast, under China’s 10th five-year plan (2001–05), plantation

timber accounted for 38 percent of China’s previous 223 million m3

 logging quota.44

Following the implementation of the NFPP in 1998, Chinese domestic industrial roundwood

production declined while log and lumber imports increased rapidly. Industrial roundwood

production declined through 2002 but began to increase beginning in 2003, reaching 66.1

million m3

 in 2006.45 The development and growth of plantations in China has been a leading

factor behind the growth in domestic industrial timber harvests in recent years.46

China reportedly had approximately 53 million hectares (131 million acres) of plantation

resources in 2003, although only about 43 percent (23 million hectares or 57 million acres)

were allocated for commercial timber production.47 A key segment of China’s commercial

plantation resources are FGHY plantations. Estimates of the area of China’s FGHY 
4-10

TABLE 4.3 China veneer imports, 2002–07.

Country 2002 2003 2004 2005 2006 2007

Change

2002–07

CAGR

2002–07

Quantity (thousand cubic meters) %

Top 5 suppliers:

Malaysia 54 57 32 35 22 23 -58.0 -15.9

United States 17 17 20 18 16 16 -7.3 -1.5

Burma 0 1 1 1 2 11 4,219.5 112.4

Indonesia 9 24 24 17 21 7 -25.8 -5.8

Vietnam 2 4 3 3 6 6 175.3 22.5

All others 71 38 32 36 31 32 -55.1 -14.8

Total 153 141 112 111 98 94 -38.3 -9.2

Value in thousand $

Top 5 suppliers:

Malaysia 15,419 15,971 10,523 13,750 8,976 10,024 -35.0 -8.3

United States 17,859 23,916 34,625 36,428 37,108 37,326 109.0 15.9

Burma 189 1,514 817 345 1,036 3,560 1,786.2 79.9

Indonesia 2,346 7,302 6,629 4,227 5,881 2,485 5.9 1.2

Vietnam 1,287 1,844 1,848 1,892 3,403 2,569 99.6 14.8

All others 36,862 34,799 47,651 56,717 54,558 57,204 55.2 9.2

Total 73,962 85,345 102,094 113,360 110,962 113,168 53.0 8.9

$ per metric ton

Top 5 suppliers:

Malaysia 286 279 331 388 401 442 54.6 9.1

United States 1061 1404 1693 2033 2374 2392 125.4 17.7

Burma 710 1396 756 361 587 310 -56.3 -15.3

Indonesia 266 309 272 246 283 380 42.7 7.4

Vietnam 570 442 649 663 555 413 -27.5 -6.2

All others 520 926 1492 1559 1746 1798 245.5 28.1

Total 483 607 908 1024 1133 1199 148.1 19.9

Source: GTIS, Global Trade Atlas Database (accessed March 12, 2008).

Note: Includes HS subheadings 4408.31, 4408.39, and 4408.90.
 48 International Wood Markets Group, The China Book, part 1, 2006, 27.

 49 Other hardwood species planted in China’s FGHY plantations include eucalyptus (Eucalyptus spp.) and

aspen (Populus spp.). Softwood species planted in China’s FGHY plantations include paulownia (Paulownia

tomentosa), spruce (Picea spp.), cryptomeria (Cryptomeria japonica), larch (Larix spp.), Korean pine (Pinus

koraiensis), and masson pine (Pinus massoniana). International Wood Markets Group, The China Book, part

1, 2006, 27. Different data sources report different numbers. For example, ITTO reports that China’s total

poplar plantation area is 7 million hectares (17.3 million acres), 44 percent (3.1 million hectares or 7.7

million acres) of which is intended for timber production. ITTO, Tropical Timber Market Report, March

16–31, 2007, 10.

 50 International Wood Markets Group, The China Book, part 1, 2006, 29.

 51 Chinese industry official, interview by Commission staff, China, February 20, 2008; and International

Wood Markets Group, The China Book, part 1, 2006, 26–27.

 52 International Wood Markets Group, The China Book, part 1, 2006, 29.

 53 Ibid.

 54 USDA, FAS, China Solid Wood Products Annual 2005, July 15, 2005, 5.

 55 International Wood Markets Group, The China Book, part 1, 2006, 32. In 2006, $8.2 million (RMB 65.3

million) was invested in China’s FGHY forests. Foreign investment and private domestic investment each

accounted for about 40 percent of funds establishing FGHY plantations that year. Government funds

accounted for 8 percent. State Forestry Administration of China, China Forestry Statistical Yearbook 2006,

September 2007, 118. Incentives to encourage foreign and private investment in plantations may include

extended land-use rights, low-interest loans, subsidized interest payments, exempted income taxes, and

reduced administrative fees. See Stewart, “China’s Support Programs for Selected Industries,” June 2007,

various pages; and American Forest and Paper Association, China’s Subsidization of its Forest Products

Industry, July 2004, various pages.

 56 USDA, FAS, China Solid Wood Products Annual 2005, July 15, 2005, 5.

 57 Weiming, et al., Russian Logs in China, 2007, 1.

4-11

plantations range from 3.3–4.7 million hectares (8.2–11.6 million acres), or 14–20 percent

of all plantations intended for commercial timber production.48 Up to 60 percent of FGHY

plantation forests consist of poplar, Masson pine (Pinus massoniana), and Chinese fir

(Cunninghamia lanceolata).49 An estimated 43 percent (1.6 million hectares or 4 million

acres) of FGHY plantations is intended for the production of wood-based panels, including

poplar logs for plywood and engineered flooring, while 35 percent (1.3 million hectares or

3.2 million acres) is intended for pulp and paper production.50 Eucalyptus is another FGHY

plantation species used as core material for hardwood plywood and engineered wood

flooring, and is also used in China’s paper and medium-density fiberboard (MDF)

industries.51 Of the 56,800 hectares (140,350 acres) of FGHY plantations planted in 2004,

it is anticipated that 32 percent will be used for wood-based panels.52

As part of its plantation development strategy, China anticipates the establishment of 9.3

million hectares (23 million acres) of FGHY plantations by 2010, yielding a harvest of 97

million m3

, 13 percent of which would be used as raw material for wood-based panel

producers.53 Further, China 's target of 13 million hectares (32 million acres) of FGHY

plantation forests by 2015 would provide 133 million m3

 of timber.54 The estimated

investment required to establish these FGHY plantations is $9 billion, and reportedly these

funds are expected to come from nongovernmental sources, including domestic and foreign

direct investment.55

However, some industry observers question China’s ability to meet this goal. China will

need to plant approximately 1 million hectares (2.5 million acres) per year of FGHY

plantations from 2002 to 2015 to meet its target of 13 million hectares; however, from 2002

to 2004, China planted less than 100,000 hectares (250,000 acres) annually.56 Moreover,

China’s average plantation yield is 35 m3

 per hectare compared with a world average of 100

m3

 per hectare, calling into question China’s ability to bridge the gap between domestic

production and total timber demand, which is forecast to reach 150 million m3

 by 2010.57
 58 USDA, FAS, China Solid Wood Products Annual 2005, July 15, 2005, 5; and International Wood

Markets Group, The China Book, part 1, 2006, 32.

 59 International Wood Markets Group, The China Book, part 2, 2006, 74. However, a portion of the

reported production increase may also be attributable, in part, to a change in survey methodology to capture a

greater share of production from small mills.

 60 International Wood Markets Group, The China Book, part 3, 2006, 31.

4-12

Additional challenges include availability of suitable land and competing land uses,

ecological concerns related to monoculture plantations, expected future increases in domestic

consumption of paper products, and funding constraints.58

Production, Trade, and Consumption

China’s hardwood plywood and wood flooring industries have grown significantly in recent

years, principally in response to increasing domestic demand fueled by China’s rapid

economic growth, including robust residential construction-related activity and real estate

development. However, production increasingly exceeded domestic consumption from 2002

to 2006 and, as a result, exports accounted for an increasing share of domestic production.

Exports of hardwood plywood and wood flooring increased dramatically during the period

as foreign market demand for these products increased, particularly in the United States. As

a result of the expansion of China’s hardwood plywood and wood flooring industries,

imports of these products have declined.

Hardwood Plywood

Hardwood plywood is estimated to account for approximately 85 percent of China’s total

plywood production, which also includes certain softwood plywood. From 2002 to 2006,

Chinese production of hardwood plywood more than doubled to an estimated 23.3 million

m3

, largely driven by growth in domestic real estate development and home remodeling

(table 4.4). Production growth was particularly pronounced from 2002 to 2003, when

increasing demand, coupled with low barriers to entry in the plywood industry, led to the

establishment of thousands of new mills.59

From 2002 to 2006, Chinese domestic hardwood plywood consumption doubled to an

estimated 17.7 million m3

. Production outpaced consumption during the period. As a result,

exports increased from 13 percent of production in 2002 to 25 percent in 2006. In contrast,

imports declined by 14 percent during the period, as domestic production increasingly

displaced imports. Import penetration declined over the period, and never accounted for

more than 3.6 percent of domestic consumption.

An estimated 80 percent of hardwood plywood is consumed in the construction sector,

interior decoration, and furniture applications.60 Hardwood plywood sold into the Chinese
 61 Industry official, interview by Commission staff, China, February 20, 2008.

 62 Rutton and Hock, “Reviving Tropical Plywood,” May 2004, 23; and industry official, interview by

Commission staff, China, February 20, 2008.

 63 Industry official, interview by Commission staff, China, February 20, 2008.

 64 Industry official, interview by Commission staff, Portland, OR, August 13, 2007.

4-13

TABLE 4.4 China’s hardwood plywood: Production, trade, and consumption, 2002–06

Item 2002 2003 2004 2005 2006

Change

2002–06

CAGR

2002–06

1,000 cubic meters %

Productiona 9,720 17,990 17,960 21,530 23,360 140.3 24.5

Imports 317 438 486 379 272 -14.2 -3.8

Exports 1,214 1,424 2,843 3,926 5,883 384.6 48.4

Domestic apparent 

consumption 8,823 17,004 15,603 17,983 17,749 101.2 19.1

% of units

Import penetration 3.6 2.6 3.1 2.1 1.5 NA NA

Exports to production 12.5 7.9 15.8 18.2 25.2 NA NA

Source: Production figures from ITTO, Annual Review and Assessment of the World Timber Situation 2006, app. 1,

July 2006, table T1-1; State Forestry Administration of China revised production data; and International Wood

Markets Group, The China Book, part 2, 2006, 250. Trade data from GTIS, Global Trade Atlas Database (accessed

March 17, 2008).

Note: Hardwood plywood trade data include the following 2006 6-digit HS subheadings and their subclassifications:

4412.13, 4412.14, 4412.22, 4412.23, and 4412.29. To the extent possible, export volumes were adjusted to reflect

reporting countries’ import volumes of hardwood plywood from China. However, because engineered wood flooring is

classified in the same HS subheadings as hardwood plywood, exports are likely overstated and therefore domestic

apparent consumption is likely understated.

 a

Based on staff estimates. Chinese hardwood plywood production figures as reported by ITTO were revised to

take into account revised poplar plywood production figures as reported by the State Forestry Administration of

China. Hardwood plywood is estimated to account for approximately 85 percent of China’s total annual plywood

production based on softwood plywood production figures for 2005 as reported in International Wood Markets Group,

The China Book, part 2, 2006, 250.

domestic market reportedly tends to be used to make furniture, which is often exported to

developed country markets, including the United States.61 Common thicknesses of plywood

produced in China range from 2.6 to 3.0 mm (approximately one-tenth of an inch) for thin

panels to 18 mm for thicker panels.62 According to one Chinese producer, common

thicknesses of face veneers for plywood produced for export markets are 0.5–0.6 mm,63

although other plywood producers reportedly use much thinner face and back veneers than

this. A common thickness for a face veneer produced in China is 0.15 mm, whereas in

Indonesia it is typically twice as thick.64

Chinese hardwood plywood exports to major markets increased significantly from 2002 to

2006. Hardwood plywood export volumes from China increased by about 385 percent to an

estimated 5.9 million m3

, while export values reached $1.9 billion, a 480 percent increase

from 2002 (table 4.5). However, since engineered wood flooring is classified in the same HS
4-14

TABLE 4.5 China hardwood plywood exports, 2002–06

Country 2002 2003 2004 2005 2006

Change

2002–06

CAGR

2002–06

Quantity (thousand cubic meters) %

Top 5 export markets:

United Statesa 285 443 1,281 1,689 2,326 716.2 69.0

EU-27 159 164 340 821 910 473.4 54.7

Japan 275 287 344 407 630 128.8 23.0

Canada 16 16 60 85 413 2,546.4 126.8

Singapore 42 61 109 114 283 574.5 61.2

All other 438 454 710 810 1,321 202.0 31.8

Total 1,214 1,424 2,843 3,926 5,883 384.6 48.4

Value in thousand $

Top 5 export markets:

United States 99,802 156,439 415,872 600,003 967,936 869.9 76.5

EU-27 30,155 58,596 131,755 226,189 343,120 1,037.9 83.7

Japan 85,975 95,484 122,045 138,938 211,122 145.6 25.2

Canada 5,078 5,465 18,215 22,771 32,941 548.7 59.6

Singapore 11,401 15,924 25,874 26,098 39,427 245.8 36.4

All other 95,186 99,369 169,596 217,741 304,329 219.7 33.7

Total 327,597 431,277 883,358 1,231,741 1,898,876 479.6 55.2

$ per cubic meter

Top 5 export markets:

United States 350 353 325 355 416 18.8 4.4

EU-27 190 357 388 276 377 98.4 18.7

Japan 312 333 355 341 335 7.3 1.8

Canada 326 352 305 266 80 -75.5 -29.6

Singapore 271 262 238 228 139 -48.7 -15.4

All other 218 219 239 269 230 5.9 1.4

Total 270 303 311 314 323 19.6 4.6

Source: GTIS, Global Trade Atlas Database (accessed March 17, 2008).

Note: Includes the following HS 6-digit subheadings and their subclassifications: 4412.13, 4412.14, 4412.22,

4412.23, and 4412.29. These subheadings also include engineered wood flooring; therefore plywood export figures

are likely overstated. To the extent possible, exports were adjusted to reflect only importing countries’ hardwood

plywood imports from China.

 a

Includes Puerto Rico.

subheadings as hardwood plywood and because China exports significant volumes of

engineered wood flooring, hardwood plywood export figures are likely overstated.

Hardwood plywood exports to the United States, China’s largest export market, increased

eight-fold during the period, driven largely by growth in the U.S. housing market.
 65 TFT, China Wood Products Supply Chain Analysis, March 2007, 9.

 66 Industry official, e-mail message to Commission staff, November 7, 2007.

 67 Industry official, e-mail message to Commission staff, April 4, 2008. Other sources estimate bamboo

flooring production to be much lower; for example, the China Timber Distribution Association reports 2006

bamboo flooring production closer to 8 million m2

. Industry official, e-mail message to Commission staff,

January 24, 2008.

 68 International Wood Markets Group, The China Book, part 2, 2006, 157.

 69 Wood flooring was second to ceramic tile as the most popular type of floor covering in China in 2005.

Ceramic tiles are reportedly still preferred in commercial establishments because they are easier to clean.

Industry official, interview by Commission staff, China, February 17, 2008; and Catalina Research Inc.,

Wood Flooring, November 2005, 173.

 70 Reliable domestic consumption figures are difficult to obtain because various sources report different

production and trade figures, resulting in inconsistent data.

 71 Industry official, e-mail message to Commission staff, September 6, 2007; and industry official,

interview by Commission staff, China, February 17, 2008.

4-15

Wood Flooring

From 2002 to 2007, China’s total wood flooring production increased by 64 percent to 139

million m2

, or at an annual rate of 10 percent (table 4.6). Engineered wood flooring

production more than quadrupled to 75 million m2

. In contrast, solid wood flooring

production decreased by 32 percent to 44 million m2

. Increasing raw material supply

shortages and high prices for tropical species used in the solid wood flooring industry have

resulted in a gradual decline in production, both absolute and relative to engineered wood

flooring.65 The growth in consumption of engineered wood flooring is attributable, in part,

to its price advantage over solid wood flooring and, in part, to its stability once installed.66

As a result, engineered wood flooring output overtook solid wood flooring output in China

in 2006. China’s bamboo flooring output grew at an average annual rate of 38 percent during

the 2002–07 period to 20 million m2

, although these production figures include engineered

wood flooring consisting of a bamboo face and solid wood core and are likely overstated.67

Total wood flooring production capacity in China greatly exceeds production, resulting in

significant excess capacity. From 2000 to 2004—the most recent year for which data are

available—total wood flooring production capacity (excluding laminated flooring capacity)

increased by 285 percent to 270 million m2

 as compared with production of 108 million m2,

corresponding to an estimated total wood flooring capacity utilization rate of 40 percent.

Solid wood flooring accounted for 200 million m2

 of capacity (35 percent capacity utilization

rate in 2004), engineered wood flooring for 60 million m2

 (55 percent), and bamboo flooring

for 10 million m2

 (50 percent).68

China is the world’s largest wood flooring market. Wood flooring is widely used in housing

developments, and is reportedly regarded by many Chinese consumers to be more

aesthetically pleasing than ceramic tile or carpet.69 China’s domestic consumption of wood

flooring (solid, engineered, and bamboo) was estimated to be approximately 120 million m2

in 2006,70 up by almost 40 percent since 2002, with the majority of domestic market demand

growth occurring in engineered wood flooring, which grew at an estimated annual rate of 44

percent from 2002 to 2006.71 Although estimates vary, solid wood flooring is generally

believed to have accounted for 42–48 percent (50–58 million m2

) of domestic consumption
 72 Industry official, e-mail message to Commission staff, September 6, 2007; and industry official,

interview by Commission staff, China, February 17, 2008.

 73 Industry official, interview by Commission staff, China, February 17, 2008.

 74 As noted earlier, export volumes are difficult to assess because engineered wood flooring is classified

with plywood, and solid hardwood flooring is classified with other products. Moreover, although China

created 8-digit breakouts in HS 4409.20 in 2005 to delineate between solid hardwood flooring, bamboo

flooring, and other continuously shaped wood products, Chinese export figures vary widely from, and are

often lower than, market countries’ reported imports. In addition, market countries’ import volumes are

reported in various units of measure, making meaningful comparison difficult.

 75 GTIS, Global Trade Atlas Database (accessed March 19, 2008).

4-16

TABLE 4.6 China wood flooring production, 2002–07

2002 2003 2004 2005 2006 2007

Change

2002–07

CAGR

2002–0

7

Million square meters %

Solid 65 70 70 50 45 44 -32.3 -7.5

Engineered 16 22 33 46 60 75 368.8 36.2

Bamboo 4 4 5 6 25 20 400.0 38.0

Total 85 96 108 102 130 139 63.5 10.3

Million square feet

Solid 700 753 753 538 484 474 -32.3 -7.5

Engineered 172 237 355 495 646 807 368.8 36.2

Bamboo 43 43 54 65 269 215 400.0 38.0

Total 915 1,033 1,163 1,098 1,399 1,496 63.5 10.3

Source: China National Forest Products Industry Association.

Note: 1 square meter equals approximately 10.76 square feet.

in 2006, while engineered flooring and bamboo flooring combined accounted for 53–58

percent (63–70 million m2

).72 While megacities such as Beijing and Shanghai account for the

largest share of the solid wood flooring market, real estate development is reportedly

accelerating in mid-sized Chinese cities while slowing in larger ones.73

The estimated value of China’s solid wood flooring exports increased by 319 percent to $1.1

billion from 2002 to 2006.74 75 Over 80 percent of China’s solid wood flooring exports were

concentrated in three markets in 2006—the EU, the United States, and Canada—in 2006, up

from 55 percent in 2002. From 2002 to 2006, an increasing percentage of China’s exports

of solid wood flooring to Japan were diverted to the EU and Canadian markets. As a result,

the EU accounted for 42 percent ($480 million) of Chinese exports in 2006, while Canada

accounted for 13 percent ($148 million). China’s solid wood flooring exports to the United

States increased by almost 340 percent to $299 million, or at an annual rate of close to 45

percent (table 4.7). The United States consistently accounted for approximately one-quarter

to one-third of China’s solid wood flooring exports during the period.
 76 International Wood Markets Group, The China Book, part 2, 2006, 72–74.

 77 Ibid., 79.

 78 Industry official, interview by Commission staff, China, February 18, 2008.

 79 Industry official, interview by Commission staff, China, February 18, 2008.

4-17

TABLE 4.7 China solid wood flooring exports, 2002–06

2002 2003 2004 2005 2006

 Change

2002–06

CAGR

2002–06

Thousand $ %

Top export 

markets:

EU-27 76,114 110,878 212,136 313,582 480,417 531.2 58.5

United States 68,202 112,258 217,952 289,047 299,346 338.9 44.7

Canada 6,650 25,845 75,410 132,436 147,647 2,120.2 117.1

Japan 74,427 90,521 96,704 98,998 107,430 44.3 9.6

Hong Kong 22,877 23,341 23,818 21,763 17,094 -25.3 -7.0

Australia 2,001 4,457 10,431 12,663 15,641 681.8 67.2

Korea 9,934 9,555 10,299 12,742 11,670 17.5 4.1

Ukraine 70 139 822 3,465 7,251 10,326.9 219.6

Mexico 1,850 3,775 6,968 6,806 5,865 217.0 33.4

Malaysia 249 733 1,698 2,811 5,185 1,979.7 113.6

All others 9,985 11,391 18,724 29,578 43,271 333.4 44.3

Total 272,359 392,893 675,963 923,891 1,140,817 318.9 43.1

Source: GTIS, Global Trade Atlas Database (accessed March 19, 2008).

Note: Data reported at the HS 2006 6-digit level for HS subheading 4409.20 (nonconiferous wood continuously

shaped along any of its edges) and 4418.30 (parquet panels). Exports represent reporting countries’ import

statistics, and also include other hardwood products classified under HS subheading 4409.20, such as moldings.

Capital Costs and Investment

While specific figures are unavailable, capital costs in the hardwood plywood and wood

flooring industries in China can vary widely from small-scale cottage mills to larger exportoriented mills. Capital costs are reportedly low for small-scale plywood and flooring

producers, and as a result, barriers to entry into the industry are low.76 Larger export-oriented

mills, including the top 20 domestic plywood mills, tend to be either joint ventures with

foreign firms or domestically owned private companies.77 Investment by these firms,

including investment in advanced foreign manufacturing technology, is more substantial.

Some larger Chinese plywood and wood flooring producers are increasingly considering

investment opportunities in both domestic and overseas plantations to secure raw materials.

One Chinese flooring producer has plans to invest in poplar and eucalyptus plantations in

China and elsewhere in Asia.78 In addition, the plywood and wood flooring industries in

China are consolidating, with larger firms acquiring smaller ones.79
 80 USITC hearing transcript, October 3, 2007, 228–29 and 231–32.

 81 A higher recovery rate implies a lower yield loss, which reduces raw material conversion costs. In

comparison to China, raw material recovery rates in other plywood-producing countries are reportedly lower,

ranging from 45–55 percent. However, one U.S. plywood producer is able to attain log utilization rates of

55–60 percent by utilizing computer systems that analyze the shape of a log and its position in the lathe in

order to optimize yields. International Wood Markets Group, The China Book, part 2, 2006, 71 and 92; and

industry officials, interviews by Commission staff, China, February 17–25, 2008, and the United States, July

17, 2007.

 82 Industry officials, interviews by Commission staff, China, February 18–19, 2008.

 83 Rutton and Hock, “Reviving Tropical Plywood,” May 2004, 27.

4-18

Production Costs

Hardwood plywood and wood flooring production processes in China generally include a

relatively high labor content, particularly for the small mills that constitute the vast majority

of Chinese producers. Although Chinese producers have relatively high raw materials costs

(particularly for imported logs), low wage rates help to reduce overall wood processing costs

by allowing producers to hire workers to perform certain tasks manually that would not be

as cost effective at higher wage rates.80 Such manual tasks may include hand scraping,

repairing core defects in flooring to eliminate voids in tongues and grooves, and stitching

together broken veneer pieces to produce veneer sheets to be pressed for both plywood and

flooring cores. By performing certain tasks manually, raw material waste is reduced, and

higher raw material recovery rates can be achieved, reportedly ranging from 50–70 percent,

or higher.81 As a result, raw material conversion costs and ultimately, operating costs, are

reduced. The ability to utilize relatively inexpensive labor has been cited by Chinese

producers as a significant competitive advantage.82

Additionally, by using veneer produced from domestic plantation logs as core material and

importing the species used for the thinner face and back veneers, plywood and engineered

flooring mills are able to reduce raw material costs on a per unit basis. In contrast, escalating

raw material costs have reportedly negatively affected the solid wood flooring industry,

which relies heavily on imported tropical logs and lumber. Although manufacturing costs

vary greatly across a broad range of hardwood plywood and wood flooring products because

of differences in dimension, species, grade, and technology utilized, general estimates of

manufacturing costs for hardwood plywood and engineered and solid wood flooring

producers in China are provided in table 4.8.

Raw Material Costs

Various tropical and temperate hardwood species are used to produce hardwood plywood

and wood flooring. With respect to plywood and engineered wood flooring, various tropical

and temperate species are used to produce face and back veneers, whereas less expensive

domestic plantation poplar is used as core veneer. Domestic plantation poplar logs may cost

only a quarter of the cost of tropical logs,83 depending on the species. 
 84 Endesa-Botrosa, “Structural Changes in the Tropical Plywood Industry,” September 26, 2005, citing

RWS Engineering Oy; and industry officials, interviews with Commission staff, Lancaster, PA, December

18, 2007, and China, February 16–25, 2008.

 85 Industry official, e-mail message to Commission staff, November 16, 2007.

 86 Industry officials, interview by Commission staff, China, February 16–25, 2008; and International

Wood Markets Group, The China Book, part 2, 2006, 175–76.

 87 International Wood Markets Group, The China Book, part 2, 2006, 157.

 88 Ibid., 157.

 89 Wu, “Why China Plywood Competitive {sic},” September 26, 2005.

4-19

TABLE 4.8 Examples of manufacturing costs for hardwood plywood and wood flooring producers in China

Hardwood plywood Engineered flooring Solid wood flooring

% of total manufacturing costs

Raw material 60–67 73–75 77–80

Labor 10–13 6–9 5–8

Othera 20–30 18–19 14–16

$

per cu. meter per sq. meter per sq. foot per sq. meter per sq. foot

Raw material 215–360 12 1.12 15.50 1.44

Labor 40–60 1.00–1.50 .09–.14 1.00–1.50 .09–.14

Other 65–180 3.00 .28 3.00 .28

Total 320–600 16.00–16.50 1.49–1.54 19.50–20.00 1.81–1.86

Source: Hardwood plywood and wood flooring industry officials, interviews by Commission staff, China, February

18–25, 2008.

Note: One square meter equals approximately 10.76 square feet.

 aOther costs may include energy costs, tenant fees, water, and other factory overhead.

For Chinese hardwood plywood, raw material can typically account for 60–70 percent of

operating costs.84 For hardwood plywood made with domestic poplar core veneer and

imported tropical face and back veneers, the cost of imported material can range from 10 to

15 percent,85 or less. As noted earlier, plywood produced in China reportedly has thinner face

veneers. As a result, some Chinese mills may have a cost advantage with respect to the

amount of more expensive tropical face veneer used per unit of output.

With respect to wood flooring, raw material costs typically range from 70 to 80 percent of

operating costs, although raw materials costs may be substantially less for engineered wood

flooring because it may include less expensive domestic poplar or other plantation species

for core material.86 With respect to solid wood flooring, the cost of raw materials has

reportedly increased by 20–40 percent in recent years, depending on the species and grade.87

The declining supply of high-quality logs and lumber from both domestic and foreign

sources has contributed to the rising raw material costs and a decline in cost competitiveness

for Chinese solid wood flooring producers.88

As of 2005, tropical face and back veneers at veneer wholesale markets generally ranged

from $280 to $350 per m3

 depending on the species and quality, whereas tropical cores

ranged from $120 to $220 per m3

.

89 Likewise, the prices of veneer-quality domestic poplar

logs reportedly doubled to $100 per m3

 from 1998 to 2005, increasing further to
 90 International Wood Markets Group, The China Book, part 2, 2006, 82; and International Wood Markets

Group, “Chinese Poplar and Poplar Plywood Update,” November, 2007.

 91 Wu, “Why China Plywood Competitive {sic},” September 26, 2005.

 92 Ibid.

 93 Industry official, interview by Commission staff, China, February 17, 2008.

 94 Industry officials, interviews by Commission staff, China, February 16–25, 2008. For one engineered

flooring producer, labor accounts for up to 25 percent of operating costs.

 95 International Wood Markets Group, The China Book, part 2, 2006, 91; Wu, “Why China Plywood

Competitive {sic},” September 26, 2005; industry official, interview by Commission staff, China, February

21, 2008; and industry official, e-mail message to Commission staff, February 14, 2008.

 96 Industry officials, interview by Commission staff, China, February 17, 2008.

 97 Industry official, interview by Commission staff, Portland, OR, August 15, 2007; and USITC hearing

transcript, October 3, 2007, 66.

 98 Including benefits such as health insurance and retirement benefits, average labor costs could be 50

percent higher. Industry official, interview by Commission staff, Portland, OR, August 15, 2007.

 99 Industry official, interview by Commission staff, China, February 18, 2008.

 100 Ibid.

 101 Ibid.

4-20

approximately $135 per m3 in 2007,90 while smaller diameter plantation logs fetch $40–$80

per m3

.

91 Poplar veneer used as plywood core material ranges from $85 to $115 per m3

,

whereas higher quality poplar veneers can range from $170 to $220 per m3

.

92 Reportedly,

Chinese farmers are increasingly switching land use away from other types of agriculture to

plant poplar plantations in response to rising poplar prices.93

Labor Costs

Labor costs for both hardwood plywood and wood flooring are estimated to typically

account for 5–15 percent of operating costs.94 Average monthly salaries can range from $100

to $150 based on 6 days per week, 10–12 hours per day, although wages may be slightly

higher depending on geographic region, inclusion of additional benefits such as insurance

and pensions, and skill level.95 Wages for Chinese workers are reportedly set to increase by

8–10 percent per year by government mandate, although some Chinese flooring producers

claim that workers’ wages actually increased by 12–15 percent in 2007 alone.96 In contrast,

average labor costs in the United States are over 20 times higher, ranging from $16 to $18

per hour,97 or $2,560–$2,880 per month based on a 40-hour work week.98

Transportation and Other Costs

Several Chinese hardwood plywood and wood flooring producers stated that transportation

costs have increased substantially since 2002. Transportation costs reportedly increased

during the 2002–06 period, due in part to rising fuel and energy costs. However, while costs

for outbound (eastbound) freight from China have reportedly increased by 20–25 percent to

approximately $2,800 per 40-foot container since 2002, costs for inbound (westbound) 

freight to China have reportedly decreased.99 In 2007, transportation costs reportedly

increased by 10–15 percent, due in part to rising fuel costs.100 Inland mills and mills in

northeastern China reportedly have greater transportation costs than those located within the

vicinity of Shanghai or other ports, such as Zhangjiagang and Lianyungang in Jiangsu

province.101 Many solid wood flooring producers in the inland areas have reportedly switched

to engineered wood flooring or laminated flooring because less expensive raw materials for
 102 Ibid.

 103 Ibid. 

 104 International Wood Markets Group, The China Book, part 2, 2006, 249.

 105 Rutton and Hock, “Reviving Tropical Plywood,” May 2004, 26.

 106 Ibid., 24. Annual flooring production in Nanxun is approximately 36 million square meters. Demand

for logs and lumber at Nanxun is approximately 3 million cubic meters per year, 90 percent of which is

imported.

 107 Ibid.

 108 Industry officials, interviews by Commission staff, China, February 18–29, 2008.

 109 Industry official, interview by Commission staff, China, February 18, 2008.

 110 Industry officials, interviews by Commission staff, China, February 18–26, 2008.

 111 Industry official, interview by Commission staff, China, February 20, 2008.

4-21

these products can offset increased transportation costs.102 In early 2008, transportation costs

to the U.S. west coast for one Chinese flooring producer averaged $99 per m3

, or 6–8 percent

of the landed cost of flooring product.103 Other industry analysts estimate freight costs to the

U.S. market to average $60 per m3

.

104

Marketing

The vast majority of China’s plywood and wood flooring production is sold through

domestic wholesale markets. As of 2001, there were reportedly 344 wholesale markets and

651 retail markets, the vast majority of which were informal markets. Most wholesale

markets are privately owned, and consist of a large number of vendors that sell various

building materials, including timber, plywood, and flooring. Major customers include

retailers, construction companies, and other panel producers.105

Nanxun Building Materials Market (Zhejiang province) is the largest plywood distribution

center in China, and prices set in Nanxun are reportedly close to acting as a reference price

for the rest of the country. Nanxun is also the largest production and distribution base for

wood flooring.106 Dongguang Houjie Xingye Timber and Plywood Market is located in a

major furniture production center in Guangdong province and is reportedly the largest

distribution center in southern China. Approximately 60 percent of lumber and plywood sold

in this market is imported. Shanghai Furen Forest Products Wholesale Market sells plywood

and flooring products, with over 50 percent of sales being tropical hardwood products

primarily from Indonesia and Burma.107

Branding in the Chinese domestic market is becoming an increasingly important way to

differentiate products. With respect to wood flooring, there are reportedly five large brands

in the Chinese domestic market.108 Chinese consumers are reportedly particularly responsive

to brands for solid wood flooring, as it generally commands a price premium compared to

laminated and engineered flooring.109 In the Chinese market, larger plywood and flooring

producers may distribute product through their own franchised retail outlets under their own

brand name, or distribute their products through branded retail stores such as B&Q or Home

Depot, either under their own brand name or under the retailer’s brand.110 Larger plywood

and flooring producers may also produce other products to diversify their product mix to

build brand recognition.111

Certain Chinese plywood and wood flooring producers also supply private label products to

foreign producers, including U.S. hardwood plywood producer Columbia Forest Products,
 112 Industry officials, interviews by Commission staff, China, February 18–26, 2008; and USITC hearing

transcript, October 3, 2007, 49–50 and 235.

 113 Ibid.

 114 Ibid.

 115 International Wood Markets Group, The China Book, part 3, 2006, 32.

 116 Rutton and Hock, “Reviving Tropical Plywood,” May 2004, 23.

 117 International Wood Markets Group, The China Book, part 3, 2006, 32.

 118 USDA, FAS, Chinese Wood Usage Continues Rapid Growth, July 11, 2007, 11; TFT, China Wood

Products Supply Chain Analysis, March 2007, 3; and USDA, FAS, China Solid Wood Products Annual 2006,

July 13, 2006, 7.

4-22

as well as U.S. engineered flooring producers Somerset Hardwood Floors and Mohawk

Flooring.112 Chinese producers may sell their plywood and flooring products on a contractual

basis under the brand name of a foreign producer per the foreign producer’s specifications,

as well as under the brand name of foreign retailers.113 According to several Chinese plywood

and wood flooring producers, Home Depot is one of the largest U.S. buyers of Chinese

hardwood plywood and wood flooring.114

Pricing

Prices vary widely for hardwood plywood and wood flooring in the Chinese market (tables

4.9 and 4.10). Domestically produced hardwood plywood using domestic poplar logs as core

material is generally priced lower than imported plywood.115 Prices for tropical hardwood

plywood are generally higher than domestic poplar plywood.116 Additionally, compared to

smaller private mills, plywood produced from larger joint ventures is generally priced higher

as a result of differences in quality and end-use applications.117 In general, Chinese plywood

and wood flooring producers reportedly face intense price competition and low profit

margins, as their products are commodities and, until recently, benefitted from little product

differentiation or branding.118

TABLE 4.9 Listed export prices for various plywood products, February 2008 

Species Dimension (mm) Thickness (mm) Price range ($ per cu. meter)

Poplar (Populus spp.) a

1220 x 2440 3–5 419–558

1220 x 2440 9–15 349–447

1220 x 2440 18 279–391

Chinese fir (Cunninghamia

lanceolata) 500 x 1000 21–27 335–391

Black walnut (Juglans nigra), oak

(Quercus spp.), and teak

(Tectona grandis) 1120 x 2440 3 837–1117

Source: Fordaq Timber Network, citing Shanghai Jiashan Kalhua International Wood Market, China, February 13,

2008, found at http://www.fordaq.com, accessed April 8, 2008.

Note: Original prices quoted in RMB, which were converted to dollars by using the February 2008 exchange rate as

reported by the U.S. Federal Reserve (1 dollar = 7.1644 RMB).

 a

Equivalent to a 4 x 8 foot sheet.
4-23

TABLE 4.10 Listed wholesale domestic prices for Chinese domestic and imported solid wood flooring products,

February 2008

Origin Species Price range ($ per sq. meter)

Standarda Wideb

China European oak (Quereus spp.) 25.12 27.64

Alder (Alnus spp.)/birch (Betula spp.)

16.05 18.42

Pinnata (Pometia pinnata) 13.26 14.66

South America Balsamo (Myroxylon balsamum) 45.08 53.04

Cumaru (Dipteryx odorata) 26.52 29.31

Tauari (Couratari spp.) 20.94 22.33

Southeast Asia Merbau (Intsia spp.) 23.45 24.85

Keranji (Dialium spp.) 22.33 23.03

Kulim (Scorodocarpus boreensis) 20.24 21.77

Africa Awora (Garcinia spp.) 24.85 25.82

Sapelli (Entandrophragma

cyclindricum) 23.73 25.12

Iroko (Chlorophora spp.) (c

) 22.05

Source: Fordaq Timber Network citing Shanghai Furen Wood Floor Distribution Center, February 5, 2008.

Note: Original prices were quoted in RMB, which were converted to dollars by using the February 2008 exchange

rate as reported by the U.S. Federal Reserve (1 dollar = 7.1644 RMB).

 aStandard refers to solid wood flooring in 18 mm x 90 mm x 900 mm fixed lengths. 

 b

Wide size refers to 18 mm x 120 mm x 900 mm fixed lengths. 

 c

Not available.
 119 USDA, FAS, China Eliminates Re-Export Preferences, October 17, 2006, 4; and USDA, FAS, China

Wood Trade Policy Updates, November 14, 2006, 3.

 120 USDA, FAS, China Wood Trade Policy Updates, November 14, 2006, 2.

 121 Ibid.

 122 USDA, FAS, China Reduces Wide Range of VAT Rebates, July 26, 2007, 3.

4-24

Government Programs

Past Chinese government policies have focused on protecting domestic natural forest

resources and emphasizing the development and utilization of plantation resources as raw

material for China’s wood processing industries. Trade policies such as the processing trade

(duty-free re-export) program and the VAT export rebate program were created to promote

the development of certain value-added manufacturing industries, including domestic wood

processing industries. Recent reductions in VAT export rebates for exported hardwood

plywood and wood flooring, as well as a consumption and export tax on solid wood flooring

alone, have reportedly recently discouraged export growth for both products.119

Chinese plywood and wood flooring producers, particularly those located in economic

development zones, may also benefit from preferential tax rates, exempted income tax, and

other investment incentives. Such benefits would apply to all manufacturing investments

located in such zones and would not be limited solely to the plywood and wood flooring

industries.

Trade Policies 

China has utilized the processing trade preference program and the VAT export rebate

program to encourage the development of the domestic wood processing industry and

conserve domestic forest resources. The processing trade preference program allows dutyfree and VAT-free treatment for imported materials that are processed and re-exported as a

value-added item.120 Under the VAT export rebate program, certain exported products qualify

for a VAT export rebate if the products contain domestic raw materials. Because these two

programs provided benefits to an exporter using either imported or domestic raw materials,

there was little discrimination based on the origin of the raw materials.121

Although hardwood plywood and wood flooring have benefitted from duty-free and VATfree imported raw materials under the processing trade preference program, recent reductions

in VAT export rebates for hardwood plywood and engineered flooring, as well as the

elimination of VAT export rebates for certain solid wood flooring, aim to discourage exports

of these products by increasing the amount of VAT owed on exported products. The majority

of changes were made for products deemed by the government to be energy intensive,

heavily polluting, resource consuming products, or products prone to international trade

frictions.122 Table 4.11 outlines recent changes to trade preference programs affecting both

the hardwood plywood and wood flooring industries.
 123 International Wood Markets Group, “Chinese Poplar and Poplar Plywood Update,” November 2007.

 124 Ibid.

 125 Ibid.

 126 Industry officials, e-mail message to and telephone interview by Commission staff, April 4, 2008.

4-25

TABLE 4.11 Changes to trade preference programs

Program

Hardwood plywood and engineered

wood flooring (HS 4412)

Solid wood flooring 

(HS 4409 and 4418)

Processing trade preference

program

Authorized HS 4418.30 Authorized

HS 4409.20 Eliminated (9/06)

HS 4409.20 Re-authorized (11/06)

Value-added tax (VAT) 17 percent(a

) 17 percent (HS 4409.20)(a)

VAT export rebate before

9/15/2006

13 percent 13 percent (HS 4418.30)

Zero (HS 4409.20 - eliminated from

program 1/04)

VAT export rebate effective

9/15/2006

11 percent Zero (HS 4409.20)

11 percent (HS 4418.30)

VAT export rebate effective

7/1/2007

5 percent for certain plywood;

eliminated for other plywood(b

)

Zero (HS 4409.20)

11 percent (HS 4418.30)

VAT paid effective 7/1/2007 12 percent for certain plywood; 17

percent for other plywood

17 percent (HS 4409.20)

6 percent (HS 4418.30)

Additional policy changes:

Consumption tax None 5 percent (4/06)

Export tax None 10 percent for solid wood flooring

(9/06)

Source: USDA, FAS, China Eliminates Re-Export Preferences, tables 1–2, October 17, 2006, app. 2; USDA, FAS,

China Wood Trade Policy Updates, November 14, 2006, 2; USDA, FAS, China Solid Wood Products Annual 2006,

July 13, 2006, 7; and USDA, FAS, China Reduces Wide Range of VAT Rebates, tables 1–2, July 26, 2007, 5–32.

Note: Table refers to 2006 HS subheadings.

a

The actual value of VAT paid for the exported finished product is the difference between the value of VAT paid

for an imported input and the value of the VAT amount owed for the exported finished product. b

Plywood products eliminated from the VAT rebate include those made from endangered species (“imminent

danger” according to Chinese tariff terminology) of tropical and other hardwoods. Also eliminated from the VAT

rebate are certain blockboard, laminated woods, and parquet panels.

Reductions in VAT export rebates for other hardwood plywood products, coupled with

increasing labor, energy, and raw materials costs, have reportedly had a negative financial

impact on Chinese hardwood plywood producers.123 For example, over 80 percent of

plywood mills that produce for export have reportedly experienced cost increases that are

cutting into company profits, which typically were already low at around 3 percent.124 As a

result of these cost increases, many small- and medium-sized Chinese mills have reportedly

reduced production levels or have gone out of business.125 In 2007 alone, 700 small plywood

mills reportedly ceased production, due to a reduction in VAT export rebates, increasing

production costs, lagging foreign demand, and low export prices.126
 127 International Wood Markets Group, The China Book, part 3, 2006, 102.

 128 USDA, FAS, China Wood Trade Policy Updates, November 14, 2006, 2.

 129 Ibid., 3.

 130 Ibid.

 131 USDA, FAS, China Eliminates Re-Export Preferences, October 17, 2006, 4.

 132 Industry official, interview by Commission staff, China, February 19, 2008.

 133 For example, see Nantong Economic Technological Development Area located in Jiansgu province,

http://www.netda.com, and Moganshan (Deqing) Economic Development Zone located in Zhejiang province,

http://www.dqcom.gov.cn/en, which is administered by the Deqing Foreign Trade and Economic

Cooperation Bureau. 

 134 For a list of Chinese laws and corresponding programs, see Stewart, “China’s Support Programs for

Selected Industries,” June 2007.

 135 Jin, Minister of Finance, People’s Republic of China, “Explanation on the Draft Enterprise Income

Tax,” March 8, 2007.

4-26

Recent policy changes have created additional financial challenges for China’s solid wood

flooring producers. In addition to a 5 percent consumption tax on solid wood flooring (to be

paid by the manufacturer)127 imposed in April 2006, the central government levied a 10

percent export tax on solid wood flooring in October 2006, despite re-authorizing solid wood

flooring for processing trade preferences the previous month.128 Because many larger solid

wood flooring manufacturers are export oriented, some industry observers believe that the

current policies may contribute to the rationalization of the Chinese solid wood flooring

industry.129

Some industry analysts believe that the objective of recent policy changes and subsequent

reversals is to protect domestic timber resources and slow investment in China’s wood

processing industries while maintaining the employment and competitiveness of the existing

industry.130 In addition, the reduction in VAT export rebates for hardwood plywood and

wood flooring and the imposition of a consumption and export tax on solid wood flooring

discourage exports, thereby implicitly favoring companies that produce for China’s domestic

market.131 Despite these challenges, some producers are focusing on productivity

improvements to offset the loss in VAT export rebates and to maintain competitiveness.132

Other Policies

Chinese plywood and wood flooring producers, particularly those located in economic

development zones, may have benefitted from certain assistance programs and investment

incentives, including exemption from corporate income tax for two years starting from the

first year of making profits and preferential corporate income taxes thereafter; re-investment

of tax rebates; reductions in property taxes; and negotiable land prices.133 Investment

incentives, often directed to foreign invested enterprises (FIEs), apply to all manufacturing

investments located in such zones. In addition, various Chinese laws generally provide a

range of preferential tax policies predominantly to FIEs, but also to domestic Chinese

enterprises.134 However, on January 1, 2008, a new Chinese tax law took effect which

eliminated preferential tax breaks for FIEs and made the tax rates for domestic firms and

foreign invested enterprises uniform.135
 136 WTO, Delegation of the United States, “China: Certain Measures Granting Refunds,” February 7,

2007.

 137 Memorandum of Understanding Between the United States of America and the People’s Republic of

China Regarding Certain Measures Granting Refunds, Reductions or Exemptions from Taxes or Other

Payments.

 138 The European Commission defined the product concerned as “plywood consisting solely of sheets of

wood, each ply not exceeding 6 mm thickness, with at least one outer ply of okoumé, originating in the PRC,

currently classifiable within CN code ex 4412 13 10.” Both plywood made entirely of okoumé and plywood

with one or two outer faces made of okoumé with core layers made from other species were included in the

product description. See Council Regulation (EC) No. 1942/2004 (November 2, 2004) imposing a definitive

anti-dumping duty and collecting definitively the provisional duty imposed on imports of okoumé plywood

originating in the People’s Republic of China, 336/8.

 139 Ibid., 336/6 and 336/8.

 140 Plywood consisting solely of sheets of wood, each ply not exceeding 6 mm in thickness. WTO,

Committee on Anti-Dumping Practices, “Semi-Annual Report Under Article 16.4 of the Agreement,

Turkey,” March 22, 2007, for the period July 31–December 31, 2006.

 141 WTO, Committee On Anti-Dumping Practices, “Semi-Annual Report Under Article 16.4 of the

Agreement, Israel,” April 17, 2007, for the period July 31–December 31, 2006.

4-27

In February 2007, the United States requested WTO consultations with China concerning

certain policies prohibited under WTO rules, including export subsidies and import

substitution practices.136 Enterprises in economic development zones, including hardwood

plywood and wood flooring producers, may have benefitted from such policies. In November

2007, China entered into a memorandum of understanding with the United States in which

it agreed to eliminate such practices by January 1, 2008.137

Foreign Government Programs

With respect to certain plywood, China’s exports are subject to antidumping duties in the

EU, Turkey, and Israel. In 2003, the EU found China to be dumping okoumé plywood

during the 1999–2003 period, resulting in a countrywide dumping margin of 66.7 percent.138

During the investigation, the European Commission recognized that the majority of Chinese

exports of okoumé plywood had thinner face plies than the Community domestic like

product, and found that in some cases a difference in face thickness could result in a price

difference of 3.6–5.5 percent. In addition, the European Commission concluded that the

combined impact of differences in face thickness, glue quality, and the quality of inner plies

of Chinese producers corresponded to a price difference of 10–15 percent. As a result, the

European Commission added a 10 percent adjustment to the c.i.f. price of cooperating

Chinese exporting producers when calculating the dumping margins.139

Turkey initiated an antidumping investigation against Chinese plywood in February 2006,

resulting in a final antidumping margin of $240 per m3

.

140 Likewise, Israel initiated

antidumping proceedings with respect to certain MDF and plywood faced by veneer or

lacquer paper from China in December 2004, resulting in an antidumping margin of 44.7

percent.141

 1

 Data and information on flooring is often included under the category of builder’s joinery, also includes

doors, windows, shutters, stairs, and door or window frames.

5-1

CHAPTER 5

Other Foreign Suppliers 

The other primary suppliers of wood flooring and hardwood plywood to the U.S.

market—Brazil, Canada, Indonesia, Malaysia, and Russia—share many characteristics. All

five suppliers have large forested areas with significant supplies of raw material; together,

they account for more than 40 percent of the world’s forested area. Three of the countries

(Brazil, Indonesia, and Malaysia) are principally suppliers of tropical hardwood products,

and the other two (Canada and Russia) are principally suppliers of temperate/boreal

hardwood products. As shown in chapter 2, these countries, along with China, are not only

the principal suppliers to the U.S. market, but account for significant shares of global exports

of hardwood plywood and wood flooring. These countries are well adapted to compete in

this market due to large natural forest resources and plantation areas (particularly in the

tropical countries), generally low labor costs (with the exception of Canada), and large

integrated forest industries with large scale facilities and an export orientation. For these

countries, there is generally more information available for their plywood industries than for

their flooring industries.1

 In addition, information is more readily available for industries

producing solid wood flooring than for engineered wood flooring.

Industry Structure and Capacity

In contrast to the United States and China, the wood flooring and hardwood plywood

industries in the five other supplier countries are typically more vertically integrated

(particularly the hardwood plywood industry) and have access to larger tracts of timber as

part of concessions on government-owned forest land. These concessions provide hardwood

product firms with a steady supply of timber for their production processes. The wood

flooring and hardwood plywood industries in these countries are privately owned and use

essentially the same technologies to produce flooring and plywood as the United States.

Brazil, Indonesia, Malaysia, and Russia have larger-scale plywood mills than does Canada,

but the mills are on a similar scale to large U.S. firms. Little data and information are

available on the size and structure of the wood flooring industries in these countries (table

5.1).
 2

 Rutton and Hock, “Reviving Tropical Plywood,” May 2004, 18.

 3

 Industry official, interview by Commission staff, Washington, DC, September 14, 2007.

 4

 USITC hearing transcript, October 3, 2007, 222.

 5 FloorBiz.com, “BR-111 Imports and Exports, Inc: About Us,” undated (accessed January 16, 2008).

5-2

TABLE 5.1 Foreign supplier countries: Sawmills, plywood mills, and other wood product producers, number of firms

and installed capacity (1,000 cubic meters)

Sawmills Plywood mills

Country Firms Installed Capacitya Firms Installed Capacitya

Brazil 10,000 NA b<200 NA

Canada c50 d5,389 12 d5,389

Indonesia 327 7,460 113 12,000

Malaysiae 1,132 24,370 174 10,720

Russia NA NA 30–40 3,700

Source: USDA, FAS, Indonesia Solid Wood Products: Annual 2006, June 28 2006, 4; and Government of Malaysia,

"Wood-Based Industry," 2006, 425.

a

Installed capacity in thousands m3 per year. b

This includes softwood and hardwood mills. c

Solid wood flooring firms.

d

Capacity converted from 300 million square feet with an average thickness of 0.632 inches. e

Malaysian firms and installed capacity figures are for 1995.

Brazil

While most of the plywood industry in Brazil is located in the southern portion of the

country, the bulk of tropical (hardwood) plywood production remains in the north.

According to the ITTO, an estimated 300 mills were in operation in 2000, 60 percent of

which were medium- to large-scale companies; the remaining 40 percent were small-scale

operations. At that time, 40 companies accounted for about 60 percent of plywood

production capacity.2

 However, recent reports suggest that the number of plywood mills is

now under 200 and that there may be only about 10 remaining that produce significant

volumes of hardwood plywood.3

 According to Brazilian industry officials, the “Brazilian

hardwood flooring industry is dwarfed by the U.S. industry. {Brazilian} production and

capacity are rather small when comparted to U.S. production and capacity {and} the

Brazilian presence in the world market is smaller than the American presence.”4

Most Brazilian wood flooring operations are also located in the south. Reportedly, there are

some large-scale operations in this sector. BR-111, a major U.S.-based importer and

distributor, has the largest flooring mill in South America (located outside of São Paulo),

producing more that 1.4 million square feet of flooring per month for distribution to

domestic and international markets.5

 Complete information is not available on the number

or size of Brazilian wood flooring firms.
 6

 Industry officials, interviews by Commission staff, Washington, DC, August 10 and September 14,

2007; and company annual reports and Web sites of various Canadian hardwood plywood producers.

 7

 Industry officials, interviews by Commission staff, Washington, DC, August 10 and September 14,

2007.

 8

 Industry officials, interviews by Commission staff, Washington, DC, August 10 and September 14,

2007.

 9

 About one-third of Canadian wood flooring production capacity is in Ontario and two-thirds are in

Quebec.

 10 Industry officials, interviews by Commission staff, Washington, DC, September 14, October 10, and

November 14, 2007; and company annual reports and Web sites of various Canadian wood flooring

producers.

5-3

Canada

The hardwood plywood industry in Canada is about one-quarter the size of the hardwood

plywood industry in the United States and comprises approximately one dozen firms. Three

of these firms are divisions of large integrated Canadian forest products companies. The

remainder are not vertically integrated, and one is a division of a large U.S. hardwood

plywood producer. The four largest producers account for 60–80 percent of total Canadian

hardwood plywood production.6

 Three Canadian producers have integrated hardwood

plywood operations—slicing and/or peeling hardwood logs and then gluing and pressing the

veneer layers into the final product. The other producers purchase cores and face and back

veneers. Although the scale of production operations for some U.S. hardwood plywood firms

is larger than that of Canadian firms, production equipment and technology is similar

because it is purchased from the same vendors. The age of the production equipment is also

generally similar.7

 Employment in the industry in Canada totals approximately 1,000–2,000,

but the number of workers has declined in recent years.

Approximately 60 percent of Canada’s hardwood plywood production capacity is located

in Ontario with the remainder in Quebec; Ontario and Quebec contain most of Canada’s

hardwood forests. Total capacity to produce hardwood plywood in Canada has been flat

during the past five years with no consolidation of producers or expansion of capacity during

this period.8

The wood flooring industry in Canada is approximately one-quarter the size of the U.S.

wood flooring industry and consists of approximately 50 firms, mostly small, family-owned

businesses producing primarily or exclusively wood flooring. Most are located in eastern

Canada; a few small producers are located in British Columbia and the maritime provinces.9

Most producers have only one plant, while a few of the bigger ones have multiple plants.

Only two of these firms are vertically integrated, with their own logging and sawing

operations. The industry is fragmented, with the top four producers accounting for 20–40

percent of total Canadian production of wood flooring. A handful of Canadian wood flooring

firms produce both solid wood and engineered wood flooring. The vast majority of firms

only make solid wood flooring, of which approximately 50 percent of these only make

unfinished solid wood flooring and 50 percent make both finished and unfinished solid wood

flooring. Employment in the Canadian industry numbers several thousand but has reportedly

declined during the past few years.10 Capacity in Canada has fluctuated over the past 5 years,

with some new players entering the market during the 2003–05 period but then going out of

business in 2006. Reportedly there is a moderate amount of unused wood flooring
 11 Industry officials, interviews by Commission staff, Washington, DC, September 14, October 10, and

November 14, 2007. 

 12 Government of Indonesia, Department of Statistics, “Industry Database,” undated (accessed February

22, 2008).

 13 Less than 5 percent of the capacity of the Indonesian wood products industry is unaffiliated with

concessions. Indonesian Commercial Newsletter, “Plywood Industry Requires Consolidation and

Restructuring,” April 9, 2002.

 14 Flooring statistics are believed to be incorporated into both the plywood and sawnwood industries data.

 15 Turner, Katz, and Buongiorno, Implications for the New Zealand Wood Products Sector, July 2007, 16.

 16 Adams, ITTO, “Is This the End of Thin-Panel Tropical Plywood?” 2003.

 17 World Bank, “Sustaining Economic Growth,” December 2006, 71.

 18 Ibid.

 19 Indonesian Commercial Newsletter, “Plywood Industry Requires Consolidation and Restructuring,”

April 9, 2002. 

5-4

production capacity in Canada; very little consolidation of wood flooring producers in

Canada has occurred in the past 5 years.11

Indonesia

The forest products industry in Indonesia is geographically concentrated in the Indonesian

states on Borneo and Sumatra. Borneo alone accounts for 68 percent of plywood production,

49 percent of sawn timber production, and 99 percent of veneer production.12 The

government of Indonesia generally ties logging concession rights to firms with downstream

production capabilities, such that logging firms must operate plywood mills, sawmills, or

other wood processing facilities.13 According to official production statistics, the plywood

industry is nearly twice the size of the sawnwood industry,14 and roughly the same size as the

Indonesian veneer industry. The Indonesian wood flooring industry is small relative to the

plywood industry.

There are a large number of plywood mills in Indonesia relative to the country’s output,

indicating that the plywood industry suffers from overcapacity and low productivity.15

According to a 2003 ITTO report, Indonesia’s capacity utilization was approximately 40

percent; the overall Asian plywood sector was reportedly operating at 50 percent of

capacity.16 In 2006, a significant share of Indonesia’s plywood mills were idle due to

production equipment limitations or lack of raw materials, with the remaining operating at

less than 50 percent capacity.17 Some plants that did not already have the ability toprocess

small diameter logs or the ability to peel logs down to a small diameter were reportedly

retooling their operations in preparation for restarting production in order to utilize available

raw material.18 In the late 1990s, plywood mills accounted for more than 50 percent of

employment in the wood products sector; more recent data are not available.

The plywood industry in Indonesia is dominated by large-scale business groups such as the

Barito Pacific Group (BPG), the Djajanti Group, and the Kalimanis Group, which have forest

logging concessions and operate plants that produce a wide range of products including

hardwood plywood and wood flooring.19 BPG, comparable in production capacity and

relative size to large U.S. firms, is the largest group in the Indonesian plywood industry. It

operates at least 10 wood processing mills, of which 5 have dedicated plywood production

lines with an annual plywood production capacity of approximately 1.5 million m3

. In its

2005 annual report, BPG reported that over 85 percent of its production was exported, with
 20 PT Barito Pacific Timber Tbk Integrated Wood Industries, Annual Report 2005, 5. BPG’ s primary

markets include: the United States (17.1 percent), Japan (7.7 percent), Europe (8.2 percent), Middle East

(31.3 percent), Korea (14.9 percent), and local market (14.9 percent). Taiwan, China, and Hong Kong

account for less than 5.0 percent of its annual production.

 21 Ibid., 7 and 19.

 22 Malaysia Timber Industry Board, “Malaysia Export Statistic: Year 2006,” updated January 10, 2008.

 23 Ibid.

 24 Rutton and Hock, “Reviving Tropical Plywood,” May 2004, 17–18.

 25 Industry representative, e-mail message to Commission staff, July 19, 2007.

 26 European Federation of the Plywood Industry, Annual Report, 2006–2007, June 28, 2007.

 27 Industry representative, e-mail message to Commission staff, July 19, 2007.

 28 Industry representative, e-mail message to Commission staff, July 19, 2007.

5-5

the largest share of its exports shipped to the Middle East.20 Plywood accounts for nearly 80

percent of BPG’s total production. However, plywood production and sales volume declined

by approximately 62 percent from 2002 to 2005 partly due to crackdowns on illegal logging

that resulted in the closure of two of BPG’s five dedicated plywood production lines.21

Malaysia

As in Indonesia, Malaysian production is specialized by region. Production of primary forest

products such as logs, plywood, and veneer is heavily concentrated in the Malaysian states

of Sabah and Sarawak on Borneo. The plywood industry consists of 174 mills with the

largest and most efficient plants located in Sarawak, which accounted for 63 percent of

Malaysia’s plywood production volume in 2001; Sabah accounted for 22 percent in the same

year and Peninsular Malaysia for 15 percent.22 Plywood accounted for more than 30 percent

of Malaysian wood product exports in 2006. Although the number of mills is evenly

distributed across Malaysia, Sarawak has larger mills compared to the rest of the country and

accounted for nearly 70 percent of the total value of plywood exports in 2006.23 While the

plywood industries in Sarawak and Sabah are export oriented, most of Peninsular Malaysia’s

production is from smaller mills, which supply primarily local consumers such as wooden

furniture producers. Peninsular Malaysia accounted for only 5 percent of the total value of

Malaysian plywood exports in 2006.24

Russia

Most producers of hardwood plywood in Russia are located in European Russia, north of

Moscow, close to major sources of hardwood logs. There are presently 30–40 Russian mills

producing hardwood plywood, primarily using birch.25 Russian plywood production capacity

in 2007 totaled 3.7 million m3

, a 6 percent increase over the 2006 level.26 Major producers

and exporters include the Sveza Group mills, the largest producer in Russia, with major mills

located in St. Petersburg, Kostroma, and Perm; Parfino Plywood Factory, with its plywood

mill located in the Novgorod region; and Syktyvkar Plywood Mill, with its mill located in

Komi Republic.27 The three companies collectively account for nearly one-half of Russian

annual production capacity of hardwood plywood and one-half of Russian exports to the

United States. Sveza Group’s 2006 capacity was approximately 590,000 m3

; Syktyvkar’s

was 170,000, and Parfino’s 100,000. In terms of exports, the Sveza Group accounted for 28

percent of Russian exports to the United States, Syktyvkar for 10 percent, and Parfino, 11

percent.28 Since 2002, annual investment in the overall Russian forest products industry has
 29 Van Leeuwen, Wood Markets: Monthly International Report, November 2006, 5.

 30 ABIMCI, “2004 Sector Study,” undated (accessed March 26, 2008), 8.

 31 FAO, State of the Worlds Forests 2007, 2007, Annex 102–140.

 32 USDA, FAS, Brazil: Solid Wood Products Annual Report 2006, December 8, 2006, 3.

 33 FAO, State of the Worlds Forests 2007, 2007, Annex 102–140; and Tembec, Annual Report 2006,

September 2006.

 34 Hardwood Plywood and Veneer Association Web site, http://www.hpva.org/products/facts.asp

(accessed April 23, 2007).

5-6

risen more than threefold, to an estimated $2.4 billion in 2006, and the main sources of

foreign investment in the Russian forest sector are principally northern European and

Chinese firms.29

Raw Material Supply

Brazil

Brazilian forested area consists of natural forests and plantations that occupy nearly

two-thirds of the country’s total land area (table 5.2).30 Hardwoods make up two-thirds of the

approximately 6 million hectares (14.8 million acres) of plantations; the remaining one-third

are softwood plantations.31 Native forests in Brazil are under both private and public

ownership. Private production areas reached 240 million hectares (593 million acres) in

2006, about one-half of the total native forest area, and private forests are the major source

of tropical wood production. The remaining inventory of native forests is destined for

conservation units and indigenous lands. Legal production in public conservation forest areas

is minimal.32

Canada

In Canada, hardwoods account for 15 percent of the total forested area, softwoods account

for another 67 percent, and the remaining 18 percent consists of forests of mixed

composition. Like Malaysia, provincial governments in Canada, as opposed to the federal

government, retain ownership of most forest land. Moreover, most of the hardwood in

Canada is harvested from these provincially owned public lands through licensing

agreements with Canadian forest firms.33 Private forests (about one-half of which are located

in Ontario and Quebec) are a second source of raw material for flooring and plywood

producers.34

Indonesia

Indonesia ranks second behind Brazil in the extent of its tropical forest area, most of which

is located on the islands of Sumatra and Borneo. Indonesia’s forest lands are classified into
 35 Production forests are natural stands that are used primarily for industrial roundwood production;

conversion forests are those forests slated for conversation to other uses, such as for city expansion and

infrastructure development; and conservation/protected forests are those areas that are designated for

preservation in its natural state. FAO, “Global Forest Resources Assessment 2005,” 2006, 209.

 36 Inhutani I-IV are state-owned forestry companies with concession rights that compete in the wood

products industry. Down to Earth. “Kalimantan, Indonesia: All Logged Out,” February 21, 1997; and Turner,

Katz, and Buongiorno, Implications for the New Zealand Wood Products Sector, July 2007, 16.

 37 FAO, “Update 34,” December 2000, 70; FAO, “Global Forest Resources Assessment 2005,” 2006, 197

and 209.

5-7

TABLE 5.2 Foreign supplier countries: Forest resources, 2005

Country

Forested

area

Production

forests

Plantation

forests Notes

Million hectares

Brazil 478 240 6a 483 million hectares in the Amazon region,

of which about 240 million hectares are

privately owned.

Canada 310 235 NA Production forests are officially classified as

commercial forests. Ownership: 71 percent

provincial, 23 percent federal, and 6 percent

private.

Indonesia 88 62 3 Production includes forest concessions for

conversion as well as limited production

forests. 1.3 million hectares are community

forests.

Malaysia 21 12 2 2.3 million additional hectares are available

for logging or conversion to other uses such

as crop or housing development.

Russia 809 771 17 45 percent privately owned.

Source: FAO, State of the Worlds Forests 2007, 2007, annex 102–140; Government of Indonesia, Department of

Statistics, Industry Database”, undated (accessed February 11, 2008); USDA, FAS; Malaysia: Solid Wood Products

Annual 2007 Report, July 10, 2007, 6; and Russia–Geographic Website. www.geographic.org (accessed May 11,

2008).

a

Includes pine and other softwoods.

three groups: production (54 percent); conversion to other uses (28 percent); and

conservation/protection forest (18.6 percent).35 Forests are primarily owned by the national

government and managed through concessions to integrated wood products companies.36

These concessions provide the government some control in balancing illegal logging and

deforestation with domestic demand. Even with centralized control, deforestation remains

a serious concern. In fact, Indonesia’s forest area has decreased by an estimated 24 percent

since 1990.37

Malaysia

Malaysia has the smallest forest area of the five countries, with its forested area divided

between Peninsular Malaysia and the states of Sabah and Sarawak on Borneo. While forests
 38 The policy aims to increase planted forest area from 320,000 hectares in 2006 to 500,000 hectares. The

government of Malaysia announced that the Forest Plantation Development Sdn. Bhd. (FPD) will disburse

loans to five companies to establish 75,000 hectares of new forest plantations. Global Wood, “Soft Loans

Awarded for Forest Plantation Development,” July 15, 2007.

 39 Shivdenko, “Russian Forests at the Beginning of the Third Millennium,” 2003.

 40 Interfax–CNA, Russia’s Timber, Woodworking, Pulp and Paper Industry in 2004–2005, August 2005,

6. 

 41 Roshchupkin, “The Forest Resources of Russia by Region,” undated (accessed May 7, 2007).

 42 Schloenhardt, “The Illegal Trade in Timber and Timber Products in the Asia-Pacific Region,” 2008, 65.

 43 Roshchupkin, “The Forest Resources of Russia by Region,” undated (accessed May 7, 2007).

 44 Ibid.

 45 Official Indonesian 2005 production statistics report that while Borneo accounted for 36 percent of total

Indonesian log production (Central Kalimantan and East Kalimantan alone accounted for 17 and 15 percent

of total Indonesian log production respectively, in 2005), Borneo accounted for 71 percent of the total

harvest from concessions. While 55 percent of all logs are produced on Sumatra, this is primarily plantation

logs grown specifically for the pulp and paper industry. Plywood and flooring production are also

concentrated on Borneo and are primarily supplied by logs from natural forest concessions. Government of

Indonesia, Department of Statistics, “Industry Database,” undated (accessed February 11, 2008). It is

difficult to accurately gauge the level of Indonesian log production because: (1) official statistics only

include national forest concessions, (2) only about one-half of the companies required to report production

actually return national forestry statistics forms, and (3) there are large discrepancies between volumes

officially exported from Indonesia and volumes reported by destination countries. Turner, Katz, and

Buongiorno, Implications for the New Zealand Wood Products Sector, July 2007, 17. See also Goetzl,

“Discrepancies in Foreign Trade Data,” September 30, 2005.

5-8

cover about 60 percent of the country’s total land area, Malaysia has emphasized the use of

sustainable public and private forest plantation growth to supplement the supply of industrial

roundwood for its wood products industry.38 As in Canada, harvesting of Malaysian forest

resources is controlled by concessions issued to private companies by the various state

governments.

Russia

Russian forested lands cover approximately 810 million hectares (2 billion acres) and

constitute more than 45 percent of the country’s total area.39 The dominant share (about 75

percent) of Russia’s forest resources are of various coniferous species such as larch.40 The

commercial forests are distributed largely within three geographic zones: the European

region, the western and the eastern Siberian region, and the Far East region.41 Approximately

70 percent of Russia’s forests are concentrated in the Far East region and Siberia, in

relatively close proximity to China and other main markets in the Asia-Pacific region.42

Hardwoods are primarily located in the European and Far East regions (accounting for 40

and 44 percent of the hardwood resources, respectively);43 the Siberian region only accounts

for 16 percent of the total hardwood resources.44

Log Production, Trade and Consumption

The largest hardwood log producer, Brazil, is the only country of the five examined that had

an appreciable decrease in log production from 2002 to 2006. Canada and Malaysia

registered increased log production whereas Indonesian and Russian production remained

relatively stable during the period (table 5.3). Log production in Indonesia and Malaysia, like

plywood production, is heavily concentrated on the island of Borneo.45
 46 GTIS, Global Trade Atlas Database (accessed June 5, 2007).

 47 Ibid.

 48 GTIS, Global Trade Atlas Database (accessed June 5, 2007). Oak log exports constituted an estimated

18 percent of log exports to China by volume and an estimated 25 percent of log exports by value in 2006. 

5-9

TABLE 5.3 Foreign supplier countries: Hardwood log production, trade, and consumption, 2002–06

Source 2002 2003 2004 2005 2006

CAGR

2002–06

Production (1,000 cubic meters) %

Brazil 96,484 76,416 67,359 74,067 70,265 -7.6

Canada 33,936 33,617 35,581 37,400 37,400 2.5

Indonesia 26,500 26,000 23,000 18,000 26,000 -0.5

Malaysia 17,913 21,531 24,399 24,910 26,992 10.8

Russia 37,400 34,706 29,600 35,000 36,800 -0.4

Imports (1,000 cubic meters)

Brazil 13 12 9 8 6 -17.6

Canada 2,579 2,085 2,401 2,025 2,500 -0.8

Indonesia 149 51 70 84 70 -17.2

Malaysia 418 109 93 73 100 -30.1

Russia 20 21 17 0 0 -100.0

Exports (1,000 cubic meters)

Brazil 405 211 211 85 85 -32.3

Canada 363 316 331 208 250 -8.9

Indonesia 1,000 800 137 102 100 -43.8

Malaysia 5,092 5,468 5,118 5,759 4,700 -2.0

Russia 8,400 9,460 10,372 13,300 14,500 14.6

Domestic consumption (1,000 cubic meters)

Brazil 96,091 76,217 67,157 73,990 70,186 -7.6

Canada 36,152 35,386 37,651 39,217 39,650 2.3

Indonesia 25,649 25,251 22,933 17,982 25,970 0.3

Malaysia 13,239 16,172 19,374 19,224 22,392 14.0

Russia 29,020 25,267 19,245 21,700 22,300 -6.4

Source: ITTO, Annual Review and Assement of the World Lmber Situation 2006, July 2006, appen. 1, table 1-1C;

and FAOSTAT, Forestry Database (accessed October 10, 2007).

Canada, which imported nearly 10 percent of its domestic consumption, was the only one

of the five with significant hardwood log imports; the other four countries imported less than

1 percent of their domestic consumption in any given year. Brazil, Canada, and Indonesia

appear to be consuming nearly all of their hardwood log production in the manufacture of

downstream products, such as flooring, veneer, and plywood. Russia and Malaysia were the

only countries that reported substantial exports of industrial hardwood logs from 2002 to

2006, Russia exported nearly 40 percent of its production in 2006.

During the 2002–06 period, Russia was the world’s leading exporter of hardwood logs,

accounting for more than one-quarter of such exports in 2006 and nearly three-quarters of

the total of these five suppliers.46 Russian exports increased by 73 percent to 14.5 million m3

($737 million) during this period, principally to China, Japan, and Europe.47 China accounted

for the biggest increase in total Russian exports of hardwood logs during this period; such

exports increased more than fivefold during the 2002–2006 period, accounting for 28 percent

of total Russian exports in 2006, by volume.48
 49 The production of lumber and plywood together account for almost 90 percent of total domestic log

consumption. Seneca Creek Associates LLC and Wood Resources International LLC, “Illegal,” Illegal

Logging and Global Wood Markets, November 2004, 83; and ITTO, Annual Review and Assessment of the

World Timber Situation 2006, July 2006, 4–11.

 50 Malaysia exported 28 percent of its production in 2002 as compared to 17 percent in 2006.

 51 GTIS, Global Trade Atlas Database (accessed June 5, 2007). 

 52 Seneca Creek Associates LLC and Wood Resources International LLC, “Illegal,” Illegal Logging and

Global Wood Markets, November 2004, 83. 

 53 U.S. Department of State official, e-mail message to Commission staff, September 28, 2007.

 54 Separate data for the products are not available. There is also little or no available data on solid or

engineered wood flooring production for the selected countries.

 55 Similar production, trade, and consumption data are not available for wood flooring.

5-10

Limitations on harvests from natural stands notwithstanding, Malaysian production of logs,

lumber, and veneer increased in recent years to supply the rapidly growing domestic

demand, rather than export markets.49 Malaysia consumed a greater share of its raw materials

during the period, increasing from 74 percent in 2002 to over 83 percent in 2006.50

Nevertheless, Malaysia still accounts for over 20 percent (by value) of global log exports.51

Malaysian plywood and wood flooring manufacturers rely principally on domestic raw

material. Meranti (Shorea spp.), Nyatoh (Palaquium spp. and Payena spp.), and Keruing

(Dipterocarpus spp.) are the species of timber most commonly used in plywood production,

and the government of Malaysia has banned the export of logs of these species from

Peninsular Malaysia52 to ensure a sufficient supply of logs for domestic production activities

on both Peninsular and the Borneo states of Malaysia.53 Sarawak exports its logs primarily

to China, Japan, and India. While Japan has historically been the largest market for

Malaysian logs exports, India and China are becoming important markets. In 2006, China,

Japan, and India accounted for about 25 percent of roundwood exports from Malaysia.

Production, Trade, and Consumption

Of these five supplier countries, the leading producers of hardwood plywood and wood

flooring are Indonesia and Malaysia (table 5.4).54 Moreover, Indonesia and Malaysia each

produce approximately three times more plywood than the United States (see table 2.2 in

chapter 2). The top exporters are also Indonesia and Malaysia (table 5.5). The top export

markets for most of these five suppliers were the United States and the EU, with Japan being

an important market for Indonesia and Malaysia (table 5.6).

Production of hardwood plywood increased in Brazil, Malaysia, and Russia during the

2002–06 period (table 5.4).55 Plywood production in Indonesia dropped suddenly in 2004 but

nearly regained 2002 levels by 2006. With the exception of Canada, the five countries

imported negligible quantities during the period; however they each exported 23–94 percent

of their production.
5-11

TABLE 5.4 Foreign supplier countries: Hardwood plywood production, trade, and consumption, 2002–06

Source 2002 2003 2004 2005 2006

CAGR

2002–06

Production (1,000 cubic meters) %

Brazil 1,100 1,220 1,380 1,305 1,387 6.0

Canada 300 300 300 302 293 -0.6

Indonesia 6,550 6,111 4,514 4,534 6,111 -1.7

Malaysia 4,341 4,771 4,734 5,006 5,072 4.0

Russiaa 1,821 1,978 2,246 2,556 2,598 9.3

Imports (1,000 cubic meters)

Brazil 0 0 0 0 0 NA

Canada 305 375 236 221 268 -3.2

Indonesia 4 1 7 14 7 15.0

Malaysia 52 64 13 29 30 -12.8

Russiaa 31 41 43 54 46 10.4

Exports (1,000 cubic meters)

Brazil 750 850 462 550 321 -19.1

Canada 369 348 363 442 435 4.2

Indonesia 5,520 5,092 3,205 2,696 3,205 -12.7

Malaysia 3,614 3,875 4,349 4,537 4,800 7.4

Russiaa 1,157 1,201 1,438 1,527 1,577 8.0

Domestic consumption (1,000 cubic meters)

Brazil 350 370 918 755 1,066 32.1

Canada 236 327 173 81 126 -14.5

Indonesia 1,034 1,020 1,315 1,852 2,913 29.6

Malaysia 779 960 398 498 302 -21.1

Russiaa 695 818 851 1,083 1,067 11.3

Source: ITTO, Annual Review and Assement of the World Lmber Situation 2006, July 2006, appen. 1, table 1-1C;

and FAOSTAT, Forestry Database (accessed October 10, 2007).

a

Includes both softwood and hardwood plywood; industry sources estimate that more than 90 percent of

production and nearly 100 percent of exports consist of hardwood plywood.
5-12

TABLE 5.5 Foreign supplier countries: Exports and imports of plywood and wood flooring, 2002–06

Source 2002 2003 2004 2005 2006

CAGR

2002–06

Thousands of $ %

Plywood and engineered wood

flooring:

Brazil:

Exports to:

United States 64,290 81,574 117,085 74,064 60,731 -1.4

United Kingdom 51,053 42,475 71,583 46,875 49,040 -1

Puerto Rico (U.S.) 14,520 16,784 25,239 17,185 11,805 -5

 All other 65,158 81,175 118,172 89,351 74,515 3.4

 Total exports 195,021 222,008 332,079 227,475 196,091 0.1

 Total imports 384 28 134 279 497 6.7

Canada:

Exports to:

United States 198,513 190,040 219,388 263,340 255,238 6.5

Bermuda 38 76 189 624 531 93.3

United Kingdom 0 129 32 623 336 

 All other 637 693 1,747 1,941 1,275 18.9

 Total exports 199,188 190,938 221,356 266,528 257,380 6.6

 Total imports 85,198 93,893 136,108 127,123 153,104 16

Indonesia:

Exports to:

Japan 633,139 542,104 586,229 488,870 597,459 -1.4

United States 153,124 106,067 110,611 100,301 111,847 -7.6

Taiwan 62,043 77,761 76,967 61,611 54,388 -3.2

 All other 514,550 569,249 478,209 418,454 331,414 -10.4

 Total exports 1,362,856 1,295,181 1,252,016 1,069,236 1,095,108 -5.3

 Total imports 2,761 1,277 5,181 5,947 16,733 56.9

Malaysia:

Exports to:

Japan 498,154 551,795 721,204 701,821 1,033,521 20.0

United States 119,323 102,249 162,274 160,347 183,857 11.4

Korea 111,223 123,388 101,315 131,678 160,654 9.6

 All other 265,637 283,716 382,920 419,737 486,131 16.3

 Total exports 994,337 1,061,148 1,367,713 1,413,583 1,864,163 17.0

 Total imports 2,443 1,095 3,114 6,024 12,283 49.7

Russia:

Exports to:

United States 89,098 84,030 124,576 125,627 96,149 1.9

Egypt 22,467 26,087 25,267 41,415 47,979 20.9

Germany 11,410 15,050 27,329 33,249 42,006 38.5

 All other 119,164 133,474 196,850 272,302 318,624 27.9

 Total exports 242,139 258,641 374,022 472,593 504,758 20.2

 Total imports 2,997 3,964 4,663 6,377 10,632 37.2

See note at end of table.
5-13

TABLE 5.5 Foreign supplier countries: Exports and imports of plywood and wood flooring, 2002–06—Continued

Source 2002 2003 2004 2005 2006

CAGR

2002–06

Thousands of $ %

Solid wood flooring:

Brazil:

Exports to:

United States 71,900 106,680 195,754 222,548 292,814 42.1

France 7,411 10,876 29,887 39,851 51,248 62.2

Netherlands 5,500 11,480 20,289 23,577 37,108 61.2

 All other 39,527 53,037 75,647 90,575 125,414 33.5

 Total exports 124,336 182,073 321,577 376,551 506,584 42.1

 Total imports 390 668 287 2,427 3,052 67.3

Canada:

Exports to:

United States 101,501 149,013 163,488 132,028 113,950 2.9

Ireland 6,848 8,924 8,491 6,246 5,353 -6.0

United Kingdom 8,943 8,512 5,249 4,390 3,743 -19.6

 All other 9,649 15,360 11,558 11,729 9,689 0.1

 Total exports 126,941 181,809 188,786 154,393 132,735 1.1

 Total imports 142,383 170,422 253,502 305,934 331,124 23.5

Indonesia:

Exports to:

United States 36,992 49,549 63,818 64,375 93,989 26.3

China 95,770 109,570 118,633 117,003 85,177 -2.9

Netherlands 16,560 24,415 36,308 38,088 62,414 39.3

 All other 204,537 245,373 327,070 379,316 465,015 22.8

 Total exports 353,859 428,907 545,829 598,782 706,595 18.9

 Total imports 1,856 782 2,843 2,076 5,607 31.8

Malaysia:

Exports to:

Japan 39,082 43,278 52,121 54,293 50,768 6.8

United States 47,810 39,728 51,656 48,026 48,975 0.6

Netherlands 18,250 21,847 26,200 26,969 38,871 20.8

 All other 122,897 120,684 153,764 139,255 168,858 8.3

 Total exports 228,039 225,537 283,741 268,543 307,472 7.8

 Total imports 14,072 21,423 28,493 25,083 40,869 30.5

Russia:

Exports to:

Lithuania 0 0 72 160 3,592 

Kazakhstan 1,034 1,326 1,639 1,871 2,172 20.4

United States 194 258 434 772 1,184 57.2

 All other 1,424 2,538 4,385 4,587 7,163 49.8

 Total exports 2,652 4,122 6,530 7,390 14,111 51.9

Total imports 10,677 12,577 15,003 19,657 30,417 30

See note at end of table.
5-14

TABLE 5.5 Foreign supplier countries: Exports and imports of plywood wood flooring, 2002–06—Continued

Source 2002 2003 2004 2005 2006

CAGR

2002–06

Thousands of $ %

Plywood and engineered and solid

wood flooring:

Brazil:

Exports to:

United States 136,190 188,254 312,839 296,613 353,545 26.9

France 8,666 13,118 33,911 42,382 55,341 59.0

United Kingdom 52,504 43,729 72,777 48,824 51,835 -0.3

 All other 121,998 158,980 234,129 216,209 241,953 18.7

 Total exports 319,358 404,081 653,656 604,028 702,674 21.8

 Total imports 774 696 420 2,706 3,549 46.3

Canada:

Exports to:

United States 300,014 339,053 382,877 395,368 369,188 5.3

Ireland 6,901 8,968 8,527 6,301 5,373 -6.1

United Kingdom 8,943 8,641 5,282 5,013 4,079 -17.8

 All other 10,272 16,085 13,458 14,239 11,475 2.8

 Total exports 326,130 372,747 410,144 420,921 390,115 4.6

 Total imports 227,581 264,315 389,611 433,057 484,228 20.8

Indonesia:

Exports to:

Japan 677,099 594,125 668,728 571,483 659,165 -0.7

United States 190,116 155,616 174,429 164,676 205,836 2.0

China 160,610 208,324 200,869 179,704 133,330 -4.5

 All other 688,890 766,023 753,818 752,154 803,371 3.9

 Total exports 1,716,715 1,724,088 1,797,844 1,668,017 1,801,702 1.2

 Total imports 2,761 1,277 5,181 5,947 16,733 56.9

Malaysia:

Exports to:

Japan 537,236 595,073 773,326 756,114 1,084,289 19.2

United States 167,132 141,977 213,930 208,372 232,832 8.6

Korea South 117,611 129,066 107,694 138,141 167,737 9.3

 All other 400,397 420,570 556,506 579,499 686,777 14.4

 Total exports 1,222,376 1,286,686 1,651,456 1,682,126 2,171,635 15.5

 Total imports 16,515 22,518 31,606 31,107 53,152 33.9

Russia:

Exports to:

United States 89,293 84,289 125,010 126,398 97,333 2.2

Egypt 22,467 26,087 25,267 41,415 47,979 20.9

Germany 11,478 15,265 27,849 33,925 42,908 39.0

 All other 121,554 137,122 202,427 278,245 330,650 28.4

 Total exports 244,792 262,763 380,553 479,983 518,870 20.7

 Total imports 13,674 16,541 19,666 26,034 41,049 31.6

Source: GTIS, Global Trade Atlas Database (accessed May 15, 2008).

Note: Export values as reported at the 6-digit level for HTS subheadings 4409.20, 4412.13, 4412.14, 4412.22,

4412.29, 4412.23, and 4418.30. 
 56 According to industry officials, the Brazilian industry relies primarily on exotic species such as Jatoba,

Ipe,, Cumaru, and Muracatiara (also known as Brazilian Cherry, Walnut, Teak, and Tigerwood, respectively) 

These species exist only in Brazil and do not grow anywhere in {North America}. USITC hearing transcript,

October 3, 2007, 217.

 57 Combi-plywood is hardwood plywood with face and back of tropical hardwood veneer and core of pine

veneer and is considered hardwood plywood for the purposes of this study.

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TABLE 5.6 Foreign supplier countries: Share of exports of hardwood plywood and wood flooring by 

market, 2002–06 (%)

Source 2002 2003 2004 2005 2006

Brazil:

 United States 42.6 46.6 47.9 49.1 50.3

 EU 37.6 35.2 35.2 33.2 35.2

 Canada 1.5 2.2 2.5 3.0 2.4

 All other 18.2 16.0 14.4 14.8 12.1

Canada:

 United States 92.0 91.0 93.4 93.9 94.6

 EU 5.4 6.2 4.0 3.5 3.1

 Japan 0.5 0.7 0.6 0.5 0.3

 All other 2.1 21.0 2.1 2.0 1.9

Indonesia:

 Japan 39.4 34.5 37.2 34.3 36.6

 EU 11.3 11.1 13.5 15.5 16.9

 United States 11.1 9.0 9.7 9.9 11.4

 All other 38.2 45.4 39.6 40.4 35.1

Malaysia:

 Japan 44.0 46.2 46.8 44.9 44.9

 United States 13.7 11.0 13.0 12.4 10.7

 EU 9.3 8.3 9.6 8.2 9.8

 All other 33.0 34.4 30.6 34.5 29.6

Russia:

 EU 41.3 42.6 47.4 50.4 54.7

 United States 36.5 32.1 32.8 26.3 18.8

 Egypt 9.2 9.9 6.6 8.6 9.2

 All other 13.0 15.4 13.1 14.6 17.2

Source: GTIS, Global Trade Atlas (accessed May 15, 2008).

Note: Export values as reported at the 6-digit level for HTS subheadings 4409.20, 4412.13, 4412.14, 4412.22,

4412.29, 4412.23, and 4418.30. 

Canada, Malaysia, and Russia were the only countries to increase exports of hardwood

plywood during the period, whereas Indonesian hardwood plywood exports decreased by 42

percent. During the period, Indonesian domestic consumption of hardwood plywood

increased by 182 percent. In fact, domestic consumption increased in 3 of th 5 countries

(except for Canada and Malaysia); domestic consumption nearly tripled in Brazil.

An estimated 60 percent of Brazilian plywood in 2000 was produced from tropical

hardwood;56 the remainder came from softwood (particularly pine) from the plantations in

the south of the country. Softwood plywood and combi-plywood57 are now the major types
 58 Although there are no official production data on wood flooring, Commission staff estimated tropical

hardwood lumber production based on data from industry leaders and unofficial data furnished by the sector.

 59 ANPM, written submission to the USITC, October 3, 2007, question 1, Q-2.

 60 Ibid., 2.

 61 HPVA, Hardwood Stock Panels: Annual Statistical Report for Calendar Year 2004, 2005. Data for

2002 are not available. These data are from Canadian hardwood plywood producers and likely account for

the majority of total Canadian production of hardwood plywood. Industry officials, interviews by

Commission staff, Washington, DC, August 14, 2007 and September 13, 2007.

 62 One Canadian hardwood plywood producer stated that Canadian demand has been flat or has increased

slightly during the past five years. 

 63 Industry officials, interviews by Commission staff, Washington, DC, August 14, 2007, and September

13, 2007.

 64 Wood flooring trade associations in Canada do not collect production or shipment data from their

members. No production or shipment data for wood flooring are available from the Canadian government.

 65 Industry officials, interviews by Commission staff, Washington, DC, September 13, 2007, October 24,

2007, and November 7, 2007.

5-16

of plywood produced in Brazil, and their use is continuing to increase due to the increased

availability of materials from fast-growing pine plantations.58

As Brazilian manufacturers have developed downstream products such as engineered wood

flooring and cabinetry, hardwood plywood exports have decreased, falling by 57 percent

from 2002 to 2006. The United States and the United Kingdom remain the top destination

for Brazilian exports of hardwood plywood, about one-third of exports are to the United

States, about one-quarter to Europe, and the remainder to other markets.59 Moreover, Brazil

is the leading producer of “exotic” species of solid wood flooring. Brazil accounts for about

5 percent of such U.S. hardwood-flooring sales.60

Canadian production of hardwood plywood fluctuated only slightly during the 2002–06

period (table 5.4). In 2006, hardwood plywood made with a veneer core accounted for 65

percent of total Canadian production of hardwood plywood; hardwood plywood made with

particle board cores, MDF cores, and cores made from other material accounted for 27

percent, 6 percent, and 2 percent, respectively, of total Canadian production.61 Canadian

domestic consumption of hardwood plywood decreased during the past five years and is only

3 percent of U.S. domestic consumption.62 The decline of the wood furniture industry in

Canada has reduced their domestic demand for hardwood plywood.63

Production of wood flooring in Canada is believed to have grown from 2002 to 2005, but

to have declined or been flat since then.64 Production for a growing Canadian market has

been dampened by increased wood flooring imports and a decline in exports to the United

States because of the appreciating Canadian dollar, the weakening U.S. housing market, a

decline in demand for some of the Canadian wood species used to make flooring, and rising

U.S. imports of wood flooring from other countries. Canadian consumption of wood flooring

is believed to have grown during the past five years in response to strong construction and

remodeling activity and some displacement of other types of flooring by wood flooring.65

Industry estimates indicate that in 2007, 25 percent of domestic wood flooring production

was consumed domestically. The rapid growth in imports of wood flooring and hardwood

plywood suggests that imports likely increased their share of the Canadian market for these

products over the period. 

Overall, Canadian exports of wood flooring and hardwood plywood rose steadily from 2002

to 2005. In 2006, however, exports declined by 7.3 percent to $390 million. The United

States remained the top destination (accounting for 90 percent of all Canadian hardwood
 66 UNCTAD Info Comm, “Tropical Timber Production,” undated (accessed May 19, 2008).

 67 ITTO, Annual Review and Assessment of the World Timber Situation 2006, July 2006, 10–11.

 68 USITC hearing transcript, October 3, 2007, 284.

 69 Turner, Katz, and Buongiorno, Implications for the New Zealand Wood Products Sector, July 2007, 16.

 70 Adams, “Is This the End of Thin-panel Tropical Plywood?” 2003.

 71 There is no evidence that domestic consumption has expanded faster than exports.

 72 ITTO, Annual Review and Assessment of the World Timber Situation 2006, July 2006, 10–11; and FAO,

“Forest Industry Structures,” May 1997, 33.

 73 GTIS, Global Trade Atlas Database (accessed June 5, 2007).

 74 ITTO, “Annual Review and Assessment of the World Timber Situation 2006,” July 2006, 10–11.

 75 ITTO, “Forest Industry Structures,” May 1997, 28.

5-17

plywood exports throughout the period). Imports of hardwood plywood, and wood flooring,

much of which came from the United States, more than doubled (table 5.5).

According to the ITTO, Indonesia’s hardwood plywood production increased by

approximately 35 percent to over 6.1 million m3

 from 2004 to 2006 (table 5.4). Due to

logging quotas and crackdowns on illegal logging, however, Indonesian plywood production

had been depressed in 2004 and 2005 to approximately 4.5 million m3

.

66 Due in part to raw

material constraints, Indonesian plywood production was forecast to remain stable in 2007.67

Indonesia specializes in the production and exportation of thin plywood (2.7 and 3.4

millimeters thick), which is not typically produced in the United States. The veneers of

Indonesian species are smooth, lightweight, light in color, and open grained, which allow

them to be used in many different applications.68

The Indonesian plywood industry suffers from overcapacity and low productivity.69 In 2003,

Indonesia’s capacity utilization was approximately 40 percent. The overall Asian plywood

sector reportedly operates at 50 percent of capacity.70 Data on Indonesian production of wood

flooring is not available. However, Indonesia, the world’s second largest producer of tropical

hardwood lumber, produced approximately 7 million m3

 of such lumber in 2006. It is likely

that the production of solid wood flooring has grown significantly since 2002, as exports

from Indonesia have registered strong growth.71

Indonesia’s top export markets for hardwood plywood and wood flooring are Japan (55

percent) and the United States (10 percent) (table 5.6).72 Middle Eastern and European

markets are increasingly important markets for Indonesian plywood producers. Indonesian

imports of hardwood plywood have been negligible since 2002, in part because imports of

veneer, plywood, and parquet flooring are subject to a 5–10 percent rate of duty.

The value of Indonesian exports of solid wood flooring nearly doubled since 2002, growing

by approximately 20 percent per year to nearly $707 million in 2006 (table 5.5). The EU was

the top destination for Indonesian solid wood flooring exports during the 2004–06 period

and accounted for 35 percent of the total in 2006. The second leading export market was

China, accounting for 12 percent of Indonesian exports.73 Indonesian imports of solid wood

flooring are negligible.

During the 2002–06 period, Malaysian hardwood plywood production increased by 17

percent by volume (table 5.4), and production was forecast to increase by 2 percent to 5.2

million m3

 in 2007.74 Reportedly, raw materials previously exported as sawnwood and veneer

from Sabah and Sarawak are now being converted to plywood at domestic mills.75 According

to Malaysian Timber Forum, the tightening of available raw materials and the emergence of

substitute materials (e.g., MDF) contributed to the slight contraction of the Malaysian
 76 Malaysian Timber Forum, “People Who Live in Glass Houses,” undated (accessed August 20, 2007).

 77 Seneca Creek Associates LLC, and Wood Resources International LLC, Illegal Logging and Global

Wood Markets, November 2004, 82–83.

 78 Malaysian Timber Forum, “People Who Live in Glass Houses,” undated (accessed August 20, 2007).

 79 GTIS, Global Trade Atlas Database (accessed June 5, 2007).

 80 Ibid.

 81 According to one industry source, 92 percent of all Russian plywood production consists of hardwood

(mainly birch) and nearly 100 percent of plywood exports are birch, as softwood plywood produced in

Russia is too low in quality for export markets. According to another source, there is only one large softwood

plywood mill operating in Russia today. Industry official, e-mail messages to Commission staff, June 5 and

19, 2007. FAO, FAOSTAT Forestry Database (accessed June 5, 2007).

 82 Industry official, e-mail message to Commission staff, June 5, 2007.

 83 European Federation of the Plywood Industry, Annual Report, 2006-2007, June 8, 2007; and GTIS,

Global Trade Atlas Database (accessed June 5, 2007).

 84 Rutton and Hock, “Reviving Tropical Plywood,” May, 2004, 35–37.

5-18

plywood industry in 2004.76 More than 70 percent of Malaysia’s plywood production is

exported to markets in Asia (table 5.6), principally Japan and Korea.77 The growth of

Malaysian plywood production was driven by foreign market demand; Malaysian exports

rose by 1.2 million m3

 while the domestic market declined by nearly 500,000 m3 (table 5.4).

Due to the increased use of substitute materials such as particleboard and MDF, domestic

consumption of plywood has decreased, pushing the Malaysian plywood industry to find

additional export markets.78

Malaysian exports of solid wood flooring increased 35 percent by value from 2002 to 2006,

with the largest increase in 2004 (table 5.5). The EU has been the leading market for

Malaysian solid wood flooring since 2002, and accounted for 43 percent of all Malaysian

exports of solid wood flooring in 2006. The next leading export market was Japan at $50.7

million, accounting for 17 percent of Malaysian exports.79 Malaysian imports of solid wood

flooring are negligible.80

Russian production of plywood rose by 9.3 percent from 2002 to 2006 reflecting strong

housing-related demand in Russia and strong demand for Russian exports of plywood (table

5.4).81 In 2006, exports of plywood accounted for over 60 percent of the total volume of

plywood produced in the Russian Federation.82 Russian exports of hardwood plywood

increased by 75 percent in quantity terms and more than doubled in value terms during the

2002–06 period to 1.4 million m3

 ($504 million).83 The United States was Russia’s leading

market for hardwood plywood and wood flooring in 2006, accounting for 19 percent of total

Russian exports (table 5.6).

Production Costs

Given the wide variation in the quality, type, and species of raw materials and the large

number of wood flooring and hardwood plywood products, the cost of production for wood

flooring and hardwood plywood is not readily available. For all the foreign suppliers covered

by this study, the cost of raw material, whether it be logs, lumber, or veneer, accounts for the

largest portion of the cost of production for both wood flooring and hardwood plywood. Raw

material costs, as a percentage of the cost of the product, range from 40 to 80 percent,

followed by labor, which is generally 15–25 percent of the cost of production.84
 85 Industry officials, interviews by Commission staff, Washington, DC, August 14 and September 13,

2007.

 86 Ibid.

 87 Seneca Creek Associates LLC and Wood Resources International LLC, “Illegal Logging and Global

Wood Markets,” November 2004, 72–73.

 88 Rutton and Hock, “Reviving Tropical Plywood” 2004, 37.

 89 Ibid., 15 and 27.

 90 Industry officials, interviews by Commission staff, Washington, DC, September 14 and October 10,

2007.

5-19

Raw Material Costs

Log and lumber markets reportedly are competitive in these supplier countries, and because

hardwood logs, particularly higher-valued logs, are traded internationally, log prices in these

countries track global markets to some degree.

In Canada, hardwood log costs reportedly have been rising, due to rising harvesting costs

and the cost of transporting logs from greater distances. However, one Canadian producer

noted that the costs for particle board cores, MDF cores, and hardwood veneer have

generally been flat over the 2002–06 period.85 Hardwood lumber costs for wood flooring

producers in Canada rose from 2002 to 2005, but flattened or declined thereafter.86

In Indonesia, the cost for legally harvested hardwood logs varied from $50 to $140 per m3,

and illegally sourced logs reportedly were 35–50 percent of the legal timber price.87 In

Malaysia, logs account for around 50 percent of production costs in Sabah and Sarawak and

up to 60 percent in Peninsular Malaysia for plywood and sawn timber producers.88

Downstream producers in Peninsular Malaysia do not have concessions and purchase their

raw materials on one- or two-month contracts. Therefore, volatility in log prices is a major

concern, because plywood is generally sold one or two months ahead, using short term (i.e.,

three month) contracts, it is difficult for mills to adequately plan for and purchase logs at an

acceptable price, and to organize the logistics of production and transport in such a way that

plywood is delivered on time.89 Malaysian hardwood log prices more than doubled during

the 2002–07 period (figure 5.1).

 Labor Costs 

The cost of labor, the second largest cost component, is considerably lower in the foreign

supplier industries than in the United States with the exception of Canada. Despite the fact

that forest industries are major employers in the economies of these supplier countries, data

on labor costs for these specific industries are not readily available. However, labor appears

to account for fairly similar percentages of the cost of production in all supplier countries.

In Brazil labor typically accounts for 15–20 percent of the total cost of production for wood

flooring.90 In Canada, labor accounts for 10–15 percent of the total cost of production for
 91 Industry officials, interviews by Commission staff, Washington, DC, September 14, October 10, and

November 7, 2007.

 92 Ibid.

 93 Based on a 45-hour work week and 52 weeks a year, Indonesian workers are paid $0.22–0.39 per hour

on Borneo; wages on Sumatra average $0.28 per hour. Workers in the plywood and other wood processing

sectors on Borneo and Sumatra are paid less, between $0.22 and $0.28 per hour. Government of Indonesia,

Ministry of Manpower and Transmigration, “Wage Matters,” undated (accessed November 11, 2007).

5-20

wood flooring and from 15–30 percent of the total cost of production of hardwood plywood.

Wages in Canada, at least for hardwood plywood workers, have increased by roughly 3–5

percent annually in the past few years. For one large Canadian wood flooring firm, wages

for factory workers are C$10–C$15 ($9–$14) per hour plus benefits, and wages for

supervisors are C$15–C$20 ($14–$19) per hour plus benefits.91 Given the recent appreciation

of the Canadian dollar, wages and benefits for workers in the wood flooring industry and the

hardwood plywood industry in Canada are believed to be comparable to, or even higher than,

wages and benefits for workers in the U.S. industries.92

According to official Indonesian wage statistics, monthly wage rates in East Kalimantan,

where a majority of the wood flooring and hardwood plywood production occurs, were Rp

400,000 ($43). Wage rates in South Kalimantan, with a smaller forest products industry,

were as low as Rp 377,500 ($41). The average monthly wage rate for employees in the

plywood and wood processing sector on Sumatra was Rp 510,400 ($55). However, the

average monthly wages for Borneo increased by over 37 percent from 2003 to 2006. On

average, production related workers that earn Rp 400,000–700,000 ($43–$76) per month,

work 45–60 hours a week.93

In contrast to Indonesia, basic wage rates in Malaysia vary according to location and

industrial sector, while supplementary benefits (e.g., bonuses, uniforms, free or subsidized

transport, performance incentives) can vary from company to company. The average basic

monthly salary ranges from Rm 515 ($145) for unskilled workers to Rm 565 ($159) for

50

100

150

200

250

2002 2003 2004 2005 2006 2007

$ per cubic meter

Kapur Keruing Meranti

FIGURE 5.1 Malaysia: Nominal hardwood log prices, 2002–07

Source: ITTO Pricing Database (accessed February 20, 2008).
 94 There is no national minimum wage law applicable to the manufacturing sector in Malaysia. Based on

a 45-hour work week and 52 weeks a year, Malaysian workers are paid approximately between $0.74 and

$1.06 an hour. Malaysian Industrial Development Authority, “Minimum Wage by Region,” undated

(accessed May 19, 2008).

 95 Production for order helps users reduce their inventory carrying costs. Industry officials, interviews by

Commission staff, Washington, DC, August 10 and September 13, 2007.

 96 The plywood layer directly under installed wood flooring or other floor coverings. Underlayment

provides a smooth surface on which to install flooring.

 97 Ibid.

5-21

semi-skilled workers, and wages may reach Rm 734 ($207) for skilled workers/craftsmen.94

Data specific to the plywood and flooring industries are not available.

Marketing Practices

For hardwood plywood, the channels of distribution within the U.S. market are similar for

the producers for all five foreign suppliers, and not unlike those for domestic producers.

Production in foreign supplier countries for the U.S. market is generally produced to order,

not for inventory, and typically consists of many batch-type orders rather than long

production runs of a few standard types of hardwood plywood.95 Since most hardwood

products are produced to order, the product, and not the country of origin, appears to be the

dominant characteristic in determining the channels of distribution. Competitive products

move through the same channels of distribution. Thin hardwood plywood, which

predominately goes to producers of manufactured homes and RVs, has different distribution

channels and does not appear to compete head-to-head with domestic U.S. products.

Imported wood flooring goes through distributors or wholesalers, as well as the major

branded U.S. manufacturers, to flooring installers for use as underlayment.96

Distribution channels for Canadian plywood are very similar or the same as those for U.S.

plywood. Wholesale Canadian producers sell the vast majority of their hardwood plywood

through numerous building materials distributors, which in turn sell to end users. Small

volumes of hardwood plywood are also sold directly to furniture and cabinet makers and to

large retail outlets. The channels of distribution for Canadian hardwood plywood have not

changed significantly in the past five years.97
 98 Ibid.

 99 Ibid.

 100 Industry officials, interviews by Commission staff, Washington, DC, September 10, October 24, and

November 14, 2007.

5-22

The channels of distribution for wood flooring are similar to those for hardwood plywood,

although somewhat simpler, and do not vary among suppliers. Direct purchasers of imported

solid and engineered wood flooring include distributors, homebuilders, flooring retailers and

installers, independent hardwood specialty stores, building materials distributors, and

homebuilding stores. The majority of imported solid wood flooring is likely handled by

distributors that have direct ties with, or represent, producers in the five supplier countries.

Finally, it appears that branding is more important for wood flooring than for hardwood

plywood.98

Prices

The price trends in this section are based on industry observations or individual company

price sheets, since there are no independently published price series or indexes for wood

flooring or hardwood plywood in the United States or foreign supplier markets.

In Canada, prices for hardwood plywood reportedly were flat or have declined in the past

five years due to increased competitive pressures and rising imports.99 According to industry

sources, prices for wood flooring declined in the past few years because of competition from

low-priced imports and the construction slowdown in the United States. Some producers

experienced greater price deterioration for engineered wood flooring than for solid wood

flooring, and attributed that difference to increased Canadian imports of engineered wood

flooring from China.100

Prices for Indonesian thin (2.7 mm) plywood increased considerably since 2002 (figure 5.2).

Malaysian prices, although following the same pattern, remained slightly above Indonesian

prices for the same product. Prices for 3 mm plywood from Indonesia and Malaysia,

although similar to 2.7 mm plywood, did not increase as much (figure 5.3). Furthermore,

Indonesian and Malaysian prices diverged in early 2006 with Malaysian prices remaining

above those of Indonesia throughout 2006 and 2007. Thick plywood (6 mm–19 mm),

although following the same increasing price trend as thin plywood, was considerably less

expensive than the other sizes (figure 5.4). Brazilian thick plywood remained above similar

plywood from Indonesia and Malaysia throughout the period. This price gap was most

notable from 2002 to 2004. However once Indonesia and Malaysia began cracking down

on illegal logging in 2004, the price gap began to close and by 2007, prices nearly converged

with those for Brazilian plywood.
5-23

100

200

300

400

500

2002 2003 2004 2005 2006 2007

$ per cubic meter

Indonesia Malaysia

FIGURE 5.3 Plywood: Indonesia and Malaysia nominal 3 mm plywood prices, 2002–07

Source : ITTO Pricing Database (accessed February 20, 2008).

100

200

300

400

500

2002 2003 2004 2005 2006 2007

$ per cubic meter

Indonesia Malaysia

FIGURE 5.2 Thin Plywood: Indonesia and Malaysia nominal 2.7 mm plywood prices, 2002–07

Source : ITTO Pricing Database (accessed February 20, 2008). 
 101 Schloenhardt, “The Illegal Trade in Timber,” 2008, 68; CITES Web site. http://www.cites.org

(accessed June 30, 2008); Convention on Biological Diversity Web site. http://www.cbd.int (accessed June

30, 2008); and International Tropical Timber Agreement Web site. http://www.itto.or.jp (accessed June 30,

2008).

 102 USDA, FAS, “Brazilian Softwood Plywood Production and Export Continue to Accelerate,” March 4,

2005, 2.

 103 ITTO, “Brazil,” 2006, 208.

5-24

Government Programs

A wide range of policies, strategies, laws, and regulations have been developed in these five

supplier countries to facilitate forest management, as well as to promote the development of

the wood products industries. This extensive government involvement is attributable to the

high degree of state ownership of forest resources and the relative importance of the forest

products sector to the national economies of these countries. Moreover, all of these major

supplier countries are signatories to a number of key international treaties, including the

Convention on the International Trade in Endangered Species (CITES), the Convention on

Biological Diversity, and the International Tropical Timber Agreement.101 Illegal logging is

a primary concern in four of the five countries—Russia and the three tropical countries,

Brazil, Indonesia, and Malaysia. All of these countries have taken steps to combat domestic

illegal logging, with varying degrees of success.

Brazilian forest products incentives, such as tax breaks, beneficial credit programs, and

subsidies, are designed to promote exports. For example, the government offers tax and tariff

exemptions for equipment imported for the production of forestry goods for export, an excise

and sales tax exemption on these exported goods, and eligibility for a rebate on the social

contribution tax (pensions).102

The Brazilian national forest policy, the National Forest Program 2000–2010 (Programa

Nacional de Florestas, PNF), was launched in 2001 to ensure that forests are sustained.103

One of the goals of the program is to establish 50 million hectares (124 million acres) of

managed national forests and 20 million hectares (49 million acres) of forest plantations on

100

200

300

400

500

2002 2003 2004 2005 2006 2007

$ per cubic meter

Indonesia 6mm Malaysia 9-18mm Brazil 5.7mm

FIGURE 5.4 Thick plywood: Brazil, Indonesia and Malaysia nominal plywood prices, 2002–07

Source : ITTO Pricing Database (accessed February 20, 2008). 
 104 These measures include: (1) a moratorium on the harvesting and sale of over-harvested species; (2) the

introduction and implementation of measures to control illegal logging through high-tech devices for

timber-tracing and satellite data transfer; (3) limiting the area allowed for farming in forest properties in the

Amazon; (4) yield regulation in natural selection forests; and (5) restoration forestry programs. ITTO,

“Brazil,” 2006, 210–13.

 105 ANPM, written submission to the USITC, October 3, 2007, III, A, 6, and Q-5. However, deforestation

rates reportedly increased substantially from August to December of 2007. BBC News, “Brazil Amazon

deforestation soars,” January 24, 2008, http://news.bbc.co.uk/2/hi/americas/7206165.stm (accessed August 5,

2008).

 106 ANPM, written submission to the USITC, October 3, 2007, III, C, 7.

 107 Natural Resources Canada, The State of Canada’s Forests, 2007.

 108 Natural Resources Canada, The State of Canada’s Forests 2005–2006, 2006.

 109 Industry officials, interviews by Commission staff, Washington, DC, August 14, September 13,

October 10, and November 7, 2007.

 110 Indonesia has more that 17,000 islands within its borders which make enforcing the log export ban

difficult.

 111 EU Voluntary Partnership Agreement Web site.

http://www.illegal-logging.info/sub_approach.php?subApproach_id=121 (accessed May 19, 2008).

 112 Industry official, telephone interview by Commission staff, November 11, 2007.

5-25

private land by 2010. The legislation also establishes penalties for forest crimes (Decree no.

3179). Recent measures taken by the Brazilian government to protect the Amazon are

reportedly producing positive results.104 In August 2007, the government reported that the

rate of deforestation in the Amazon rainforest dropped by 25 percent in 2006 to the lowest

recorded rate since the mid-1970’s. Reportedly, preliminary data for 2007 show that

deforestation had further declined by 9,600 square kilometers, representing a 31 percent

decline from 2006.105 In 2007, nine Brazilian nongovernmental organizations entered a pact

aimed at ending deforestation in seven years.106

Though not specifically targeting wood flooring and hardwood plywood, the Canadian

federal and provincial governments have taken steps to maintain the competitiveness of the

Canadian forest products sector. In February 2007, the Canadian federal government

announced the Forest Industry Long-Term Competitiveness Initiative, a program of financial

assistance to the forest products sector in such areas as the development of new wood

products and manufacturing processes, the development of new export markets, and worker

retraining.107 In 2005 and 2006, the province of Ontario announced financial assistance to its

forest products sector in such areas as worker training, electricity conservation, and more

efficient use of wood fiber. In 2006, the province of Quebec budgeted substantial financial

aid to its forest products sector.108 However, according to Canadian industry officials, there

are no government programs that specifically target the hardwood plywood industry or the

wood flooring industry in Canada.109

Like Brazil, Indonesia has several policies aimed at reducing illegal logging. These polices

limit and control the transportation of logs within Indonesia as well as ban international trade

of raw logs.110 Important Indonesian policies include the log export ban and the sawnwood

export tax. To further combat illegal logging, the government of Indonesia also signed

MOUs with Japan, the United Kingdom, and the United States. Furthermore, like Malaysia,

Indonesia is currently negotiating a voluntary partnership agreement as a means to

implement the EU’s FLEGT licensing system (see chapter 2).111

In contrast with Brazil and Indonesia, representatives of the Malaysian industry claim that

illegal logging is a minor issue in its forest sector.112 Malaysia has established certification

and transportation policies to ensure that logs imported, transported, and/or exported are all

of legal origin. Moreover, since 2005 Malaysia has banned the importation of Indonesian
 113 ITTO, Annual Review and Assessment of the World Timber Situation 2006, July 2006, 10–11; and

FAO, “Forest Industry Structures,” May 1997, 33.

 114 ITTO, Annual Review and Assessment of the World Timber Situation, 2006, July 2006, 33.

 115 U.S. Department of State official, e-mail message to Commission staff, September 28, 2007.

 116 Van Leeuwen, Wood Markets: Monthly International Report, April 2007, 1.

 117 Roberts, Carreau, and Lethbridge, “Russia Plans to Dramatically Increase Its Export Tax On Logs,”

February 22, 2007, 4. 

 118 Van Leeuwen, Wood Markets: Monthly International Report, April 2007, 4.

 119 Ibid., 5.

 120 Logs typically constitute as much as 65 percent of the variable cost of producing plywood. Roberts,

Carreau, and Lethbridge, “Russia Plans to Dramatically Increase Its Export Tax On Logs,” February 22,

2007, 6.

5-26

logs and squared timber to assist Indonesia in its efforts to combat illegal logging,

particularly by stemming the flow of illegal logs crossing its sparsely populated land border

with Indonesia on Borneo. The Malaysian Timber Industries Board reported that the

prohibition of imports of large square and scantling (LSS) logs with a diameter of less than

60 inches was also meant to help curb illegal logging in Indonesia. Limitations on the size

of timber that can be traded ensures that younger trees are not felled so that forests have time

to regenerate.

The Malaysian government promotes the exportation of downstream value-added products,

including plywood and flooring by applying export taxes on raw materials. Malaysia also

discourages imports of plywood by applying a 45 percent import tariff. Veneer faces a 25

percent import tariff, although face veneers may be imported free of duty.113 The government

also administers programs to expand timber processing capacity such as tax rebates or

processing incentives to the millers and log producers, provision of land infrastructure,

establishment of shipping facilities, and the development of special areas for timber-based

activities known as timber processing zones.114 Further, the Ministry of Plantation Industries

and Commodities provides support for the development of forest plantations by providing

15 years of tax relief to firms establishing forest plantations. Companies can either take tax

deductions equivalent to the amount of investment made, or obtain group relief, which

allows a company to offset the losses incurred from the profits of another company within

the same group.115

The Malaysian government has established several agencies to develop and promote its

forest industries: the Malaysian Timber Industry Board, which regulates the timber industry;

the Forest Department, which oversees timber resources; and the National Timber

Certification Council, which develops and monitors the national timber certification scheme.

Russia primarily uses export tax policies to promote the development of its wood processing

sector, including hardwood plywood and wood flooring. In February 2007, the government

of Russia announced a new log export tax schedule that will result in rates of 40 percent by

January 2009.116 The government of Russia hopes that this policy will attract both foreign and

domestic investment in the next two to three years,117 particularly from neighboring log

importing nations.118 The government of Russia expects its log export policies to increase its

exports of downstream wood products in five to seven years.119 Analysts estimate that the

direct effects will include lower log prices in Russia, which would benefit local flooring and

plywood manufacturers,120 and higher log prices outside Russia given both the magnitude of

the export tax increase and Russia’s large share of the global log market. Thus, Russian

plywood should be more competitive in global markets. Indirect effects will likely be felt by

timber operations in North America that may benefit as they supply part of the gap caused

by the reduction in Russian log exports, while Chinese and European sawmills that rely on
 121 Van Leeuwen, Wood Markets: Monthly International Report, April 2007, 5; and Roberts, Carreau, and

Lethbridge, “Russia Plans to Dramatically Increase Its Export Tax On Logs,” February 22, 2007, 6–7.

 122 Schloenhardt, “The Illegal Trade in Timber,” 2008, 68; and Federal Forestry Agency of RF, Concept

of National Action Plan for Preventing Illegal Logging and Associated Trade, March 2006, 16.

 123 Federal Forestry Agency of RF, Concept of National Action Plan, March 2006, 12.

 124 Roberts, Carreau, and Lethbridge, “Russia Plans to Dramatically Increase Its Export Tax On Logs,”

February 22, 2007, 10. 

5-27

Russia as a principal of hardwood logs may face log shortages and higher Russian log

prices.121

Under the Forest Code 2006, the Russian Federal Forest Agency established a number of

initiatives to reduce illegal logging, one of which was an effort to cover 100 percent of the

area of commercially exploited forests with a remote sensing system, with a goal of reducing

illegal logging by 20–30 percent within the first two years.122 Other initiatives included

improvements to the system for obtaining and monitoring logging licenses, establishment

of long-term forest leasing of remote sensing/monitoring, and facilitation of the national

forest certifications systems.123 In 2007, the Russian government adopted the 2007 Forest

Code with the goal of accelerating investment in the forest sector.

The principal features of this code were the creation of a legislative and legal system to

guarantee the rights of investors and provide the stability needed to attract foreign

investment, and a shift in the ownership of forest resources from federal to regional

authorities.124

6-1

CHAPTER 6

Competitive Conditions in the U.S. Market 

The structure of the global wood flooring and hardwood plywood market is changing.

Production of wood flooring and hardwood plywood has increased in developing countries

even as developed countries remain the largest markets for these products. Consequently,

trade in these products is increasing. In addition to the increased capability and new entrants

in foreign industries, relatively high production costs in the United States, recent trends in

exchange rates, and structural changes in the U.S. industries and U.S. markets shaped the

competitive environment during the 2002–07 period.

U.S. production, consumption, and trade of wood flooring and hardwood plywood all

increased during the 2002–07 period. However, the share of the domestic markets supplied

by domestic industries is declining, and the share held by imports is rising. In 2002, U.S.

producers supplied about two-thirds of the U.S. wood flooring and hardwood plywood

market. By 2007, U.S. producers supplied just over one-half of the U.S. market. Domestic

market share is particularly important as the U.S. industries have traditionally focused on the

large U.S. market, and exports have historically accounted for a small share of U.S.

production. This decline in domestic market share is due to a number of factors.

The key factors affecting the competitive position of the U.S. wood flooring and hardwood

plywood industries in the U.S. market include the following:

• U.S. demand for wood flooring and hardwood plywood showed very strong growth

for most of the period, driven in large part by the continued strength of the U.S.

residential housing market. Spurred by this growing demand, domestic flooring

producers were able to significantly increase production and capacity. In contrast,

hardwood plywood producers did not increase production or capacity during the

period.

• A significant shift in U.S. market preferences toward products such as prefinished

wood flooring, exotic species for solid wood flooring, and engineered wood

flooring, largely benefitted foreign suppliers who were able to respond to increased

U.S. demand.

• U.S. producers of wood flooring and hardwood plywood increased imports of

finished products either to broaden product lines or to supplement domestic

production and increased imports of platforms for engineered wood flooring and

hardwood plywood to lower production costs. 

• Reportedly increasing market power of large domestic retailers, coupled with their

logistical ability to source products overseas, contributed to the further erosion of

the domestic market share of the U.S. wood flooring and hardwood plywood

industries and may also have weakened U.S. producers’ ability to negotiate prices.
6-2

• China emerged as a major global competitor and supplier to the U.S. market.

Despite an expanding domestic market, the rapid growth of Chinese production and

exports of engineered wood flooring and hardwood plywood moved China from

being a net importer to a large net exporter. China accounted for most of the growth

in U.S. imports during the 2002–07 period.

• The declining value of the U.S. dollar relative to other major currencies, which

boosted U.S. exports to some markets, did not affect the major U.S. suppliers’

currencies equally. For example, China was able to increase exports to the United

States and increase its market share, partly at the expense of other foreign suppliers

such as Brazil and Canada (whose currencies appreciated even more).

Factors Affecting Competitive Position

Competitive position is affected by demand factors and supply factors. On the demand side,

a primary market driver has been the demand for residential construction and renovation.

This demand in turn drives the demand for solid and engineered wood flooring and for

products such as furniture, cabinetry, and wall paneling that utilize hardwood plywood.

Other demand factors include changes in consumer tastes and preferences, the presence in

the market of traditional and new products, new standards or quality requirements, a growing

focus on environmental concerns, marketing practices, and the channels of distribution for

the products. Supply-side factors include variable production costs (led by raw material and

labor costs), capital costs, investment, capacity utilization, infrastructure, proximity to

markets, and product innovations, as well as the structure of the industry (i.e., concentration,

and vertical and horizontal integration). In addition to the demand and supply factors in the

U.S. market, currency exchange rates and the demand for wood flooring and hardwood

plywood in other economies have important effects on the competitiveness of wood flooring

and hardwood plywood industries.

Demand Factors 

Markets for Products 

The U.S. market for traditional wood flooring and hardwood plywood products is subject to

the cyclical nature of the markets for U.S. residential housing, manufactured homes, and

RVs. During the 2002–06 period, U.S. consumption of wood flooring and hardwood

plywood rose rapidly before declining in 2007 (figure 6.1). The dramatic growth and

subsequent drop in consumption generally parallels the performance of the U.S. housing

market, particularly traditional construction (figure 6.2). Other market segments showed a

mixed pattern. Shipments of RVs increased by 25 percent over the period from 2002 to 2006

before declining by 10 percent in 2007, while shipments of manufactured homes declined

by more than 40 percent during the 2002–07 period.
6-3

0

1000

2000

3000

4000

5000

6000

2002 2003 2004 2005 2006 2007

$ millions

Shipments Consumption Imports Exports

FIGURE 6.1 U.S. shipments, consumption, imports, and exports of wood flooring and 

hardwood plywood, 2002–07

Source: Compiled from U.S. producer and importer questionnaires.

0

500

1000

1500

2000

2500

2002 2003 2004 2005 2006 2007

Thousands 

Housing starts Manufactured housing RVs

FIGURE 6.2 Housing starts, manufactured housing shipments, and RV shipments, 2002–06

Source: USDOC, Census Bureau; and Recreational Vehicle Industry Association.
 1

 USITC hearing transcript, October 3, 2007, 180.

6-4

Major U.S. producers and large intermediate consumers increasingly looked abroad for

sources of supply as they tried to reduce costs to better compete in end markets. As such,

imports accounted for an increasing share of the growing U.S. wood flooring and hardwood

plywood market even as U.S. production rose over the period. A growing share of imports

of wood flooring were by U.S.-based producers sourcing products and inputs from foreign

markets. Additionally, newer products, such as engineered wood flooring, are enjoying faster

demand growth than traditional products such as solid wood flooring. It is in this segment

that imports rose most rapidly, with the major U.S. flooring manufacturers and the large U.S.

building materials retailers reportedly accounting for much of that import growth.

Wood flooring 

Collectively, U.S. shipments of solid and engineered wood flooring rose rapidly during the

period under review, increasing from $1.5 billion in 2002 to nearly $2.2 billion in 2004,

before declining to $2.0 billion in 2007. However, some U.S. wood flooring producers were

not able to take full advantage of favorable market trends. For example, U.S. producers of

unfinished oak strip flooring, a product that has remained virtually unchanged for decades,

were unable to take advantage of increasing U.S. demand for prefinished flooring, widewidth flooring, and flooring of exotic species. Imports of these prefinished products are at

least partially responsible for the increased import market share of the U.S. solid wood

flooring market, which rose from 16 percent in 2002 to 27 percent in 2007 as imports more

than tripled by 2005 before declining over the next two years (figure 6.3). 

At the same time, imported engineered wood flooring captured nearly one-half of the rapidly

rising domestic market in that product, increasing from 22 percent to 49 percent over the

same period that imports rose by 350 percent (figure 6.4). The introduction of engineered

wood flooring has expanded the overall U.S. wood flooring market, as it can be used in

applications not suitable for solid wood flooring. Further, the strong growth in U.S.

consumption of engineered wood flooring relative to solid wood flooring during the period

indicates that it captured some of the market for traditional solid wood flooring. Engineered

wood flooring now accounts for nearly 40 percent of the U.S. wood flooring market.

Although industry executives do not consider laminate flooring to be a substitute for wood

flooring, they nevertheless testified at the Commission hearing that the prices of both wood

and laminate flooring had fallen and that the price gap had narrowed.1

 Therefore, in spite of

the strong growth of engineered wood flooring during the period, the increasing share of the

overall floor covering market captured by laminate flooring has likely put price pressure on

wood flooring, particularly in the residential remodeling end use.
6-5

0

500

1000

1500

2000

2500

2002 2003 2004 2005 2006 2007

$ millions

Shipments Consumption Imports Exports

FIGURE 6.3 U.S. shipments, consumption, imports, and exports of solid wood flooring, 

2002–07

Source: Compiled from U.S. producer and importer questionnaires and official statistics of the 

U.S. Department of Commerce.

0

200

400

600

800

1000

1200

1400

2002 2003 2004 2005 2006 2007

$ millions

Shipments Consumption Imports Exports

FIGURE 6.4 U.S. shipments, consumption, imports, and exports of engineered wood 

flooring, 2002–07

Source: Compiled from U.S. producer and importer questionnaires and official statistics of the 

U.S. Department of Commerce.
6-6

Consumer tastes and preferences have also changed during the period. Expansion of the

housing and renovation markets resulted in an increased demand for exotic woods in flooring

products relative to traditional species such as oak. This change in demand led to increased

imports of products such as solid wood flooring made from tropical woods, particularly those

from Latin America.

Finally, growing consumer and government sensitivity to global environmental issues such

as forest degradation and destruction has increased demand for wood products made from

legally sourced raw material grown in sustainably managed forests. It is not clear how this

aspect affects the market, either through price premiums or market share, as data are not

readily available. Also, some firms produce and market sustainable products without making

claims about certification. The “Green” building codes, such as LEED, have also increased

demand for such products from the commercial building sector. Flooring made from

bamboo—perceived by some consumers to be more sustainable than hardwoods harvested

from natural forests—has benefitted from this trend.

Hardwood plywood 

In contrast to the growth in U.S. shipments of both solid and engineered wood flooring,

shipments of hardwood plywood were essentially flat over the period, while consumption

increased by about half and imports rose by more than two-thirds from 2002–07 (figure 6.5).

The share of U.S. imports of hardwood plywood in the U.S. market rose from 51 percent in

2002 to 62 percent in 2007. However, a significant share, perhaps one-third, of U.S. imports

of hardwood plywood consists of thin plywood, a segment in which U.S. producers typically

do not compete. Demand from U.S. makers of cabinets and fixtures rose, while demand from

furniture makers declined, an important but declining market for U.S. plywood producers.

As with flooring, the quality of hardwood plywood is a significant demand factor, and the

U.S. industry has turned toward higher grade products, rather than the utility grades,

choosing to go up the quality scale rather than trying to lower costs to compete in the market

with imports for lower grades of hardwood plywood. This trend has been influenced by the

earlier loss of large segments of the furniture market as that industry increasingly moved

production offshore. Another quality factor influencing the demand for hardwood plywood

is the level of formaldehyde emissions. Finally, environmental awareness and “Green”

building codes have increased the demand for certified hardwood plywood products.

As in the flooring segments, substitute products are also applying competitive pressure on

U.S. hardwood plywood manufacturers, particularly in the lower grades. For example,

plywood with cores other than veneer, such as particle board or MDF, is gaining market

share relative to low-grade plywood. In addition, MDF and particle board are increasingly

competing directly with low-grade plywood in some applications, such as furniture and

cabinetry, in both domestic and foreign markets.
 2

 The pattern of forest land tenure in the United States, particularly in the East, where hardwoods are

typically privately owned on relatively small parcels, may also contribute to the inelastic nature of raw

material supply. Not only must timber production compete with other land uses, but when timber is sold, it is

often sold at auction. This is in contrast to most other supplying countries where tenure is secured through

negotiated concessions involving relatively large parcels.

6-7

Exports 

Foreign demand for U.S. wood flooring and hardwood plywood was strong during the

2002–07 period. In 2002, exports of solid wood flooring accounted for 8 percent of U.S.

production; by 2007, the export share had risen to 12 percent. At the same time, the export

share for engineered wood flooring doubled from 7 percent to 14 percent. The decline in the

value of the dollar, particularly against the Canadian dollar, is the principal factor for the

increase, as most U.S. export growth was to Canada. 

Supply Factors 

Raw Material 

As noted in chapter 2, the United States is the world’s largest producer of hardwood logs,

the basic raw material for wood flooring and hardwood plywood. U.S. hardwood forest

resources remain abundant and include certain species particularly well suited to the

manufacture of wood flooring and hardwood plywood. However, during a period of strong

market growth and increasing production, at least for wood flooring, U.S. lumber production

was basically flat, and the particular grades of lumber preferred by the U.S. solid wood

flooring industry were in tight supply. This reportedly inelastic supply may ultimately have

somewhat constrained U.S. production of wood flooring.2

0

500

1000

1500

2000

2500

3000

2002 2003 2004 2005 2006 2007

$ millions

Shipments Consumption Imports Exports

FIGURE 6.5 U.S. shipments, consumption, imports, and exports of hardwood plywood, 

2002–07

Source : Compiled from U.S. producer and importer questionnaires and official statistics of 

the U.S. Department of Commerce.
6-8

With one exception, the other major foreign suppliers of wood flooring and hardwood

plywood are also well-endowed with natural stands of hardwood resources, and each has

desirable species, e.g., Russian birch and Indonesian or Malaysian lauan for hardwood

plywood, and certain Brazilian species are currently very popular for flooring in the U.S.

market. As in the United States, however, raw material supplies in these countries tightened

over the period, partly a function of efforts to address illegal logging, and prices for raw

materials increased.

China is unique among the large producers of wood flooring and hardwood plywood in not

being well-endowed with forest resources and having a limited domestic supply of natural

raw material with which to feed its rapidly growing wood products industry. However, by

providing a large portion of the material necessary for veneer cores, its poplar plantations

have greatly aided, if not made possible, the growth of China’s engineered wood flooring

and hardwood plywood industries, because for engineered wood flooring and hardwood

plywood, imported raw material is necessary only for face and back veneers. As the

production data in chapter 4 demonstrate, China’s competitive position is not nearly as

strong for solid wood flooring, where it is necessary to import essentially all of the lumber

necessary for its production.

Cost of Production

As noted in the global overview in chapter 2, the United States and the six foreign suppliers

to the U.S. market all have large wood products industries that produce flooring and

plywood, and each has at least some firms with large production capacities, technical ability,

and large outputs. Thus, global competition is based on relative production costs, product

quality, and product differentiation. 

The U.S. industries are generally at a disadvantage vis-á-vis most foreign suppliers with

respect to production costs, which are among the most important determinants of industry

profitability and competitiveness in wood flooring and hardwood plywood. In addition to

the cost of procuring raw material, production costs include labor, energy, capital costs of

buildings and equipment, inventory and marketing costs, and transport of wood flooring and

hardwood plywood to customers. Given the wide variety of products and various levels of

quality produced in all three segments (solid wood flooring, engineered wood flooring, and

hardwood plywood) per unit production costs across countries for aggregated products may

be neither very illustrative nor particularly useful. However, broadly speaking these

industries are high variable cost industries, with raw material generally accounting for 50 to

80 percent and labor 15 to 25 percent of total production costs. 

Variable costs 

Raw material

The U.S. industries were not at a competitive disadvantage with respect to the cost of raw

material vis-à-vis most foreign competitors. The average U.S. cost of raw material for solid

wood flooring ranged from $1.30 to $1.50 per square foot during the 2002–06 period and

averaged 62–66 percent of the total production cost. The cost of raw material rose over the

period for U.S. producers, but may not be rising faster than that of the major competitors.
 3

 Goetzl and Ekström, “Report on the Review of the U.S. Market,” 2007, p 13.

 4

 USITC hearing transcript, October 3, 2007, 235.

6-9

In Brazil, Indonesia, Malaysia, raw material is reportedly increasingly scarce, due in part to

crackdowns on illegal logging, and prices are reported to have increased substantially during

the period. For example, the Malaysian prices for two species of tropical hardwood

commonly used in the manufacture of hardwood plywood have increased at a faster rate than

U.S. hardwood log prices (figure 6.6). This suggests that U.S. producers’ competitive

position may be improved at least with respect to raw material.

The cost of core material in China is likely lower than that in the United States, reflecting

the abundant supply of poplar. Chinese producers likely pay competitive market prices

within China for raw material, both domestic and imported. Because China is the worlds'

largest importer of hardwood logs, it is doubtful that China has a competitive advantage in

the cost of raw material other than that conferred by the availability of the poplar plantations.

Labor 

Except for Canada, the United States is at a competitive disadvantage with respect to labor

costs, which typically are the second leading cost item in wood flooring and hardwood

plywood production. U.S. and Canadian labor rates ranked highest among major producers,

at $10 to $20 per hour in 2006. Brazil has lower labor costs than the United States, with

hourly rates in the manufacturing sector just over $4 per hour.3

 Labor rates in Malaysia and

Indonesia are about $40 per month (less than $0.25 per hour). Despite the use of hand labor

by Chinese producers in much of the production process, China’s overall labor cost is

relatively low,4

 due to relatively low wage rates, typically around $1.00 per hour. Labor rates

in the hardwood plywood industry in Russia are not available.

Other inputs and costs 

The United States is reportedly competitive with respect to other production costs, such as

energy, adhesives, finishes, and transportation. All global producers have been affected by

rising costs for many of these items in recent years.
 However, in China, capital costs are relatively low for wood flooring and plywood producers, the vast 5

majority of which are small, and these lower capital costs also contributed to the growth of the industry. 

6-10

Fixed costs 

As noted in Chapter 3, domestic production capacity for wood flooring increased

substantially over the period, while production capacity for hardwood plywood remained

essentially unchanged. Estimated capacity utilization rates in the United States were 80 to

90 percent for solid wood flooring, slightly above 80 percent for engineered wood flooring,

and from 70 to 80 percent for hardwood plywood over the period.

Given that the technology for producing these products is similar throughout the global

industry, and that raw material, labor, and other variable inputs constitute the vast majority

of the cost of production, variations in capital costs may not be a particularly significant

competitive factor. However, capacity utilization rates and levels of new investment may 5

be indicators of competitiveness, although not as significant as would be the case in high

fixed-cost (or capital-intensive) industries. As noted earlier, some industries, such as those

in Indonesia, are reportedly operating at very low rates of capacity utilization, which hinders

their competitiveness. Canadian producers also noted that some of their plants are idle

during part of the year. Capacity utilization rates for flooring plants in China are

approximately 40 percent.
 6

 Industry official, interview with Commission staff, June 25, 2008.

 7

 Large retail/wholesale firms include regional and national chains of lumber supply stores, as well as

mass merchandisers such as the large home supply stores and club stores. 

 8

 Goetzl,and Ekström, “Report on the Review of the U.S. Market,” 2007, 58.

6-11

Industry Structure 

As noted in chapter 3, the hardwood plywood and the wood flooring industries are highly

concentrated in the United States, and this concentration has increased slightly over the

period. According to industry statistics, in 2006, the five largest hardwood plywood

companies accounted for over 75 percent (by quantity) of U.S. production, with a total of

approximately 24 manufacturers in the United States. Similarly, in 2006, the five largest

companies producing wood flooring accounted for almost 60 percent of total U.S.

production, with approximately 155 manufacturers in the United States.

Although data are not available, the wood flooring and hardwood plywood industries in most

major foreign competitors are likely not as concentrated as in the United States and Canada.

The concentration in the U.S. industries suggests a structure in which a few large firms are

able to have influence over demand and price, while many of the smaller U.S. firms may be

price takers. In such an industry structure, the larger firms are able to exert some control over

prices through branded or niche products, vertical or horizontal integration, or expanded

international operations. Smaller firms, in contrast, may be more impacted by import

competition and have fewer resources to integrate their production or to procure products

and inputs overseas.

With respect to certain other suppliers, the U.S. wood flooring and hardwood plywood

industries have a competitive disadvantage in weak linkages to logging operations but a

competitive advantage in strong linkages to distributors and retailers, especially through

nationally branded products. However, this advantage may be diminishing as distributors and

retailers establish relationships with foreign supplier industries and domestic producers

source more of their nationally branded product offshore. Vertical coordination (ownership,

concessions, or contracts linking producers to logging operations, distributors, and retailers)

in the wood flooring and hardwood plywood industry typically enhances competitiveness

by giving producers more certainty about raw material supply, distributor demand, and

prices.

Channels of Distribution 

Rising concentration in the distribution chain, particularly at the retail level, is reportedly

hindering the ability of U.S. wood flooring and hardwood plywood firms to maintain market

share by influencing prices for wood flooring and hardwood plywood. Greater competition

in the U.S. market between U.S. and imported wood flooring and hardwood plywood is

reportedly partly a result of greater market power held by retailers, particularly the large

building and home supply companies, as these enterprises have more logistical capability

than smaller retailers to source products from overseas.6

 The share of the U.S. retail market

held by the large retailers7

 has risen sharply in recent years.8 For example, the large building

and home supply companies accounted for a reported 38 percent of the market for all wood

flooring in 2007, up from 29 percent in 2002. This increase in market share has come largely

at the expense of the floor covering stores, whose share of the retail wood flooring market
 9

 Catalina Research, Inc., 2005. Industry official, interview with Commission staff, August 6, 2008.

 10 Industry official, interview with Commission staff, June 25, 2008.

 11 The domestic producer prices are indexed to protect the confidentiality of the data. Indexed prices were

derived by dividing each yearly price by the 2002 price and multiplying by 100. 

6-12

has dropped from 67 percent to less than 60 percent during the same period.9 The large

building and home supply companies reportedly are taking an even larger share of the market

for engineered wood flooring, the fastest-growing market segment.10

Imported solid and engineered wood flooring is also sold through the networks of the major

floor covering producers and importers. Increasingly, both domestic producers and foreign

producers or their importers seeking nationwide distribution of their products must negotiate

contract terms directly with these retail chains.

Exchange Rates 

The recent decline in the value of the U.S. dollar has aided the U.S. industries’

competitiveness vis-à-vis most foreign suppliers in the U.S. market. The declining value of

the dollar puts upward pressure on prices of imported wood flooring and hardwood plywood

products from all leading foreign supplier industries and thus tends to raise the prices of U.S.

wood flooring and hardwood plywood that compete with such imports. At the same time, the

lower-valued U.S. dollar has provided a price advantage to U.S. exports not only vis-à-vis

other foreign products, but also vis-à-vis domestic products in foreign markets such as

Canada and the EU. 

Table 6.1 shows recent trends in nominal and real (inflation adjusted) exchange rates for the

U.S. dollar vis-à-vis the foreign suppliers’ currencies. All foreign currencies have

appreciated in value relative to the dollar, although in the case of the Malaysian ringgit and

the Chinese yuan, the appreciation has been significantly less and has occurred only since

mid-2006. The real values of the Brazilian real, Canadian dollar, the Indonesian rupiah, and

the Russian ruble have risen faster than the Malaysian ringgit and Chinese yuan, giving

Malaysia and China an advantage vis-à-vis the other suppliers to the U.S. market. However,

according to Chinese industry sources, many inputs used by China’s wood flooring and

hardwood plywood industry are imported and priced in U.S. dollars. These raw materials

have been subject to the same upward price pressures as other commodities priced in dollars.

For a country such as China, which had traditionally pegged its foreign exchange rate to the

dollar, this raised the cost of those inputs and mitigated some of that advantage that China

has when selling its final products into the U.S. market.

Pricing and Marketing

Trends in the prices received by U.S. producers of wood flooring and hardwood plywood

indicate the weakening competitive position of the U.S. wood flooring and hardwood

plywood industries relative to imports. Figure 6.7 shows the indexed trend in average

producer prices (unit values) for hardwood plywood and solid wood and engineered wood

flooring from 2002 to 2006 from the Commission’s questionnaire data.11 Producer prices

remained relatively flat over this period. The average of each of the producer prices declined
 12 USDOL, BLS, PPI Database (accessed May 19, 2008).

 13 United Nations, UNECEF/FAO Forest Products Annual Market Review, 2004-2005, 2005.

6-13

TABLE 6.1 Exchange rates: Units of foreign currency per U.S. dollar, 2002–06

Foreign

currency 2002 2003 2004 2005 2006 2007

% change

2002-07a

Brazilian 

real nominal 2.92 3.08 2.93 2.43 2.17 1.947 -33.3

realb 2.63 2.47 2.27 1.82 1.61 1.43 -45.5

Canadian 

dollar nominal 1.57 1.40 1.30 1.21 1.13 1.074 -31.6

real 1.56 1.39 1.30 1.22 1.16 1.11 -29.0

Chinese 

yuan nominal 8.28 8.28 8.28 8.19 7.97 7.608 -8.1

real 8.65 8.75 8.64 8.66 8.64 8.64 -6.9

Indonesian 

rupiah nominal 9,311.21 8,577.14 8,938.93 9,704.70 9,159.33 9,141.00 -1.8

real 7,802.28 6,885.52 6,946.21 7,040.42 6,081.61 5,865.47 -24.8 

Malaysian 

ringgit nominal 3.80 3.80 3.80 3.79 3.67 3.43 -9.7 

real 3.84 3.89 3.94 3.94 3.80 3.58 -6.8 

Russian 

ruble nominal 31.35 30.69 28.81 28.28 27.19 25.58 -18.4 

real 23.29 20.52 17.83 16.01 14.53 12.90 -45.3 

Source: International Monetary Fund, International Financial Statistics (monthly), various issues.

a

Calculated from unrounded data using the Consumer Price index in the United States and the foreign country. b

Real exchange rate (Year 2000=100)

slightly in 2006 from the average price received in 2002 in nominal terms. Figure 6.7 also

shows the trend in the producer price index (PPI) of materials and components used in

residential housing construction calculated by the Bureau of Labor Statistics.12 Wood

flooring and hardwood plywood prices, on average, did not keep up with the increase in

prices received by producers of other materials and components used in residential housing

construction, despite the housing and construction boom during the 2002–06 period.

Increased competition from imports moderated both price and production increases for

hardwood plywood and wood flooring during this period, resulting in low rates of growth

in producer prices for these products.13 
6-14

In addition to the small decline in the average producer prices in nominal terms, prices of

these products did not keep up with the increase in hardwood lumber prices, which likely

reduced the competitive position of the U.S. industry (figure 6.8). The average producer

price of hardwood plywood and solid and engineered wood flooring declined relative to the

price of hardwood lumber from 2002 to 2006. The decline in this price ratio indicates

increasing cost pressures as producers may not have been able to sufficiently raise prices to

pass through increased raw material prices to consumers.

Direct comparisons of U.S. producer and import prices for various wood flooring and

hardwood plywood products are difficult owing to the confidentiality of the questionnaire

data. However, there is some evidence of price pressure and competition from imports for

utility grades of hardwood plywood (figure 6.9). For example, for birch hardwood plywood

(C-3 and D-3 grades), U.S. producer pricesincreased for D-3 grade, while unit values of C-3

and D-3 grades of hardwood plywood imported from China declined during the 2004–06

period.
6-15
 Industry official, interview by Commission staff, Portland, Oregon, August 16, 2007. 14

6-16

While these products compete, the divergence in the trends in product prices is reportedly

due, at least in part, to the higher quality of the U.S. domestic product.14

The price trends for thin hardwood plywood products show a divergence between U.S. and

foreign thin hardwood plywood prices from 2002–06 (figure 6.10). The virola plywood from

Brazil and the meranti plywood from Indonesia and Malaysia are likely substitutes, and their

rising prices over the period are consistent with the rising raw material prices in those

countries. The price for 1/4-inch birch plywood produced in the United States declined over

the period, even as raw material prices were rising in the United States.
6-17

Government Programs

In addition to trade policies, government involvement is concentrated in the forestry sector,

which supplies raw material to the wood flooring and hardwood plywood industries.

Program activities generally involve research and development, forestry practices,

marketing, and export promotion.

Trade policies

Import tariffs are the principal trade policy tool for wood flooring and hardwood plywood

in major importing nations, and tariff rates in the United States are at the lower end of the

range of tariffs applied in those markets. However, in general, tariffs for these products are

relatively low in the major markets. Also, as described in chapter 2, new government

procurement and developing trade policies regarding the origin and legality of logs and

lumber used by these industries, and by extension the products made from those raw

materials, may have larger effects on market access in the future than do traditional tariff

barriers. These policies are aimed at reducing the incidence of illegal logging and trade, and

may have the additional effects of raising raw material prices in certain supplier countries,

increasing the competitiveness of legally sourced materials, and reducing forest degradation,

particularly in tropical regions.

Other government policies 

Producers in the United States and Canada receive no direct aid support from those

governments. In China, government involvement improved the competitive position of the

Chinese industries during the 2002–06 period. The wood flooring and hardwood plywood

industries benefitted from duty-free and VAT-free imports of raw materials and from VAT

export rebates. The Chinese industries have also benefitted in the past from preferential

income tax programs. However, recent reductions in VAT export rebates for certain solid

wood flooring have reduced the export incentives.

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Strategic Options for Forest Assistance in Indonesia.” Washington, DC: World Bank, December

2006.

World Forestry Center. “The Forests of Russia,” 2003. http://wfi.worldforestry.org/WF-russia.htm.

WTO. Committee on Anti-Dumping Practices. “Semi-Annual Report Under Article 16.4 of the

Agreement, Israel.” G/ADP/N/153/ISR, April 17, 2007.

_______________. “Semi-Annual Report Under Article 16.4 of the Agreement, Turkey.”

G/ADP/N/153/TUR, March 22, 2007.

WTO. Delegation of the Unites States. “China: Certain Measures Granting Refunds, Reductions, or

Exemptions from Taxes and Other Payments.” Communication to the Delegation of China and to

the Chairman of the Dispute Settlement Body. WT/DS358/1. G/L/813. G/SCM/D74.

G/TRIMS/D/25, February 7, 2007.

Wu, Shengfu. “Why China Plywood Competitive {sic}.” Presented at ITTO conference, Beijing, China,

September 26, 2005.
Biblio-10

Xiufang, Sun, Cheng Nian, and Kerstin Canby. China’s Forest Product Exports: An Overview of Trends

by Segment and Destinations. Forest Trends, 2005. http://www.forest-trends.org.

Zhang, Tony. “China’s Plantation Program: Will It Be Able to Supply the Growing Needs of Both Wood

Products and Pulp and Paper Producers?” Presented at China’s Boom: Implications for

Investment & Trade in Forest Products and Forestry, Vancouver, BC, January 18–20, 2006.
APPENDIX A

Request Letter and Letter Amending the

Schedule

Unitoil j5tatu @enste: 

COMMIlTEE ON FINANCE 

RU39ELL4ULUVAN. 6TFFOIRCMA WASHINGTON, DC 2051(1-6200 KOUN UAVlS, WPUPUCAN STAFFDMECTOR AND CHEF COUNSEL 

-..- 

c2:;;i. February28,2 07 

The Honorable Dadel R. Pearson 

Chailnlan 

U.S. International Trade Commission 

500 E Street, SW 

Washington, DC 20436 

P 

i 

i 1 

In order to gain a better understanding of the trends and new dev L p& .in.the gbWieB.fleoring and 

Dear Chairman Pearson: 

hardwood plywood industries, the Committee requests, pursuant to section 332(g) of the Tariff Act of 1930, that 

the U.S. International Trade Commission institute an investigation and provide a report on the competitive 

conditions affecting the U.S. wood flooring and hardwood plywood industries during tlie period from 2002- 

2006. The Commission’s report on this investigation should provide to the extent possible, the folxowjng: 

e An overview ofthe US, markets for solid and engineered wood flooring (both unfmbhed and factoIy 

finished products), and hardwood plywood; 

a A description of the U.S. industries for wood flooring and hardwood pIpood and the industries in the 

principal coudt~%s (including Canada, China, Brazil, Indonesia, Malaysia, Russia) suppJyhg the U.S. 

market, including trends in production, capacity, employment, and consumption; 

An examination of US. trade patterns and the €actors affecting trade patterns, including tariffs and other 

border measures; 

An analysis of the factors affecting the competitive position of US. producers and the principal foreign 

suppliers to the U.S. market including raw materials, illegal logging, technolo$cal capabilities, labor 

practices, environmentd policies, government programs, and substitutes for wood flooring and 

hardwood plywood; 

Views of industry, homebuilden, importers and other interested parties on developments in the supplg3 

of and the demand for wood flooring and hardwood plywood, inGluding tlie effect of imports and 

substitutes for each product. 

The Commission should submit its report to the Committee not Iater than fifieerl months from the receipt of fld? 

request. The Committee intends to make the report available to the public in its entirety. Therefore, I request ths 

the report not include any confidential business information. The Comi~sion’s assistance in this matter is 9 greatly appreciated. 

r.4 

+ 

I 

-- 

Yl -= 4 

M 
MAX BAUCUS, MONTANA, CHAIRMAN 

JOHN D. ROCKEFELLER IV, WESTVlRGlNlA 

KENT CONRAD, NORTH DAKOTA 

JEFF BINGAMAN, NEW MEXICO 

JOHN F. KERRY, MASSACHUSElTS 

BLANCHE L. LINCOLN, ARKANSAS 

RON WYDEN, OREGON 

CHARLES E. SCHUMER, NEW YORK 

DEBBIE STABENOW. MICHIGAN 

MARIA CANTWELL, WASHINGTON 

CHUCK GRASSLEY, IOWA 

ORRIN G. HATCH, UTAH 

OLYMPIA J. SNOWE. MAINE 

JON KYL, ARIZONA 

GORDON SMITH, OREGON 

JIM BUNNING, KENTUCKY 

MIKE CRAPO. IDAHO 

PAT ROBERTS, KANSAS 

JOHN ENSIGN, NEVADA 

Wnited States Senate KEN SALAZAR, COLORADO JOHN E. SUNUNU, NEW HAMPSHIRE COMMITTEE ON FINANCE 

WASHINGTON, DC 20510-6200 RUSSELL SULLIVAN, STAFF DIRECTOR 

KOLAN DAVIS, REPUBLICAN STAFF DIRECTOR AND CHIEF COUNSEL 

March 7,2008 

The Honorable Daniel Pearson 

Chairman 

U.S. International Trade Commission 

500 E Street, SW 

Washington, DC 20436 

Dear Chairman Pearson: 

In a letter dated February 28,2007, the Committee requested, pursuant to section 332(g) of the 

Tariff Act of 1930, that the Commission institute an investigation and provide a report on the 

competitive conditions affecting the U.S. wood flooring and hardwood plywood industries. I 

asked that the Commission provide its report to the Committee no later than 15 months from 

receipt of the request, or by June 6,2008. 

I am amending the Committee's request, and now ask that the Commission provide its completed 

report no later than August 15,2008. 

Sincere1 

I .-" 
APPENDIX B

Federal Register Notices

19960 Federal Register / Vol. 72, No. 76 / Friday, April 20, 2007 / Notices 

Terauds, Bureau of Reclamation, 

Albuquerque Area Office, 555 Broadway 

NE, Suite 100, Albuquerque, New 

Mexico 87102. 

Copies of the FEIS are available for 

public inspection and review at the 

following locations: 

• Bureau of Reclamation, 

Albuquerque Area Office, 555 Broadway 

NE., Suite 100, Albuquerque, New 

Mexico 87102 

• Southern Peaks Public Library, 423 

4th Street, Alamosa, Colorado 81101 

• Taos Public Library, 402 Camino de 

la Placita, Taos, New Mexico 87571 

• City of Espan ̃ola Library, 405 Paseo 

de Onate, Espan ̃ ola, New Mexico 87532 

• Albuquerque Main Library, 501 

Copper NW., Albuquerque, New Mexico 

87102 

• Santa Fe Public Library, 145 

Washington Street, Santa Fe, New 

Mexico 87501 

• El Paso Public Library, Clardy Fox 

Branch, 5515 Robert Alva Avenue, El 

Paso, Texas 79905 

• Thomas Branigan Memorial Library, 

200 East Picacho Avenue, Las Cruces, 

New Mexico 88001 

• Socorro Public Library, 401 Park 

Street, Socorro, New Mexico 87801 

FOR FURTHER INFORMATION CONTACT: Ms. 

Valda Terauds, Bureau of Reclamation, 

Albuquerque Area Office, 555 Broadway 

NE., Suite 100, Albuquerque, New 

Mexico 87102; telephone 505–462–

3584; facsimile 505–462–3593; e-mail: 

vterauds@uc.usbr.gov. 

Ms. April Sanders, U.S. Army Corps 

of Engineers Albuquerque District, 4101 

Jefferson Plaza NE, Albuquerque, New 

Mexico 87109; telephone 505–342–

3443; facsimile 505–342–3195; e-mail: 

april.f.sanders@usace.army.mil. 

Mr. Nabil Shafike, PhD, New Mexico 

Interstate Stream Commission, 121 

Tijeras NE, Suite 2000, Albuquerque, 

New Mexico 87102; telephone 505–764–

3866; facsimile 505–764–3893; e-mail: 

nabil.shafike@state.nm.us. 

SUPPLEMENTARY INFORMATION: Pursuant 

to various legal authorities, and subject 

to allocation of supplies and priority of 

water rights under state law, 

Reclamation and the Corps operate 

dams, reservoirs, and other facilities in 

the upper Rio Grande basin to: 

(1) Store and deliver water for 

agricultural, domestic, municipal, 

industrial, and environmental uses; 

(2) Assist the Commission in meeting 

downstream water delivery obligations 

mandated by the Rio Grande Compact; 

(3) Provide flood protection and 

sediment control; and 

(4) Comply with existing laws, 

contract obligations, and international 

treaties. 

The Upper Rio Grande Basin Water 

Operations Review (Review) provides 

the basis of, and is integral to, 

preparation of the FEIS. The purpose of 

the Review and FEIS is to: 

(1) Identify flexibilities in operation of 

federal reservoirs and facilities in the 

upper Rio Grande basin that are within 

existing authorities of Reclamation, the 

Corps, and the Commission, and in 

compliance with Federal and State laws; 

(2) Develop a better understanding of 

how these facilities could be operated 

more efficiently and effectively as an 

integrated system; 

(3) Formulate a plan for future water 

operations at these facilities that is 

within the existing authorities of 

Reclamation, the Corps, and the 

Commission; complies with Federal, 

State, and other applicable laws and 

regulations; and assures continued safe 

dam operations; 

(4) Improve processes for making 

decisions about water operations 

through better interagency 

communication and coordination and 

facilitation of public review and input; 

and 

(5) Support compliance by the Corps, 

Reclamation, and the Commission with 

applicable laws and regulations, 

including, but not limited to, the 

National Environmental Policy Act and 

the Endangered Species Act. 

The FEIS addresses water operations 

at the following facilities with the noted 

exceptions and limitations: 

• Flood control operations at Platoro 

Reservoir (the Review and FEIS include 

only flood control operations at Platoro 

that are under the Corps’ authority; 

water supply operations at Platoro are 

under local control) 

• Closed Basin Division-San Luis 

Valley Project 

• Heron Dam and Reservoir 

• Abiquiu Dam and Reservoir 

• Cochiti Dam and Reservoir 

• Low Flow Conveyance Channel 

• Flood control operations at 

Elephant Butte Dam and Reservoir 

(because of current litigation, water 

supply operations at Elephant Butte are 

not included in the Review or FEIS) 

• Flood control operations at Caballo 

Dam and Reservoir (because of current 

litigation, water supply operations at 

Caballo are not included in the Review 

or FEIS). 

Proposed Federal Action 

Reclamation, the Corps, and the 

Commission identified Alternative E–3 

as the preferred alternative for water 

operations in the upper Rio Grande 

basin. This alternative allows for 

increased native (Rio Grande) water 

conservation and storage in Abiquiu 

Reservoir, maintains current channel 

capacity below Abiquiu Dam, increases 

channel capacity below Cochiti Dam, 

and allows a full range of operation for 

the Low Flow Conveyance Channel, 

with continued communication and 

coordination for flood control 

operations at Elephant Butte and 

Caballo Dams. 

No decision will be made on the 

proposed Federal action until 60 days 

after the release of the FEIS. After the 

60-day waiting period, Reclamation, the 

Corps, and the Commission will 

complete individual agency Records of 

Decision. The Records of Decision will 

identify the action(s) that will be 

implemented and discuss all factors 

leading to the decision(s). 

Dated: March 2, 2007. 

Rick L. Gold, 

Regional Director—Upper Colorado Region, 

Bureau of Reclamation. 

[FR Doc. E7–7034 Filed 4–19–07; 8:45 am] 

BILLING CODE 4310–MN–P 

INTERNATIONAL TRADE 

COMMISSION 

[Investigation No. 332–487] 

Wood Flooring and Hardwood 

Plywood: Competitive Conditions 

Affecting the U.S. Industries 

AGENCY: United States International 

Trade Commission. 

ACTION: Institution of investigation and 

scheduling of hearing. 

SUMMARY: Following receipt on March 6, 

2007, of a request from the Senate 

Committee on Finance, the Commission 

instituted investigation No. 332–487, 

Wood Flooring and Hardwood Plywood: 

Competitive Conditions Affecting the 

U.S. Industries, under section 332(g) of 

the Tariff Act of 1930 (19 U.S.C. 

1332(g)). 

DATES:

April 11, 2007: Date of institution. 

August 22, 2007: Deadline for filing 

requests to appear at the public 

hearing. 

August 29, 2007: Deadline for filing prehearing briefs and statements. 

September 13, 2007, 9:30 a.m.: Public 

hearing. 

October 5, 2007: Deadline for filing 

post-hearing briefs and statements. 

December 28, 2007: Deadline for filing 

written statements. 

June 6, 2008: Transmittal of report to the 

Committee on Finance. 

ADDRESSES: All Commission offices, 

including the Commission’s hearing 

rooms, are located in the United States 


sroberts on PROD1PC70 with NOTICES
Federal Register / Vol. 72, No. 130 / Monday, July 9, 2007 / Notices 37261 

North, Range 7 East, New Mexico 

Principal Meridian, Colorado were 

accepted on May 16, 2007. 

The plat and field notes, in duplicate, 

of the dependent resurvey of certain 

mineral claims in Township 43 North, 

Range 4 West, New Mexico Principal 

Meridian, Colorado, were accepted on 

June 6, 2007. 

The plat, and field notes, in duplicate, 

of the dependent resurvey in Township 

8 South, Range 76 West, and the plat, 

in duplicate, of the entire record, of the 

dependent resurvey of a portion of the 

west boundary of Township 9 South, 

Range 76 West, both of the Sixth 

Principal Meridian, Colorado were 

accepted on June 19, 2007. 

Randall M. Zanon, 

Chief Cadastral Surveyor for Colorado. 

[FR Doc. E7–13186 Filed 7–6–07; 8:45 am] 

BILLING CODE 4310–JB–P 

INTERNATIONAL TRADE 

COMMISSION 

[Investigation No. 332–487] 

Wood Flooring and Hardwood 

Plywood: Competitive Conditions 

Affecting the U.S. Industries 

AGENCY: United States International 

Trade Commission. 

ACTION: Rescheduling of public hearing. 

SUMMARY: The Commission has 

rescheduled the public hearing in this 

investigation from September 13, 2007, 

to October 3, 2007. As announced in the 

notice of institution of the investigation 

published in the Federal Register on 

April 20, 2007 (72 FR 19960), the 

hearing will be held at the U.S. 

International Trade Commission 

Building, 500 E Street, SW., 

Washington, DC; it will begin at 9:30 

a.m. Certain dates relating to the filing 

of written statements and other 

documents have been changed; the 

revised schedule of dates is set out 

immediately below. All other 

requirements and procedures set out in 

the notice published on April 20, 2007, 

continue to apply. In the event that, as 

of the close of business on September 

12, 2007, no witnesses are scheduled to 

appear at the hearing, the hearing will 

be canceled. Any person interested in 

attending the hearing as an observer or 

nonparticipant may call the Secretary to 

the Commission (202–205–2000) after 

September 12, 2007, for information 

concerning whether the hearing will be 

held. 

DATES: April 11, 2007: Date of 

institution. 

September 12, 2007: Deadline for 

filing requests to appear at the public 

hearing. 

September 19, 2007: Deadline for 

filing pre-hearing briefs and statements. 

October 3, 2007, 9:30 a.m.: Public 

hearing. 

October 24, 2007: Deadline for filing 

post-hearing briefs and statements. 

January 11, 2008: Deadline for filing 

all other written statements. 

June 6, 2008: Transmittal of report to 

the Committee on Finance. 

FOR FURTHER INFORMATION CONTACT: 

Industry-specific information may be 

obtained from Fred Forstall, Co-Project 

Leader, (202–205–3443 or 

alfred.forstall@usitc.gov,) or David 

Ingersoll, Co-Project Leader, (202–205–

2218 or dave.ingersoll@usitc.gov). For 

information on legal aspects of the 

investigation, contact William Gearhart 

of the Commission’s Office of the 

General Counsel at 202–205–3091 or 

william.gearhart@usitc.gov. The media 

should contact Margaret O’Laughlin, 

Office of External Relations at 202–205–

1819 or margaret.olaughlin@usitc.gov. 

Hearing impaired individuals are 

advised that information on this matter 

can be obtained by contacting the TDD 

terminal on 202–205–1810. General 

information concerning the Commission 

may also be obtained by accessing its 

Internet address (http://www.usitc.gov). 

Persons with mobility impairments who 

will need special assistance in gaining 

access to the Commission should 

contact the Secretary at 202–205–2000. 

Issued: July 3, 2007. 

By order of the Commission. 

Marilyn R. Abbott, 

Secretary to the Commission. 

[FR Doc. E7–13187 Filed 7–6–07; 8:45 am] 

BILLING CODE 7020–02–P 

INTERNATIONAL TRADE 

COMMISSION 

[USITC SE–07–013] 

Government in the Sunshine Act 

Meeting Notice 

AGENCY HOLDING THE MEETING: United 

States International Trade Commission. 

TIME AND DATE: July 20, 2007 at 2:30 p.m. 

PLACE: Room 101, 500 E Street, SW., 

Washington, DC 20436, Telephone: 

(202) 205–2000. 

STATUS: Open to the public 

MATTERS TO BE CONSIDERED: 

1. Agenda for future meetings: none. 

2. Minutes. 

3. Ratification List. 

4. Inv. Nos. 731–TA–1114–1115 

(Preliminary) (Certain Steel Nails from 

China and the United Arab Emirates)—

briefing and vote. (The Commission is 

currently scheduled to transmit its 

determination and Commissioners’

opinions to the Secretary of Commerce 

on or before July 30, 2007.) 

5. Inv. Nos. 701–TA–447 and 731–

TA–1116 (Preliminary) (Circular 

Welded Carbon-Quality Steel Pipe from 

China)—briefing and vote. (The 

Commission is currently scheduled to 

transmit its determination to the 

Secretary of Commerce on July 23, 2007; 

Commissioners’ opinions are currently 

scheduled to be transmitted to the 

Secretary of Commerce on or before July 

30, 2007.) 

6. Outstanding action jackets: none. 

In accordance with Commission 

policy, subject matter listed above, not 

disposed of at the scheduled meeting, 

may be carried over to the agenda of the 

following meeting. 

By order of the Commission. 

Issued: July 3, 2007. 

William R. Bishop, 

Hearings and Meetings Coordinator. 

[FR Doc. E7–13228 Filed 7–6–07; 8:45 am] 

BILLING CODE 7020–02–P 

INTERNATIONAL TRADE 

COMMISSION 

[USITC SE–07–013] 

Government in the Sunshine Act 

Meeting Notice 

AGENCY HOLDING THE MEETING: United 

States International Trade Commission. 

TIME AND DATE: July 20, 2007 at 2:30 p.m. 

PLACE: Room 101, 500 E Street, SW., 

Washington, DC 20436, Telephone: 

(202) 205–2000. 

STATUS: Open to the public. 

MATTERS TO BE CONSIDERED: 

1. Agenda for future meetings: None. 

2. Minutes. 

3. Ratification List. 

4. Inv. Nos. 731–TA–1114–1115 

(Preliminary) (Certain Steel Nails from 

China and the United Arab Emirates)—

briefing and vote. (The Commission is 

currently scheduled to transmit its 

determination and Commissioners’

opinions to the Secretary of Commerce 

on or before July 30, 2007.) 

5. Inv. Nos. 701–TA–447 and 731–

TA–1116 (Preliminary) (Circular 

Welded Carbon-Quality Steel Pipe from 

China)—briefing and vote. (The 

Commission is currently scheduled to 

transmit its determination to the 

Secretary of Commerce on July 23, 2007; 

Commissioners’ opinions are currently 

scheduled to be transmitted to the 

Secretary of Commerce on or before July 

30, 2007.) 


rwilkins on PROD1PC63 with NOTICES
C-1

APPENDIX C

HTS Descriptions and Tariff Information

 1

 USITC hearing transcript, October 3, 2007, 19. 

 2

 CBP, statement to the Senate Committee on Energy and Natural Resources, Subcommittee on Public

Lands and Forests, May 30, 2007.

 3

 Amendments to the HS are made by the World Customs Organization on a five year cycle. 

C-3 

U.S. Tariff Treatment

Classification of wood flooring and hardwood plywood is complicated by the variety of

wood flooring and hardwood plywood products, technical refinements in the manufacture

of these products, the development of new products (e.g., bamboo flooring), and the

complexity of the HTS (shown in tables C-1 to C-3). Classification issues are evident in the

large number of customs rulings issued by the U.S. Customs and Border Protection (CBP)

for these products.

The U.S. wood flooring and hardwood plywood industries contend that U.S. importers

sometimes intentionally misclassify imports of these products to avoid paying the

appropriate duties.1

 In August 2005, U.S. industry associations brought allegations of

misclassification to the attention of CBP. Subsequently, CBP initiated national enforcement

operations targeting imports of wood flooring and hardwood plywood, which uncovered

widespread misclassification.2

 

Finally, changes to the HTS, resulting from the 2007 Harmonized Schedule (HS)

amendments,3

 had an impact on the classification of wood flooring and hardwood plywood.

These changes include (1) establishing distinct subheadings for bamboo products in various

headings of chapter 44, (2) restructuring the subheadings in heading 4412, and (3) clarifying

the classification of assembled flooring through additional U.S. chapter note 4(b). These

changes further complicate analysis of import trends because 2007–08 import statistics do

not correspond directly to data from earlier years. (A comparison of old and new

subheadings in headings 4409, 4412, and 4418 and some relevant customs rulings are

presented in table C-4.)
C-4 

TABLE C-1 Wood flooring: HTS heading 4409, tariff rates, 2008

a

General bSpecial cColumn 2

HTS provision Article description Rates (percent ad valorem)

4409

4409.10 

4409.10.05

4409.10.20

4409.21

4409.21.05

4409.21.90

4409.29

4409.29.05

4409.29.25

4409.29.25.30

4409.29.25.50

4409.29.25.60

Other

Wood (including strips and friezes for parquet flooring,

not assembled) continuously shaped (tongued,

grooved, rebated, chamfered, V-jointed, beaded,

molded, rounded or the like) along any of its edges,

ends or faces, whether or not planed, sanded or

end-jointed:

Coniferous:

Wood continuously shaped along any of its

ends, whether or not also continuously

shaped along any of its edges or faces, all

the foregoing whether or not planed, sanded

or end-jointed:

Other:

Wood flooring:

Nonconiferous:

Of bamboo:

Wood continuously shaped along any of

its ends, whether or not also

continuously shaped along any of its

edges or faces, all the foregoing whether

or not planed, sanded or end-jointed :

Other:

Other:

Wood continuously shaped along any of

its ends, whether or not also

continuously shaped along any of its

edges or faces, all the foregoing whether

or no planed, sanded or end-jointed:

Other:

Wood flooring:

Maple (Acer spp.):

Birch (Betula spp.) and beech

(Fagus spp.):

Other:

3.2%

Free

3.2%

Free

3.2%

Free

Free

Free

Free

33 1/3%

33 1/3%

33 1/3%

$1.70/m3

33 1/3%

8%

Source: Harmonized Tariff Schedule of the United States (2008).

a

Normal trade relations, formerly known as the most-favored-nation duty rate. b

The "Free" duty rate is available for the designated tariff lines for the following U.S. trade preference programs: GSP,

U.S.-Australia FTA, U.S.-Bahrain FTA, NAFTA, U.S.-Chile FTA, CBERA, U.S.-Israel FTA, ATPA/ATPDEA, U.S.-Jordan FTA,

U.S.-Morocco FTA, CAFTA, and the U.S.-Singapore FTA. c

Applies to imports from a small number of countries that do not enjoy normal trade relations duty status.
C-5 

TABLE C-2 Wood flooring and hardwood plywood: HTS heading 4412, tariff rates, 2008

a

General bSpecial cColumn 2

HTS provision Article description Rates (percent ad valorem)

4412

4412.10

4412.10.05

4412.10.90

4412.31

4412.31.05

4412.31.05.20

4412.31.05.40

4412.31.05.60

4412.31.25

4412.31.25.10

4412.31.25.20

4412.31.40

4412.31.40.40

4412.31.40.50

Plywood, veneered panels and similar laminated wood:

Of bamboo:

Plywood

Other

Other plywood consisting solely of sheets of wood

(other than bamboo), each ply not exceeding 6

mm in thickness:

With at least one outer ply of tropical wood

specified in subheading note 1 to this

chapter::

Not surface covered, or surface covered

with a clear or transparent material

which does not obscure the grain,

texture or markings of the face ply:

With a face ply of birch (Betula

spp.):

Panels not exceeding in any

dimension 3.6 mm in

thickness, 1.2 m in width and

2.2 m in length :

Other:

Not surface covered :

Other:

With a face ply of Spanish cedar

(Cedrela spp.) or walnut (Juglans

spp.):

With a face ply of Spanish

cedar (Cedrela spp.) :

With a face ply of walnut

(Juglans spp.):

Other:

With at least one outer ply of

the following tropical woods:

Dark Red Meranti, Light Red

Meranti, White Lauan, Sipo,

Limba, Okoumé, Obeche,

Acajou d'Afrique, Sapelli,

Virola, Mahogany, Palissandre

de Para, Palissandre de Rio or

Palissandre de Rose :

 With a face ply of

mahogany (Swietenia

spp. or Khaya spp.):

Other:

Panels not

exceeding in

any dimension

3.6 mm in

thickness, 1.2 m

in width and 2.2

m in length:

8%

Free

Free

8%

8%

d

Free

e

Free

Free

40%

50%

40%

40%

See source at end of table
C-6 

TABLE C-2 Wood flooring and hardwood plywood: HTS heading 4412, tariff rates, 2008—Continued

a

General Special bColumn 2

HTS provision Article description Rates (percent ad valorem)

4412.31.40.60

4412.31.40.70

4412.31.51

4412.31.51.30

4412.31.51.50

4412.31.51.60

4412.31.51.70

4412.31.60

4412.31.91

4412.32

4412.32.05

4412.32.05.20

4412.32.05.40

4412.32.05.60

4412.32.25

4412.32.25.10

4412.32.25.20

Other:

Not surface

covered:

Other:

Other:

With a face ply of sen

(Kalopanax: spp.):

Other

Panels not exceeding in

any dimension 3.6 mm in

thickness, 1.2 m in width

and 2.2 m in length:

Other:

Not surface covered:

Other:

Other

With at least one outer ply of the

following tropical woods: Dark Red

Meranti, Light Red Meranti, White

Lauan, Sipo, Limba, Okoumé,

Obeche, Acajou d'Afrique, Sapelli,

Virola, Mahogany, Palissandre de

Para, Palissandre de Rio or

Palissandre de Rose

Other:

Other, with at least one outer ply of

nonconiferous wood:

Not surface covered, or surface covered

with a clear or transparent material

which does not obscure the grain,

texture or markings of the face ply:

With a face ply of birch (Betula

spp.):

Panels not exceeding in any

dimension 3.6 mm in

thickness, 1.2 m in width and

2.2 m in length

Other:

Not surface covered:

Other:

With a face ply of Spanish cedar

(Cedrela spp.) or walnut (Juglans

spp.):

With a face ply of Spanish

cedar (Cedrela spp.):

With a face ply of walnut

(Juglans spp.):

8%

8%

8%

Free

5.1%

f

Free

g

Free

f

Free

e

Free

40%

40%

40%

50%

40%

See source at end of table.
C-7 

TABLE C-2 Wood flooring and hardwood plywood: HTS heading 4412, tariff rates, 2008—Continued

a

General Special bColumn 2

HTS provision Article description Rates (percent ad valorem)

4412.32.31

4412.32.31.30

4412.32.31.40

4412.32.31.50

4412.32.31.60

4412.32.31.70

4412.32.56

4412.39

4412.39.10

4412.39.30

4412.39.40

4412.39.50

4412.94 

4412.94.10

4412.94.10.30

4412.94.10.50

Other:

With a face ply of sen

(Kalopanax spp.):

With a face ply of mahogany

(Swietenia spp. or Khaya

spp.):

Panels not exceeding in

any dimension 3.6 mm in

thickness, 1.2 m in width

and 2.2 m in length:

Not surface covered:

Other:

Other

Other, with both outer plies of coniferous

wood:

Not surface covered, or surface covered

with a clear or transparent material

which does not obscure the grain,

texture or markings of the face ply:

With a face ply of Parana pine

(Araucaria angustifolia):

With a face ply of European red

pine (Pinus silvestris):

Other:

Other

Other

Blockboard, laminboard and battenboard:

With at least one outer ply of

nonconiferous wood:

Plywood:

Not surface covered, or

surface covered with a clear or

transparent material which

does not obscure the grain,

texture or markings of the face

ply:

With a face ply of birch

(Betula spp.):

Other:

Not surface

covered:

Other:

8%

8%

Free

3.4%

8%

5.1%

Free

e

Free

e

Free

h

Free

e

Free

i

Free

40%

40%

40%

40%

40%

40%

50%

See source at end of table
C-8 

TABLE C-2 Wood flooring and hardwood plywood: HTS heading 4412, tariff rates, 2008—Continued

a

General Special bColumn 2

HTS provision Article description Rates (percent ad valorem)

4412.94.31

4412.94.31.05

4412.94.31.11

4412.94.31.21

4412.94.31.31

4412.94.31.41

4412.94.31.60 

4412.94.31.71

4412.94.41

4412.94.51

4412.99

4412.99.06

4412.99.10

4412.99.10.20 

Other:

Wood flooring

Other

With a face ply

of Spanish

cedar (Cedrela

spp.):

With a face ply

of walnut

(Juglans spp.):

With a face ply

of sen

(Kalopanax

spp.):

With a face ply

of mahogany

(Swietenia spp.

or Khaya spp.):

Other:

Not surface

covered:

Other:

Other:

Other:

Other:

With at least one outer ply of

nonconiferous wood:

Containing at least one layer of

particleboard:

Other:

Plywood:

Not surface covered, or

surface covered with a

clear or transparent

material which does not

obscure the grain, texture

or markings of the face

ply:

With a face ply of

birch (Betula spp.):

Panels not

exceeding in

any dimension

3.6 mm in

thickness, 1.2 m

in width and 2.2

m in length:

8%

8%

Free

Free

Free

f

Free

j

Free

40%

40%

40%

40%

50%

See source at end of table
C-9 

TABLE C-2 Wood flooring and hardwood plywood: HTS heading 4412, tariff rates, 2008—Continued

a

General Special bColumn 2

HTS provision Article description Rates (percent ad valorem)

4412.99.10.30

4412.99.10.40

4412.99.31

4412.99.31.10

4412.99.31.20

4412.99.31.30

4412.99.31.40

4412.99.31.50

4412.99.31.60

4412.99.31.70

4412.99.41

4412.99.51

Other:

Not surface

covered:

Other:

Other:

With a face ply

of Spanish

cedar (Cedrela

spp.):

With a face ply

of walnut

(Juglans spp.):

 With a face ply

of sen

(Kalopanax

spp.):

With a face ply

of mahogany

(Swietenia spp.

or Khaya spp.):

Other:

Panels not

exceeding

in any

dimension

3.6 mm in

thickness,

1.2 m in

width and 

2.2 m in

length:

Other, not

surface

covered:

Other

Other:

Other:

8%

8%

Free

f

Free

j

Free

40%

40%

40%

Source: Harmonized Tariff Schedule of the United States (2008).

a

Normal trade relations, formerly known as the most-favored-nation duty rate. b

The "Free" duty rate is available for all of the designated tariff lines noted in the "Special" column for the following U.S. trade

preference programs: U.S.-Australia FTA, U.S.-Bahrain FTA, NAFTA, U.S.-Chile FTA, CBERA, U.S.-Israel FTA, ATPA/ATPDEA,

U.S.-Jordan FTA, U.S.-Morocco FTA, CAFTA, and the U.S.-Singapore FTA. The designated tariff lines differ only in how the

specific product is treated under GSP and, in one case, under AGOA. c

Applies to imports from a small number of countries that do not enjoy normal trade relations duty status. d

Brazil, Ecuador, and Indonesia are not eligible under GSP. e

Brazil is not eligible under GSP.

f

Brazil and Indonesia are not eligible under GSP.

g

Indonesia is not eligible under GSP.

h

Russia is not eligible under GSP.

i

Also free of duty under AGOA.

j

Brazil, Colombia, Ecuador, and Indonesia are not eligible under GSP.
C-10 

TABLE C-3 Wood flooring: HTS heading 4418, tariff rates, 2008

a

General bSpecial cColumn 2

HTS provision Article description Rates (percent ad valorem)

4418

4418.71

4418.71.10

Other:

4418.71.20

4418.71.90

4418.72

4418.72.20

4418.72.90

4418.79.00

4418.90

4418.90.46

4418.90.46.90

Builders' joinery and carpentry of wood, including

cellular wood panels and assembled flooring panels;

shingles and shakes:

Assembled flooring panels:

For mosaic floors:

Solid:

Other:

Having a face ply more than 6 mm

in thickness:

Other:

Other, multilayer:

Having a face ply more than 6 mm in

thickness:

Other:

Other:

Other:

Other:

Other:

Free

Free

8%

3.2%

8%

3.2%

3.2%

d

Free

e

Free

d

Free

e

Free

e

Free

33 1/3%

33 1/3%

40%

33 1/3%

40%

33 1/3%

33 1/3%

Source: Harmonized Tariff Schedule of the United States (2008).

a

Normal trade relations, formerly known as the most-favored-nation duty rate. b

The "Free" duty rate is available for all of the designated tariff lines noted in the "Special" column for the following U.S. trade

preference programs: U.S.-Australia FTA, U.S.-Bahrain FTA, NAFTA, U.S.-Chile FTA, CBERA, U.S.-Israel FTA, ATPA/ATPDEA,

U.S.-Jordan FTA, U.S.-Morocco FTA, CAFTA, and the U.S.-Singapore FTA. The designated tariff lines differ only in how the

specific product is treated under GSP. c

Applies to imports from a small number of countries that do not enjoy normal trade relations duty status. d

Brazil and Indonesia are not eligible under GSP.

e

Brazil is not eligible under GSP.
C-11

TABLE C-4 Wood flooring and hardwood plywood: Comparison of 2006 and 2008 HTS

HTS Subheading NTR 

2006 2008 Rate of Duty 

Coniferous, unfinished, end-matched 4409.10.05 4409.10.05 3.2 NYL84Non-coniferous, unfinished, end-matched, Jatoba 4409.20.05 4409.29.0515 3.2 N0182

Non-coniferous, unfinished, end-matched, Ipe 4409.20.05 4409.29.0525 3.2Non-coniferous, unfinished, end-matched, Santos mahogany 4409.20.05 4409.29.0535 3.2Non-coniferous, unfinished, end-matched, Cumaru 4409.20.05 4409.29.0545 3.2Non-coniferous, unfinished, end-matched, Other 4409.20.05 4409.29.0555 3.2Coniferous, unfinished 4409.10.20 4409.10.20 freeNon-coniferous, unfinished, Maple 4409.20.2530 4409.29.2530 free NYI825

Non-coniferous, unfinished, birch and beech 4409.20.2550 4409.29.2550 free

Non-coniferous, unfinished, Other 4409.20.2560 4409.29.2560 freeConiferous, factory-finished 4418.90.4590 4418.90.4690 3.2 NYK88

Non-coniferous, factory-finished 4418.90.4590 4418.90.4690 3.2 N00574

Veneer coreTropical & birch face plies < 4 mm 4412.13.05 4412.31.05 freeTropical, Spanish cedar or walnut face plies < 4 mm 4412.13.25 4412.31.25 8.0 N0167Tropical, tropical face ply as specified < 4 mm 4412.13.40 4412.31.40 8.0 NYE89Tropical face ply < 4 mm 4412.13.51 4412.31.51 8.0 NYI830Tropical & other tropical face ply < 4 mm, surface covered 4412.13.60 4412.31.60 8.0 N00334

Tropical face ply < 4 mm, surface covered 4412.13.91 4412.31.91 8.0Nonconiferous & birch face plies < 4 mm 4412.14.05 4412.32.05 free N0143Nonconiferous & Spanish cedar or walnut face plies < 4 mm 4412.14.25 4412.32.25 5.1 NYI863

Nonconiferous < 4 mm 4412.14.31 4412.32.31 8.0 NYK88

NYL80NYL85NYR04

Nonconiferous < 4 mm, surface covered 4412.14.56 4412.32.56 8.0Coniferous outer plies, face ply < 4 mm 4412.19.40 4412.39.40 8.0 NYK80

Coniferous outer plies, face ply < 4 mm, surface covered 4412.19.5050 4412.39.5050 5.1Any of the above with face ply 4 to 6 mm 4418.72.95 8.0 NYL80
C-12

TABLE C-4 Wood flooring and hardwood plywood: Comparison of 2006 and 2008 HTS–Continued

HTS Subheading NTR 

Product 2006 2008 Rate of Duty Particleboard, MDF, or solid coreTropical ply w/ layer of particleboard, face ply <4 mm 4412.22.06 4412.99.06 free N0098Tropical, plywood, solid core, birch face ply < 4 mm 4412.22.10 4412.94.10 free N0182Tropical, plywood, other core, birch, face ply < 4 mm 4412.22.10 4412.99.10 freeTropical, plywood, solid core, face ply < 4 mm 4412.22.31 4412.94.31 8.0 N0091

N0182N00574

Tropical, plywood, other core, face ply < 4 mm 4412.22.31 4412.99.31 8.0Tropical, plywood, solid core, face ply < 4 mm, surface covered 4412.22.41 4412.94.41 8.0

Tropical, plywood, other core, face ply < 4 mm, surface covered 4412.22.41 4412.99.41 8.0

Tropical, solid core, face ply < 4 mm 4412.22.51 4412.94.51 freeTropical, other core (e.g., HDF), face ply < 4 mm 4412.22.51 4412.99.51 free N0185

Nonconiferous w/ layer of particleboard, face ply < 4 mm 4412.23.01 4412.99.06 free NYJ86Nonconiferous, plywood, solid core, birch face ply < 4 mm 4412.29.15 4412.94.10 freeNonconiferous, plywood, other core, birch face ply < 4 mm 4412.29.15 4412.99.10 freeNonconiferous, plywood, solid core, face ply < 4 mm 4412.29.36 4412.94.3105 8.0 NYK89

NYM87

Nonconiferous, plywood, other core, face ply < 4 mm 4412.29.36 4412.99.31 8.0Nonconiferous, plywood, solid core, face ply < 4 mm, surface covered 4412.29.46 4412.94.41 8.0

Nonconiferous, plywood, other core, face ply < 4 mm, surface covered 4412.29.46 4412.99.41 8.0

Nonconiferous, solid core, face ply < 4 mm 4412.29.56 4412.94.51 free N0143Nonconiferous, other core, face ply < 4 mm 4412.29.56 4412.99.51 free NYL84

Any of the above w/ face ply > 6 mm 4418.72.2000 3.2Any of the above with face ply 4-6 mm 4418.72.9000 8.0 N00574Bamboo flooringGrain of plies parallel, face ply < 4 mm 4412.29.56 4412.10.90 free NYK80

Grain of plies parallel, face ply 4 to 6 mm 4412.29.56 4418.72.91 free N0046

N0108

Grain of plies parallel, face ply > 6 mm 4412.29.56 4418.72.20 3.2 N0197Grain of plies perpendicular, face ply < 4 mm 4412.29.36 4412.10.05 8.0Grain of plies perpendicular, face ply 4 to 6 mm 4412.29.36 4418.72.90 8.0 NYK89Grain of plies perpendicular, face ply > 6 mm 4412.29.56 4418.72.20 3.2Solid core, bamboo face ply 4 to 6 mm 4412.29.36 4418.72.90 3.2 N0100
TABLE C-4 Wood flooring and hardwood plywood: Comparison of 2006 and 2008 HTS–Continued

HTS Subheading NTR 

Product 2006 2008 Rate of Duty 

C-13

Veneer core, bamboo face ply, 4-6 mm 4412.14.31 4418.72.90 3.2 N0113aBamboo strips turned on edge (vertical) 4412.29.56 4418.79.00 3.2 N0108

N0100N01584

Bamboo strand flooring 4418.90.45 4418.90.46 3.2 N0176Cork flooringLaminated cork flooring 4504.10.30 4504.10.30 free NYJ82

Parquet (mosaic) flooringSolid 4418.30.0000 4418.71.1000 8.0 NYG89Engineered, face > 6 mm 4418.30.0000 4418.71.2000 8.0Engineered, other 4418.30.0000 4418.71.9000 8.0Veneer coreTropical & birch face plies 4412.13.05 4412.31.05 freeTropical, Spanish cedar or walnut face plies 4412.13.25 4412.31.25 8.0

Tropical, tropical face ply as specified 4412.13.40 4412.31.40 8.0 N0041

Tropical face ply 4412.13.51 4412.31.51 8.0Tropical & other tropical face ply, surface covered 4412.13.60 4412.31.60 8.0 N00334Tropical face ply < 4 mm, surface covered 4412.13.91 4412.31.91 8.0Nonconiferous & birch face plies 4412.14.05 4412.32.05 free NYM87

Nonconiferous & Spanish cedar or walnut face plies 4412.14.25 4412.32.25 5.1 NYH84Nonconiferous 4412.14.31 4412.32.31 8.0 NYH84

N0186

Nonconiferous, surface covered 4412.14.56 4412.32.56 8.0Particleboard, MDF, or solid coreTropical ply w/ layer of particleboard 4412.22.06 4412.99.06 free

Tropical, plywood, solid core, birch face ply 4412.22.10 4412.94.10 freeTropical, plywood, other core, birch face ply 4412.22.10 4412.99.10 freeTropical, plywood, solid core 4412.22.31 4412.94.31 8.0 N0167Tropical, plywood, other core 4412.22.31 4412.99.31 8.0
TABLE C-4 Wood flooring and hardwood plywood: Comparison of 2006 and 2008 HTS–Continued

HTS Subheading NTR 

Product 2006 2008 Rate of Duty 

C-14

Tropical, plywood, solid core, surface covered 4412.22.41 4412.94.41 8.0

Tropical, plywood, other core, surface covered 4412.22.41 4412.99.41 8.0Tropical, solid core 4412.22.51 4412.94.51 freeTropical, other core 4412.22.51 4412.99.51 freeNonconiferous w/ layer of particleboard 4412.23.01 4412.99.06 free

Nonconiferous, plywood, solid core, birch face ply 4412.29.15 4412.94.10 free N0167Nonconiferous, plywood, other core, birch face ply 4412.29.15 4412.99.10 freeNonconiferous, plywood, solid core 4412.29.36 4412.94.31 8.0Nonconiferous, plywood, other core 4412.29.36 4412.99.31 8.0Nonconiferous, plywood, solid core, surface covered 4412.29.46 4412.94.41 8.0

Nonconiferous, plywood, other core, surface covered 4412.29.46 4412.99.41 8.0Nonconiferous, solid core 4412.29.56 4412.94.51 freeNonconiferous, other core 4412.29.56 4412.99.51 free N0203

a The classification of bamboo flooring made of vertically oriented strips of bamboo is currently being considered by CBP under ruling 

Sources: Harmonized Tariff Schedule of the United States (2008), and USCBP Customs Rulings Online Search System.
D-1

APPENDIX D

Hearing List of Participants
 
 D-3 

CALENDAR OF PUBLIC HEARING

Those listed below appeared as witnesses at the United States International Trade Commission’s

hearing:

Subject: Wood Flooring and Hardwood Plywood: Competitive

Conditions Affecting the U.S. Industries

Inv. No.: 332-487

Date and Time: October 3, 2007 - 9:30 a.m.

Sessions were held in connection with this investigation in the Main Hearing Room (room 101),

500 E Street, S.W., Washington, D.C.

CONGRESSIONAL APPEARANCE:

The Honorable Ron Wyden, United States Senator,

 United States Senate, State of Oregon

ORGANIZATION AND WITNESS:

Panel 1: U.S. Plywood Producers and Industry Associations

Hardwood Federation

Deb Hawkinson, Executive Director

The United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service

Workers International Union, AFL-CIO, CLC (USW)

Keith Romig, Strategic Issues Representative

Hardwood Plywood & Veneer Association (HPVA)

E.T. Altman, President, HPVA

Timber Products Company

Gail Overgard, Vice President, International Division

Columbia Forest Products

Paul Davis, Senior Marketing Analyst
 D-4 

ORGANIZATION AND WITNESS (continued):

Panel 2: U.S. Flooring Producers and Industry Associations

National Wood Flooring Association, Inc. (NWFA)

Edward S. Korczak, CEO and Executive Director, NWFA

The Wood Flooring Manufacturers Association (NOFMA)

Timm Locke, Executive Vice President, NOFMA

Tommy Maxwell, Owner, Maxwell Hardwood Flooring

Bob Haggard, Vice President, Sales, Hassell and Hughes Lumber Company

Saul Ewing, LLP

Washington, D.C.

on behalf of

Anderson Hardwood Floors, Armstrong World Industries, Inc. and Mannington Mills, Inc.

Frank J. Ready, President and Chief Executive Officer, 

North American Flooring Products, Armstrong World Industries, Inc.

Thomas S. Davis, President and Chief Executive Officer, 

Mannington Mills, Inc.

Don Finkell, President and CEO, Anderson Hardwood Floors

Jeffrey D. Nickel, Deputy General Counsel, Business & Commercial, 

Armstrong World Industries, Inc.

Jeffrey S. Levin ) - OF COUNSEL

The Master's Craft Corporation

Clyde Elbrecht, Owner
 D-5 

ORGANIZATION AND WITNESS (continued):

Panel 3: Importers' Associations, Foreign Producers and Industry Associations

International Wood Products Association (IWPA)

Brent J. Mcclendon, Executive Vice President, IWPA

Stuart H. Clarke, President, Clarke Veneers and Plywood

Donald A. Thompson, President, Thompson Mahogany Company

Bryan Cave, LLP

Washington, D.C.

on behalf of

Associaçào Nacional dos Produtores de Pisos de Madeira (ANPM) (National Hardwood

Flooring Association - Brazil):

Daniel Pagano, President, BR 111 Exotic Hardwood Flooring

Allan Nery, Representative, BR 111 Exotic Hardwood Flooring

Fabio Scandian, Representative, The Scandian Group

Lyle Vander Schaaf )

) - OF COUNSEL

Felipe Berer )

Greenberg Traurig, LLP

Washington, D.C.

on behalf of

China National Forest Products Industry Association and Various Chinese Wood Products

Companies

Shengfu Wu, Director, China National Forest Products Industry 

Association

Heping Xin, Vice President and General Manager, Guangzhou 

Panyu Kangda Board Co., Ltd.

Frank Zhang, Counsel for Chinese Producers, Beijing Dowway Law Firm

Bihong Li, Assistant General Manager, Dehau TB New 

Decoration Company, Ltd.

Jeffrey S. Neeley )

) - OF COUNSEL

Robert D. Stang )

E-1

APPENDIX E

Summary of Views of Interested Parties
 
 1

 Jeffrey S. Levin, Saul Ewing LLP, Washington DC, counsel to Anderson Hardwood Floors, Armstrong

World Industries Inc., and Mannington Mills Inc., USITC written submission, September 19, 2007.

 2

 Don Finkell, President and chief executive officer, Anderson Hardwood Floors, USITC hearing

transcript, 144–147.

 E-3

Anderson Hardwood Floors, Armstrong World Industries

Inc., and Mannington Mills Inc.1

In his pre-hearing written submission, Mr. Levin, counsel to U.S.-based wood flooring

producers Anderson Hardwood Floors, Armstrong World Industries Inc., and Mannington

Mills Inc., urged several actions by the U.S. government to promote a “level playing field”

and “fair trade” for wood flooring products, as some foreign competitors do not adhere to

international trading rules:

• First, the U. S. government should press for 1) the elimination of illegal production

and export subsidies of wood flooring, preferably through the WTO or bilateral

consultations and negotiations where practical, or through legislation or other

enforcement mechanisms if necessary; and 2) the Chinese government to both

correct its foreign exchange rate system, and enforce and expand its recently

announced repeal of tax rebates to wood flooring exports.

• Second, U.S. Customs and Border Protection (Customs) should continue its Priority

Trade Initiative to enforce the proper tariff classification, duty collection, and

country-of-origin marking of imported wood flooring products.

• Third, Congress should hold hearings, accept public input, and pass legislation that

expands the Lacey Act to prohibit the importation of endangered timber species, and

the U.S. government should negotiate multilateral and bilateral trade limits on

endangered timber species and trade measures that encourage economically viable

and sustainable forestry management to counter illegal logging.

• Fourth, Congress should extend the Trade Adjustment Assistance Program for 

U.S. workers who lose their jobs as a result of global trade.

• Finally, the Commission’s report in this investigation should be comprehensive,

including all of the relevant facts, data, and trends both within the industry and

market for hardwood flooring products, so that its report will “serve as the

preeminent and objective factual repository upon which necessary and appropriate

actions can be based by the executive and legislative branches of our government.”

Anderson Hardwood Floors2

In his hearing testimony, Mr. Finkell, of Anderson Hardwood Floors (Anderson), a vertically

integrated producer from sawing logs to finishing hardwood flooring, stated that unless

something is done quickly to address the unfair competitive environment, many more family-
 3

 Frank J. Ready, president and chief executive officer, North American Flooring Products, Armstrong

World Industries Inc., USITC hearing transcript, 133–38.

 4

 Allan Nery, representative, BR 111 Exotic Hardwood Flooring, USITC hearing transcript, 216–21; and

Daniel Pagano, president, BR 111 Exotic Hardwood Flooring, USITC hearing transcript, 237–40.

 E-4

owned producers will not be as lucky as his firm (sold in October 2007) in aligning

themselves with a larger producer within the U.S. hardwood flooring industry.

Armstrong World Industries Inc.3

In his hearing testimony, Mr. Ready, of Armstrong World Industries Inc. (Armstrong), which

described itself as the largest U.S. producer of wood flooring, expressed the view, which he

said was shared by many domestic producers, that the industry’s playing field is not only no

longer level, but is also becoming increasingly unbalanced. He said that although some

domestic producers, including Armstrong, import small amounts of certain hardwood

flooring and even operate production facilities abroad, these and other efforts to enhance

their own competitiveness and to promote sustainable forestry practices are undermined by

foreign competitors who depend upon illegal logging, government subsidies, and evasion of

duties through tariff mis-classification. 

BR 111 Exotic Hardwood Flooring4

In his hearing testimony, Mr. Nery, of BR 111 Exotic Hardwood Flooring, an associate

member of the Brazilian National Hardwood Flooring Association (ANPM), which imports,

develops, and supplies exotic hardwood flooring products from Brazil to the U.S. market,

claimed that hardwood flooring products from Brazil are of such unique character (e.g.,

density, wear resistance, color, and grain patterns) that they do not compete with products

of domestic origin and command a higher price in the more upscale niche market.

In his hearing testimony, Mr. Pagano, also of BR 111 Exotic Hardwood Flooring, said that

Brazil’s laws are more than adequate to prevent illegal logging, including licencing

requirements to move sawn logs, and proof-of-origin requirements to ship lumber, plywood,

or flooring.
 10 Jeffery S. Neeley, and Robert D. Stang, Greenberg Traurig, LLP, Washington, DC, counsels to China

National Forest Products Industry, USITC written submission, October 24, 2007; and Shengfu Wu, director,

China National Forest Products Industry Association, USITC hearing transcript, 226–30.

 11 Paul Davis, senior marketing analyst, Columbia Forest Products, USITC hearing transcript, 46–53.

 E-5

China National Forest Products Industry Association

(CNFPIA)10

In his post-hearing written submission, Mr. Neely, counsel to CNFPIA, disputed certain

allegations by the U.S. wood flooring industry. He asserted that 1) subsidy allegations are

vague rather than firm-specific for either the hardwood plywood or wood flooring industries

in China, and are inconsistent with findings by Canadian authorities on a similar industry;

2) illegal logging cannot possibly account for more than a small fraction of the competitive

cost advantages of Chinese products; 3) illegal logging is not within the control of Chinese

hardwood plywood or wood flooring producers anyway; 4) the lack of U.S. formaldehyde

emission regulations weakens allegations of Chinese failures to meet emissions standards;

and 5) some of the same U.S. firms that aided the development efforts of Chinese firms now

complain about Chinese success in the U.S. market.

In his hearing testimony, Mr. Wu of CNFPIA, addressed what he considered the misperception that Chinese plywood and wood flooring industries are unable to meet the quality

or style standards in developed countries. According to Mr. Wu, (1) almost all wood for

plywood and wood flooring cores comes from domestic plantation resources and only a

small portion of face veneer is imported, (2) China has a cost advantage in production of

labor-intensive plywood and wood flooring products, and (3) Chinese exporting firms

regularly comply with industry standards worldwide. On the last point, Mr. Wu noted that

China sells these products in both the Japanese and European markets that impose some of

the highest standards in the world, so in certain respects, the internal Chinese market has

higher product standards than the United States, which he said relies largely on voluntary

industry standards.

Columbia Forest Products11

In his hearing testimony, Mr. Davis, of Columbia Forest Products (Columbia), which claims

to be one of the largest manufacturers of hardwood plywood products in North America,

favors market-driven approaches to suppress illegal log trading, including a certification

chain of national, regional, and local distributors and fabricators in the Forest Stewardship

Council (FSC) network across North America. Mr Davis encouraged the Commission to

consider how forest certification programs can be utilized to manage the trade and sources

of legal timber.
 12 Bihong Li, assistant general manager, Dehau TB New Decoration Co. Ltd., USITC hearing transcript,

pp. 230–33.

 13 Heping Xin, vice president and general manager, Guangzhou Panyu Kangda Board Ltd., through Frank

Zhang, Dowway Law Firm, counsel for Chinese Producers, USITC hearing transcript, 233–37.

 14 Deb Hawkinson, executive director, Hardwood Federation, USITC hearing transcript, 15–22.

 E-6

Dehau TB New Decoration Co. Ltd.12

In his hearing testimony, Mr. Li of Dehau TB New Decoration Co. Ltd. (Dehau), stated that

his firm exports 70 percent of its plywood to the United States, its products meet U.S.

standards for formaldehyde emissions and certification of the legal status of its logs, and

Dehau does not sell its hardwood products in the United States at unfairly low prices. With

regard to unfairly low prices, he said that sales at such prices would be harmful to the firm’s

stock price and to its corporate survival.

Guangzhou Panyu Kangda Board13

In his hearing testimony, Mr. Xin of the Guangzhou Panyu Kangda Board (through Counsel,

Mr. Zhang), stated that multi-layered engineered wood flooring sells for lower prices than

solid wood flooring, due to consumer preference and willingness to pay more for solid wood

flooring. According to Mr. Xin, the Chinese industry developed this product and

manufactures it efficiently to high quality standards. By contrast, he said that there are few

producers and little production of this product in the United States, because the U.S. industry

is still learning how to manufacture it and has not yet approached the quality or efficiency

standards of the Chinese product.

Hardwood Federation14

In her hearing testimony, Ms. Hawkinson, of the Hardwood Federation of industry

associations that represent producers and distributors of hardwood products in the United

States, said that the more systemic problems currently confronting the U.S. hardwood

plywood and flooring industry include: 1) numerous foreign countries that support their

wood products manufacturing with grants and loans, low-priced resources, tax benefits, and

other subsidies; 2) U.S. wood products exporters also face much higher tariffs abroad than

those countries who export to the United States; 3) foreign exporters also mis-classify their

products to avoid paying U.S. import duties; 4) labor standards, workplace safety, and

environmental protection are less stringent, or even non-existent, in foreign countries than

in the United States; and 5) allegedly, a significant quantity of timber in foreign countries

with state-controlled forest resources is extracted illegally from protected forests, in excess

of concession limits, and without payment of royalties or duties.
 15 Robin Grove, chair, Hardwood Import Coalition, Washington DC, USITC written submission, January

11, 2008.

 16 E.T. Altman, president, HPVA, USITC hearing transcript, 31–37.

 17 Bob Haggard, vice president, sales, Hassell and Hughes Lumber Co., USITC hearing transcript,

123–27.

 E-7

Hardwood Import Coalition15

In his written submission, Mr. Grove, of the Hardwood Import Coalition (Coalition) of firms

that import solid and engineered wood flooring as well as hardwood plywood, claimed that

imports increased not necessarily because of illegal and unfair trade practices, but rather due

to increased U.S. demand and shifts in consumer preferences toward a wide and oftentimes

exotic array of products, some of which are only available from other countries. Coalition

members import these products to take advantage of better prices, higher quality, better

service, and more dependable supplies. Hence, instead of imposing punitive import duties

or restrictions upon the entire industry, Mr. Grove suggested that the U.S. government

should target those firms that willfully engage in unfair, deceptive, or illegal business

practices, while allowing legitimate firms to import wood flooring into the U.S. market

unimpeded.

Hardwood Plywood & Veneer Association (HPVA)16

In his hearing testimony, Mr. Altman, of the HPVA said his members produce more than 85

percent of the stock panel hardwood plywood and nearly 60 percent of the engineered

hardwood flooring in the United States. He expressed concern that imported hardwood

plywood from China does not meet the voluntary U.S. industry consensus standard

ANSI/HPVA-1 that limits formaldehyde emissions, although the Chinese product is stamped

as meeting this standard. He said that the U.S. industry has invested in control methods that

dramatically reduced formaldehyde emission levels among domestic hardwood products over

the past two decades, but that imported wall paneling had 2–5 times the emissions failure

rate of domestic wall paneling during the 2001–05 period.

Hassell and Hughes Lumber Co.17

In his hearing testimony, Mr. Haggard, of domestic hardwood flooring producer Hassell and

Hughes Lumber Co., claimed that U.S. producers are competitively disadvantaged and that

potential adverse impacts upon raw materials suppliers and other supporting businesses result

from foreign competitors not bearing the same regulatory requirements for environmental

protection, employee health and safety, and sustainable forestry practices as do U.S.

producers.
 18 Brent J. McClendon,, executive vice president, IWPA, USITC hearing transcript, 206–09; and USITC

written submission, October 24, 2007.

 19 Kristin H. Mowry, Jill A. Cramer, and Jodi B. Herman, Mowry International Group LLC, Washington

DC, counsels to J. Michael & Co. LLC and Fine Furniture Ltd., USITC written submission, January 11,

2008.

 E-8

International Wood Products Association (IWPA)18

In his hearing testimony and post-hearing written submission, Mr. McClendon, of the IWPA,

representing some 220 U.S. firms that produce or import wood products, stated that imported

wood products provide broad economic benefits to the United States by meeting growing

demand for quality products at affordable prices, providing access to wood species not

grown in the United States, and supporting domestic U.S. jobs throughout the logistics chain.

He said that the IWPA, in opposing illegal logging, works aggressively with and commends

the U.S. Government for its initiatives, including the U.S.-Indonesia Memorandum of

Understanding; the U.S.-China strategic economic dialogue to initiate a bilateral agreement;

and the U.S.-Peru Free Trade Agreement annex that address this issue. However, he said

that the IWPA finds it difficult to accept the U.S. industry’s argument that illegal logging is

causing a lack of competitiveness in the U.S. market, for it is difficult to prove how much

illegal logging is occurring and where the logs are destined. According to Mr. McClendon,

most illegal logs do not enter into international trade and most imports into the United States

are accompanied by the necessary permits and other documents to certify that they are traded

legally under international and national laws and regulations. He also expressed confidence

that Customs has both the authority and capabilities necessary to deal with mis-classification

and fraudulent labeling of imports. However, he said that IWPA opposes legislation to

amend the Lacey Act because the legislation would not provide any assistance to foreign

government efforts to eliminate illegal logging and holds U.S. firms and their customers

liable for any illegal activity that occurs in forests, sawmills, transport, and ports in foreign

locations.

J. Michael & Co. LLC and Fine Furniture Ltd.19

In their written submission, on behalf of J. Michael & Co. LLC (an importer of engineered

wood flooring) and Fine Furniture Ltd. (an exporter and manufacturer of engineered wood

flooring), Ms. Mowry, Ms. Cramer, and Ms. Herman singled out two issues for the

Commission’s consideration: the need to conduct separate analysis of wood flooring and

hardwood plywood and the need to gather its own data instead of relying on Customs data

for its analysis. In support of the first point, they asserted that the wood flooring and

hardwood plywood industries are two distinct industries with vast differences in product

appearances, usage, distribution channels, customer perceptions, manufacturing, and price.

Accordingly, they suggested that the Commission conduct this investigation through the lens

of the like-product standard in unfair trade investigations and conclude that the products

manufactured by the wood flooring and hardwood plywood industries are not like products.

They also stated that Customs data for wood flooring and hardwood plywood are imprecise,
 20 Thomas S. Davis, president and chief executive officer, Mannington Mills Inc., USITC hearing

transcript, 138–44.

 21 Clyde Elbrecht, owner, Master’s Craft Corp., USITC hearing transcript, 147– 52.

 22 Tommy Maxwell, owner, Maxwell Hardwood Flooring, USITC hearing transcript, 127–33.

 E-9

especially for engineered wood flooring, so the Commission should rely instead on

Commission-collected information.

Mannington Mills Inc.20

In his hearing testimony, Mr. Davis, of engineered hardwood flooring producer Mannington

Mills Inc. (Mannington), said that he was more concerned about the substantial import

growth in recent years, particularly from China, than about the weak residential housing

market and rising production costs. Mr. Davis claimed that China became the world’s

dominant producer and exporter by 2006, at the expense of both U.S. and other foreign

producers. He attributed China’s growth to low-cost but highly skilled labor, an undervalued

currency, substantial government subsidies, and suspect logging practices. These factors and

alleged use of U.S. designs enabled Chinese producers to leap-frog over the development

and marketing stages in a short time frame and at minimal cost, to under-cut domestic

producers with cheaper knock-offs of U.S. brands in the U.S. market.

Master’s Craft Corp.21

In his hearing testimony, Mr. Elbrecht, of solid wood flooring producer Master’s Craft

Corp., claimed that undertaking the veneering and pressing stage in China, not only enables

his U.S.-based firm to compete in a global market, but also supports both the U.S. hardwood

timber industry and jobs for Americans, and ensures that U.S.-origin raw materials continue

to retain a competitive edge. According to Mr. Elbrecht, any proposed regulations to level

the playing field should address only those products of non-native origin or products

manufactured or acquired illegally, as protective regulations affecting products with

domestic content would render them uncompetitive and unable to support the U.S. timber

industry. Further, any protective tariffs imposed upon goods imported from China could

backfire by tempting other countries to respond, thus rendering U.S. exports less competitive

abroad.

Maxwell Hardwood Flooring22

In his hearing testimony, Mr. Maxwell, of domestic hardwood flooring producer Maxwell

Hardwood Flooring (Maxwell), noted that the domestic industry’s already small profit

margin is narrowing due to low hardwood flooring prices and rising fuel charges. He also

said that the major competitive disadvantage for domestic producers is the alleged

government subsidies provided to foreign competitors.
 23 Edward S. Korczak, chief executive officer and executive director, NWFA, USITC hearing transcript,

114–16.

 24 Stephanie Lester, vice president, International Trade, RILA, Arlington VA, USITC written submission,

December 19, 2007.

 25 Gail Overgard, vice president, International Division, Timber Products Co., USITC hearing transcript,

38–45.

 E-10

National Wood Flooring Association Inc. (NWFA)23

In his hearing testimony, Mr. Korczak, of the NWFA, which includes both U.S. and foreign

distributors, dealers, contractors, and producers of wood flooring, affirmed that the distinct

products of both U.S. and foreign wood flooring manufacturers are competitive in a global

industry when it is characterized by free trade and fair marketing. By contrast, he said that

China and certain other nations were cited for illegal logging, mislabeling products to evade

import tariffs, and government subsidies benefitting their own wood flooring industries.

Retail Industry Leaders Association (RILA)24

In her written submission, Ms. Lester of the RILA, which represents the largest retailers in

the United States, including a number of retailers that carry wood flooring products, said that

artificially restricting imports would adversely affect retailers by limiting the variety of

flooring products they can provide to consumers and by restricting supply, which can

increase prices that would then be shouldered by consumers of flooring products who could

potentially switch to other flooring products, thus further eroding the market share of U.S.

producers. Even though hardwood and softwood flooring may sometimes be cheaper to

produce overseas, the additional shipping and import tariff costs, as well as the additional

shipping time, do not easily allow for product customization, which the retailer must

consider. Hence, domestically produced flooring from domestically grown wood is still

highly competitive when compared with imports of finished products. Further, she said that

rising U.S. exports (benefitting from higher worldwide demand due to consumer preferences,

shipping costs, and a weaker U.S. dollar) and declining U.S. imports shows that the U.S.

market for hardwood and softwood flooring is still highly competitive, with neither imports

nor domestic products dominating, conditions that RILA anticipates to continue into at least

the near future.

Timber Products Co.25

In his hearing testimony, Mr. Overgard, of the Timber Products Co., stated that his firm

insists that its timber imports from China must comply with U.S. domestic laws and

standards. However, he expressed concern about timber documentation, emissions standards,

duty evasion, and subsidies. Logs entering China are difficult to document because they pass

through many different traders. He said that as a result, plywood entering the United States

from China is highly undervalued. Further, Chinese hardwood plywood producers are not
 26 Holly R. Hart, Legislative director, USW, Washington DC, USITC written submission, August 29,

2007; and Keith Romig, strategic issues representative, USW, USITC hearing transcript, 22–30.

 E-11

effectively being held to any type of standard for formaldehyde emissions, as plywood

entering from China often measures 10–60 times the standard for plywood produced in the

United States. He said that manufacturers in China often place a birch backing on another

hardwood face to take advantage of the duty-free status of birch plywood and avoid the 8-

percent rate of duty applied to any other faced plywood. Finally, according to Mr. Overgard,

the Chinese government often subsidizes its wood products industry through VAT rebates,

grants, favorable interest rates on loans, debt forgiveness, and tax concessions.

United Steel, Paper and Forestry, Rubber, Manufacturing,

Energy, Allied Industrial and Service Workers International

Union, AFL-CIO, CLC (USW)26

In her pre-hearing written submission, Ms. Hart, of the USW, stated that the rapid growth

in U.S. imports of hardwood plywood and flooring and consequent deterioration in the U.S.

trade balance occurred largely due to the influx of imports from newly emerging exporters,

particularly China, but also Brazil and Chile. According to Ms. Hart, this rapid import

growth of hardwood flooring and plywood is attributed principally to systematic nonenforcement of logging laws and government failures to prohibit illegal log imports that

enabled downstream wood products industries to enjoy unfair advantages from lower input

costs. Further, industries in many foreign countries rely on lax labor and environmental

standards to enhance their competitiveness. 

In his hearing testimony, Mr. Romig, of the USW, claimed that many segments of both the

paper and woodworking industries are disadvantaged by the unfair trade practices of foreign

competitors, particularly cutthroat pricing and competitors who take full advantage of lax

labor and environmental standards abroad. Mr. Romig cited statistics of the American Forest

and Paper Association indicating that as much as 23 percent of global hardwood exports and

30 percent of hardwood plywood exports are of suspicious origin and that these illegal

exports depress world prices by 7–16 percent. Likewise, statements of the Organization of

Economic Cooperation and Development were cited by Mr. Roming indicating that

significant percentages of the wood from China, Russia, Indonesia, and Brazil are of

suspicious origin and that these four countries now account for nearly 50 percent of wood

flooring imports to the United States and 66 percent of U.S. hardwood plywood imports.
 27 Jeffrey S. Levin, Saul Ewing LLP, Washington DC, counsel to the U.S. Plywood and Wood Flooring

Industries, USITC written submission, October 24, 2007. This brief was submitted on behalf of the

Hardwood Federation, HPVA, NWFA, NOFMA, Anderson, Armstrong, Columbia, Mannington, and Timber

Products, who together formed this ad hoc coalition.

 28 Tim Locke, executive vice president, NOFMA, USITC hearing transcript, 116–23.

 E-12

U.S. Plywood and Wood Flooring Industries27

In his post-hearing written submission, Mr. Levin, counsel to the U.S. Plywood and Wood

Flooring Industries, stated that these industries have been severely harmed by unfair import

competition that displaced U.S. market share held by the domestic producers, despite market

conditions during 2002–06 that should have benefitted them, including record demand for

hardwood plywood and flooring. Mr. Levin attributed the problems confronting the domestic

industries to three factors. First, tariff classifications for these products are unwieldy, which

causes widespread confusion in the trading community among foreign suppliers, U.S.

importers, and even Customs officials. Second, exploding import growth in recent years,

with products from China leading the increase, as China has grown from an insignificant

player in 2002 to predominate by 2006. Finally, Chinese producers and exporters benefit

from a nearly limitless supply of cheap yet highly skilled labor, an undervalued fixed

exchange rate, and subsidies that allegedly include discounted loans for export-oriented

enterprises, loan forgiveness for state-owned enterprises, preferential lending mechanisms,

grants, and foreign currency retention schemes.

Wood Flooring Manufacturers Association (NOFMA)28

In his hearing testimony, Mr. Locke, of NOFMA, said that his organization represents U.S.

hardwood flooring manufacturers who produce approximately 75 percent of the solid

unfinished flooring produced in the United States. He expressed concern about the volume

of finished hardwood flooring entering the U.S. market that is being mis-classified as solid

unfinished hardwood products, allegedly to avoid paying duties. Further, although import

volumes have declined since 2006, in part due to stepped-up Customs enforcement, imported

finished hardwood flooring still enters the U.S. market at prices below the cost for domestic

mills to produce unfinished flooring stock.