# United States International Trade Commission

Investigation No. 332-487 USITC Publication 4032 A ugust 2008 

# Wood Flooring and Hardwood Plywood: Competitive Conditions Affecting the U.S. IndustriesAddress 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 Lane y -Cummin g s Director of Operations

Robert A. Ro g owsk y 

## 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



## Au g ust 2008 Publication 4032 

# 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 plyw ood 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 ri se 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 th e 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 c ountries (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 produ cers 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

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# 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 l ogging 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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-5iv 

# CONTENTS–Continued

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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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-27v 

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# 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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-17vi 

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# 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 c onsumption 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: producti on, 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 vari ous plywood production, February 2008 . . . . . . . . . . . . . . . . . . 4-22 4.10. Listed wholesale domestic prices for Chinese domestic and imported solid wood flooring products, February 2008 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-23vii 

# CONTENTS–Continued

Page

4.11. Changes to trade preference programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-25 5.1. Foreign supplier countries: Sawmills, pl ywood 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: Hard wood plywood production, trade, and consumption 2002–06 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-11 5.5. Foreign supplier countries: Exports and im ports of plywood and wood flooring, 2002–06 . 5-12 5.6. Foreign supplier countries: Share of e xports of hardwood pl ywood and wood flooring by market, 2002–06 (%) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-15 6.1. Exchange rates: Units of fo reign currency per U.S. dollar, 2002–06 . . . . . . . . . . . . . . . . . . 6-13



# Figures

ES.1. U.S. shipments, consumption, im ports, and exports of wood flooring and hardwood plywood, 2002–07 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix ES.2. U.S. imports of wood fl ooring and hardwood plywood, 2002–07 . . . . . . . . . . . . . . . . . . . . xi 1.1. Raw material production flows fo r wood flooring and hardwood plywood . . . . . . . . . . . . . 1-4 2.1. Nonconiferous industr ial roundwood: Major trade flows, (million $), 2006 . . . . . . . . . . . . 2-4 2.2. Reported global imports of wood fl ooring and hardwood plywood, 2002 and 2006 . . . . . . 2-6 2.3. Reported global exports of wood fl ooring 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 fo r 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 pr ices, 2002–06, and January–June 2007 . . . . . . . . . . . . . . . . . . . 3-21 3.5. U.S. hardwood plywood pr ices, 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, a nd Malaysia nominal plywood prices, 2002–07 . . . . . 5-24 6.1. U.S. shipments, consumption, im ports, 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, im ports, 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, impor ts, 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 e ngineered wood flooring producer prices, averaged selected grades, and PPI for single-unit residential construction inputs and materials, 2002–06 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-14viii 

# 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 . . . . . . . . . . 6-16ix 

# 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 fo reign 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 Se nate Finance Committee for information on and analysis of the trends and new developmen ts in the global wood flooring and hardwood plywood industries that have affected the comp etitive 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 pattern s 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 positi on 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. Cons umption 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 remode ling 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., fu rniture 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 c onsumption and production in 2007 of both wood flooring and hardwood plywood.



### U.S. Production of Wood Flooring In creased 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 expor ts. 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. sh ipments 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 hardw ood plywood rose from $1.2 billion in 2002 to $2.7 billion in 2006 before declining to $2.5 billi on in 2007. Impor ts of solid wood flooring, engineered wood flooring, and hardwood plyw ood increased by 140 percent, 350 percent, and 67 percent, respectively. The six largest globa l suppliers (Brazil, Canada, China, Indonesia, Malaysia, and Russia) are also the largest suppliers of wood floor ing and hardwood plywood to the U.S. market (figure ES.2). Imports from Br azil, 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 

### Cha nge s in U .S. M ar ke t P r e fer e nc e s Be ne fit te d Im por ts M or e Than Do m e st ic P roduction

A sig nificant shift in U. S. m ark et preferences towa rd p roduc ts suc h as prefin ished woo d fl oo ri ng , e xo ti c sp ec ie s fo r so li d w oo d fl oo ri ng , a nd e ng in ee re d w oo d fl oo ri ngla rg el y benefitt e d

f o r e i g n s up p l i e r s w h o w e r e a b l e t o r e s p o n d

t o i n c r e a s e d

U

. S

. d e m a n d

. U

. S.
pr oduc ers of woo d floo ring and hard woo d p ly woo d inc reased their im ports of finish ed
pr od uc ts e it he r to b ro ad en

p ro du ct li ne s or sup pl em en t d om es ti c pr od uc ti on

. U

. S

. p ro du ce rs also in creased their im

ports of p latform s (interm ediate inputs) for en g ineered woo d floo ring and hardw ood plywoo d to lowe r produ ction costs. The rep ortedly increa sing m ark et po wer of larg e dom estic retailers, coupled with their log istical ability to source produ cts ov erseas, contribu ted to the further erosion of the dom estic m ark et sha re of the U .S. w ood flooring and hardw ood plywoo d industries and m ay also hav e put downw ard pressure on U. S. produ cers’ prices.



### Chi na Em e r ge d as a M aj or G lob al C om pe ti to r and Su pplie r to th e U. S. Market

D es pi te an ex pa nd in g do m es ti c m ark et , the rap id g ro w th o f C hi ne se p ro du ct io n an d ex po rt s

m ov ed C hina from

a net im porter to a larg e ne t exp orter o f eng ineere d wo od f l ooring and hardw ood plywoo d. Chin a acc ounted for m ost o f the g rowthin U. S. i mpor t s during the 2002 –07 period, increa sing stead ily at a n av erag e an nual rate of 37 percen t. C hina is the l a r ges t ha r dw oo d p l ywo od pr od uc e r in th e wor l d a nd a s i gni f

i c a nt pr od uc e r

of woo d f l oo r i ng.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 rat es 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 w ood flooring and plywood industries such as preferential tax breaks fo r 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 supplie rs to the U.S. market account for more than three-fourths of global exports of wood fl ooring and hardwood plywood. Brazil, Canada, Indonesia, Malaysia, and Russia produce substa ntial surpluses of wood flooring and plywood products and are export oriented. Moreove r, 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 fasterthan the Malaysian ringgit and Chinese yuan, giving Malaysia and China a definite advantag e vis-à-vis the other suppliers to the U.S. market. However, for a supplier such as Ch ina, which relies heavily on imported raw materials, the declining U.S. dollar has also ra ised 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 pr oducts 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 h as 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 relativ ely 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 percen t. 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 (C ommittee) requested that the U.S. International Trade Commission (Commission) prepare a report under s ection 332(g) of the Tariff Act of 1930 (19 U.S.C. 1332(g)) that provides information on the competitive c onditions 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 pa rticipant 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 sh are made by Chinese products are particularly noteworthy. China is now the largest U.S. supplier of wood floori ng 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, illegal2 Fillets of solid wood may be substituted for veneer in the co re 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, impor ters, and other interested parties on developments in the supply of and th e 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 floor ing 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 r ubber flooring), ceramic floor tiles, and laminate flooring. U.S. demand for wood flooring is clo sely tied to U.S. residential housing construction and remodeling, which account for the vast majority of sales.

Although wood flooring is predominantly ma de 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 dimensiona lly stable than solid wood flooring and thus can be installed in areas that were previous ly 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. 34 Veneer (i.e., peeler) logs are higher in value than l ogs used for lumber because they are relatively large, straight, and free of defects and/or large knots. To prep are 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 bl anks) is sometimes an in termediate step in the production of finished hardwood plywood. U.S. hard wood 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 pl ywood is principally derived from demand for cabinets, furniture, store fixtures, recreational vehicles, and manufactured homes as well as U.S. residential housing constructi on and remodeling. Because pr oducts 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 ven eer and the desired thickness of the finished product. Plywood production generally begins by either pee ling or slicing a log into thin sheets. 4 Rotary (peeled) veneer 5 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 so metimes 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 ta riff 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 shape d along any of its edges, ends or faces ), 4412 ( see1-48 Certain imports of those wood flooring and hard wood plywood products that are not normally free of duty may be free of duty under the various bilateral U.S. free trade agreements or ot her 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 produc ts, 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 disc repancies include differences in cl assification or units of measure, errors in data collection and compilation, in consistent 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 floori ng 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. Th is is due to the classification issues noted above (overl apping 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 corres ponding 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 ch apter 3 on major foreign suppliers to the U.S. market. The global trade data shown in chapte r 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 incl ude 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 approxima tes 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 co mmon unit of measure (square meters) using conversion factors obtained from industry sour ces. 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 im porter 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 producti on data for wood flooring and hardwood plywood are not generally available. The estimates of gl obal 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 th e 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 ha rdwood plywood shown in chapter 3 are based on questionnaire data . For both products, estimates were adjusted to account for the shipments of known non-r esponding 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 questionna ires 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 prev ented 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 produ cers and importers reported information for all questions or across all pricing products a nd/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 larg e 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 fo r 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 f actors noted in the Committee’s letter include raw materials, illegal logging, technological capabilities, labor practices, environmental policies, government programs, and substitu tes 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 c oncentration 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 factor s 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 th is investigation were two questionnaires developed by Commission staff. One questionnair e was designed to be completed by firms in the United States that produce wood floor ing 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 plyw ood 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 questionna ires 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 floor ing and hardwood plywood. That information was used to develop estimates of U.S. trad e, market size, and market shares for wood flooring and hardwood plywood.

The Commission developed a list of 280 comp anies believed to be producers of wood flooring and hardwood plywood and 160 compan ies believed to be importers of wood flooring and hardwood plywood. Copies of both questionnaires were mailed to all 440 companies, because some producers are al so 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 Commissi on held a public hearing on October 3, 2007. The information gathered at the hearing and fro m 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. Fiel d 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 plyw ood. 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 mate rials (logs, lumber, and veneer), supply chain/marketing channels, pricing, and othe r 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 supp lier industries competing in the U.S. market. Appendices to this report contain the requestletter 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, et c.) 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. A bout two-thirds of industrial roundwood 1 has traditionally been produced in North America and Europe. With that supply of raw material, those same regions have been the major pr oducers of downstream wood and paper products. However, this traditional pattern is changi ng. Growth in the production of wood products, in general, and wood flooring and hardwood plywood in particul ar, is shifting to developing economies, especially to China. Although gl obal production figures for certain hardwood products are not readily available, and trade flows for these products are difficult to track, data sugge st 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 s uppliers 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 e xports of wood floori ng and hardwood plywood.

Industry observers generally believe that illegal logging, which increases th e 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 measu res 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 fo rest 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 histor ically depended upon local supplies of suitable raw material from existing natural forests, th e largest global suppliers of wood flooring and2 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 Organizati on (ITTO) are not comprehensive globally.

3 Softwoods typically predominate in natural fore sts at higher latitudes, and hardwoods predominate in natural forests at lower latitudes. C ountries 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 produ cers 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 a nd hardwood plywood to the U.S. market collectively accounted for over 60 percent of global production of ha rdwood 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 ha rdwoods and softwoods. To date, the United States is the largest global producer of hardw ood 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 l ogs as well. Desirable indigenous species may confer a competitive advantage with respect to the production of wood flooring and hardwood plywood. For example, Russian birc h and Indonesian or Malaysian lauan are in demand for hardwood plywood, and Brazilian e xotic tropical species are in demand for flooring. China is not well e ndowed with natural forests, 4 but recently established poplar plantations provide an important supply of co re veneer for China’s plywood and engineered wood flooring industries.

Trade in hardwood logs and veneer is typica lly limited to higher-value species that are intended for such end uses as furniture, floori ng, cabinets, and paneling. Trade in lowervalue species is generally restricted to rela tively 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 core5 Global trade statistics are not available separa tely for hardwood saw logs and veneer logs.

6 Annual Report, 2006–2007 , European Federation of the Plywood I ndustry, 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 v eneer 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 produc tion of both wood flooring and hardwood plywood during the 2002–06 period. Although da ta are not available for global wood flooring production, it is believed that produc tion increased substantially, largely in response to robust residential and commercial construc tion 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 am ong 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 supp liers to the U.S. market accounted for more than three-fourths of global production of hard wood plywood (table 2.2). However, the shift in global production of hardwood plywood towa rd 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.2-4FIGURE 2.1Non-coniferous industrial roundwood: Major trade flows, (million $), 2006109291414414272235232345LEGENDMajor exportersMajor importersSource: 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 problem atic. 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 inc onsistent conversions. Illegal harv esting and trade may contribute to additional discrepancies. Goetzl, “Discr epancies 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 act ual trends for wood flooring and hardwood plywood. Owing to the overlap in HS classifications betweenengineered 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 globa l 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 pape r 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 shar e in 2002 to a 15 percent share of global wood products trade in 2006. 7 Global imports of wood fl ooring 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 importe r 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, r espectively) than Japan’s imports (7 percent).Annual Re port , 2006–2007 , Eur opea

n Fe der at ion of

the Ply w ood Indus try , J

une 28, 2007, v ar ious 9
pages.

2 -6 im po rt s ex pa nd ed

a t f as te r ra te s (1 6 an d 17 pe rc en t, re sp ec ti v el y ) th an Jap an ’s im po rt s (7
percen t). J a pan' s m ore m oderate g rowthw as d ue, in pa rt, to the relativ ely slowg rowthof the Japanese housing m ark et du ring the 2002 –06 by histo rically

low interest rates, Euro pean

re si de nt ia l c on st ru ct io n, f or b ot h ne w a nd

r en ov at io ns r ep orte dly beg an a s tr on g u

pw ar d trend in 20 04. I n ad dition to the trend in residential constru ction , E urope an d em and for 9

woo d flooring is increasingrelative to o ther ty pes of flooring . C onsu m

ption of en g ineered solid woo d floo ring repo rtedly acce lerated during the last five y ears, and by 20 06, EuropeanD uringthe 2002–06 pe riod, J apa nes e housi ng s ta

rts inc re as ed at

an a v er ag e annua l r at e of 2 pe rc ent

. 10 Yas u sh i Oka m o to , ed it o r o f Japan Lum ber J ournal , e -m ai l m es sa g e to C om m is si on s ta f

f , Fe brua ry 18, 2008. Ibi d. 11 Ibi d. 12

2 -7 consu m ption of woo d flooring was appro xim ately 114 m illion square m eters or p e riod. 10 Dri v e n 5

. 5 p e r c e n t o f

t h e t o t a l f

l o o r i n g m a r k e t

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a v er ag e an nu al r at e of

4 p er ce nt

. 12

The top three e xporters o f w ood flooring and

hard woo d p ly woo d (C hina, Malay sia, and I nd on es ia ) ac co un te d fo r ab ou t t w o- th ir ds o f g lo ba l e xp orts ( by v al ue ) duri ng2 00 2 (f

ig ur e 2. 3)

. C hi ne se e xp orts p os te d th e la rg es t g ai n am on g a ll s up pl ie r co un tr ie s fr om 2 00 2 to 2006 , in creasing stead ily at a n av erag e an nual rate of 37 percen t during t he p e r i od, and

accou nted for alm ost o ne- half o f the i nc r e a s e i n g lobal expo rts. I n 2 006, C hina ov ertook Malay sia to becom e the larg est g lobal supp lier. Malay sian e xports increased stead ily at a n

av erag e an nual rate of 13 percen t, while I ndon esian exports peak ed in 20 04. B raz ilian an d R us si an e xp orts g re w a t a n av er ag e an nu al r at e of 15 p er cen t, wh il e C an ad ia n ex po rt s expan ded m

uch m ore slo wly

(3 percen t) during the period. The m aj or g lobal trade flo ws for hardw ood plywoo d an d w ood flooring are presente d in fig ure 2 .4.2-8FIGUR E 2.4H ardwood plyw ood and wood flooring: Major trade flows, (m illion $), 2006So urce: GTIS , Glo bal Trad e Atlas Da ta base .3533181,0842062472122323696592848231,267304LEGE NDM a jo r exp ortersM a jo r imp orters13 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 fo r these products are reported in cubic meters, square meters, or metric tons. Quantities reported in metric t ons or square meters have been converted to cubic meters using average weights and thicknesses; quantitie s 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 fl ooring and hardwood pl ywood expanded at a somewhat slower rate than the dollar valu e 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 steadi ly at an average annual rate of 43 percent in quantity terms. The quantity of Russian e xports also increased rapidly, at an average annual rate of 22 percent. Quantities of expor ts 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 be nefitted 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 a CAGR 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 th e FAO, regions with developed economies and temperate forests generally have stable or increasing forest area, while regions with14 FAO, State of the World’s Forests 2007 , 2007, viii. The causes of deforestation vary by location and include logging for raw material fo r 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 l ogs and sawn timber in producing countries and government procurement policies aimed at reducing illegal logging. Some industry observers also consider certain activities of pr ivate sector entities that object to imports of some wood products to be disrupting market access.

16 FAO, “Governments Making Progress in Curbi ng Illegal Logging,” December 5, 2005, 1. For a comprehensive look at the extent of illegal logging, th e 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 Tr ade in Endangered Species of Wild Fauna and Flora (CITES). For instance, Brazilian rosew ood 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 causi ng lost revenue for national governments and local communities. 16

In 2001, the OECD estimated that approximate ly 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 thatabout 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 valu e 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 organiza tions (NGOs) often incorporate other issues such as the awarding of logging concessions, sustainable forest management, compliance with labor and environmental la ws and regulations, proper collection of taxes, royalties and fees, and an absence of corruption. Th e differences between governmental and NGO definitions may help explain some of the variation found in assessments of the extent of illegal logging. 2223 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 W ood 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 inte rnational trading rules and agreements. 23



## Estimated Rates of Illegal Logging in Production and Exports

It is often difficult to determine the origin of l ogs 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 ava ilable from many different suppliers and is then turned into wood and paper products by firm s 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 mo re difficult by inadequacies in the statistics for forests and wood processing industries. Official estimates of timber harvests and production of wood products are often questiona ble. 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 l ogs and wood products. 25

Two comprehensive studies of the economic impact of illegal logging examined the available assessments of the extent of illega l 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 Ameri can 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 susp icious 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 the2-12 TABLE 2.4 Estimated rates of suspicious industrial roundwood harvests Country a Alphametric b Seneca 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 forest s in Brazil, Indonesia, and Malaysia are predominantly hardwood.
b Seneca Creek and Associates and W ood Resources International, “ Illegal” Logging and Global Wood Markets, November 2004, 11–13. The ranges repr esent figures reported by vari ous authors and organizations, and the assumed figures are those used in their anal ysis of the impacts on the U.S. industry.

TABLE 2.5 Estimated rates of suspicious trade % of Exports

Country a Alphametric b Seneca 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 produc tion. 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 of ten 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 c ould lead to increased incentives for illegal logging. 29

The price differential between legal and illegal l ogs 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 adva ntage to those who use illegal logs in the manufacture of wood products, illegal logging h as 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 sp ecific 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. Ho wever, 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 threatened32 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/prese ntations/200706/Lopez-Casero.ppt

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

.

2-14 and endangered species, including trade in fore st 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, a nd wood products, includi ng substantial imports from countries identified as high risk for illegal logging and related trade. 32 In 2003, the EU adopted the Forest Law Enforcement, Govern ance 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 a nd wood products, particularly from tropical countries. During 2006, the government of Japan announced changes to its public procurement policy concerning wood-based pr oducts, 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 ve rification 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. 3738 USAID, “Initiative Against Illegal Logging,” May 20, 2004, 1.

39 White House, “President’s Initiative Against I llegal 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 a nd 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 fi ghting 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 co mpliance 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 I ndonesia signed a memorandum of understanding (MOU) 40 that is designed to promote forest c onservation 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, enhan ced 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-sponsor ed 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 preventi on, and nature reserve protection. 43

Peru

The recently ratified Peru Trade Promotion Agreement (PTPA) between the United States and Peru includes new and innovative provi sions on combating illegal logging. The PTPA environment chapter includes a first-ever a nnex 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 le gal trade in timber products. Under a separate partnership, the United States is helping Pe ru and Colombia to monitor and verify the management of forests under logging con cessions, including facilitating the sharing of technologies and approaches for increased for est 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, C onservation, and Energy Act amended the Lacey Act Amendments of 1981 45 (Lacey Act or Act) to extend the Act to imports of wood and wood products harvested from illegal sour ces. 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-nativ e 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 wo rd “taken” to include, with respect to a plant, “harvested, cut, logged, or removed”; and expa nds 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 th e 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. 4647 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 a nd social environment.” I TTO, “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 H ectares,” April 3, 2008, 3.

51 The SFI and FSC have provisions for chain-of-cus tody tracking and certification. Given the number of small land holdings in the United States, chain-of-c ustody 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 ar ea consisting of plantations rather than native forests. 48 National and international programs certify individual land holders, companies, and national, state, or community forests. Typi cally, 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 la nd. 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 fo rest area in the developing countries; theseforest 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 Sta ndard Association (CSA) Sustainable Forest Management Program (CAN/CSA Z809) is the leading certification program in Canada. Other national systems include the Malaysia n 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 majo r markets of Europe and the United States. In2-18 developing markets, domestic demand for cer tified products is much more limited, but several of these countries are substantial supplie rs 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 certifi cation. 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 processe s 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-vi s 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 u ses, but declining demand in other end uses moderated the overall growth of U.S. consum ption of hardwood plywood. Contrary to the upward trend that U.S. producers of wood fl ooring 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 hard wood plywood grew rapidly during 2002–07. The six major global suppliers of these products iden tified 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 incr eased 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. manufactur ers of wood flooring and hardwood plywood.2 The Commission received 65 usable producer questionna ires 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 ava ilable 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., oa k, 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 Co mmission 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 ch apter 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. hard wood 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 th at 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 hardw oods, 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 d eclined 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 account ed for only 3–5 percent of consumption in each year of the period. There were no clear patterns in U.S. e xports of ha rdwood logs during the 2002–06 period, but they consisten tly accounted for only 3 to 4 percent of production. 67 The top five producing states (Pennsylvania, Tenne ssee, Virginia, West Virginia, and North Carolina) accounted for 38 percent of U.S. hardwood lumber produc tion 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 reporte dly 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, su ch as Brazil, are reportedly beginning to import more U.S. logs and lumber. The constrained supply of dom estic 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 Incr eased 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 c onsumption 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 offici al 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 subseque ntly declined. U.S. exports of hardwood lumber generally increased during the 2002–06 peri od, 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 cons umption 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 ( percen t) 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 ba lance 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 remode ling 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 per cent of wood purchases by res ponding 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 abu ndant, 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. hardw ood sawmills. Declining demand for high-grade lumber reportedly constrained total U.S. ha rdwood 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 lumb er 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 pl ywood 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 platforms 12 accounted for 8 percent. Purchasing patterns were generally stable, with only one firm reporting nonacquisition-related changes. As w ith solid wood flooring, U.S. manufacturers of engineered wood flooring are largely relia nt on U.S. raw materials. In 2006, responding U.S. manufacturers purchased 92 percent of th eir 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 l ogs increased at an average annual rate of 11 percent, and export unit value increased fro m $257 per cubic meter to $276 per cubic meter.

15 Convention on International Trade in Enda ngered 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 Ameri can, 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 soli d wood flooring firms’ concerns about decreased availability of raw materials. Repor tedly, 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 harves ting 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 tr ade in that species, limited the availability of mahogany veneer.


# Trade

This section discusses trends in U.S. trade w ith 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, ra pid 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 chap ter 2 (China, Canada, Indonesia, Malaysia, Brazil, and Russia) are also the largest s uppliers of wood floori ng 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 valu e 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 s uppliers 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 conver ted to square measure bas ed on an estimated average thickness of 13 mm.16 A total of 51 U.S. flooring firms submitted questi onnaires 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 approxima tely 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 fl ooring producers reported increased capacity.

3-8 

## U.S. Exports

The value of U.S. exports of wood floori ng 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 ar e 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 pe riod, 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 la rger 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 ove r 27 million square feet. In the same year, there were approximately 126 U.S. manufacturer s 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 engine ered wood flooring manufacturer Capella19 Armstrong Industries, “Armstrong Announces Inve stments in Hardwood Fl ooring,” March 15, 2006.

20 Wood Digest , “Mohawk Industries, Inc. Announces Purcha se 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 conver ted to square measure bas ed on an estimated average thickness of 13 mm.

Engineered Wood and solid wood flooring manufacturer HomerWood. 19 Two notable acquisitions occurred in 2007. Reportedly seeki ng increased participation in the U.S. wood flooring market, U.S. flooring firm, M ohawk, purchased the wood floori ng 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 Competiti on with Product Diversity,” April 2007, 48.

23 Estimates of capacity utilization are based on th e 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 produ cers reported that there was no particular seasonality to their shipments of wood fl ooring, although on average the shipments of responding firms in 2006 were somewhat larger in the th ird 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 ma jor 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 Eu ropean demand for Brazilian wood flooring, increasing consumption in Brazil, and timber s upply constraints in Brazil. USITC hearing transcript, October 3, 2007, 222–24.

3-10 The level of vertical integration of indivi dual 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 engin eered wood flooring, separ ate plants may perform veneer production, panel produc tion, 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 expenditu re for new capacity varied widely, from less than $1 million to over $100 million. The averag e 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 ra te of about 3 percent, but in 2007 reported employment declined to below 2002 levels.

U.S. shipments of solid wood flooring pos ted 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 fl ooring increased more quickly than solid wood flooring. U.S. imports of solid wood floor ing 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 pe netration declined in 2007. 26 Reported direct imports of3-11 TABLE 3.5 U.S. solid and engineered wood flooring: Shipments, consum ption, and trade, 2002–07 Estimated a CAGR 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 s ections for engineered wood flooring and hardwood plywood only reflect imports for which U.S. manufacturer s 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 ha rdwood plywood industries are unavailable. However, data for average hourly earnings of production work ers in the U.S. wood products manufacturing sector indicate that wage rate increases were relativel y 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 a nd 11 percent respectively, but declined in 2007 subsequent to the market downturn. Gr owth in solid flooring consumption was somewhat less than that for engineered w ood 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 (tab le 3.6). Consistent with the peak in U.S. lumber prices in 2004, the reported average i ndustry 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 ge nerally 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. engi neered wood flooring firms increased from 32 million square feet in 2002 to over 41 milli on square feet in 2006. Estimated capacity utilization increased from 82 percent in 2002 to 95 percent in 2004 and declined to 8429 Estimated capacity utilization for the first half of 2007 was 80 percent. Responding U.S. engineered wood flooring firms typically calculate plant cap acity 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 0.5 0 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 0.5 5 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 in tegration. The number of production workers reported by U.S. engineered wood flooring firms increased at an average annual rate of 10 percent during th e 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 estimat ed U.S. shipments of engineered wood flooring grew at an average annual rate of 7 percen t, slightly faster than that of solid flooring shipments, and accounted for an increasing percen tage 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 pe netration 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. expor ts 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 tw o 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 rela tive 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 floor ing 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 floori ng 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 averag e 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 av ailability 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 coul d 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 e xpansion 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 rela tive 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 cons truction 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 rat es, 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. mark et 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 pape r layer is printed with photo designs to mimic the surface of natural materials. U.S. sales of laminate fl ooring have grown rapidly and are expected to continue to grow due to strong sales in residential rem odeling, where its advantages are durability and easy installation (i.e., locking tongue and groove technology) a nd maintenance. Despite the fact that it is often printed to simulate wood flooring, ma jor U.S. flooring firms have laminate flooring in their product lines and do not regard it as a substitute for wood flooring. Lamina te 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 tran script, October 3, 2007, 180–182; Floor Covering Weekly , “Statistical Report ‘06,” July 23–30, 2007, 1; and Mille r, “Mannington Floors the Competiti on 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 e xpressed 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 ne vertheless takes a share of the U.S. market that otherwise would likely have been supplied by flooring of U.S. species. US ITC, 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 relati ve 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) sp ecies 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 is40 Hardwood Market Report, 2006: The Year at a Glance, 2007, 18.

41 Questionnaire data indicated that in 2006, 64 per cent 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 per cent, 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. pr oducers include products such as high-end, custom, and designer flooring, parquet floori ng, 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. engi neered wood flooring production. 41 There was also a trend toward thicker flooring. With respect to solid wood floor ing, 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 produ cers 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 th at 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 as43 Other factors identified by producers as sources of competitive advantage included characteristics of the firms themselves (e.g., tradition of product innovation, family ownershi p, brand, and longevity in the market), product attributes (e.g., dimensions, wear layers, color, and finishes) and manufacturing (e.g., custom work, grading, precise to lerances, 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 ma y require special services such as just-in-time inventories and warehousing, promo tional 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 impor ts 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 fo r engineered wood flooring as opposed to solid wood flooring.

There is also a trend in the U.S. market towa rd 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. so lid 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 pe rcent 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 th at 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). Mo st domestic and importe d 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 on3-18 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

Exports48 Catalina Research Inc., Wood Flooring , November 2005, 62.

49 Wood flooring importers typically work through distri butors 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 re tail 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 tran saction-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 quotin g 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 pa yment, 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 pr oducers averaging one week or less. Reported average lead times ranged from 1 to 12 week s for sales produced to order, with most producers averaging 4 weeks or less. For engi neered wood flooring, reported average lead times ranged from 3 to 14 days for orders shi pped 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 comp arable to 2002. The decline was, in part, attributed to increased production from North American producers, increasing imports, and53 Industry official, e-mail message to Commission staff, April 21, 2008.

54 Commission questionnaires solicited price informati on 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., nondom estic) species. Engineered products included a hand-scraped product and a sawn face product in a ddition to products with oak and exotic faces.

55 The number of reporting firms for these products wa s not sufficient to allow prices to be reported directly.

56 The limited number of responding produ cers 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 oa k with a face ply less than 1 mm thick and flooring with a sawn face.

57 Additionally, there are an estimated 90 U.S. esta blishments engaged in th e manufacture of hardwood veneer. USDOC, Census Bureau, Hardwood Veneer and Plywood Manufacturing: 2002 , September 2004, 5.

58 Industry official, interview by Commi ssion staff, Eugene, OR, August 17, 2007.

59 The share of U.S. production accounted for by easte rn plants ranged between 50 and 53 percent during the 2002–06 period. HPVA, Hardwood Stock Panels, Annual Statis tical Report for Calendar Year 2004

, 2005, 41 and 71; and HPVA, Hardwood Stock Panels, Annual Statis tical Report for Calendar Year 2006

, 2007, 45 and 75.

3-20 weakening U.S. demand for unfinished, oak st rip flooring relative to exotic, plank, and prefinished flooring. 53

Average annual prices collected from U.S. produ cer questionnaires for three solid oak strip flooring products generally track weekly i ndustry 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. hardw ood 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 re latively 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 squa re feet. Hardwood plywood producers also60 Industry official, interview by Commi ssion staff, Old Fort, NC, July 18, 2007.

61 U.S. producers do not think that shipments are pa rticularly 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 incl uding veneer, doors, par ticleboard, 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, so me firms specialize in slicing the veneer, while others specialize in the splicing (i.e., edge gl uing) 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. W ith 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 a dvantageous, 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 mi nimum 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 com ponents, sp ecial 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 pe riod, 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. Th e 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 in creased 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 a62 Industry data show that the decline was not confin ed 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 interi or 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 questi onnaire responses, the average thickne ss of U.S. imports of hardwood plywood ranged from one-tenth inch (2.5 mm) to one-e ighth 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 in creased at an average annual rate of 11 percent during the period. Some U.S. producers activ ely 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 remain ed in the 7–9 percent range between 2002 and 2006, but subsequently declined in 2007.

TABLE 3.8 U.S. hardwood plywood: shipment s, consumption, and trade, 2002–07 Estimated a CAGR 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 During64 HPVA, Hardwood Stock Panels, Annual Sta tistical Report for Calendar Year 2004 , 2005, 41and 71, and HPVA, Hardwood Stock Panels, Annual Statis tical 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, duri ng the 2002–06 peri od. In 2006, U.S. consumption of hardwood plywood totaled $2.5 billion, or 4.0 billion squa re feet (table 3.9). U.S. consumption of hardwood plywood decreased 3 percent by va lue and 14 percent by quantity in 2007.

TABLE 3.9 U.S. Hardwood plywood produ cers: 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 0.0 9 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 declini ng 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 (tab le 3.9). The percentages of the cost of goods sold accounted for by raw materials, direct la bor, 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 pl ywood is generally an intermediate product that is used to manufacture a variety of othe r 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. 6465 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 Sta tistical Report for Calendar Year 2004 , 2005, 41 and 71; and HPVA, Hardwood Stock Panels, Annual Sta tistical Report for Calendar Year 2006 , 2007, 45 and 75.

68 Demand from the office furniture and dormitory fu rniture segments has remained steady. Industry officials, interviews by Commi ssion staff, Portland, OR, August 16, 2007, and Eugene, OR, August 17, 2007.

69 HPVA, Hardwood Stock Panels, Annual Sta tistical Report for Calendar Year 2004 , 2005, 41, 71; and HPVA, Hardwood Stock Panels, Annual Sta tistical 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 in ch) and 3.4 mm (3/16 inch) 3-ply panels. Industry officials, interviews by Commissi on 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 plyw ood 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 fo r U.S. producers to make th in plywood. Smooth, knot-free lauan ( Shorea spp. ) logs from Indonesia or Malaysia are we ll suited for thin plywood and give those countries a competitive advantage. U.S. RV manufact urers use thin lauan plywood for its strength, light

3-25 U.S. industry statistics indicate that shipme nts to both cabinet and fixture manufacturers increased during the period. Cabinet manufacturer s, 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 2 002–06 period at an average annual rate of 5 percent. This spurred an increase in the quan tity 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 re d 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 mo re 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. Di rect 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 dur ing 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 home 70 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 ofweight, and flexibility, which allows it to conform to inte rior contours. It is usually laminated with printed paper for interior applications or with fiber gl ass and aluminum for exte rior walls. IWPA, “Innovation Continues to Drive the RV Industry,” 2005, 52–53; and industry officials, interv iews by Commission staff, Dillard, OR, August 15, 2007, and Portland, OR, August, 13–14, 2007.

73 RVIA, “Historical Glance: RV Wholesale Sh ipments,” 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 Co mmission 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 d ecreased 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 W holesale 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 Commi ssion staff, Old Fort, NC, July 18, 2007.

76 Market niches identified by responding producers in cluded 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, r esponding U.S. producers and importers reported that 70 percent of U.S. production and 55 pe rcent 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 fo r 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 interchang eable with imports than U.S.-made wood flooring because of the wider diversity of end uses for ha rdwood plywood. Nevertheless, hardwood plywood from U.S. and foreign sources was generally regarded by both producers and importers to be somewhat interchang eable. 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. ma nufacturers 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 l ess influential than the other factors.O ne U. S. pr oduce r not ed tha t t he m ar k et f or A -g ra de ply

w ood re m ai ned st ea dy

duri ng the 2002–06 77 perio d bu t that the m arke t f or B-grade panels w as been e rod ed by com petitio n from

im po rted C-grade panels. T he current in du stry

standard grades w ere c on solid ated in th e m id-1 98 0s by the HP V A . This tradition al 78

m arke ting appro ach em

ph asize d selling the “entire log.” T y pically , an ef

f ort would be m ade to create special
pane ls f or l ar g e cus tom er s, w

hile re si dual produc tion w ent to othe r c ust om er s. Som e U. S. f irm s note d a dec re as ing re lia

nce on the tra diti onal m ar k et ing a pproa ch bas ed on s ta

ndar d H PV A

g ra des in f

av or of
pro prietary

gra des (i.e., com

pany-s pecif

ic brands o r gra des). In th eir v iew , the standard gra des have been “com m od itized” or are def

icient because they

allow w ide qu ality

va riation w ithi n grades a

nd do n ot con sider all def ects or fe atures of venee r that influence appearance a nd custom er appeal. Reportedl y , this trend started bef ore the inc re as e in i m

ports but ac ce le rate d a s im ports inc re as ed. T he use of propr ie ta ry bra nds does not im ply the us e of

hig her -v al ue or hi g her -qua lit y v ene er s. Indus try

of f ic ia ls , t el ephone int er

v ie w s by C o mmis si o n st aff, Ja n u ar y 31
, 2 0 0 8 ; an d i n d u st ry offi ci al s, i n t er vi ew b y Co mmis si o n st aff, Ale xa n d r i a, V A, Se pte m ber 24, 2007.

3- 28 so ph is ti ca ti on

. ” P ri ce a nd b us in es s re la ti on sh ip s w er e re g ar de d as th e ne xt m os t i nf lu en ti al
, and produ ct av ailability

w as reg arded as less influe ntial tha n the othe r factors.



### P roduct Trends in H ardwood P lyw ood

U

. S

. p ro du ct io n of

h ar dw oo d pl y w oo d is tre nd in g tow ar d th in ne r pa ne ls
, as m anuf ac tu re rs

an d ot he r co ns um er s of ha rdw oo d pl y w oo d re du ce c os ts

. Th e tr ad it io na l 3 /4 in chp an el s ti ll

accou nted for m ost U. S. shipm ents, but a s a percen t of total U .S. ship m ents, it declin ed fro m 65 p er ce nt

to 5 4 pe rc en t d

ur in g th e 20 02 –0 6 pe ri od
, w hi le th e pe rc en ta g es of th in ne r pa ne ls
g enerally increa sed (table 3.1 0). I n co ntrast, 3/4 in ch p ly woo d ac coun ted fo r on ly abo ut on efourth of rep orted U. S. im ports.

I n 2 006, arch itectural g rades (i.e., g rades AA
, A, and B) accou nted for 66 percen t of reported U. S. shipm ents, and both U.S. producers and im porters sug g est that U. S. prod uction trended
towa rd hig her g rades during the 2002 –06 period , as U.S. im ports increased

. I m

ports of h ig h- 77 g rade plywoo d are l im ited; in their questionn aire responses, very few U.S. im

porters reported
any im po r t s o f architectural g rade plywoo d. Rath er, U. S. im ports are m ostly

low er- g rade panels (i.e., g rades C and D), and im porters claim that U. S. produ ction is no w confine d to a

narrow rang e of g rades that n o lon g er inclu des “utility ply woo d.” 7879 Industry official, interview by Commi ssion staff, Washingt on, DC, May 3, 2007.

3-28 TABLE 3.10 Hardwood Plywood: Shares of U.S. sh ipments 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 ques tionnaire da ta, 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 th e 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 reporte d percentage of pr efinished imports of hardwood plywood exhibited no clear pattern, ra nging 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. Grow ing environmental awareness was evident in formaldehyde emissions reductions and incr easing air quality standards, increased fiber sourcing standards (e.g., FSC standards), a nd 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 manufact ured homes. The current HUD standard is 0.3 parts per million (ppm), whereas CARB phase 1 levels are 0.08 ppm for hard wood plywood, 0.18 ppm for particleboard, and 0.21 ppm for MDF. Phase 2 levels are 0.05, 0.09, a nd 0.11 ppm, respectively. Hamler, “Plywood Gets a Makeover,” July 2007, 49.

82 Industry official, interview by Commi ssion 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. USIT C, hearing transcript, October 3, 2007, 33–34 and 43; and Hamler, “Plyw ood Gets a Makeover,” July 2007, 48.

85 Commission questionnaires solicited prices for 10 ha rdwood plywood products: five birch face, two oak face, and two maple face panels of va rious grades in addition to one thin panel of various face species. All other price data received from U.S. producers and impor ters 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, partic leboard, and MDF) and the pr oducts 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 neverthe less 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 th at 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 we re received from U.S. producers to allow prices to be reported for three hardwood plywood products: birc h, 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. Re ported prices of the other products increased at average annual rates of 3–4 percent.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 consumpti on, 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 pr oduct quality, and/or a lack of innovative designs. However, increased domestic and foreign inv estment—particularly from Taiwan and other southeast Asian countries—and imported a dvanced technology from the United States, Japan, and Europe have contributed to im proved 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 negativ ely 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 th e processing trade preference program and the value-added tax (VAT) export re bate 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 fra gmented, 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 (m 3 ). 1 Many of these cottage mills reportedly speci alize 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. Ar ound 200 plywood producers reportedly have an annual production capacity of more than 20,000 m 3 , while around a dozen have an annual2 International Wood Markets Group, The China Book , part 2, 2006, 77.

3 Average annual production capacity estimates fo r 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 Intern ational 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 m 3

. 2 In comparison, the average reported plant size in the United States is approximately 87,000 m 3

. 3 Overall, the average annual production capacity of Chinese plyw ood producers is reportedly less than 4,500 m 3 each, or about 5 percent of reporting U.S. producers’ aver age annual production capacity. China’s total annual plywood production capacity is estimated to be 25–30 million m 3 , of which 85 percent is hardwood. 4

Medium-sized mills, whose annual pr oduction capacity ranges from approximately 2,000–10,000 m 3 , 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 m 3 , 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 co ttage 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 m 3 to 300,000 m 3 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 e xported 20 percent of production that year. 7 Although China’s export-oriented plywood produ cers are significantly larger than the average Chinese plywood mill, they account fo r 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 lo cated near tree plantations in the southern and southeastern provinces of Jia ngsu, Zhejiang, Fujian, and Guangdong. 9 Important plywood production centers in northern Ch ina 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 s uppliers, 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 m 3 , approximately12 International Wood Markets Group, “Chi na’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 producti on volume. However, lamina ted 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 c onverted 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 la minated 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 m 3 of domestic poplar plantation logs and almost 3 million m 3 of imported logs and veneer annually. 12 Reportedly, 335 mills produce finished plywood, while the remainder are engaged in veneer pr oduction for both plywood and engineered wood flooring. 13 Of the 335 mills, 48 have production capacity reportedly exceeding 50,000 m 3 per year, while two producers have an annua l production capacity greater than 100,000 m 3

. 14 In 2006, total plywood exports from Pizhou reached 3.2 million m 3 , 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 m 3 , although larger mills reportedly produce 2,000–10,000 m 3 annually. 17 In comparison, the average annual production of U.S. solid wood floor ing producers is approximately 8,700 m 3 , almost nine times larger than thatof 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 relativel y more concentrated. In 2005, there were estimated to be around 100 Chinese engineered wood flooring producers. 2122 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 ma terials from cooperatives that process bamboo stalks into strips, which are further processed and glue d together to form the basis of an engineered bamboo flooring product. Some bamboo flooring produ cers 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 m 3 for smaller engineered flooring mills, which is comparable in size to the average Chinese plywood mill, to 15,000 m 3 for large

ones. 22 In comparison, the reported average plan t size in the United States is almost 50,000

m 3 , substantially larger than the averag e 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, a lthough 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 comparativ ely small segment of China’s overall wood flooring industry. There are an estimat ed 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 Chin a 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 grow th has led to growing domestic consumption of wood products that has outpaced the supply of domes tic 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 the31 GTIS, Global Trade Atlas Database (accessed J une 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 pe rcent 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 na tural 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 almo st 36 percent of Chin a’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, includi ng 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 ot her bamboo products.



## China’s Raw Material Imports

China is the world’s largest importer of ha rdwood 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 engineer ed 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, a nd 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 m 3 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. 364-6 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 reduc ing 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 m 3 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, C ongo, Cameroon, and the Cent ral 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 S outheast Asia and West Africa nevertheless increased overall. In Africa, declining tropical log supplies from Gabon were offset by increased supplies from Equatorial Guinea and C ongo. Likewise in Southeast Asia, declining tropical log shipments from Indonesia were o ffset 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 m 3 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 a nd Brazil helped to partially offset the declining import volumes from Malaysia a nd Indonesia. Reportedly, over one-half of Brazil’s lumber exports to China are des tined 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. 404-8 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 Sourc e: 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 th at requires the Secretary of State, in consultation with the Secretary of Commerce and other appropriate Fe deral officials, to submit to Congress, within a year of enactment, a report on Burma's timber trade. The re porting 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 Burm a's timber trade, and information about the chains of custody of wood products from Burm a; illegalities, abuses, or corruption in the Burmese timber sector; and a description of the consumer and commercial applica tions unique to Burmese hardwoods. The report must also include recommendations regard ing the following: (1) alternatives to Burmese hardwoods for commercial applications ; (2) strategies for encouraging su stainable management of timber in locations that compete with Burm ese hardwoods; (3) the U.S. and in ternational customs documents and declarations that would need to be kept and compile d 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. An y 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, “Chi na’s ‘City of Plywood’,” November 2007.

47 The remainder of China’s plantations include prot ective forests (i.e., to mitigate soil erosion), economic or agricultural plantations such as orchards, fuelwood, and other forestcover. International Wood Markets Group, “Chinese Domestic Timber Harvest is Grow ing,” November 2007; and International Wood Markets Group, The China Book , part 1, 2006, 20–21. The State Forest Ad ministration (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 hectar e equals approximately 2.5 acres.

4-9 Chinese veneer imports declined by 38 pe rcent to 94,300 metric tons fro m 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 I ndonesia—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 acc ount for 63 percent of China’s 248 million

m 3 logging quota. 43 In contrast, under China’s 10th five-year plan (2001–05), pl antation timber accounted for 38 percent of China’s previous 223 million m 3 logging quota. 44

Following the implementation of the NFPP in 1998, Chinese domestic industrial roundwood production declined while log and lumber im ports increased rapidly. Industrial roundwood production declined through 2002 but began to increase beginning in 2003, reaching 66.1 million m 3 in 2006. 45 The development and growth of plan tations in China has been a leading factor behind the growth in domestic industrial timber harvests in recent years. 46

China reportedly had approxima tely 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 FGHY4-10 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 subheadi ngs 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 Chin a’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 milli on 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 st aff, 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. Fore ign investment and privat e domestic investment each accounted for about 40 percent of funds establishi ng FGHY plantations that year. Government funds accounted for 8 percent. State Fore stry 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, subsidi zed interest payments, exempted income taxes, and reduced administrative fees. See Stewart, “China’s Support Programs for Selected Industries,” June 2007, various pages; and American Fo rest 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 pa per 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 m 3 , 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 m 3 of timber. 54 The estimated investment required to establish these FGHY plantations is $9 billion, and reportedly these funds are expected to come from nongovernment al 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 hect ares (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 m 3 per hectare compared with a world average of 100

m 3 per hectare, calling into question China’s ability to bridge the gap between domestic production and total timber demand, whic h is forecast to reach 150 million m 3 by 2010. 5758 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 rela ted to monoculture plantations, e xpected future increases in domestic consumption of paper produc ts, and funding constraints. 58



# Production, Trade, and Consumption

China’s hardwood plywood and wood flooring indus tries have grown significantly in recent years, principally in response to increasing domestic demand fueled by China’s rapid economic growth, including robust residential c onstruction-related activity and real estate development. However, production increasi ngly exceeded domestic consumption from 2002 to 2006 and, as a result, exports accounted for an increasing share of domestic production. Exports of hardwood plywood a nd wood flooring increased dramatically during the period as foreign market demand for these products incr eased, particularly in the United States. As a result of the expansion of China’s ha rdwood 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 cer tain softwood plywood. From 2002 to 2006, Chinese production of hardwood plywood more than doubled to an estimated 23.3 million

m 3 , largely driven by growth in domestic real estate development and home remodeling (table 4.4). Production growth was par ticularly 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 m 3 . 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 th e period, as domestic production increasingly displaced imports. Import penetration declin ed 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 Chinese61 Industry official, interview by Commi ssion staff, China, February 20, 2008.

62 Rutton and Hock, “Reviving Tropical Plywood,” Ma y 2004, 23; and industry official, interview by Commission staff, China, February 20, 2008.

63 Industry official, interview by Commi ssion staff, China, February 20, 2008.

64 Industry official, interview by Commi ssion staff, Portland, OR, August 13, 2007.

4-13 TABLE 4.4 China’s hardwood plywood: Producti on, trade, and consumption, 2002–06

Item 2002 2003 2004 2005 2006 Change 2002–06 CAGR 2002–06 1,000 cubic meters %
Production a 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 t he extent possible, export volu mes were adjusted to reflect reporting countries’ import volumes of hardwood plywood fr om China. However, because engineered wood flooring is classified in the same HS subheadings as hardwood plywood, exports are likely overst ated and therefore domestic apparent consumption is likely understated.

a Based on staff estimates. Chinese hardwood plywood produc tion 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, whic h 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 (a pproximately one-tenth of an inch) for thin panels to 18 mm fo r 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 m 3 , while export values reached $1.9 billion, a 480 percent increase from 2002 (table 4.5). However, since engineer ed wood flooring is classified in the same HS4-14 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 States a 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 subclassificati ons: 4412.13, 4412.14, 4412.22, 4412.23, and 4412.29. These s ubheadings also include engineered wood floori ng; therefore plywood export figures are likely overstated. To t he 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 Stat es, 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 st aff, April 4, 2008. Othe r 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 m 2 . 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 mo st popular type of floor covering in China in 2005. Ceramic tiles are reportedly still preferred in commercia l establishments because they are easier to clean. Industry official, interview by Commission staff, Chin a, 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 st aff, 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 m 2 , or at an annual rate of 10 percent (table 4.6). Engineered wood flooring production more than quadrupled to 75 million m 2 . In contrast, solid wood flooring production decreased by 32 percent to 44 million m 2 . 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, bot h 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 m 2 , 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 capac ity (excluding laminated flooring capacity) increased by 285 percent to 270 million m 2 as compared with production of 108 million m 2

, corresponding to an estimated total wood floor ing capacity utilization rate of 40 percent. Solid wood flooring accounted for 200 million m 2 of capacity (35 percent capacity utilization rate in 2004), engineered wood flooring for 60 million m 2 (55 percent), and bamboo flooring for 10 million m 2 (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 m 2 in 2006, 70 up by almost 40 percent since 2002, with the majority of domestic market demand growth occurring in engineered wood flooring, wh ich 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 m 2 ) of domestic consumption72 Industry official, e-mail message to Commission st aff, September 6, 2007; and industry official, interview by Commission staff, China, February 17, 2008.

73 Industry official, interview by Commi ssion staff, China, February 17, 2008.

74 As noted earlier, export volumes are difficult to a ssess because engineered wood flooring is classified with plywood, and solid hardwood flooring is classi fied 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 Data base (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 approx imately 10.76 square feet.

in 2006, while engineered flooring and bamboo flooring combined accounted for 53–58 percent (63–70 million m 2 ). 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 consis tently accounted for approximately one-quarter to one-third of China’s solid w ood 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 Commi ssion staff, China, February 18, 2008.

79 Industry official, interview by Commi ssion 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 fo r HS subheading 4409.20 (nonconi ferous wood continuously shaped along any of its edges) and 4418.30 (parquet panels). Exports repres ent 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, capita l costs in the hardwood plywood and woodflooring 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 ma nufacturing 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 inv est in poplar and eucalyptus plantations in China and elsewhere in Asia. 78 In addition, the plywood a nd wood flooring industries in China are consolidating, with larger firms acquiring smaller ones. 7980 USITC hearing transcript , October 3, 2007, 228–29 and 231–32.

81 A higher recovery rate implies a lower yield loss, which reduces raw materi al 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 analy ze 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 Co mmission 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 th e 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 ra tes 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 elimin ate 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 ine xpensive labor has been cited by Chinese producers as a significant competitive advantage. 82

Additionally, by using veneer produced from dom estic plantation logs as core material and importing the species used for the thinner f ace 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 negativel y affected the solid wood flooring industry, which relies heavily on imported tropical l ogs and lumber. Although manufacturing costs vary greatly across a broad range of hard wood plywood and wood flooring products because of differences in dimension, species, grade, and technology utilized, general estimates of manufacturing costs for hardwood plywood a nd 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 a nd engineered wood flooring, various tropical and temperate species are used to produce f ace and back veneers, whereas less expensive domestic plantation poplar is used as core ven eer. 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 Tr opical Plywood Industry,” September 26, 2005, citing RWS Engineering Oy; and industry officials, intervie ws 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 sta ff, 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 hardw ood 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
Other a 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 approx imately 10.76 square feet.

a Other 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 ma y 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 materi al 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 m 3 depending on the species and quality, whereas tropical cores ranged from $120 to $220 per m 3

. 89 Likewise, the prices of veneer-quality domestic poplar logs reportedly doubled to $100 per m 3 from 1998 to 2005, increasing further to90 International Wood Markets Group, The China Book , part 2, 2006, 82; and International Wood Markets Group, “Chinese Poplar and Popl ar Plywood Update,” November, 2007.

91 Wu, “Why China Plywood Competitive {sic},” September 26, 2005.

92 Ibid.

93 Industry official, interview by Commi ssion staff, China, February 17, 2008.

94 Industry officials, interviews by Commission sta ff, 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 offici al, interview by Commission staff, China, February 21, 2008; and industry official, e-mail messa ge to Commission staff, February 14, 2008.

96 Industry officials, interview by Co mmission 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 Commi ssion staff, China, February 18, 2008.

100 Ibid.

101 Ibid.

4-20 approximately $135 per m 3 in 2007, 90 while smaller diameter plantation logs fetch $40–$80
per m 3

. 91 Poplar veneer used as plywood core material ranges from $85 to $115 per m 3

, whereas higher qual ity poplar ve neers can range from $170 to $220 per m 3

. 92 Reportedly, Chinese farmers are increasingly switching land u se 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 regi on, inclusion of additional benefits such as insurance and pensions, and skill level. 95 Wages for Chinese workers ar e reportedly set to increase by 8–10 percent per year by government manda te, 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 floor ing producers stated that transportation costs have increased substantially since 2002. Transportation costs reportedly increased during the 2002–06 period, due in part to rising fu el 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 trans portation 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 fl ooring because less expensive raw materials for102 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 m illion cubic meters per year, 90 percent of which is imported.

107 Ibid.

108 Industry officials, interviews by Co mmission staff, China, February 18–29, 2008.

109 Industry official, interview by Commi ssion staff, China, February 18, 2008.

110 Industry officials, interviews by Co mmission staff, China, February 18–26, 2008.

111 Industry official, interview by Commi ssion 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 Chin ese flooring producer averaged $99 per m 3 , 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 m 3

. 104



# Marketing

The vast majority of China’s plywood a nd 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 wh ich were informal markets. Most wholesale markets are privately owned, and consist of a large number of vendors that sell various building materials, including timber, plyw ood, and flooring. Major customers include retailers, construction compani es, 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 re portedly 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 Gua ngdong province and is reportedly the largest distribution center in southern China. Approxi mately 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 percen t 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 fl ooring, 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 gene rally 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 ow n franchised retail outlets under their own brand name, or distribute their products thr ough 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 produ cers also supply private label products to foreign producers, including U.S. hardwood plywood producer Columbia Forest Products,112 Industry officials, interviews by Commission sta ff, 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 produ cer 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 hardw ood 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 Kal hua 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 convert ed 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)
Standard a Wide b 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 W ood Floor Distribution C enter, 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. Feder al Reserve (1 dollar = 7.1644 RMB).

a Standard 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 expor t rebate program were created to promote the development of certain value-added ma nufacturing industries, including domestic wood processing industries. Recent reductions in VAT export rebates for exported hardwood plywood and wood flooring, as well as a consum ption and export tax on solid wood flooring alone, have reportedly recently discour aged export growth for both products. 119

Chinese plywood and wood floori ng producers, pa rticularly those located in economic development zones, may also benefit from prefer ential 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 lim ited solely to the plywood and wood flooring industries.



## Trade Policies

China has utilized the processing trade pref erence program and the VAT export rebate program to encourage the development of the domestic wood processing industry andconserve 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 usi ng 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 tele phone 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-aut horized (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 per cent 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 bet ween the value of VAT paid for an imported input and the va lue of the VAT amount owed fo r the exported finished product.
b Plywood products eliminated from the VAT rebat e include those made from endangered species (“imminent danger” according to Chinese tariff terminology) of tropi cal and other hardwoods. Also eliminated from the VAT rebate are certain blockboard, laminated woods, and parquet panels.

Reductions in VAT export rebates for ot her hardwood plywood products, coupled with increasing labor, energy, and raw materials cost s, 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. 126127 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 Commi ssion 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 Devel opment 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 progr ams, see Stewart, “Chi na’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 percen t 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 Oc tober 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 obj ective 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 em ployment 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 consum ption and export tax on solid wood flooring discourage exports, thereby implicitly favori ng 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 e xport 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 prope rty 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 add ition, 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 Chin ese tax law took effect which eliminated preferential tax breaks for FIEs and made the tax rates for domestic firms and foreign invested enterprises uniform. 135136 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 concer ned as “plywood consisting solely of sheets of wood, each ply not exceeding 6 mm thickness, with at l east 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 Ar ticle 16.4 of the Agreement, Turkey,” March 22, 2007, for the period July 31–December 31, 2006.

141 WTO, Committee On Anti-Dumping Practices, “S emi-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 rul es, 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 unde rstanding 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 expo rts 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 Commi ssion 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 thickn ess, 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 adjust ment 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 m 3

. 140 Likewise, Israel initiated antidumping proceedings with respect to cer tain MDF and plywood faced by veneer or lacquer paper from China in December 2004, resulting in an antidumping margin of 44.7 percent. 1411 Data and information on flooring is often included unde r the category of builder’s joinery, also includes doors, windows, shutters, stai rs, 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 princi pally suppliers of tr opical hardwood products, and the other two (Canada and Russia) are principally suppliers of temperate/boreal hardwood products. As shown in chapter 2, th ese 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 cost s (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 Ch ina, the wood flooring and hardwood plywood industries in the five other supplier countri es 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 for est land. These concessions provide hardwood product firms with a steady supply of timber for their production processes. The wood flooring and hardwood plywood i ndustries in these c ountries 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 m ills, and other wood product producers, number of firms and installed capacity( 1,000 cubic meters ) Sawmills Plywood mills

Country Firms Installed Capacity a Firms Installed Capacity a Brazil 10,000 NA b <200 NA Canada c 50 d 5,389 12 d 5,389 Indonesia 327 7,460 113 12,000 Malaysia e 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 m 3 per year.
b This includes softwood and hardwood mills

. c Solid wood flooring firms.
d Capacity converted from 300 m illion square feet with an aver age 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 m ills 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 a bout 10 remaining that produce significant volumes of hardwood plywood. 3 According to Brazilian industr y officials, the “Brazilian hardwood flooring industry is dwarfed by th e 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 st aff, Washington, DC, A ugust 10 and September 14, 2007; and company annual reports and Web sites of various Canadian hardwood plywood producers.

7 Industry officials, interviews by Commission st aff, Washington, DC, A ugust 10 and September 14, 2007.

8 Industry officials, interviews by Commission st aff, Washington, DC, A ugust 10 and September 14, 2007.

9 About one-third of Canadian wood flooring producti on capacity is in Ontario and two-thirds are in Quebec.

10 Industry officials, interviews by Commission sta ff, Washington, DC, Septem ber 14, October 10, and November 14, 2007; and company annual reports a nd 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. Th e age of the production equipment is also generally similar. 7 Employment in the industry in Ca nada 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 consolidati on of producers or expansion of capacity during this period. 8

The wood flooring industry in Ca nada is approximately one-quarter the size of the U.S. wood flooring industry and consis ts 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, w ith the top four producers accounting for 20–40 percent of total Canadian production of wood fl ooring. 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 industr y 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 m oderate amount of unused wood flooring11 Industry officials, interviews by Commission sta ff, Washington, DC, Septem ber 14, October 10, and November 14, 2007.

12 Government of Indonesia, Department of Statis tics, “Industry Database,” undated (accessed February 22, 2008).

13 Less than 5 percent of the capacity of the I ndonesian 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 incorporatedinto 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 Cons olidation and Restructuring,” April 9, 2002.

5-4 production capacity in Canada; very little c onsolidation 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 firm s 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 w ood 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 suffe rs 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 sh are of Indonesia’s plywood mills were idle due to production equipment limitations or lack of ra w 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 r estarting 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 cap acity of approximately 1.5 million m 3 . In its 2005 annual report, BPG reported that over 85 pe rcent of its production was exported, with20 PT Barito Pacific Timber Tbk Integrated Wood Industries, Annual Report 2005 , 5. BPG’ s primary markets include: the United States (17.1 percent), Japa n (7.7 percent), Europe (8.2 percent), Middle East (31.3 percent), Korea (14.9 percent), and local ma rket (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 messa ge 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 messa ge to Commission staff, July 19, 2007.

28 Industry representative, e-mail messa ge 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. Howeve r, 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 specia lized 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 plywo od 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 e xports in 2006. Although the number of mills is evenly distributed across Malaysia, Sarawak has larger m ills 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 expor t oriented, most of Peninsular Malaysia’s production is from smaller mills, which supply primarily local consumers such as wooden furniture producers. Peninsular Malaysia account ed 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 m 3 , 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 Pe rm; 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 acc ount 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 m 3 ; 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 Stat es, Syktyvkar for 10 percent, and Parfino, 11 percent. 28 Since 2002, annual investment in the overall Russian forest products industry has29 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 We b 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 inve ntory 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 Mala ysia, provincial governments in Ca nada, as opposed to the federal government, retain ownership of most forest land. Moreover, most of the hardwood in Canada is harvested from these provincia lly 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 Born eo. Indonesia’s forest lands are classified into35 Production forests are natural stands that ar e used primarily for industrial roundwood production; conversion forests are those forests sl ated 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, “G lobal 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, “G lobal 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 6 a 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 Dat abase”, 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); conve rsion 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 balanc ing 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 forests38 The policy aims to increase planted forest ar ea from 320,000 hectares in 2006 to 500,000 hectares. The government of Malaysia announced that the Forest Pl antation 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 Plantati on 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 Ru ssia 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 Ru ssia by Region,” undated (accessed May 7, 2007).

44 Ibid.

45 Official Indonesian 2005 production statistics report th at while Borneo accounted for 36 percent of total Indonesian log production (Central Kalimantan and Ea st 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 Da tabase,” undated (accessed February 11, 2008). It is difficult to accurately gauge the level of Indonesianlog 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 repor ted by destination countries. Turner, Katz, and Buongiorno, Implications for the New Zealand Wood Products Sector , July 2007, 17. See also Goetzl, “Discrepancies in Foreign Tr ade 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, harves ting 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 w ithin 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 concentrat ed 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. 4546 GTIS, Global Trade Atlas Data base (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 l og 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 th eir 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 expor ts 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 worl d’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 m 3 ($737 million) during this period, princi pally 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. 4849 The production of lumber and plywood together account for almost 90 percent of total domestic log consumption. Seneca Creek Associates LLC a nd 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 producti on 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 st aff, 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 consumpti on data are not available for wood flooring.

5-10 Limitations on harvests from natural stands not withstanding, Malaysia n 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 manufact urers 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 Malaysia 52 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 pe rcent of roundwood exports from Malaysia.



# Production, Trade, and Consumption

Of these five supplier countries, the lead ing 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 Indonesi a 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 peri od; however they each exported 23–94 percent of their production.5-11 TABLE 5.4 Foreign supplier countries: Hardwood pl ywood 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 Russia a 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
Russia a 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
Russia a 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
Russia a 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 s ources estimate that more than 90 percent of production and nearly 100 percent of ex ports 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 industr y 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 a nd 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 pl ywood for the purposes of this study.

5-15 TABLE 5.6 Foreign supplier countries: Share of expor ts 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 Sourc e: 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-plywood 57 are now the major types58 Although there are no official production data on wood flooring, Commission staff estimated tropical hardwood lumber production based on data from industry l eaders and unofficial data furnished by the sector.

59 ANPM, written submission to the USIT C, October 3, 2007, question 1, Q-2.

60 Ibid., 2.

61 HPVA, Hardwood Stock Panels: Annual Statis tical Report for Calendar Year 2004 , 2005. Data for 2002 are not available. These data are from Canadi an hardwood plywood producers and likely account for the majority of total Canadian production of ha rdwood plywood. Industry officials, interviews by Commission staff, Washi ngton, 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 sta ff, Washington, DC, Augus t 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 sta ff, Washington, DC, Sept ember 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 dow nstream products such as engineered wood flooring and cabinetry, hardwood plywood e xports 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 fl uctuated 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 cor es made from other material accounted for 27 percent, 6 percent, and 2 percent, r espectively, 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 domes tic 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 impor ts 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 th eir share of the Canadian market for these products over the period.

Overall, Canadian exports of wood floor ing 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 (accounti ng for 90 percent of all Canadian hardwood66 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 expa nded 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 Data base (accessed June 5, 2007).

74 ITTO, “Annual Review and Assessment of th e 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 m 3 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 m 3

. 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 pr oduced 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 approxima tely 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 m 3 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 neglig ible 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 near ly $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 m 3 in 2007. 74 Reportedly, raw materials previously exported as sawnwood and veneer from Sabah and Sarawak are now being c onverted 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 Malaysian76 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 Data base (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. Accordi ng to another source, there is only one large softwood plywood mill operating in Russia today. Industry offici al, 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 m 3 while the domestic market declined by nearly 500,000 m 3 (table 5.4). Due to the increased use of substitute materi als 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 de mand for Russian exports of plywood (table 5.4). 81 In 2006, exports of plywood accounted fo r 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 m 3 ($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 ava ilable. 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 fo r 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. 8485 Industry officials, interviews by Commission st aff, Washington, DC, A ugust 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 st aff, Washington, DC, Se ptember 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 highe r-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 co res, 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 m 3

, 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 Malays ia for plywood and sawn timber producers. 88 Downstream producers in Peninsular Malays ia 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 com ponent, is considerably lower in the foreign supplier industries than in the United States w ith 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 notreadily 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 percen t of the total cost of production for wood flooring. 90 In Canada, labor accounts for 10–15 percen t of the total cost of production for91 Industry officials, interviews by Commission sta ff, Washington, DC, Septem ber 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, betw een $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 to tal 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 w ood flooring firm, wages for factory workers are C$10–C$15 ($9–$14) pe r 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 fo r 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 a nd 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 incr eased by over 37 percent from 2003 to 2006. On average, production related workers th at 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 fro m company to company. The average basic monthly salary ranges from Rm 515 ($145) fo r 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 inventor y carrying costs. Industry officials, interviews by Commission staff, Wash ington, 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 ch annels of distribution. Competitive products move through the same channels of di stribution. 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 distri bution for Canadian hardwood plywood have not changed significantly in the past five years. 9798 Ibid.

99 Ibid.

100 Industry officials, interviews by Commission sta ff, Washington, DC, Septem ber 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 dist ributors, homebuilders, flooring retailers and installers, independent hardwood specialty st ores, building materials distributors, and homebuilding stores. The majority of impor ted 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 im portant 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 sl owdown 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 pa ttern, 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 I ndonesia 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 Biologi cal 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, a nd regulations have been developed in these five supplier countries to facilitate forest manage ment, as well as to promote the development of the wood products industries. This extensive gove rnment 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 ta x 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 c ontrol 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 fore sts; and (5) restoration forestry programs. ITTO, “Brazil,” 2006, 210–13.

105 ANPM, written submission to the US ITC, October 3, 2007, III, A, 6, and Q-5. However, deforestation rates reportedly increased substantially from A ugust 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 US ITC, 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 rainfor est dropped by 25 percent in 2006 to the lowest recorded rate since the mid-1970’s. Reporte dly, 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 nongovernment al organizations entered a pact aimed at ending deforestation in seven years. 106

Though not specifically targeting wood floor ing and hardwood plywood, the Canadian federal and provincial government s have taken steps to maintain the competitiveness of the Canadian forest products sector. In Febr uary 2007, the Canadian federal government announced the Forest Industry Long-Term Compe titiveness 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 devel opment 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 pr ovince 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 w ithin 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 Malays ia has banned the im portation of Indonesian113 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 st aff, 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 Dramatica lly 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 Ti mber 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 illega l logging in Indonesia. Limitations on the size of timber that can be traded ensures that younge r trees are not felled so that forests have time to regenerate.

The Malaysian government promotes the expor tation of downstream value-added products, including plywood and flooring by applying expor t 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 devel opment 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 i nvestment 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 sev eral 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 de velops 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 fl ooring. 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 shar e 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 on121 Van Leeuwen , Wood Markets: Monthly International Report , April 2007, 5; and Roberts, Carreau, and Lethbridge, “Russia Plans to Dramatically Increas e 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 Illega l 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 Fe deral 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 sensi ng/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. 1246-1 

# 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 a nd 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 add ition 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 th e 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 sh are held by imports is rising. In 2002, U.S. producers supplied about two-thirds of th e 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 pos ition 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 hard wood 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 pref erences toward products such as prefinished wood flooring, exotic species for solid wood flooring, and engineered wood flooring, largely benefitted foreign supplie rs 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 broade n 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 larg e 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, th e 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, di d not affect the major U.S. suppliers’ currencies equally. For example, China w as 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 fact ors and supply factors. On the demand side, a primary market driver has been the dema nd for residential cons truction and renovation. This demand in turn drives the demand for solid and engineered wood flooring and for products such as furniture, cabinetry, a nd 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 prac tices, 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 st ructure of the industry (i.e., concentration, and vertical and horizontal integration). In a ddition to the demand and supply factors in the U.S. market, currency exchange rates an d 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 floori ng and hardwood plywood pr oducts 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. cons umption of wood flooring and hardwood plywood rose rapidly before declining in 2007 (figure 6.1). The dramatic growth and subsequent drop in consumpti on 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 2007Thousands

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 producer s 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 acc ounting 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. Howe ver, 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 re sponsible 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 floor ing. Further, the strong growth in U.S. consumption of engineered wood flooring rela tive 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 lami nate 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 a nd 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 lami nate flooring has likely put price pressure on wood flooring, particularly in th e 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 ch anged during the period. Expansion of the housing and renovation markets resulted in an in creased 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 sen sitivity to global environmental issues such as forest degradation and destruction has increased demand for wood products made from legally sourced raw material grown in sustaina bly managed forests. It is not clear how this aspect affects the market, either through pri ce 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” build ing 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. shipme nts 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 pl ywood is a significant demand factor, and the U.S. industry has turned toward higher gr ade products, rather than the utility grades, choosing to go up the quality scale rather than tr ying to lower costs to compete in the market with imports for lower grades of hardwood plyw ood. 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 dema nd 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 add ition, 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 Stat es, 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 involvi ng relatively large parcels.

6-7 

### Exports

Foreign demand for U.S. wood flooring a nd hardwood plywood was strong during the 2002–07 period. In 2002, exports of solid w ood 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 Ca nadian 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 pl ywood. 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 forei gn 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 I ndonesian 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, ra w material supplies in these countries tightened over the period, partly a function of effort s to address illega l 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 a nd having a limited domestic supply of natural raw material with which to feed its rapidl y 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, th e growth of China’s engineered wood flooring and hardwood plywood industries, because fo r 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 th e most important determinants of industry profitability and comp etitiveness 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 marke ting 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 acr oss countries for aggregated products may be neither very illustrative nor particular ly 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 per cent of total production costs.

Variable costs

Raw material

The U.S. industries were not at a competitive di sadvantage with respect to the cost of raw material vis-à-vis most foreign competitors. Th e 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 co st. 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 Re view 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 repor ted 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 confe rred 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 lowe r 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 transportati on. All global producers have been affected by rising costs for many of these items in recent years.How eve r, in Ch ina, capital costs are relative ly low f or w oo d floorin g a

nd ply w oo d pro du cers, the v ast 5

m aj orit y of w hic h are s m al l, and the se low er c api ta l c ost s al so cont

ribut ed to t

he g row th of the indus try

.

6- 10 Fixed cos ts

As noted in C hapter 3, dom estic p roduc tion c apacity for w ood flooring increa sed

s ub s t a n t i a l l y

o v e r t h e p e r i o d
, w h i l e p r o du c t i o n c a p a c i t y f o r h a r d w o o d

p l y w o o d rem ained

es se nt ia ll y

u nc ha ng ed

. E st im at ed

c ap ac it y u ti li z at io n ra te s in th e U ni te d S ta te s w er e 80 to 90 pe r c e nt f

or s ol i d wo od f

l oo r i ng, s l i ght l y a bo ve 80 p e r c e nt fo r en gin e e r e d wo od fl oo r i ng, and from 70 to 80 percen t for hardw ood plywoo d o v er the period.

Giv en th at the techno log y for produ cing t hese produ cts is sim ilar throu g hout the g lobal in du st ry , a nd

th at r awm at er ia l, la

bo r, a nd o th er v ar ia bl e in pu ts c on st itut e th e v as t m ajor it y of the cos t of produ ction, v ariat i on s i n c a pital co sts m ay no t be a pa rticularly

sig nificant

com petitiv e facto r. H owe v er, capacity utiliz ation rates an d lev els of new inv estm ent m ay 5 be in di c a t or s o f

c o mp e t i t i ven e s s , a l t ho ugh no t as si gni f i c a nt as wou l d b e th e ca s e in hi gh fixed- cost (o r cap ital- intensiv e) industries. As noted earlier, som e industries, such as th ose in I nd on es ia
, are rep orte dl y op er at in g at v er

y lo w r at es o f ca

pa ci ty u ti li z at io n, w hi chh in de rs th ei r co m pe ti ti v en es s. C an ad ia n pr od uc er s al so n ot ed

th at s om e of th ei r pl an ts a re id le duri ngp ar t o f th e y ea r. C ap ac it y u ti li z at io n ra te s fo r fl oo ri ngp la nt s in C hi na a re ap pr ox im at el y

4 0 pe rc en t.6 Industry official, interview w ith Commission staff, June 25, 2008.

7 Large retail/wholesale firms include regional and na tional chains of lumber supply stores, as well as mass merchandisers such as the larg e home supply stores and club stores.

8 Goetzl,and Ekström, “Report on the Re view 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 fl ooring and hardwood plywood industries in most major foreign competitors are likely not as con centrated as in the United States and Canada. The concentration in the U.S. industries suggest s 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 inte grate 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. Howeve r, this advantage may be diminishing as distributors and retailers establish relationships with fore ign supplier industries and domestic producers source more of their nationally branded product offshore. Vertical coordination (ownership, concessions, or contracts linking producers to l ogging operations, distribut ors, 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, pa rticularly 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 floori ng 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 pow er 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 retailers 7 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 sh are has come largely at the expense of the floor covering stores, whose share of the retail wood flooring market9 Catalina Research, Inc., 2005. Industry official , interview with Commission staff, August 6, 2008.

10 Industry official, interview w ith 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. Incr easingly, 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 industri es 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 dom estic products in foreign markets such as Canada and the EU.

Table 6.1 shows recent trends in nominal and r eal (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 pr essures as other commodities priced in dollars. For a country such as China, which had traditiona lly pegged its foreign exchange rate to the dollar, this raised the cost of those inputs a nd 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. pr oducers 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 declined12 USDOL, BLS, PPI Databa se (accessed May 19, 2008).

13 United Nations, UNECEF/FAO Forest Products A nnual Market Review, 2004-2005, 2005.

6-13 TABLE 6.1 Exchange rates: Units of fore ign currency per U.S. dollar, 2002–06 Foreign currency 2002 2003 2004 2005 2006 2007 % change 2002-07 a
Brazilian real nominal 2.92 3.08 2. 93 2.43 2.17 1.947 -33.3
real b 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 us ing the Consumer Price index in the United States and t he 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 calculate d 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. 136- 14 I n ad dition to the sm all dec line in the av erag e produ cer prices in nom inal term s, prices of th es e pr od

uc ts did no t k ee p u

p w it h th e in cr ea se in ha rdw oo d lu m be r pr ic es , w hi chli k el y reduce d the com

petitiv e po sition o f the U. S. industry (fig ure 6 .8). The a ver a g e pro ducer price of hardw ood plywoo d and solid and eng ineered woo d flooring declined relativ e to the price o f hard

woo d lum

ber fro m 20 02 to 20 06. The de cline in this price ra tio ind icates in cr ea si ngc os t p re ss ur es a s pr od uc er s m ay

n ot h av e be en

a bl e to s uf fi ci en tl y r ai se pr ic es to pass throug h inc reased raw m aterial price s to consu m ers.

Dir e c t c o m

p a r i s o n s o f

U

. S

. p r o du c e r

a n d i m p o r t p r i c e s f

o r v a r i o u s w o o d

f l o o r i n g and ha rdw oo d pl y w oo d pr od

uc ts ar e di ff

ic ul t o w in g to th e co nf

id en ti al it y

o f th e qu es ti on na ir e data. How ev er, there is som e ev idence of p rice pre ssure and com petition from

im ports for utility g rades of h ardw ood plywoo d (fig ure 6 .9). Fo r exa m ple, for birc h h ardw ood plywoo d ( C -3 a n d D-3 gr a d e s )
, U. S

. p r o du c e r p r i c e s i n c r e a s e d f o r D -3 gr a d e , w h i l e u n i t va l u e s o f C-3 and D- 3 g rades of h ardw ood plywo od im ported from

C hina declined

du ring the 2004 –06 period.6- 15Indus try of f ic ia l, inte rv ie w

by Com m is si on s ta f

f , Portl and, O re g on, A

ug ust 16, 2007. 14

6- 16 Wh il e th es e pr od

uc ts com pe te , the div er g en ce in

th e tr en ds in

p ro du ct p ri ce s is r ep orte dl y du e, a t l ea st

in p ar t, to th e hi g he r qu al it y o f th e U

. S

. d om es ti c pr od uc t. 14

The price trends for thin hardw ood plywoo d p roduc ts sho w a div erg ence betw een U. S. and foreig n thin

hard woo d p ly woo d p rices from 20 02–0 6 (fig ure 6 .10 ). The v irola p ly woo d from B ra z il a nd

th e m er an ti p ly

w oo d fr om

I nd on es iaa nd

Ma la y si a ar e li k el y

s ub st itut es , a nd

th ei r rising prices ov er the period are co nsistent with the risin g ra w mat e r i a l prices in tho se

coun tries. The price fo r 1/4- inch birch plywoo d p roduc ed in the United

State s de clined ov er the p eriod, ev en a s raw m aterial price s w ere risingin the U nited States.6-17 

### Government Programs

In addition to trade policies, government involve ment is concentrated in the forestry sector, which supplies raw material to the w ood flooring and hardw ood plywood industries. Program activities generally involve research and development, forestry practices, marketing, and export promotion.

Trade policies

Import tariffs are the principal trade polic y 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. Howe ver, 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 rega rding 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 al so benefitted in the past from preferential income tax programs. However, recent reducti ons in VAT export rebates for certain solid wood flooring have reduced the export incentives.Biblio-1 

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# 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



### MMAX 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 Notices19960 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


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.)


# APPENDIX C HTS Descriptions and Tariff Information1 USITC hearing transcript, October 3, 2007, 19.

2 CBP, statement to the Senate Committee on Ener gy 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, t echnical 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 th e 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 asso ciations brought allegations of misclassification to the attention of CBP. Subsequently, CBP initiated national enforcement operations targeting imports of wood flooring and hard wood 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 earlie r 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 b Special c Column 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/m 3

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 fo r the designated tariff lines for the follo wing 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 b Special c Column 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 tableC-6 TABLE C-2 Wood flooring and hardwood plywood: HTS heading 4412, tariff rates, 2008

— Continued

a General Special b Column 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 b Column 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 tableC-8 TABLE C-2 Wood flooring and hardwood plywood: HTS heading 4412, tariff rates, 2008

— Continued

a General Special b Column 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 tableC-9 TABLE C-2 Wood flooring and hardwood plywood: HTS heading 4412, tariff rates, 2008

— Continued

a General Special b Column 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 tari ff lines noted in the "Special" column for the following U.S. t rade 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.-Singapor e FTA. The designated tariff li nes 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 ar e 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 Indones ia are not eligible under GSP.C-10 TABLE C-3 Wood flooring: HTS heading 4418, tariff rates, 2008

a General b Special c Column 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 tari ff lines noted in the "Special" column for the following U.S. t rade 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.-Singapor e FTA. The designated tariff li nes 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-11TABLE C-4Wood flooring and hardwood plywood: Comparison of 2006 and 2008 HTSHTS Subheading NTR Customs2006 2008 Rate of Duty Ruling(s)Coniferous, unfinished, end-matched 4409.10.05 4409.10.053.2 NYL84912, HQ966511Non-coniferous, unfinished, end-matched, Jatoba 4409.20.05 4409.29.0515 3.2 N018276Non-coniferous, unfinished, end-matched, Ipe 4409.20.05 4409.29.0525 3.2Non-coniferous, unfinished, end-matched, Santos mahogany4409.20.05 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 NYI82516Non-coniferous, unfinished, birch and beech 4409.20.2550 4409.29.2550 freeNon-coniferous, unfinished,Other 4409.20.25604409.29.2560 freeConiferous, factory-finished4418.90.4590 4418.90.4690 3.2 NYK88580, NYL88584Non-coniferous, factory-finished 4418.90.4590 4418.90.46903.2 N005740, NYM83957Veneer coreTropical & birch face plies < 4 mm 4412.13.05 4412.31.05 freeTropical, Spanish cedar or walnutface plies < 4 mm 4412.13.25 4412.31.25 8.0 N016791Tropical, tropical face ply as specified < 4 mm 4412.13.40 4412.31.40 8.0 NYE89394, N016791Tropical face ply < 4mm 4412.13.51 4412.31.51 8.0 NYI83048Tropical & other tropical face ply < 4mm, surface covered4412.13.60 4412.31.60 8.0 N003349Tropical 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 N014319, NYL81697Nonconiferous & Spanish cedar or walnutface plies < 4 mm4412.14.25 4412.32.25 5.1 NYI86315Nonconiferous < 4 mm 4412.14.31 4412.32.31 8.0 NYK88580, N018580,NYL80482, NYI83048,NYL85524, N014319,NYR04361Nonconiferous < 4 mm, surface covered 4412.14.56 4412.32.56 8.0Coniferous outer plies, face ply< 4 mm 4412.19.40 4412.39.408.0 NYK80312, NYR04361Coniferous outer plies, face ply <4 mm, surface covered 4412.19.5050 4412.39.5050 5.1Any of the above with face ply4 to 6 mm 4418.72.958.0 NYL80482, NYI83048C-12TABLE C-4Wood flooring and hardwood plywood: Comparison of 2006 and 2008 HTS–ContinuedHTS Subheading NTR CustomsProduct2006 2008 Rate of Duty Ruling(s)Particleboard, MDF, or solid coreTropical ply w/ layer of particleboard,face ply <4 mm 4412.22.06 4412.99.06 free N009861Tropical, plywood, solid core, birchface ply < 4 mm 4412.22.10 4412.94.10 free N018276Tropical, plywood, other core, birch,face ply < 4 mm 4412.22.10 4412.99.10 freeTropical, plywood, solid core, faceply < 4 mm 4412.22.31 4412.94.31 8.0 N009195, N007691,N018276, NYL84773,N005740Tropical, 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 8.0Tropical, plywood, other core, face ply< 4 mm, surface covered 4412.22.41 4412.99.41 8.0Tropical, solid core, face ply < 4 mm 4412.22.51 4412.94.51 freeTropical, other core (e.g., HDF), faceply < 4 mm 4412.22.51 4412.99.51 free N018581, N018579Nonconiferous w/ layer of particleboard,face ply < 4 mm 4412.23.01 4412.99.06 free NYJ86751Nonconiferous, 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, faceply < 4 mm 4412.29.36 4412.94.3105 8.0 NYK89145, NYL84772,NYM87186Nonconiferous, 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 8.0Nonconiferous, plywood, other core, face ply < 4 mm, surface covered 4412.29.46 4412.99.41 8.0Nonconiferous, solid core, faceply < 4 mm 4412.29.56 4412.94.51 free N014319Nonconiferous, other core, face ply < 4 mm 4412.29.56 4412.99.51 free NYL84771, N004602Any of the above w/ face ply > 6 mm 4418.72.2000 3.2Any of the above with faceply 4-6 mm 4418.72.9000 8.0 N005740Bamboo flooringGrain of plies parallel, face ply< 4 mm 4412.29.56 4412.10.90free NYK80976, N009491Grain of plies parallel, face ply4 to 6 mm 4412.29.56 4418.72.91 free N004630, N006431,N010868, N016268Grain of plies parallel, faceply > 6 mm 4412.29.56 4418.72.20 3.2 N019775Grain of plies perpendicular, face ply < 4 mm 4412.29.36 4412.10.05 8.0Grain of plies perpendicular, faceply 4 to 6 mm 4412.29.36 4418.72.90 8.0 NYK89493Grain of plies perpendicular, face ply > 6 mm 4412.29.56 4418.72.20 3.2Solid core, bamboo face ply 4 to6 mm 4412.29.36 4418.72.90 3.2 N010035, N011396TABLE C-4Wood flooring and hardwood plywood: Comparison of 2006 and 2008 HTS–ContinuedHTS Subheading NTR CustomsProduct2006 2008 Rate of Duty Ruling(s)

C-13Veneer core, bamboo face ply,4-6 mm 4412.14.314418.72.90 3.2 N011396aBamboo strips turned on edge (vertical) 4412.29.56 4418.79.00 3.2 N010868,N009461,N010035, N014321,N015849Bamboo strand flooring 4418.90.45 4418.90.46 3.2 N017610, N0100035Cork flooringLaminated cork flooring4504.10.30 4504.10.30free NYJ82489Parquet (mosaic) flooringSolid 4418.30.0000 4418.71.1000 8.0 NYG89486Engineered, face > 6mm 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 plies4412.13.25 4412.31.25 8.0Tropical, tropical face ply asspecified 4412.13.40 4412.31.40 8.0 N004190Tropical face ply 4412.13.51 4412.31.51 8.0Tropical & other tropical face ply,surface covered 4412.13.60 4412.31.60 8.0 N003349Tropical face ply < 4 mm, surface covered 4412.13.91 4412.31.91 8.0Nonconiferous & birch faceplies 4412.14.05 4412.32.05 free NYM87266Nonconiferous & Spanish cedar or walnut face plies 4412.14.25 4412.32.25 5.1 NYH84065Nonconiferous 4412.14.31 4412.32.31 8.0 NYH84065, NYR02554,N018677Nonconiferous, surface covered 4412.14.56 4412.32.56 8.0Particleboard, MDF, or solid coreTropical ply w/ layer ofparticleboard 4412.22.06 4412.99.06 freeTropical, 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, solidcore 4412.22.31 4412.94.31 8.0 N016760Tropical, plywood, othercore 4412.22.31 4412.99.31 8.0TABLE C-4Wood flooring and hardwood plywood: Comparison of 2006 and 2008 HTS–ContinuedHTS Subheading NTR CustomsProduct2006 2008 Rate of Duty Ruling(s)

C-14Tropical, plywood, solid core, surface covered 4412.22.41 4412.94.41 8.0Tropical, 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 ofparticleboard 4412.23.01 4412.99.06 freeNonconiferous, plywood, solid core, birch face ply 4412.29.15 4412.94.10 free N016760Nonconiferous, 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 covered4412.29.46 4412.94.41 8.0Nonconiferous, plywood, other core,surface covered4412.29.46 4412.99.41 8.0Nonconiferous, solidcore 4412.29.56 4412.94.51 freeNonconiferous, other core 4412.29.56 4412.99.51 free N020370aThe classification of bamboo flooring made of vertically oriented strips of bamboo is currently being considered by CBP underruling number N015849.Sources: Harmonized Tariff Schedule of the United States (2008), and USCBP Customs Rulings Online Search System.D-1 

# APPENDIX D Hearing List of ParticipantsD-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 inv estigation 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, Manuf acturing, 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 AnalystD-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 , OwnerD-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 Piso s 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 Parties1 Jeffrey S. Levin, Saul Ewing LLP, Washington DC, counsel to A nderson Hardwood Floors, Armstrong World Industries Inc., and Mannington Mills Inc ., USITC written submission, September 19, 2007.

2 Don Finkell, President and chief executive o fficer, 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, Armstr ong 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 fo r 1) the elimination of illegal production and export subsidies of wood flooring, pr eferably through the WTO or bilateral consultations and negotiations where prac tical, or through legi slation 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 reba tes to wood flooring exports.

• Second, U.S. Customs and Border Protecti on (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 im portation of endangered timber species, and the U.S. government should negotiate mu ltilateral 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 repos itory upon which necessary and appropriate actions can be based by the executive a nd legislative branches of our government.”



# Anderson Hardwood Floors 2

In his hearing testimony, Mr. Finkell, of A nderson 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 Hardw ood Flooring, USITC hearing transcript, 216–21; and Daniel Pagano, president, BR 111 Exotic Hard wood 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 sust ainable forestry practices are undermined by foreign competitors who depe nd upon illegal logging, government subsidies, and evasion of duties through tariff mis-classification.



# BR 111 Exotic Hardwood Flooring 4

In his hearing testimony, Mr. Nery, of BR 111 Exotic Hardwood Flooring, an associate member of the Brazilian National Hardwood Fl ooring 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 pa tterns) 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-o rigin requirements to ship lumber, plywood, or flooring.10 Jeffery S. Neeley, and Robert D. Stang, Greenbe rg Traurig, LLP, Washington, DC, counsels to China National Forest Products Industry, USITC written subm ission, October 24, 2007; a nd Shengfu Wu, director, China National Forest Products Industry A ssociation, 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. N eely, counsel to CNFPI A, 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 ai ded the development efforts of Chinese firms now complain about Chinese su ccess 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 certa in respects, the internal Chinese market has higher product standards than the United Stat es, which he said relies largely on voluntary industry standards.



# Columbia Forest Products 11

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 distribut ors 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 manage r, 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 Chines e Producers, USITC hearing transcript, 233–37.

14 Deb Hawkinson, executive director, Hardw ood 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 certifi cation 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 Board 13

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 prefer ence 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 Federation 14

In her hearing testimony, Ms. Hawkinson, of the Hardwood Federation of industry associations that represent producers and dist ributors of hardwood products in the United States, said that the more systemic problems currently confronting the U.S. hardwood plywood and flooring industry in clude: 1) numerous foreign countries that support their wood products manufacturing with grants and loan s, low-priced resources, tax benefits, and other subsidies; 2) U.S. wood products exporte rs 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 extr acted 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 wr itten submission, January 11, 2008.

16 E.T. Altman, president, HPVA, USITC hearing transcript, 31–37.

17 Bob Haggard, vice president, sales, Hassell a nd Hughes Lumber Co., USITC hearing transcript, 123–27.

E-7 

# Hardwood Import Coalition 15

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. Hen ce, 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 e ngage 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 formal dehyde 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 emissi on 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 pa neling 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. produ cers are competitively disadvantaged and that potential adverse impacts upon raw materials suppliers and other supporting businesses result from foreign competitors not bearing the sam e 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 Fu rniture 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 ec onomic 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 domes tic U.S. jobs throughout the logistics chain. He said that the IWPA, in opposing illegal l ogging, 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 th at 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 internationa l trade and most imports into the United States are accompanied by the necessary permits and othe r 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 capab ilities 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 for ests, 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 c onduct 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 Commi ssion conduct this investigation through the lens of the like-product standard in unfair trade i nvestigations and conclude that the products manufactured by the wood flooring and hard wood 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 execu tive officer, Mannington Mills Inc., USITC hearing transcript, 138–44.

21 Clyde Elbrecht, owner, Master’s Craf t Corp., USITC hearing transcript, 147– 52.

22 Tommy Maxwell, owner, Maxwell Hardw ood 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 e ngineered hardwood flooring producer Mannington Mills Inc. (Mannington), said that he was mo re concerned about the substantial import growth in recent years, particularly from Ch ina, 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 th e 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, a nd 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 protec tive regulations aff ecting products with domestic content would render them uncompe titive 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 Flooring 22

In his hearing testimony, Mr. Maxwell, of domestic hardwood flooring producer Maxwell Hardwood Flooring (Maxwell), noted that th e 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 disadvant age for domestic producers is the alleged government subsidies provided to foreign competitors.23 Edward S. Korczak, chief executive officer and ex ecutive 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 Divisi on, Timber Products Co., USITC hearing transcript, 38–45.

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# 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 floor ing 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 fo r illegal logging, mislabeling products to evade import tariffs, and government subsidies be nefitting 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 retaile rs that carry wood flooring products, said that artificially restricting imports would adversel y affect retailers by limiting the variety of flooring products they can provide to cons umers 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, t hus 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 fl ooring 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 a bout timber documentation, emissions standards, duty evasion, and subsidies. Logs entering Ch ina 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 not26 Holly R. Hart, Legislative director, USW, Washington DC, USITC written submission, August 29, 2007; and Keith Romig, strategic issues repres entative, 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 th e 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 f aced plywood. Finally, according to Mr. Overgard, the Chinese government often subsidizes its wood products industry through VAT rebates, grants, favorable interest rates on loan s, 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 floori ng and consequent deterioration in the U.S. trade balance occurred largely due to the in flux 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 pr incipally 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 forei gn 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 disadvantag ed by the unfair trade practices of foreign competitors, particularly cutthroat pricing a nd 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 Ch ina, Russia, Indonesia, and Brazil are of suspicious origin and that these four count ries 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 submissi on, October 24, 2007. This brie f was submitted on behalf of the Hardwood Federation, HPVA, NWFA , NOFMA, Anderson, Armstrong, Co lumbia, Mannington, and Timber Products, who together formed this ad hoc coalition.

28 Tim Locke, executive vice president, NOFMA, USITC hearing transcript, 116–23.

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# U.S. Plywood and Wood Flooring Industries 27

In his post-hearing written submission, Mr. Le vin, 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 s hould have benefitted them, including record demand for hardwood plywood and flooring. Mr. Levin attr ibuted the problems confronting the domestic industries to three factors. First, tariff classi fications for these products are unwieldy, which causes widespread confusion in the tradi ng 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. Fina lly, Chinese producers and exporters benefit from a nearly limitless supply of cheap yet highly skilled labor, an undervalued fixed exchange rate, and subsidies that allegedl y include discounted loans for export-oriented enterprises, loan forgiveness fo r 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 produ ce approximately 75 percent of the solid unfinished flooring produced in the United St ates. 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, a llegedly to avoid paying duti es. 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.