Phone Conversation with Dave Grulke, Cabinet Makers Association on 11/2/10.

1. Number of “Fabricators”

a. Roughly what percentage of all U.S. custom cabinet manufacturing firms are members of your 

association? Are there any characteristics that may be typical of firms not represented by your 

organization? For example, a specific area of the country, or a type of kitchen cabinet or cabinet 

construction. About 1% of all cabinet makers. Mainly 10 person or less shops.

i. Of manufacturers of wood kitchen cabinets, what percentage would you estimate use 

composite wood products (hardwood plywood, particleboard, or medium density fiberboard) 

in their cabinets? 100%

ii. Of these manufacturers using composite wood products, what percentage would you estimate 

produce at least some product lines that are CARB compliant because they use CARB 

certified panels or component parts and follow the CARB recordkeeping and labeling 

requirements? Markets are mainly within 100 miles of home base. Guess between 50% to 

70% of established professional cabinet shops would be compliant. These account for 2/3’s 

to 3/4’s of the custom cabinet market. Shops in/near California would be compliant.

iii. Do the manufacturers that are producing CARB compliant product lines also carry product 

lines for sale outside of California that are not CARB compliant? If, so what percentage of 

production volume would you estimate are product lines that are not compliant with CARB 

because they do not use CARB certified panels or component parts or do not follow the 

CARB recordkeeping and labeling requirements? Don’t know.

2. Impact of Labeling Requirements

a. A national regulation of composite wood products could potentially require manufacturers that use 

composite wood materials to put a label on every separate item that gets produced and shipped out. 

Given this, could you estimate the average number of labels that would be needed annually for each 

manufacturer that uses composite wood materials? Not sure. Raised issue that 50% of the work 

involves assembling components on site. How would labeling requirements handle that?

b. If labels were required for each shipment of products instead of each individual item, about how may 

items would be included in a typical shipment? Don’t know.

3. Number of Wood Veneer “Laminator Product” Manufacturers

a. The recent federal legislation uses the term laminated product to mean a finished good (such as a 

custom panel, cabinet, window, door, or piece of furniture) that is produced by affixing a wood 

veneer to a purchased platform. How many of your members would you say produce such laminated 

products by affixing wood veneer themselves? Please do not include other types of laminates (such 

as high pressure laminates, thermally fused papers, vinyl films, decorative foils, or polypropylene 

films) in your answer. Very, very few would do this. This is outsourced. If someone did this, it might 

be a very small custom piece that they did.

b. For those manufacturers that would be classified as wood veneer laminators, how common is it for 

these manufacturers to also fabricate products using purchased panels that were already finished with 

a wood veneer or other decorative finish?

c. What percentage of the production of wood veneer laminated products are produced using 

formaldehyde-based resins to affix wood veneers to purchased platforms?
d. If wood veneer laminators using UF resins were to switch to a lower emission resin, what would be 

the likely resin choice?

e. Of those wood veneer laminators that use no-added formaldehyde resins, what are the most common 

adhesives used? 

f. If wood veneer laminators were subject to the same third party testing requirements as CARB, about 

how many different product types would need to be third party certified for a typical manufacturer?

General Comments:

 CMA recommends delaying rule until economic conditions improve.