Phone conversation between Matt LaPenta and Phil Duvic (AWI) on November 18, 2010.

1. Number of “Fabricators”

a. What would you estimate is the percentage of your members that engage in manufacturing architectural 

woodwork, for example, moulding, wood flooring, and windows and doors?

Represents 1200 manufacturers, 1005 of which are in NAICS 33721. They make woodwork, moulding, 

casework.

i. Of these manufacturers, what percentage would you estimate use composite wood products 

(hardwood plywood, particleboard, or medium density fiberboard) in their products? 

100%

ii. Of these manufacturers, what percentage would you estimate produce at least some product lines 

that are CARB compliant because they use CARB certified panels or component parts and follow 

the CARB recordkeeping and labeling requirements? 

Don’t know

b. What percentage of your members also manufacturer other wood products, such as cabinets, furniture, or 

casework? casework

Of these manufacturers, what percentage would you estimate use composite wood products (hardwood 

plywood, particleboard, or medium density fiberboard) in their products? 100%

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? Don’t know

c. 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? A labeling requirement makes little sense for custom orders – instead a 

certification statement with invoice makes more sense.

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.

Almost nobody would do this. Members do not include architectural panel manufacturers – ask HPVA 

about them.
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? n/a

c. What percentage of the production of wood veneer laminated products are produced using formaldehydebased resins to affix wood veneers to purchased platforms? n/a

d. If wood veneer laminators using UF resins were to switch to a lower emission resin, what would be the 

likely resin choice? n/a

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

adhesives used? n/a

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? n/a