U.S. International Trade Commission

Publication 4434 November 2013

Washington, DC 20436

Hardwood Plywood from China

Investigation Nos. 701-TA-490 and 731-TA-1204 (Final)
U.S. International Trade Commission

COMMISSIONERS 

Irving A. Williamson, Chairman 

Shara L. Aranoff 

Dean A. Pinkert 

David S. Johanson 

Meredith M. Broadbent 

F. Scott Kieff

Robert B. Koopman

Staff assigned

Address all communications to 

Secretary to the Commission 

United States International Trade Commission 

Washington, DC 20436

Director, Office of Operations

Fred Ruggles, Investigator 

Alberto Goetzl, Industry Analyst 

James Fetzer, Economist 

Charles Yost, Accountant 

Lita David-Harris, Statistician 

Darlene Smith, Statistical Assistant 

Rhonda Hughes, Attorney 

James McClure, Supervisory Investigator 

Special asistance from

Enter staff names and titles here
U.S. International Trade Commission

Washington, DC 20436 

www.usitc.gov

Publication 4434 November 2013

Hardwood Plywood from China

Investigation Nos. 701-TA-490 and 731-TA-1204 (Final)

  

CONTENTS

Page

i

Determinations............................................................................................................................... 1

Views of the Commission ............................................................................................................... 3

Part I:  Introduction ............................................................................................................... I‐1

Background................................................................................................................................ I‐1

Statutory criteria and organization of the report..................................................................... I‐2

Statutory criteria ................................................................................................................... I‐2

Organization of report........................................................................................................... I‐3

Market summary....................................................................................................................... I‐3

Summary data and data sources............................................................................................... I‐4

Previous and related investigations.......................................................................................... I‐4

Nature and extent of subsidies and sales at LTFV .................................................................... I‐4

Subsidies................................................................................................................................ I‐4

Sales at LTFV.......................................................................................................................... I‐5

The subject merchandise .......................................................................................................... I‐6

Commerce’s scope ................................................................................................................ I‐6

Tariff treatment..................................................................................................................... I‐8

The product............................................................................................................................... I‐9

Description and applications................................................................................................. I‐9

Manufacturing processes.................................................................................................... I‐10

Domestic like product issues................................................................................................... I‐12
  

CONTENTS

Page

ii

Part II:  Conditions of competition in the U.S. Market .......................................................... II‐1

U.S. market characteristics....................................................................................................... II‐1

U.S. purchasers......................................................................................................................... II‐1

Channels of distribution........................................................................................................... II‐1

Geographic distribution ........................................................................................................... II‐3

Supply and demand considerations......................................................................................... II‐3

U.S. supply ............................................................................................................................ II‐3

U.S. demand ......................................................................................................................... II‐5

Substitutability issues............................................................................................................. II‐11

Lead times .......................................................................................................................... II‐11

Knowledge of country sources........................................................................................... II‐12

Factors affecting purchasing decisions............................................................................... II‐12

Comparisons of domestic products, subject imports, and nonsubject imports................ II‐17

Elasticity estimates................................................................................................................. II‐24

U.S. supply elasticity........................................................................................................... II‐24

U.S. demand elasticity ........................................................................................................ II‐24

Substitution elasticity ......................................................................................................... II‐25

Part III:  U.S. producers’ production, shipments, and employment...................................... III‐1

U.S. producers......................................................................................................................... III‐1

U.S. production, capacity, and capacity utilization................................................................. III‐3

U.S. producers’ U.S. shipments and exports........................................................................... III‐3

U.S. producers’ inventories..................................................................................................... III‐4

U.S. producers’ imports and purchases.................................................................................. III‐5

U.S. employment, wages, and productivity ............................................................................ III‐5
  

CONTENTS

Page

iii

Part IV:  U.S. imports, apparent U.S. consumption, and market shares................................IV‐1

U.S. importers..........................................................................................................................IV‐1

U.S. imports............................................................................................................................. IV‐1

Negligibility.............................................................................................................................. IV‐2

Apparent U.S. consumption ....................................................................................................IV‐3

U.S. market shares ..................................................................................................................IV‐5

Ratio of imports to U.S. production ........................................................................................IV‐6

Part V:  Pricing data ..............................................................................................................V‐1

Factors affecting prices............................................................................................................V‐1

Raw material costs ...............................................................................................................V‐1

U.S. inland transportation costs...........................................................................................V‐1

Pricing practices .......................................................................................................................V‐1

Pricing methods....................................................................................................................V‐1

Sales terms and discounts....................................................................................................V‐3

Price leadership ....................................................................................................................V‐3

Price data..................................................................................................................................V‐3

Price trends.........................................................................................................................V‐11

Price comparisons ..............................................................................................................V‐11

Lost sales and lost revenue ....................................................................................................V‐13
  

CONTENTS

Page

iv

Part VI:  Financial experience of U.S. producers...................................................................VI‐1

Background..............................................................................................................................VI‐1

Operations on HARDWOOD PLYWOOD..................................................................................VI‐1

Variance analysis.................................................................................................................VI‐6

Capital expenditures and research and development expenses............................................VI‐8

Assets and return on investment............................................................................................VI‐9

Capital and investment .........................................................................................................VI‐10

Actual Negative Effects......................................................................................................VI‐10

Anticipated Negative Effects.............................................................................................VI‐11

Part VII:  Threat considerations and information on nonsubject countries .........................VII‐1

The industry in China..............................................................................................................VII‐2

U.S. inventories of imported merchandise ............................................................................VII‐4

U.S. importers’ outstanding orders........................................................................................VII‐5

Appendixes

A. ..... Federal Register notices................................................................................................. A‐1

B. ......Calendar of the public conference ................................................................................ B‐1

C. ...... Summary data................................................................................................................ C‐1

D. .... U.S. and Chinese hardwood plywood by type of material utilized andthickness of product

and face veneer.................................................................................................................D‐1

E. ...... Applications of domestic versus subject product  ......................................................... E‐1

F. ...... Nonsubject country price data...................................................................................... F‐1

Note.—Information that would reveal confidential operations of individual concerns may not

be published and therefore has been deleted.  Such deletions are indicated by asterisks.
1 

UNITED STATES INTERNATIONAL TRADE COMMISSION

Investigation Nos. 701‐TA‐490 and 731‐TA‐1204 (Final)

HARDWOOD PLYWOOD FROM CHINA

DETERMINATIONS

On the basis of the record1 developed in the subject investigations, the United States

International Trade Commission (Commission) determines, pursuant to sections 705(b) and

735(b) of the Tariff Act of 1930 (19 U.S.C. ' 1671d(b)) and (19 U.S.C. ' 1673d(b)) (the Act), that

an industry in the United States is not materially injured or threatened with material injury, and

the establishment of an industry in the United States is not materially retarded, by reason of

imports of hardwood plywood from China provided for in subheading(s) 4412.10; 4412.31;

4412.32; 4412.39; 4412.94; and 4412.99 of the Harmonized Tariff Schedule of the United

States, that the U.S. Department of Commerce has determined are subsidized and sold in the

United States at less than fair value (ALTFV@).2

BACKGROUND

The Commission instituted these investigations effective September 27, 2012, following

receipt of a petition filed with the Commission and Commerce by Columbia Forest Products,

Greensboro, NC; Commonwealth Plywood Co., Ltd., Whitehall, NY; Murphy Plywood, Eugene,

OR; Roseburg Forest Products Co., Roseburg, OR; States Industries LLC, Eugene, OR; and Timber

Products Company, Springfield, OR combined as The Coalition for Fair Trade of Hardwood

Plywood.  The final phase of the investigations was scheduled by the Commission following

notification of preliminary determinations by Commerce that imports of hardwood plywood

from China were subsidized within the meaning of section 703(b) of the Act (19 U.S.C.

' 1671b(b)) and dumped within the meaning of 733(b) of the Act (19 U.S.C. ' 1673b(b)).  Notice

of the scheduling of the final phase of the Commission=s investigations and of a public hearing

to be held in connection therewith was given by posting copies of the notice in the Office of the

Secretary, U.S. International Trade Commission, Washington, DC, and by publishing the notice

in the Federal Register on June 19, 2013 (78 FR 36791).  The hearing was held in Washington,

 1 The record is defined in sec. 207.2(f) of the Commission=s Rules of Practice and Procedure (19

CFR ' 207.2(f)).

2 Chairman Irving A. Williamson and Commissioners Shara L. Aranoff, Dean A. Pinkert, David S.

Johanson, and Meredith M. Broadbent voted in the negative. Commissioner F. Scott Kieff did not

participate in these investigations.
2 

DC, on September 19, 2013, and all persons who requested the opportunity were permitted to

appear in person or by counsel.
3

Views of the Commission

Based on the record in the final phase of these investigations, we find that an industry in

the United States is neither materially injured nor threatened with material injury by reason of

imports of hardwood and decorative plywood (“hardwood plywood”) from China found by the

U.S. Department of Commerce (“Commerce”) to be subsidized and sold in the United States at

less than fair value.1

I. Background

Parties to the Investigations.  The petitions in these investigations were filed on

September 27, 2012 by Columbia Forest Products (“Columbia”), Commonwealth Plywood Co.,

Ltd. (“Commonwealth”), Murphy Plywood (“Murphy”), Roseburg Forest Products Co.

(“Roseburg”), States Industries LLC (“States”), and Timber Products Company (“Timber

Products”), appearing collectively as the Coalition for Fair Trade of Hardwood Plywood

(“CFTHP”).  Representatives of CFTHP appeared at the hearing accompanied by counsel, and

CFTHP submitted prehearing and posthearing briefs.   

Two respondent groups participated in the final phase investigations.  Representatives

and counsel for China National Forest Products Industry Association and its members (“Chinese

Producers’ Association”), Chinese producers and exporters of the subject merchandise,

appeared at the hearing and submitted prehearing and posthearing briefs, as did

representatives and counsel for the American Alliance for Hardwood Plywood (“AAHP”), a

coalition of importers of hardwood plywood.

Data Coverage.  U.S. industry data are based on questionnaire responses from eight

domestic producers that accounted for nearly all U.S. production of hardwood plywood in

2012.2

  U.S. import data are based on official Commerce import statistics and from

questionnaire responses of 42 U.S. importers of hardwood plywood from China over the period

of investigation, which encompasses the period January 1, 2010 through June 30, 2013.3

  These

42 importers accounted for nearly 70 percent of subject imports from China in 2012.4

  The

                                                        1 Commissioner Kieff did not participate in these investigations. 2 Confidential Staff Report (“CR”) and Public Staff Report (“PR”) at Table III‐1.

3 Petitioners argued that the Commission should use official statistics in its analysis, while

respondents argued that the Commission should use questionnaire data.  The relevant subheadings

from official Census data consist largely of subject product, although some nonsubject  imports are also

included.  However, we find that the questionnaire data cover too low a share of imports to be as

reliable as the official statistics.  Thus, we find that official Census data are more comprehensive and rely

on those data in our analysis.  We note, however, that even if we had relied on the questionnaire data,

we would have made the same findings and reached the same conclusions as we have using the official

statistics.4 CR/PR at IV‐1.
4

Commission also received questionnaire responses from 89 foreign producers that accounted

for approximately 52.4 percent of U.S. imports of hardwood plywood from China in 2012.5

II. Domestic Like Product

A. In General

In determining whether an industry in the United States is materially injured or

threatened with material injury by reason of imports of subject merchandise, the Commission

first defines the “domestic like product” and the “industry.”6

  Section 771(4)(A) of the Tariff Act

of 1930, as amended (“the Tariff Act”), defines the relevant domestic industry as the

“producers as a whole of a domestic like product, or those producers whose collective output

of a domestic like product constitutes a major proportion of the total domestic production of

the product.”7  In turn, the Tariff Act defines “domestic like product” as “a product which is like,

or in the absence of like, most similar in characteristics and uses with, the article subject to an

investigation.”8

The decision regarding the appropriate domestic like product in an investigation is a

factual determination, and the Commission has applied the statutory standard of “like” or

“most similar in characteristics and uses” on a case‐by‐case basis.9  No single factor is

dispositive, and the Commission may consider other factors it deems relevant based on the

facts of a particular investigation.10  The Commission looks for clear dividing lines among

possible like products and disregards minor variations.11  Although the Commission must accept

Commerce’s determination as to the scope of the imported merchandise that is subsidized or

                                                        5 CR at VII‐3, PR at VII‐3.

6 19 U.S.C. § 1677(4)(A). 7 19 U.S.C. § 1677(4)(A).

8 19 U.S.C. § 1677(10).

9 See, e.g., Cleo Inc. v. United States, 501 F.3d 1291, 1299 (Fed. Cir. 2007); NEC Corp. v.

Department of Commerce, 36 F. Supp. 2d 380, 383 (Ct. Int’l Trade 1998); Nippon Steel Corp. v. United

States, 19 CIT 450, 455 (1995); Torrington Co. v. United States, 747 F. Supp. 744, 749 n.3 (Ct. Int’l Trade

1990), aff’d, 938 F.2d 1278 (Fed. Cir. 1991) (“every like product determination ‘must be made on the

particular record at issue’ and the ‘unique facts of each case’”).  The Commission generally considers a

number of factors, including the following:  (1) physical characteristics and uses; (2) interchangeability;

(3) channels of distribution; (4) customer and producer perceptions of the products; (5) common

manufacturing facilities, production processes, and production employees; and, where appropriate, (6)

price.  See Nippon, 19 CIT at 455 n.4; Timken Co. v. United States, 913 F. Supp. 580, 584 (Ct. Int’l Trade

1996).

10 See, e.g., S. Rep. No. 96‐249 at 90‐91 (1979). 11 Nippon, 19 CIT at 455; Torrington, 747 F. Supp. at 748‐49; see also S. Rep. No. 96‐249 at 90‐91

(Congress has indicated that the like product standard should not be interpreted in “such a narrow

fashion as to permit minor differences in physical characteristics or uses to lead to the conclusion that

the product and article are not ‘like’ each other, nor should the definition of ‘like product’ be

interpreted in such a fashion as to prevent consideration of an industry adversely affected by the

imports under consideration.”).
5

sold at less than fair value,12 the Commission determines what domestic product is like the

imported articles Commerce has identified.13

B. Product Description

Commerce defined the scope of the imported merchandise under investigation as

follows:

***ardwood and decorative plywood.  Hardwood and decorative

plywood is a flat panel composed of an assembly of two or more layers

or plies of wood veneers in combination with a core. The veneers, along

with the core, are glued or otherwise bonded together to form a finished

product. A hardwood and decorative plywood panel must have face and

back veneers which are composed of one or more species of hardwoods,

softwoods, or bamboo.  Hardwood and decorative plywood may include

products that meet the American National Standard for Hardwood and

Decorative Plywood, ANSI/HPVA HP‐1‐2009.

All hardwood and decorative plywood is included within the scope of  

***, without regard to dimension (overall thickness,  

thickness of face veneer, thickness of back veneer, thickness of core,  

thickness of inner veneers, width, or length). However, the most common  

panel sizes of hardwood and decorative plywood are 1219 x 1829 mm (48 x  

72 inches), 1219 x 2438 mm (48 x 96 inches), and 1219 x 3048 mm (48 x  

120 inches).

A “veneer” is a thin slice of wood which is rotary cut, sliced or  

sawed from a log, bolt or flitch. The face veneer is the exposed veneer  

of a hardwood and decorative plywood product which is of a superior  

grade than that of the back veneer, which is the other exposed veneer  

of the product (i.e., as opposed to the inner veneers). When the two  

exposed veneers are of equal grade, either one can be considered the  

face or back veneer. For products that are entirely composed of veneer,  

                                                       12 See, e.g., USEC, Inc. v. United States, 34 Fed. Appx. 725, 730 (Fed. Cir. 2002) (“The ITC may not

modify the class or kind of imported merchandise examined by Commerce.”); Algoma Steel Corp. v.

United States, 688 F. Supp. 639, 644 (Ct. Int’l Trade 1988), aff’d, 865 F.3d 240 (Fed. Cir.), cert. denied,

492 U.S. 919 (1989).

13 Hosiden Corp. v. Advanced Display Mfrs., 85 F.3d 1561, 1568 (Fed. Cir. 1996) (the Commission

may find a single like product corresponding to several different classes or kinds defined by Commerce);

Cleo, 501 F.3d at 1298 n.1 (“Commerce’s {scope} finding does not control the Commission’s {like

product} determination.”); Torrington, 747 F. Supp. at 748‐52 (affirming the Commission’s

determination defining six like products in investigations in which Commerce found five classes or

kinds).
6

such as Veneer Core Platforms, the exposed veneers are to be considered  

the face and back veneers, in accordance with the descriptions above.

The core of hardwood and decorative plywood consists of the layer  

or layers of one or more material(s) that are situated between the face  

and back veneers. The core may be composed of a range of materials,  

including but not limited to veneers, particleboard, and medium‐density  

fiberboard (“MDF”).

All hardwood and decorative plywood is included within the scope of  

*** regardless of whether or not the face and/or back  

veneers are surface coated, unless the surface coating obscures the  

grain, texture or markings of the wood. Examples of surface coatings  

which may not obscure the grain, texture or markings of the wood  

include, but are not limited to, ultra‐violet light cured  

polyurethanes, oil or oil‐modified or water based polyurethanes, wax,  

epoxy‐ester finishes, and moisture‐cured urethanes. Hardwood and  

decorative plywood that has face and/or back veneers which have an  

opaque surface coating which obscures the grain, texture or markings of  

the wood, are not included within the scope of ***.  

Examples of surface coatings which may obscure the grain, texture or  

markings of wood include, but are not limited to, paper, aluminum, high  

pressure laminate (“HPL”), MDF, medium density overlay (“MDO”), and  

phenolic film). Additionally, the face veneer of hardwood and  

decorative plywood may be sanded, smoothed or given a “distressed”  

appearance through such methods as hand‐scraping or wire brushing. The  

face veneer may be stained.

The scope of the investigation excludes the following items:   

(1) Structural plywood (also known as “industrial plywood” or  

“industrial panels”) that is manufactured and stamped to meet U.S.  

Products Standard PS 1‐09 for Structural Plywood (including any  

revisions to that standard or any substantially equivalent  

international standard intended for structural plywood), including but  

not limited to the “bond performance” requirements set forth at  

paragraph 5.8.6.4 of that Standard and the performance criteria  

detailed at Table 4 through 10 of that Standard; (2) products which  

have a face and back veneer of cork; (3) multilayered wood flooring, as  

described in the antidumping duty and countervailing duty orders on  

Multilayered Wood Flooring from the People's Republic of China, Import  

Administration, International Trade Administration, U.S. Department of  

Commerce Investigation Nos. A‐570‐970 and C‐570‐971 (published

December 8, 2011),and additionally, multilayered wood flooring

with a face veneer of bamboo or composed entirely of bamboo;
7

(4) plywood which has a shape or design other than a flat panel;

(5) products made entirely from bamboo and adhesives (also known

as “solid bamboo”).14

The scope in the final phase of these investigations is virtually identical to the scope in the

preliminary phase of the investigations, with the addition of bamboo to exclusion (3), the

simplification of exclusion (4), and the addition of exclusion (5).15

Hardwood plywood is a wood panel product made by gluing two or more layers of

wood veneer to a core that may itself be composed of veneers or other types of wood material

such as medium density fiberboard (“MDF”), particleboard, lumber, or oriented strand board

(“OSB”).  The outer ply or face veneer is typically the identifying species for the hardwood

plywood product and is the side of the product that will be visible in most uses.  Numerous

hardwood species are used in hardwood plywood manufacture, including oak, birch, maple,

poplar, and cherry.  However, hardwood plywood within the scope of investigation includes

plywood that may have a face veneer and/or other layers of veneer of softwood species.  The

distinguishing characteristic of hardwood plywood products is that they are used in interior and

non‐structural applications.16

Hardwood plywood is manufactured in a variety of thicknesses, with the most

common ranging from  1⁄8 inch (3.2 mm) to 1 inch (25 mm), depending upon customer

requirements and the intended end use.  The most common panel dimensions are 4 feet by

8 feet (1219 x 1829 mm), but hardwood plywood is sold in smaller and larger sheet sizes.17

Hardwood plywood is commonly used in furniture, kitchen cabinets, architectural

woodwork, wall paneling, manufactured homes, and recreational vehicles (“RVs”).  The product

is almost always used in interior applications where moisture exposure is not an issue, although

some hardwood plywood is made specifically for marine applications.  Hardwood plywood is

also used in some construction‐related applications where structural strength and moisture

resistance are not required, such as for providing a flat, stable underlayment for a finished

flooring product.18

Hardwood plywood products are differentiated by species, quality of veneer, thickness,

number of plies, type of core (veneer, particleboard, MDF, or other), and the type of adhesive

used in the manufacturing process.  Grades of hardwood plywood are determined by such

things as the number and size of knots, visible decay, splits or insect holes, surface roughness,

and other defects.  Grades are assigned to both the face and back veneers.  Plywood with the

highest face grades is used in applications where appearance is a primary consideration.  Most

hardwood plywood produced in the United States is graded according to a consensus‐based

voluntary standard developed by the Hardwood Plywood and Veneer Association (“HPVA”).  

                                                       14 78 Fed. Reg. 58273, 58283 (Sept. 23, 2013).

15 See Hardwood Plywood from the People’s Republic of China, Inv. Nos. 701‐TA‐490 and 731‐TA‐

1204 (Preliminary), USITC Pub. 4361 (Nov. 2012), at 4‐5 (“Preliminary Determination”).

16 CR at I‐10 – I‐11, PR at I‐9 – I‐10. 17 CR at I‐11, PR at I‐9.

18 CR at I‐11, PR at I‐9.
8

The highest grades of hardwood plywood carry an “AA” or “A” face grade, followed by “B,” “C,”

etc. for products with more knots, blemishes, or other defects.  The HPVA standard also assigns

numerical grades ranging from 1 to 4 to back veneers and certain other letter grades to internal

veneers.  However, not all hardwood plywood sold in the United States conforms to the HPVA

standard.19

C. Domestic Like Product Analysis

In the preliminary determinations, the Commission defined a single domestic like

product that was coextensive with the scope.  In terms of physical characteristics and end uses,

it found that all hardwood plywood consists of two or more layers of wood veneer glued to a

core.  The outer ply, or face veneer, is made from various hardwood species and is the part of

the product that will generally be visible.  All hardwood plywood is used in a range of interior

applications, most often when exposure to moisture is not an issue.20

Regarding interchangeability, the Commission found that the various thicknesses and

panel sizes of hardwood plywood are used in interior and non‐structural applications.  

However, individual applications may require specific thicknesses, sizes, and/or grades.21  In

addition, it found that although the core material is typically manufactured separately from the

veneers used for the face and/or back plies, all hardwood plywood is manufactured in the same

facilities.22  The Commission found that there are different grades of hardwood plywood, and

hardwood plywood products differ according to the species of the hardwood used as well as

the quality of the veneer, the type of core, and the type of adhesive used.  Consequently, there

are some differences in producer and customer perceptions among different hardwood

plywood products.23

The Commission found that all hardwood plywood is sold in similar channels of

distribution, namely to wholesalers or directly to original equipment manufacturers (“OEMs”).24  

The Commission found that the price of a hardwood plywood product is a function of the panel

size, face species, quality, thickness, and finish (whether stained, distressed, or otherwise

treated).25

On the basis of the above findings and because no party argued to the contrary, the

Commission defined one domestic like product, coextensive with the scope of the

investigations, in the preliminary determinations.26

For these final phase investigations, petitioners argue that the Commission should again

define the domestic like product to be coextensive with the scope.27  Respondents do not

                                                       19 CR at I‐11 – I‐12, PR at I‐9 – I‐10.

20 Preliminary Determination, USITC Pub. 4361 at 7. 21 Preliminary Determination, USITC Pub. 4361 at 7. 22 Preliminary Determination, USITC Pub. 4361 at 7.

23 Preliminary Determination, USITC Pub. 4361 at 7.

24 Preliminary Determination, USITC Pub. 4361 at 7.

25 Preliminary Determination, USITC Pub. 4361 at 7.

26 Preliminary Determination, USITC Pub. 4361 at 7.

27 Petitioners’ Prehearing Brief at 3‐4.
9

contest this position.28  The information in the record pertaining to the like product factors is

substantially unchanged from that in the preliminary phase.29  Therefore, for the same reasons

discussed in the preliminary determinations, we find one domestic like product that is

coextensive with the scope of the investigations.

III. Domestic Industry  

The domestic industry is defined as the domestic “producers as a whole of a domestic

like product, or those producers whose collective output of a domestic like product constitutes

a major proportion of the total domestic production of the product.”30  In defining the domestic

industry, the Commission’s general practice has been to include in the industry producers of all

domestic production of the like product, whether toll‐produced, captively consumed, or sold in

the domestic merchant market.  

We must determine whether any producer of the domestic like product should be

excluded from the domestic industry pursuant to 771(4)(B) of the Tariff Act.  This provision

allows the Commission, if appropriate circumstances exist, to exclude from the domestic

industry producers that are related to an exporter or importer of subject merchandise or which

are themselves importers.31  Exclusion of such a producer is within the Commission’s discretion

based upon the facts presented in each investigation.32

Two domestic producers imported and several others purchased subject imports from

China during the period of investigation.  The Commission must consequently determine

whether these producers are subject to exclusion from the domestic industry pursuant to the

related party provision of the statute and, if so, whether appropriate circumstances exist to

exclude any of them.  

                                                        28 Respondents have not addressed the issue of the domestic like product since the preliminary

phase of the investigations, when they accepted petitioners’ proposed definition.  Chinese Producers’

Association’s Postconference Brief at 2; AAHP’s Postconference Brief at 2‐3.

29 See generally CR at I‐10 – I‐20, PR at I‐9 – I‐15.

30 19 U.S.C. § 1677(4)(A).

31 See Torrington Co. v. United States, 790 F. Supp. 1161, 1168 (Ct. Int’l Trade 1992), aff’d

without opinion, 991 F.2d 809 (Fed. Cir. 1993); Sandvik AB v. United States, 721 F. Supp. 1322, 1331‐32

(Ct. Int’l Trade 1989), aff’d mem., 904 F.2d 46 (Fed. Cir. 1990); Empire Plow Co. v. United States, 675 F.

Supp. 1348, 1352 (Ct. Int’l Trade 1987).

32 The primary factors the Commission has examined in deciding whether appropriate

circumstances exist to exclude a related party include the following:

(1) the percentage of domestic production attributable to the importing producer;

(2) the reason the U.S. producer has decided to import the product subject to investigation, i.e.,

whether the firm benefits from the LTFV sales or subsidies or whether the firm must import in order to

enable it to continue production and compete in the U.S. market; and

(3) the position of the related producer vis‐a‐vis the rest of the industry, i.e., whether inclusion

or exclusion of the related party will skew the data for the rest of the industry. See, e.g., Torrington Co. v

United States, 790 F. Supp. at 1168.
10

We first analyze which domestic producers are subject to potential exclusion from the

domestic industry pursuant to the related parties provision.  *** and ***, each imported

subject merchandise during the period of investigation.33  Consequently, *** are related

parties.  We find that the five domestic producers that purchased subject imports are not

related parties.34

We next examine whether appropriate circumstances exist to exclude *** from the

domestic industry.

A. ***

*** was the second largest domestic hardwood plywood producer in 2012, accounting

for *** percent of domestic production.35  The ratio of its subject imports to production was

*** percent in 2010, *** percent in 2011, and *** percent in 2012; it was *** percent in

January‐June (“interim”) 2012 and *** percent in interim 2013.36  *** stated that it imported

subject imports “due to their low cost.”37  Its operating income margin was higher than that of

some of the other producers during the period.38 39 40  In view of *** status as a ***, the fact

                                                       33 CR/PR at Table III‐5; Preliminary Determination , USITC Pub. 4361 at 9.

34 Domestic producers *** purchased subject imports from China, but did not directly import

such merchandise.  CR/PR at Table III‐5.  The Commission has previously concluded that a purchaser may

be treated as a related party if it controls large volumes of subject imports.  The Commission has found

such control to exist when the domestic producer was responsible for a predominant proportion of an

importer’s purchases and these purchases were substantial.  See Foundry Coke from China, Inv. No. 731‐

TA‐891 (Final), USITC Pub. 3449, at 8‐9 (Sept. 2001).

In these investigations, although purchases of subject imports were made in every year of the

period by all but one producer, the annual amounts were quite small.  In 2012, *** was responsible for

the largest amount of subject import purchases, which totaled only *** percent of all subject imports.  

Compare CR/PR at Table III‐5 with CR/PR at Table IV‐1.  Each of the purchasers, except ***, is a ***.  

CR/PR at Table III‐1.  In view of the fact that none of the producers controls large volumes of subject

imports, we find that none of these producers warrants treatment as a related party.

35 CR/PR at Tables III‐1 & III‐5.

36 CR/PR at Table III‐5.  *** imported *** square feet of subject merchandise in 2010, ***

square feet in 2011, *** square feet in 2012, *** square feet in interim 2012, and *** square feet in

interim 2013.  Id. 37 CR/PR at Table III‐5 n.7.

38 CR/PR at Table VI‐2.

39 Consistent with her practice in past investigations and reviews, Commissioner Aranoff does

not rely on individual‐company operating income margins, which reflect a domestic producer’s financial

operations related to production of the domestic like product, in assessing whether a related party has

benefitted from importation of subject merchandise.  Rather, she determines whether to exclude a

related party based principally on its ratio of subject imports to domestic production and whether its

primary interests lie in domestic production or importation.

40 Commissioner Pinkert does not rely upon the importing companies’ financial performance as

a factor in determining whether there are appropriate circumstances to exclude them from the

domestic industry in these investigations.  The record is not sufficient to infer from their profitability on

(Continued...)
11

that its domestic production was far larger than its subject imports, and that no party has

argued for its exclusion from the domestic industry, we find that appropriate circumstances do

not exist to exclude *** from the domestic industry as  a related party.

B. ***

   ***, which ***, also imported subject merchandise throughout the period.41  ***

ceased production of hardwood plywood in 2011.  It stated during the preliminary phase of the

investigations that it participated in the market solely as an importer and purchaser after

February 2011.42  The Commission found that circumstances were appropriate to exclude ***

from the domestic industry during the preliminary phase.43

In the final phase of these investigations, *** did not provide a questionnaire

response.44  As *** status has not changed since the preliminary phase, we again find that

appropriate circumstances exist to exclude it as a related party.45

Accordingly, in light of the definition of the domestic like product and the foregoing

analysis, we define a single domestic industry encompassing all U.S. producers of hardwood

plywood, with the exception of ***.

IV. No Material Injury by Reason of Subject Imports

A. Legal Standards

In the final phase of antidumping and countervailing duty investigations, the

Commission determines whether an industry in the United States is materially injured or

threatened with material injury by reason of the imports under investigation.46  In making this

determination, the Commission must consider the volume of subject imports, their effect on

prices for the domestic like product, and their impact on domestic producers of the domestic

like product, but only in the context of U.S. production operations.47  The statute defines

                                                                                                                                                                               

(...Continued)

U.S. operations whether they have derived a specific benefit from importing.  See Allied Mineral

Products v. United States, 28 CIT 1861, 1865‐67 (2004). 41 We note that although petitioners argued that the record does not present appropriate

circumstances upon which to exclude any current domestic producer from the domestic industry, they

also maintained that the Commission should affirm its prior decision to exclude ***.  Petitioners’

Prehearing Brief at 8 & n.19.

42 Petitioners’ Postconference Brief at 7‐8 n.20.

43 Preliminary Determination, USITC Pub. 4361 at 9. 44 CR/PR at III‐1 n.1.    45 We note that, because of its small size and cessation of operation, exclusion of *** from the

industry as a related party does not significantly affect the data we rely on in our analysis.

46 19 U.S.C. §§ 1671d(b), 1673d(b). 47 19 U.S.C. § 1677(7)(B).  The Commission “may consider such other economic factors as are

relevant to the determination” but shall “identify each {such} factor ... and explain in full its relevance to

the determination.”  19 U.S.C. § 1677(7)(B).
12

“material injury” as “harm which is not inconsequential, immaterial, or unimportant.”48  In

assessing whether the domestic industry is materially injured by reason of subject imports, we

consider all relevant economic factors that bear on the state of the industry in the United

States.49  No single factor is dispositive, and all relevant factors are considered “within the

context of the business cycle and conditions of competition that are distinctive to the affected

industry.”50

Although the statute requires the Commission to determine whether the domestic

industry is “materially injured or threatened with material injury by reason of” unfairly traded

imports,51 it does not define the phrase “by reason of,” indicating that this aspect of the injury

analysis is left to the Commission’s reasonable exercise of its discretion.52  In identifying a

causal link, if any, between subject imports and material injury to the domestic industry, the

Commission examines the facts of record that relate to the significance of the volume and price

effects of the subject imports and any impact of those imports on the condition of the domestic

industry.  This evaluation under the “by reason of” standard must ensure that subject imports

are more than a minimal or tangential cause of injury and that there is a sufficient causal, not

merely a temporal, nexus between subject imports and material injury.53

In many investigations, there are other economic factors at work, some or all of which

may also be having adverse effects on the domestic industry.  Such economic factors might

include nonsubject imports; changes in technology, demand, or consumer tastes; competition

among domestic producers; or management decisions by domestic producers.  The legislative

history explains that the Commission must examine factors other than subject imports to

ensure that it is not attributing injury from other factors to the subject imports, thereby

inflating an otherwise tangential cause of injury into one that satisfies the statutory material

injury threshold.54  In performing its examination, however, the Commission need not isolate

                                                       48 19 U.S.C. § 1677(7)(A).

49 19 U.S.C. § 1677(7)(C)(iii).

50 19 U.S.C. § 1677(7)(C)(iii).

51 19 U.S.C. §§ 1671d(a), 1673d(a).

52 Angus Chemical Co. v. United States, 140 F.3d 1478, 1484‐85 (Fed. Cir. 1998) (“{T}he statute

does not ‘compel the commissioners’ to employ {a particular methodology}.”), aff’g, 944 F. Supp. 943,

951 (Ct. Int’l Trade 1996).

53 The Federal Circuit, in addressing the causation standard of the statute, observed that “{a}s

long as its effects are not merely incidental, tangential, or trivial, the foreign product sold at less than

fair value meets the causation requirement.”  Nippon Steel Corp. v. USITC, 345 F.3d 1379, 1384 (Fed. Cir.

2003).  This was further ratified in Mittal Steel Point Lisas Ltd. v. United States, 542 F.3d 867, 873 (Fed.

Cir. 2008), where the Federal Circuit, quoting Gerald Metals, Inc. v. United States, 132 F.3d 716, 722

(Fed. Cir. 1997), stated that “this court requires evidence in the record ‘to show that the harm occurred

“by reason of” the LTFV imports, not by reason of a minimal or tangential contribution to material harm

caused by LTFV goods.’”  See also Nippon Steel Corp. v. United States, 458 F.3d 1345, 1357 (Fed. Cir.

2006); Taiwan Semiconductor Industry Ass’n v. USITC, 266 F.3d 1339, 1345 (Fed. Cir. 2001).

54 SAA at 851‐52 (“{T}he Commission must examine other factors to ensure that it is not

attributing injury from other sources to the subject imports.”); S. Rep. 96‐249 at 75 (1979) (the

Commission “will consider information which indicates that harm is caused by factors other than less‐

(Continued...)
13

the injury caused by other factors from injury caused by unfairly traded imports.55  Nor does the

“by reason of” standard require that unfairly traded imports be the “principal” cause of injury

or contemplate that injury from unfairly traded imports be weighed against other factors, such

as nonsubject imports, which may be contributing to overall injury to an industry.56  It is clear

that the existence of injury caused by other factors does not compel a negative

determination.57

Assessment of whether material injury to the domestic industry is “by reason of” subject

imports “does not require the Commission to address the causation issue in any particular way”

as long as “the injury to the domestic industry can reasonably be attributed to the subject

imports” and the Commission “ensure{s} that it is not attributing injury from other sources to

the subject imports.”58 59  Indeed, the Federal Circuit has examined and affirmed various

Commission methodologies and has disavowed “rigid adherence to a specific formula.”60

                                                                                                                                                                              

(...Continued)

than‐fair‐value imports.”); H.R. Rep. 96‐317 at 47 (1979) (“in examining the overall injury being

experienced by a domestic industry, the ITC will take into account evidence presented to it which

demonstrates that the harm attributed by the petitioner to the subsidized or dumped imports is

attributable to such other factors;” those factors include “the volume and prices of nonsubsidized

imports or imports sold at fair value, contraction in demand or changes in patterns of consumption,

trade restrictive practices of and competition between the foreign and domestic producers,

developments in technology and the export performance and productivity of the domestic industry”);

accord Mittal Steel, 542 F.3d at 877. 55 SAA at 851‐52 (“{T}he Commission need not isolate the injury caused by other factors from

injury caused by unfair imports.”); Taiwan Semiconductor Industry Ass’n, 266 F.3d at 1345 (“{T}he

Commission need not isolate the injury caused by other factors from injury caused by unfair imports ... .  

Rather, the Commission must examine other factors to ensure that it is not attributing injury from other

sources to the subject imports.” (emphasis in original)); Asociacion de Productores de Salmon y Trucha

de Chile AG v. United States, 180 F. Supp. 2d 1360, 1375 (Ct. Int’l Trade 2002) (“{t}he Commission is not

required to isolate the effects of subject imports from other factors contributing to injury” or make

“bright‐line distinctions” between the effects of subject imports and other causes.); see also Softwood

Lumber from Canada, Inv. Nos. 701‐TA‐414 and 731‐TA‐928 (Remand), USITC Pub. 3658 at 100‐01 (Dec.

2003) (Commission recognized that “{i}f an alleged other factor is found not to have or threaten to have

injurious effects to the domestic industry, i.e., it is not an ‘other causal factor,’ then there is nothing to

further examine regarding attribution to injury”), citing Gerald Metals, 132 F.3d at 722 (the statute

“does not suggest that an importer of LTFV goods can escape countervailing duties by finding some

tangential or minor cause unrelated to the LTFV goods that contributed to the harmful effects on

domestic market prices.”).

56 S. Rep. 96‐249 at 74‐75; H.R. Rep. 96‐317 at 47.    57 See Nippon Steel Corp., 345 F.3d at 1381 (“an affirmative material‐injury determination under

the statute requires no more than a substantial‐factor showing.  That is, the ‘dumping’ need not be the

sole or principal cause of injury.”).

58 Mittal Steel, 542 F.3d at 877‐78; see also id. at 873 (“While the Commission may not enter an

affirmative determination unless it finds that a domestic industry is materially injured ‘by reason of’

subject imports, the Commission is not required to follow a single methodology for making that

determination ... {and has} broad discretion with respect to its choice of methodology.”) citing United

States Steel Group v. United States, 96 F.3d 1352, 1362 (Fed. Cir. 1996) and S. Rep. 96‐249 at 75.  
14

The Federal Circuit’s decisions in Gerald Metals, Bratsk, and Mittal Steel all involved

cases where the relevant “other factor” was the presence in the market of significant volumes

of price‐competitive nonsubject imports.  The Commission interpreted the Federal Circuit’s

guidance in Bratsk as requiring it to apply a particular additional methodology following its

finding of material injury in cases involving commodity products and a significant market

presence of price‐competitive nonsubject imports.61  The additional “replacement/benefit” test

looked at whether nonsubject imports might have replaced subject imports without any benefit

to the U.S. industry.  The Commission applied that specific additional test in subsequent cases,

including the Carbon and Certain Alloy Steel Wire Rod from Trinidad and Tobago determination

that underlies the Mittal Steel litigation.

Mittal Steel clarifies that the Commission’s interpretation of Bratsk was too rigid and

makes clear that the Federal Circuit does not require the Commission to apply an additional

test nor any one specific methodology; instead, the court requires the Commission to have

“evidence in the record” to “show that the harm occurred ‘by reason of’ the LTFV imports,” and

requires that the Commission not attribute injury from nonsubject imports or other factors to

subject imports.62  Accordingly, we do not consider ourselves required to apply the

replacement/benefit test that was included in Commission opinions subsequent to Bratsk.

The progression of Gerald Metals, Bratsk, and Mittal Steel clarifies that, in cases

involving commodity products where price‐competitive nonsubject imports are a significant

                                                                                                                                                                              

(...Continued)

59 Commissioner Pinkert does not join this paragraph or the following three paragraphs.  He

points out that the Federal Circuit, in Bratsk, 444 F.3d 1369, and Mittal Steel, held that the Commission

is required, in certain circumstances when considering present material injury, to undertake a particular

kind of analysis of non‐subject imports, albeit without reliance upon presumptions or rigid formulas.  

Mittal Steel explains as follows:

What Bratsk held is that “where commodity products are at issue and fairly traded, price

competitive, non‐subject imports are in the market,” the Commission would not fulfill its

obligation to consider an important aspect of the problem if it failed to consider whether non‐

subject or non‐LTFV imports would have replaced LTFV subject imports during the period of

investigation without a continuing benefit to the domestic industry.  444 F.3d at 1369.  Under

those circumstances, Bratsk requires the Commission to consider whether replacement of the

LTFV subject imports might have occurred during the period of investigation, and it requires the

Commission to provide an explanation of its conclusion with respect to that factor.   

542 F.3d at 878.   60 Nucor Corp. v. United States, 414 F.3d 1331, 1336, 1341 (Fed. Cir. 2005); see also Mittal Steel,

542 F.3d at 879 (“Bratsk did not read into the antidumping statute a Procrustean formula for

determining whether a domestic injury was ‘by reason’ of subject imports.”).

61 Mittal Steel, 542 F.3d at 875‐79.

62 Mittal Steel, 542 F.3d at 873 (quoting from Gerald Metals, 132 F.3d at 722), 875‐79 & n.2

(recognizing the Commission’s alternative interpretation of Bratsk as a reminder to conduct a non‐

attribution analysis).
15

factor in the U.S. market, the Court will require the Commission to give full consideration, with

adequate explanation, to non‐attribution issues when it performs its causation analysis.63

The question of whether the material injury threshold for subject imports is satisfied

notwithstanding any injury from other factors is factual, subject to review under the substantial

evidence standard.64  Congress has delegated this factual finding to the Commission because of

the agency’s institutional expertise in resolving injury issues.65

B. Conditions of Competition and the Business Cycle66  

The following conditions of competition inform our analysis of whether there is material

injury by reason of subject imports.

1. Demand Considerations

Hardwood plywood is used in a variety of mostly indoor applications, including home

remodeling applications such as kitchen cabinets.  It is also used for RVs, manufactured homes,

new homes, and commercial buildings.67  The largest market segment for U.S. importers of

hardwood plywood, and one of the largest for U.S. producers as well, is cabinetry.  Other

segments include underlayment, retail/store fixtures, and furniture.68

                                                       63 To that end, after the Federal Circuit issued its decision in Bratsk, the Commission began to

present published information or send out information requests in final phase investigations to

producers in nonsubject countries that accounted for substantial shares of U.S. imports of subject

merchandise (if, in fact, there were large nonsubject import suppliers).  In order to provide a more

complete record for the Commission’s causation analysis, these requests typically seek information on

capacity, production, and shipments of the product under investigation in the major source countries

that export to the United States.  The Commission plans to continue utilizing published or requested

information in final phase investigations in which there are substantial levels of nonsubject imports.

64 We provide in our respective discussions of volume, price effects, and impact a full analysis of

other factors alleged to have caused any material injury experienced by the domestic industry.

65 Mittal Steel, 542 F.3d at 873; Nippon Steel Corp., 458 F.3d at 1350, citing U.S. Steel Group, 96

F.3d at 1357; S. Rep. 96‐249 at 75 (“The determination of the ITC with respect to causation is ... complex

and difficult, and is a matter for the judgment of the ITC.”).    66 Hardwood plywood imports from subject producers in China accounted for 56.2 percent of

total hardwood plywood imports between September 2011 and August 2012.  See CR at IV‐3, PR at IV‐2 ‐ 

IV‐3 .  Thus, imports from China accounted for more than three percent of the volume of hardwood

plywood imported into the United States from all sources in the most recent 12‐month period for which

data are available preceding the filing of the petition and are therefore not negligible under 19 U.S.C.  

§ 1677(24).

67 CR/PR at II‐1.

68 CR/PR at Figure II‐1.  According to U.S. producers, the main segments for their product are

retail fixtures (35 percent of shipments), cabinetry (30 percent), architectural work (13 percent), and

furniture (10 percent).  For importers, the main segments were cabinets (34 percent), underlayment

(18 percent), general use (17 percent), furniture (12 percent), and RV/mobile home (12 percent).  Id.
16

  A little more than half of responding U.S. producers and importers, and just over

40 percent of responding purchasers, indicated that the market for hardwood plywood was

subject to business cycles or distinctive conditions of competition, including seasonal demand

that varied somewhat by region and by end use product.  Several producers noted seasonal

trends such as high demand from January to June or July and slower demand during the rest of

the year.69

Market participants’ perception of recent demand trends varied, with most U.S.

producers reporting a decrease in U.S. demand since 2010, most importers reporting that

demand increased or fluctuated, and most purchasers indicating that demand increased.  Firms

reporting an increase cited an improving construction and housing market and a slight upturn in

the economy, while firms reporting decreased demand cited weak demand in construction and

housing as well as low consumer confidence.70  Market participants generally reported that

demand improved in 2013.71  Available data indicate that remodeling activity in the United

States has generally increased since the first quarter of 2011, albeit at varying rates,72 and that  

U.S. shipments of manufactured homes and RVs increased from 2010 to 2012.73

Apparent U.S. consumption was 3.3 billion square feet in 2010 and 2011 and 3.5 billion

square feet in 2012.  It was 1.7 billion square feet in interim 2012 and 1.6 billion square feet in

interim 2013.74

2. Supply Considerations

The domestic industry’s share of apparent U.S. consumption rose during the period of

investigation.  It increased from 17.2 percent in 2010 to 17.8 percent in 2011 and 18.4 percent

in 2012; it was 19.1 percent in interim 2012 and 22.7 percent in interim 2013.75  Four domestic

firms accounted for almost 80 percent of 2012 U.S. production of hardwood plywood.76

During the period, subject imports supplied a larger portion of the U.S. market than

either the domestic industry or nonsubject sources.  Subject import market share was

41.9 percent in 2010, 45.8 percent in 2011, and 47.9 percent in 2012; it was 44.2 percent in

interim 2012 and 33.2 percent in interim 2013.77

Nonsubject sources included Brazil, Chile, Canada, Indonesia, Malaysia, Romania, Russia,

Uruguay, and Vietnam.78  Nonsubject import market share was 40.8 percent in 2010,

                                                       69 CR at II‐13, PR at II‐9.

70 CR at II‐15, PR at II‐10. 71 See, e.g., Tr. at 127‐28 (Mr. Dougan), 162, 165 (Mr. Rogers).

72 CR/PR at Figure II‐2.

73 CR/PR at Table II‐3. 74 CR/PR at Table IV‐3. 75 CR/PR at Table IV‐3.

76 CR/PR at II‐1 & n.1. 77 CR/PR at Table IV‐3.

78 CR/PR at IV‐1, App. F.
17

36.4 percent in 2011, and 33.7 percent in 2012; it was 36.7 percent in interim 2012 and

44.1 percent in interim 2013.79

3. Substitutability

Generally, the basic steps in the manufacturing process are similar for both imported

and domestic hardwood plywood.  However, the record shows that Chinese manufacturers use

thinner face and back veneers that are laid up moist or wet to prevent splitting or breaking

prior to being pressed.  According to respondents, smaller logs are typically utilized to

manufacture veneer for the plywood core, and the quality of veneer is typically lower than for

the domestically produced product.  The Chinese product is typically manufactured utilizing

more labor and less automation, particularly for repairing defects, preparing veneers, and

laying up veneer sheets for pressing.80

Over one‐half of responding U.S. producers indicated that domestic hardwood plywood

and the subject imports were always interchangeable, but more than 80 percent of importers

and 60 percent of purchasers characterized them as either sometimes or never comparable.81  

More than two‐thirds of responding importers and purchasers, but less than one‐half of U.S.

producers, found that differences other than price between U.S. and Chinese hardwood

plywood were always or frequently significant.82

Importers and purchasers reported that interchangeability between various sources,

including domestic and Chinese hardwood plywood, is limited by factors that include certain

lengths and widths not being available domestically; differing characteristics such as wood

species, core construction, face and back veneer thicknesses, panel strength, tolerances for

moisture content, and glues; differing quality; and availability of product.  Some importers and

purchasers noted that Chinese product has a thinner face veneer (0.25 mm to 0.35 mm) than

domestic product (0.5 mm to 0.75 mm).  Some also reported that domestic hardwood plywood

consists of high‐quality decorative panels whereas imports are typically used for non‐decorative

uses.83

                                                       79 CR/PR at Table IV‐3.

80 CR at I‐15 – I‐16, PR at I‐12.

81 CR/PR at Table II‐11, CR at II‐27, PR at II‐17.

82 CR/PR at Table II‐13, CR at II‐31, PR at II‐21.

83 CR at II‐28 – II‐29, PR at II‐17.  One importer indicated that Chinese material is of adequate

quality for certain finishing operations, but that higher‐end cabinetry requires thicker face veneer to

achieve the required end quality or finish.  Another importer reported that hardwood plywood from the

United States, Canada, and Russia is of higher quality and is more often interchangeable than is product

from other sources and that product from China consistently lacks core quality, leading to panels that

warp and crackle when handled and mold after use, contain many holes, and delaminate easily.  CR at II‐

29, PR at II‐20.  Both parties provided testimony at the hearing regarding various quality differences.  

See, e.g., Tr. at 91‐93 (Mr. Roberts) (buys from domestic producers in order to obtain a quality product

for higher end merchandise), 180 (Mr. Simon) (Chinese plywood is covered up), 188 (Mr. Simon)

(“Chinese plywood is functional and domestic plywood is beautiful”) 188 (Mr. Simon) (quality of veneers

(Continued...)
18

Depending on the market segment in which hardwood plywood is used, various

attributes may be preferable or required.  For example, differences in thickness and veneer

quality limit substitutability for certain applications.  Typically, thicker plywood is used in

cabinet fronts and sides, while thinner plywood is used for cabinet backs, drawer bottoms,

paneling, and underlayment.  In 2012, more of U.S. producers’ commercial shipments

(58 percent) were reported to be of thicker plywood (at least 16 mm) than were U.S. importers’

commercial shipments of subject Chinese imports (21 percent) and Chinese producers’ U.S.

exports (42 percent).  U.S. producers’ shipments of thin plywood (less than 6.5 mm) accounted

for 21 percent of their total shipments in 2012, as compared to 45 percent of U.S. importers’

commercial shipments of subject imports and 33 percent of Chinese producers’  U.S. exports to

the United States.

Some purchasers indicated that hardwood plywood produced in the United States and

hardwood plywood produced in China are often used for different components of the same end

product, particularly in cabinets.  Subject imports are typically used to produce the interiors,

backs, and drawer bottoms of cabinets, while domestic product is used for cabinet fronts and

sides.  Some purchasers pointed to differences in the core material/quality and/or the thinner

veneer face of the subject product as making it more suitable for applications not requiring

sanding and finishing or for laminated applications.84  In 2012, a greater proportion of U.S.

producers’ product (68.1 percent) was reported to have softwood veneer as the core than was

Chinese producers’ product (8.3 percent).  Only 3.8 percent of U.S. producers’ product was

reported to use hardwood veneer for the core, while 88.4 percent of the Chinese producers’

product was reported to do so.85  In the same year, 94.8 percent of U.S. producers’ shipments

had face veneers 0.6 mm and above in thickness, while only 0.4 percent of U.S. importers’ and

Chinese producers’ shipments were of that thickness.  Conversely, 83.2 percent of U.S.

importers’ shipments and 91.5 percent of Chinese producers’ shipments had face veneers

below 0.4 mm in thickness, while none of the U.S. producers’ product was of that thickness.86

As the preceding discussion indicates, substitutability between the domestic like

product and subject imports is limited because of variations in various product characteristics,

resulting in reports by importers and purchasers that the domestic like product and the subject

imports are often used for different applications.  Indeed, petitioners acknowledge that subject

imports are heavily concentrated in less demanding applications in the lower end of the

market,87 and the record does not indicate that subject imports would likely enter the higher

end of the market in significant quantities in the imminent future.88  Nevertheless, there is

                                                                                                                                                                              

(...Continued)

of domestically produced product is superior to Chinese), 298 (Mr. Weaver) (U.S. producers provide

better quality UV finish than the Chinese).

84 CR/PR at App. E, CR at II‐35, PR at II‐23 – II‐24.

85 CR/PR at Table D‐1.

86 CR/PR at Table D‐3.

87 See, e.g., Petitioners’ Posthearing Brief, Responses to Commissioners’ Questions at 4; Tr. at

21, 96 (Mr. Thompson), 41 (Mr. Oglesby), 50 (Mr. Awalt), 87 (Mr. Roberts).

88 We acknowledge that petitioners offered statements that subject imports are moving into

higher grades.  See Petitioners’ Posthearing Brief, Exhs. 1 at 1, 8 at 3; Tr. at 96 (Mr. Thompson), 99 (Mr.

(Continued...)
19

some overlap between the domestic like product and the subject imports across many of these

product characteristics,89 as well as some reports from purchasers that the products are used

for the same applications.90  We find that the record indicates, overall, that the domestic like

product and the subject imports are moderately substitutable.

4. Other Conditions

Although price is an important factor in purchasing decisions, quality91 and availability

are other top factors.92  Only six of 40 responding purchasers indicated that price was the most

important factor, and seven of 40 responding purchasers indicated that availability was the

most important factor.93

Raw material costs accounted for nearly 80 percent of U.S. producers’ total cost of

goods sold (“COGS”) from 2010 to 2012.  Logging prices increased by 16 percent between

January 2010 and August 2013, while hardwood veneer prices decreased by one percent.94

U.S. producers and importers reported that increases in raw material prices were the

result of various factors, including increases in the prices of logs, MDF, imported platforms,

composite core materials, softwood veneers, veneer cores, and resin.  Firms reported that

rising demand in the United States and abroad for raw materials, including increased demand in

China for logs and curtailments in hardwood and softwood veneer availability, contributed to

increased raw material prices.  Firms also reported increased costs for labor and freight.95

Approximately half of responding purchasers require their suppliers to be certified for at

least some of their purchases.  Certification procedures vary by purchaser, including testing

samples, visiting and auditing vendors, and/or relying on industry standards such as the

California Air Resource Board (“CARB”) certification.  Most suppliers reported that completion

of certification takes two weeks to four months, although responses ranged up to one year.  

Eight purchasers reported a supplier failing in its attempt to be certified to supply hardwood

plywood since 2010.96

                                                                                                                                                                              

(...Continued)

Levin).  However, these statements are not supported by the record.  See CR/PR at Table D‐4 (Chinese

producers’ and U.S. importers’ shares of thicker grades of hardwood plywood remained relatively flat

over the period of investigation); see also, e.g., AAHP’s Posthearing Brief , Exhs. 9 (making “domestic‐

style” product in China is not cost‐effective),  11 (***).    89 See CR/PR at Tables D‐1 – D‐3.

90 See CR/PR at App. E.

91 Quality is determined by such factors as strength, thickness, flatness, glue bond, moisture

content, veneer thickness, core integrity, appearance, soundness, panel stability, smoothness,

telegraphing, grain pattern, and lack of odor, delamination, mold, voids, and warp.  CR at II‐18, II‐20, PR

at II‐12.

92 CR/PR at Table II‐6.

93 CR/PR at Table II‐6, CR at II‐20, PR at II‐12.

94 CR/PR at V‐1 & Figure V‐1.

95 CR/PR at V‐1.

96 CR/PR at II‐21 – II‐22, PR at II‐15.
20

The Lacey Act imposes certain requirements on imports.97  Six U.S. producers indicated

that they have procedures in place to comply with the Lacey Act, and the majority of purchasers

indicated that they check to ensure that suppliers are in compliance with the law and that the

required import documentation has been filed.98   

C. Volume of Subject Imports

Section 771(7)(C)(i) of the Tariff Act provides that the “Commission shall consider

whether the volume of imports of the merchandise, or any increase in that volume, either in

absolute terms or relative to production or consumption in the United States, is significant.”99

The volume of subject imports increased from 2010 to 2012, but was lower in interim

2013 than in interim 2012.  Subject import volume was 1.4 billion square feet in 2010,

1.5 billion square feet in 2011, and 1.7 billion square feet in 2012; it was 749.5 million square

feet in interim 2012 and 535.0 million square feet in interim 2013.100  The market share of

subject imports was 41.9 percent in 2012, 45.8 percent in 2011, and 47.9 percent in 2012; it

was 44.2 percent in interim 2012 and 33.2 percent in interim 2013.101

Although subject import volume increased from 2010 to 2012, it did so solely at the

expense of nonsubject imports.  Shipments of the domestic like product rose steadily

throughout the period of investigation.  They totaled 565.5 million square feet in 2010, 594.7

million square feet in 2011, and 642.2 million square feet in 2012, and were 323.8 million

square feet in interim 2012 and 366.2 million square feet in interim 2013.102  The volume of

nonsubject imports, by contrast, declined from 1.3 billion square feet in 2010 to 1.2 billion

square feet in 2011 and 2012; it was 623.4 million square feet in interim 2012 and 712.1 million

square feet in interim 2013.103  The market share of the domestic like product rose steadily

from 17.2 percent in 2010 to 17.8 percent in 2011 and 18.4 percent in 2012; it was 19.1 percent

in interim 2012 and 22.7 percent in interim 2013.  In contrast, the market share of nonsubject

imports fell from 40.8 percent in 2010 to 36.4 percent in 2011 and 33.7 percent in 2012; it was

36.7 percent in interim 2012 and 44.1 percent in interim 2013.  The 7.1 percentage points in

market share that nonsubject imports lost from 2010 to 2012 exceeded the 6.0 percentage

points in market share that subject imports gained during that period.104

                                                       97 The Lacey Act, 6 U.S.C. §§ 3371‐78, prohibits trafficking in “illegal” wildlife, fish, and plants.  

Among other things, it makes it unlawful to import certain plants and plant products – including wood

that may be used in hardwood plywood – without an import declaration, which must be filed by the

importer of record.  CR at II‐22 & n.25, PR at II‐15 & n.25; Tr. at 257 (Mr. Grimson).  Compliance with the

law can be costly.   Tr. at 259 (Mr. Dougherty); see also Tr. at 71‐75 (Mr. Howlett).

98 CR at II‐22, PR at II‐15.    99 19 U.S.C. § 1677(7)(C)(i).

100 CR/PR at Table IV‐1.

101 CR/PR at Table IV‐3.

102 CR/PR at Table IV‐2.

103 CR/PR at Table IV‐2.

104 CR/PR at Table IV‐3.
21

In view of the foregoing, we find the volume of subject imports to be significant in

absolute terms and relative to consumption in the United States.  However, for the reasons we

discuss below, we do not find significant adverse price effects or a significant adverse impact on

the domestic industry by reason of the subject imports.

D. Price Effects of the Subject Imports

Section 771(7)(C)(ii) of the Tariff Act provides that evaluating the price effects of the

subject imports, the Commission shall consider whether  

(I) there has been significant price underselling by the imported merchandise as

compared with the price of domestic like products of the United States, and

(II) the effect of imports of such merchandise otherwise depresses prices to a

significant degree or prevents price increases, which otherwise would have occurred,

to a significant degree.105   

As previously discussed, while price is an important factor in purchasing decisions,

quality and availability are also important.  Moreover, as discussed earlier, there are some non‐

price differences – particularly concerning veneer thickness and core quality – between the

domestic like product and the subject imports.

The Commission collected pricing data on six products.106  Subject imports undersold

the domestic like product in 83 of 84 price comparisons, with margins of underselling ranging

from 0.9 to 56.5 percent.107  While we find this underselling to be significant within the

meaning of the statute, as discussed below we do not find that subject imports had a significant  

adverse effect on prices for the domestic like product.

Pricing data do not show a significant correlation between subject import prices and the

domestic industry’s prices or shipment volumes.  Prices for the subject imports trended upward

throughout the period of investigation for all six of the products.108  Prices also increased for

most domestically produced products rather than moving downward toward the lower prices of

                                                       105 19 U.S.C. § 1677(7)(C)(ii).

106 The products differed in characteristics such as panel thickness, wood species, and grade.   

They did not differ in terms of veneer thickness due to the lack of overlap between subject merchandise

and the domestic like product in this factor.  See CR at V‐4 – V‐5, PR at V‐3 – V‐4.  The petitioners chose

all but one of the pricing products for which data were obtained in these investigations.  See Petition at

40 (products 1‐4); Letter from Jeffrey S. Levin to the Honorable Lisa Barton at 4 (May 1, 2013) (product

5).  Respondents’ proposal for a thin panel pricing product is reflected in the description for pricing

product 6.  See Letter from Jeffrey S. Grimson to the Honorable Lisa R. Barton at  7 (May 1, 2013).  

Pricing data accounted for seven percent of U.S. producers’ shipments of hardwood plywood and

16 percent of U.S. shipments of subject imports from January 2010 through June 2013.  CR at V‐5, PR at

V‐4.   107 CR at V‐18, PR at V‐11.

108 See CR/PR at Tables V ‐3 – V‐8.
22

subject imports.109  Domestic prices increased from January‐March 2010 to April‐June 2013 for

pricing products 1, 3, and 4 by 3.0 percent, 11.9 percent, and *** percent, respectively.110  The

price for product 2 was *** in April‐June 2013 as in January‐March 2010 (it was 1.2 percent

lower).111  For product 5, the price fluctuated, ending 4.0 percent lower in April‐June 2013

compared to January‐March 2010. 112  The price for product 6 fluctuated as well, ending

16.4 percent lower in April‐June 2013 compared to January‐March 2010.113

We note petitioners’ argument that, because of subject import competition, they had to

lower prices for lower‐grade products, while at the same time raising prices for higher‐grade

product for which there was less subject import competition.114  However, the pricing data

show that during the period of investigation the domestic industry was able to raise prices for

products 1 and 3, which are lower‐grade products that accounted for the largest volumes of

domestic product among the pricing products, despite substantial volumes of subject imports

of those products at lower prices.115  The domestic industry was also able to raise prices for

product 4, a higher‐grade product, but here, too, there was substantial subject import

volume.116  Only one of the six responding U.S. producers reported having to roll back

announced price increases.117  Thus, we do not find that the record shows that prices have

been depressed to a significant degree by subject imports.

Additionally, the underselling did not cause a shift in volume from the domestic like

product to the subject imports.  To the contrary, for most of the pricing products, quarterly

shipments of domestically produced hardwood plywood were greater in 2012 when total

subject import volume was at its peak, than in 2010.118  We also note that despite the prevalent

underselling over the period of investigation, the domestic industry did not lose market share.  

Rather, as discussed above, the domestic industry’s share of apparent U.S. consumption

                                                       109 See CR/PR at Tables V‐3 – V‐8.

110 See CR/PR at Tables V‐3, V‐5 & V‐6. 111 The price was $1.07 per square foot in January‐March 2010 and $*** per square foot in April‐

June 2013.  CR/PR at Table V‐5. 112 CR/PR at Table V‐7.

113 CR/PR at Table V‐8.    114 Domestic Producers’ Posthearing Brief, Responses to Commissioner Questions at 17‐18.  

Compare CR/PR at Table V‐6 (higher‐grade product 4) with CR/PR at Table V‐8 (lower‐grade product 6).  

Product 4 is a Grade B product.  CR/PR at Table V‐6 n.1.  See also Tr. at 42 (Mr. Oglesby) (domestic

industry has to charge more for Grade A and B products because of subject import competition in Grade

C and D products).  Despite the fact that domestic producers raised prices in product 4, the volume of

that product sold by domestic producers remained relatively constant.  This evidence contradicts

petitioners’ theory that injury was experienced by the domestic industry in the higher grades.  Tr. at

94‐95 (Mr. Thompson) (stating that because domestic producers had to raise their prices in the higher

grades “to an exorbitant amount,” that “people won’t buy it.”).

115 CR/PR at Tables V‐3  & V‐5.  While there were declines in prices in some quarters for these

products, there were also many consecutive quarters for which prices remained effectively stable

despite subject imports.

116 CR/PR at Table V‐6. 117 CR at V‐21, PR at V‐13.

118 CR/PR at Tables V‐3, V‐4, V‐5, V‐7 & V‐8.
23

increased steadily throughout the period of investigation while lower‐priced subject imports

also gained market share.119  To the extent that subject imports gained market share, they did

so at the expense of nonsubject imports and without depressing domestic prices.120

We also do not find that subject imports have prevented price increases to a significant

degree.  The domestic industry’s COGS/net sales ratio was generally flat throughout most of the

period of investigation, but improved in interim 2013 as compared to interim 2012.  It was

90.1 percent in 2010, 90.6 percent in 2011 and 90.7 percent in 2012.  It was 90.6 percent in

interim 2012 and 88.8 percent in interim 2013.121  Thus, domestic producers were able to raise

prices consistent with rising production costs.

In view of the foregoing, we find no significant price depression or suppression.  While

there are confirmed lost sales in the amount of $***,122 this factor does not outweigh other

data in the record showing the lack of significant price effects.  Accordingly, we do not find

significant adverse price effects by reason of the subject imports.123

F. Impact of the Subject Imports124

Section 771(7)(C)(iii) of the Tariff Act provides that examining the impact of subject

imports, the Commission “shall evaluate all relevant economic factors which have a bearing on

the state of the industry.”125  These factors include output, sales, inventories, capacity

utilization, market share, employment, wages, productivity, profits, cash flow, return on

investment, ability to raise capital, research and development, and factors affecting domestic

prices.  No single factor is dispositive and all relevant factors are considered “within the context

of the business cycle and conditions of competition that are distinctive to the affected

industry.”

                                                       119 CR/PR at Table IV‐3.

120 CR/PR at Table IV‐3.   121 CR/PR at Table VI‐2. 122 CR/PR at Table V‐11.  Petitioners’ allegations of lost sales totaled $44.6 million.  CR at V‐21,

PR at V‐13.  No firm alleged lost revenues.  Id.    123 We note that the lack of price effects, despite significant subject import volume and

underselling, may be due in some degree to differences in product characteristics between domestic

product and subject imports, as discussed earlier.  Regardless of whether competition is attenuated,

however, the lack of evidence of adverse price effects speaks for itself.

124 The statute instructs the Commission to consider the “magnitude of the dumping margin” in

an antidumping proceeding as part of its consideration of the impact of imports.  19 U.S.C.                        

§ 1677(7)(C)(iii)(V).  In its final determination of sales at less value, Commerce found antidumping duty

margins ranging from 55.76 percent to 121.65 percent for imports of hardwood plywood from China.  

78 Fed. Reg. 58273, 58276 (Sept. 23, 2013).

125 19 U.S.C. § 1677(7)(C)(iii); see also SAA at 851 and 885 (“In material injury determinations,

the Commission considers, in addition to imports, other factors that may be contributing to overall

injury.  While these factors, in some cases, may account for the injury to the domestic industry, they also

may demonstrate that an industry is facing difficulties from a variety of sources and is vulnerable to

dumped or subsidized imports.”).
24

Most of the industry’s trade and employment indicators improved during the period of

investigation, including in interim 2013 as the industry continued to recover from the recession.  

The domestic industry’s U.S. shipments increased steadily from 2010 to 2012 and were higher

in interim 2013 than in interim 2012.126  Domestic producers’ production increased steadily

throughout the period as well,127 as did capacity utilization.128  Capacity was steady between

2010 and 2012, although it was slightly lower in interim 2013 than in interim 2012.129

The number of production and related workers rose steadily from 2010 to 2012, and

there were more workers in interim 2013 than in interim 2012.130  Hours worked followed the

same trend,131 as did wages paid,132 and productivity improved.133

The domestic industry’s financial indicators were somewhat less positive.  In particular,

operating income declined in 2011 and 2012 (but increased between interim periods),134

although net income increased.135  The operating income margin declined from 2010 to 2012,

                                                       126 U.S. shipments rose from 565.5 million square feet in 2010 to 594.7 million square feet in

2011 and 642.2 million square feet in 2012.  They were 323.8 million square feet in interim 2012 and

366.2 million square feet in interim 2013.  CR/PR at Table III‐3.

127 Production increased from 587.7 million square feet in 2010 to 619.8 million square feet in

2011 and 669.3 million square feet in 2012.  It was 338.1  million square feet in interim 2012 and 383.3

million square feet in interim 2013.  CR/PR at Table III‐2.

128 Capacity utilization climbed from 44.3 percent in 2010 to 46.7 percent in 2011 and 51.1

percent in 2012.  It was 51.4 percent in interim 2012 and 59.4 percent in interim 2013.  CR/PR at Table

III‐2.

129 Capacity totaled 1.3 billion square feet from 2010 to 2012.  It was 658.4 million square feet in

interim 2012 and 645.5 million square feet in interim 2013.  CR/PR at Table III‐2.

We note that the industry’s inventories rose over the period of investigation.  Inventories

increased from 34.5 million square feet in 2010 to 35.5 million square feet in 2011 and 37.4 million

square feet in 2012.  They were 39.2 million square feet in interim 2012 and 41.0 million square feet in

interim 2013.  CR/PR at Table III‐4.

130 The number of production and related workers increased from 1,753 in 2010 to 1,799 in 2011

and 1,868 in 2012.  It was 1,829 in interim 2012 and 1,944 in interim 2013.  CR/PR at Table III‐6.

131 Hours worked climbed from 3.8 million hours in 2010 to 3.9 million hours in 2011 and

4.1 hours in 2012.  They totaled 2.1 million hours in interim 2012 and 2.2 million hours in interim 2013.  

CR/PR at Table III‐6.

132 Wages paid rose from $65.1 million in 2010 to $66.2 million in 2011 and $72.2 million in

2012.  They totaled $35.6 million in interim 2012 and $39.0 million in interim 2013.  CR/PR at Table III‐6.

133 Productivity increased from 156.0 square feet per hour in 2010 to 157.4 square feet per hour

in 2011, then to 163.2 square feet per hour in 2012.  It was 162.1 square feet per hour in interim 2012

and 174.1 square feet per hour in interim 2013.  CR/PR at Table III‐6.

134 Operating income declined from $12.5 million in 2010 to $10.4 million in 2011 and increased

to $11.0 million in 2012.  It was $8.2 million in interim 2012 and $19.8 million in interim 2013.  CR/PR at

Table VI‐1.

135 Net income rose from $5.4 million in 2010 to $8.3 million in 2011 and fell to $6.9 million in

2012.  It totaled $5.7 million in interim 2012 and $17.6 million in interim 2013.  CR/PR at Table VI‐1.
25

but was higher in interim 2013 than in interim 2012.136  Capital expenditures increased steadily

over the period,137 while research and development expenses declined.138

Thus, despite a significant volume of subject imports and significant underselling, most

of the industry’s trade and employment indicators improved over the period of investigation.  

The industry’s operating margin was low throughout the period and declined only slightly from

2010 to 2012.  Therefore, we do not find that the record shows a significant negative

correlation between subject imports and the industry’s condition, much less a causal

relationship.

We note that some indicators improved in interim 2013 after the petitions were filed.  

However, the domestic industry’s market share, trade and employment indicators, and prices

were improving before the petitions were filed and before preliminary duties were imposed.  In

addition, most market participants reported improving market conditions in 2013, which

explains at least some of the industry’s recent improvement.  Thus, while the petitions may

have had some beneficial effect on the industry, we do not find that the pendency of these

investigations fully explains the improvement in the industry’s condition in interim 2013 or

supports a conclusion that subject imports were having an injurious impact on the domestic

industry prior to the filing of the petition.

Consequently, we find that the subject imports have not had a significant impact on the

domestic industry.

V. Threat of Material Injury by Reason of Subject Imports

A. Legal Standard

Section 771(7)(F) of the Tariff Act directs the Commission to determine whether the

domestic industry is threatened with material injury by reason of the subject imports by

analyzing whether “further dumped or subsidized imports are imminent and whether material

injury by reason of imports would occur unless an order is issued or a suspension agreement is

accepted.”139  The Commission may not make such a determination “on the basis of mere

conjecture or supposition,” and considers the threat factors “as a whole” in making its

determination whether dumped or subsidized imports are imminent and whether material

injury by reason of subject imports would occur unless an order is issued.140  In making our

                                                        136 The operating income margin was 2.1 percent in 2010 and 1.6 percent in 2011 and 2012.  It

was 2.3 percent in interim 2012 and 4.8 percent in interim 2013.  CR/PR at Table VI‐1.

137 Capital expenditures increased from $4.1 million in 2010 to $7.3 million in 2011 and

$7.4 million in 2012.  They totaled $2.7 million in interim 2012 and $8.8 million in interim 2013.  CR/PR

at Table VI‐4.

138 Research and development expenses fell from $*** in 2010 to $*** in 2011 and 2012.  They

totaled $*** in interim 2012 and $*** in interim 2013.  CR/PR at Table VI‐4.   139 19 U.S.C. § 1677(7)(F)(ii).

140 19 U.S.C. § 1677(7)(F)(ii).
26

determination, we consider all statutory threat factors that are relevant to these

investigations.141

B. Analysis142

As discussed above, the domestic industry’s performance generally improved during the

period of investigation, including when comparing interim periods.  During the period, the

domestic industry was able to increase its market share in a growing U.S. market and to

increase prices overall for its hardwood plywood products, and its operating income ratio

                                                       141 These factors are as follows:

(I) if a countervailable subsidy is involved, such information as may be presented to it by the

administering authority as to the nature of the subsidy (particularly as to whether the countervailable

subsidy is a subsidy described in Article 3 or 6.1 of the Subsidies Agreement) and whether imports of the

subject merchandise are likely to increase,

(II) any existing unused production capacity or imminent, substantial increase in production

capacity in the exporting country indicating the likelihood of substantially increased imports of the

subject merchandise into the United States, taking into account the availability of other export markets

to absorb any additional exports,

(III) a significant rate of increase of the volume or market penetration of imports of the subject

merchandise indicating the likelihood of substantially increased imports,

(IV) whether imports of the subject merchandise are entering at prices that are likely to have a

significant depressing or suppressing effect on domestic prices and are likely to increase demand for

further imports,

(V) inventories of the subject merchandise,

(VI) the potential for product‐shifting if production facilities in the foreign country, which can be

used to produce the subject merchandise, are currently being used to produce other products,

...

(VIII) the actual and potential negative effects on the existing development and production

efforts of the domestic industry, including efforts to develop a derivative or more advanced version of

the domestic like product, and

(IX) any other demonstrable adverse trends that indicate the probability that there is likely to be

material injury by reason of imports (or sale for importation) of the subject merchandise (whether or

not it is actually being imported at the time).   

19 U.S.C. § 1677(7)(F)(i).  To organize our analysis, we discuss the applicable statutory threat

factors using the same volume/price/impact framework that applies to our material injury analysis.  

Statutory threat factors (I), (II), (III), (V), and (VI) are discussed in the analysis of subject import volume.  

Statutory threat factor (IV) is discussed in the analysis of subject import price effects.  Statutory factors

(VIII) and (IX) are discussed in the analysis of impact.  Statutory factor (VII) concerning agricultural

products is inapplicable to this investigation.   142 In its final affirmative countervailing duty determination on hardwood plywood from China,

Commerce found one subsidy program to be countervailable.  Issues and Decision Memorandum for the

Final Affirmative Determination in the Countervailing Duty Investigation of Hardwood and Decorative

Plywood from the People’s Republic of China, Final Affirmative Countervailing Duty Determination (Sept.

16, 2013).  The program determined to be countervailable is the provision of electricity to Chinese

producers for less than adequate remuneration.
27

reached a period high in interim 2013.  We also have found that the subject imports did not

have a significant impact on the domestic industry during the period of investigation.

We find that the increase in subject import volume and market share during the period

of investigation does not indicate a likelihood that any increase in subject import volume in the

imminent future would result in declines in the domestic industry’s output or market share.  As

described above, we have found that the increased volume of subject imports did not have

significant adverse effects on the domestic industry during the period of investigation, during

which the industry’s market share and U.S. shipments also increased.  Increases in subject

imports resulted in declines in the volume of nonsubject imports, rather than of domestic

product.  There is no evidence in the record that these trends will change in the imminent

future.

In fact, U.S. demand is expected to continue to increase in the near future.143  The

domestic industry has increased its production144 and market share145 as apparent U.S.

consumption has grown.146  We find no evidence in the record that this trend will not continue

in the imminent future.   

We also find that excess capacity in China does not indicate the likelihood of

substantially increased imports of the subject merchandise.147  First, subject Chinese producers’

capacity increased only 5.3 percent between 2010 and 2012.148  Responding subject foreign

producers reported excess capacity of 243.4 million square feet in 2012,149 which represents

8 percent of total apparent U.S. consumption in that year.150  Subject Chinese hardwood

plywood shipments to the home market steadily increased over the period.151  Exports to other

markets increased over the period as well.152  The ratio of subject Chinese exports to the United

                                                       143 AAHP’s Posthearing Brief, Exh. 5 at 3‐4; Tr. at 124‐26 (Mr. Howlett), 270‐72 (Mr. Weaver). 144 CR/PR at Table III‐2.

145 CR/PR at Table IV‐3.

146 CR/PR at Table IV‐3. 147 Petitioners argue that the reported data regarding Chinese hardwood producers reflect only

a fraction of the entire hardwood plywood industry in China.  They submit that the production capacity

of, and production and shipments by, the Chinese producers are significantly greater than the reported

data indicate.  Petitioners’ Prehearing Brief at 53‐54.  However, the data obtained from the Chinese

foreign producers accounted for approximately 52.4 percent of U.S. imports of hardwood plywood from

China in 2012, and constitute the facts available on the record.  CR at VII‐3, PR at VII‐3.

148 CR/PR at Table VII‐1.

149 CR/PR at Table VII‐1.  Subject Chinese capacity utilization was 83.1 percent in 2010, 86.9

percent in 2011 and 87.9 percent in 2012.  It was 70.5 percent in interim 2012 and 80.2 percent in

interim 2013.  Subject Chinese capacity utilization is projected to be at 85.7 percent in 2013 and

increase to 88.9 percent in 2014.  Id. 150 Compare CR/PR at Table VII‐1 with CR/PR at Table IV‐3.

151 Home market shipments were 657.8 million square feet in 2010, 728.4 million square feet in

2011, 749.0 million square feet in 2012, 367.5 million square feet in interim 2012, and 403.7 million

square feet in interim 2013.  They are projected to be 823.7 million square feet in 2013 and 847.8

million square feet in 2014.  CR/PR at Table VII‐1.

152 Exports to other markets were 454.8 million square feet in 2010, 540.1 million square feet in

2011, 528.0 million square feet in 2012, 242.2 million square feet in interim 2012, and 270.9 million

(Continued...)
28

States as a share of Chinese producers’ total shipments increased from 35.2 percent in 2010 to

40.0 percent in 2012, but was lower in interim 2013 than in interim 2012.153  In view of Chinese

producers’ increased shipments to the home market154 and exports to other countries,155 we

find that significantly increased imports of the subject merchandise into the United States are

not imminently likely.  Further, even if subject exports from China do increase somewhat, we

do not find that any such increase would likely threaten material injury to the domestic industry

given the lack of a causal nexus between the significant volume of subject imports and any

injury to the domestic industry over the period of investigation.

We recognize that that there are outstanding antidumping duty orders or investigations

on hardwood plywood from China in other countries.156  Even if these orders have some

disciplining effect on the volume and prices of subject Chinese exports to certain markets in the

imminent future, the record does not indicate that they will significantly restrict China’s exports

generally and they will not deter the growth of home market shipments.

We recognize that U.S. importers’ end‐of‐period inventories increased between 2010

and 2012, rising nearly 45 percent from 2010 to 2012.  They were significantly lower in interim

2013 than in interim 2012, however.157  While 30 U.S. importers reported that they had placed

                                                                                                                                                                              

(...Continued)

square feet in interim 2013.  They are projected to be 568.9 million square feet in 2013 and 579.1

million square feet in 2014.  CR/PR at Table VII‐1.

153 Exports to the United States as a share of total shipments were 35.2 percent in 2010,

35.7 percent in 2011, 40.0 percent in 2012, 38.8 percent in interim 2012, and 28.3 percent in interim

2013.  They are projected to be 29.8 percent in 2013 and 31.1 percent in 2014.  CR/PR at Table VII‐1.

154 Home market shipments as a share of total shipments were 37.1 percent in 2010, 35.8

percent in 2011, 34.2 percent in 2012, 35.7 percent in interim 2012 and 41.5 percent in interim 2013.  

They are projected to be 40.3 percent in 2013 and 39.7 percent in 2014.  CR/PR at Table VII‐1.

155 Exports to other markets as a share of total shipments were 25.7 percent in 2010, 26.6

percent in 2011, 24.1 percent in 2012, 23.5 percent in interim 2012 and 27.9 percent in interim 2013.  

They are projected to be 27.8 percent in 2013 and 27.1 percent in 2014.  CR/PR at Table VII‐1.

156 In 2011, the European Union (“EU”) imposed a definitive antidumping duty on imports of

okumé plywood from China.  Antidumping duties have also been imposed by Turkey and Israel on

certain imports from China of plywood products.  In 2013, South Korea reportedly imposed preliminary

antidumping duties on plywood imports from China, and Argentina and Colombia initiated investigations

on imports of Chinese plywood.  CR at VII‐6 – VII‐7, PR at VII‐5 – VII‐6.  The Chinese Producers’

Association contends that the antidumping duty orders on Chinese plywood in the EU, Turkey and Israel

do not serve as a significant barrier to Chinese exports, because Turkey and Israel are insignificant

markets and the order in the EU covers only one specific type of plywood, which is an insignificant

percentage of total Chinese production.  Chinese Producers’ Association’s Prehearing Brief at 26;

Chinese Producers’ Association’s Posthearing Brief, Commissioner Questions at 15.

157 U.S. importers’ inventories were 248.3 million square feet in 2010, 231.4 million square feet

in 2011, and 360.7 million square feet in 2012.  They were 250.8 million square feet in interim 2012 and

218.4 million square feet in interim 2013.  CR/PR at Table VII‐2.  Subject Chinese producers’ inventories

as a percentage of their total shipments declined throughout the period and are projected to decline

further in 2013 and 2014.  They were 6.5 percent in 2010, 6.1 percent in 2011, 5.0 percent in 2012,

(Continued...)
29

orders for subject hardwood plywood from China scheduled for entry into the United States

after June 30, 2013, the total quantity could not be ascertained.158  However, the domestic

industry’s market share and condition improved over the period of investigation, despite

increasing inventories of low‐priced subject imports.  Moreover, subject import inventories

have recently fallen, and demand is expected to increase.  Thus, we do not find that these

inventories will cause significant price effects or an adverse impact on the domestic industry in

the imminent future.159  

   In addition, there is no indication in the record that the subject imports, which are

heavily concentrated in the lower end of the U.S. market,160 will enter the higher end of the

market, in which the domestic industry’s sales are focused, in significant quantities in the

imminent future or at prices that are likely to depress or suppress domestic prices.  As we

explained above, petitioners’ allegations that subject imports are moving into higher‐grade

hardwood plywood are not borne out by the record, given importer and purchaser statements

to the contrary and data showing that subject Chinese producers’ and U.S. importers’ shares of

thicker grade product remained relatively flat over the period of investigation.

We also find that imports of subject merchandise are not entering at prices that are

likely to have a significant depressing or suppressing effect on domestic prices.  As detailed

above, we have found that, during the period of investigation, subject imports neither

depressed nor suppressed domestic like product prices to a significant degree, notwithstanding

significant underselling.  In view of improving U.S. market conditions and increased demand,

even if subject imports continue to increase, it is likely that the absence of significant adverse

price effects observed during the period of investigation will continue in the imminent

future.161   

As we discussed above, most indicators of the condition of the domestic industry

improved during the period of investigation.  Moreover, we found no significant causal

relationship between the subject imports and the domestic industry’s performance during the

period of investigation.  Nothing in the record of these investigations gives us reason to believe

that subject imports will cause the condition of the domestic industry to deteriorate to a

significant degree in the imminent future.   

                                                                                                                                                                              

(...Continued)

6.4 percent in interim 2012 and 5.6 percent in interim 2013.  They are projected to be 5.0 percent in

2013 and 4.0 percent in 2014.  CR/PR at Table VII‐2.

158 CR at VII‐6, PR at VII‐5.  The quantities of these orders were reported in a variety of different

ways (i.e., containers of different sizes, square feet, cubic feet, cubic meters, square meters, and a

number reported by value only).  Thus, an exact total quantity could not be established.  Id. 159 While other types of panel products are available, we note that product shifting is not an

issue in these investigations.  See CR at II‐15, PR at II‐10.  No parties made any arguments that

production could be switched from other products to hardwood plywood.

160 See, e.g., Petitioners’ Posthearing Brief, Responses to Commissioners’ Questions at 4; Tr. at

50 (Mr. Awalt), 87 (Mr. Roberts), 178‐80, 244‐45 (Mr. Simon), 245‐46 (Mr. Wilkinson), 247‐48 (Mr.

Weaver).

161 Moreover, price data on the record show continued increases through April‐June 2013, with

no indication of imminent reduced levels.  See CR/PR at Tables V‐3 – V‐7.  
30

We further find that subject imports have had no significant actual or potential negative

effects on the existing development and production efforts of the domestic industry, including

efforts to develop a derivative or more advanced version of the domestic like product.  In fact,

the industry’s capital expenditures increased steadily and significantly over the period of

investigation.162  They increased 80.1 percent between 2010 to 2012 and were 228.6 percent

higher in interim 2013 than in interim 2012.163

In view of the foregoing, we conclude that an industry in the United States is not

threatened with material injury by reason of subject imports.

VI. Conclusion

For the reasons stated above, we determine that an industry in the United States is not

materially injured or threatened with material injury by reason of subject imports of hardwood

plywood from China that is subsidized and sold in the United States at less than fair value.

                                                        162 CR/PR at Table VI‐4.

163 CR/PR at Table C‐1.
I‐1

PART I: INTRODUCTION

BACKGROUND

These investigations result from a petition filed with the U.S. Department of Commerce

(“Commerce”) and the U.S. International Trade Commission (“USITC” or “Commission”) by

Columbia Forest Products (Columbia), Greensboro, NC; Commonwealth Plywood Co., Ltd.

(Commonwealth), Whitehall, NY; Murphy Plywood (Murphy), Eugene, OR; Roseburg Forest

Products Co. (Roseburg), Roseburg, OR; States Industries LLC (States), Eugene, OR; and Timber

Products Company (Timber Products), Springfield, OR, combined as The Coalition for Fair Trade

of Hardwood Plywood (“CFTHP”) on September 27, 2012, alleging that an industry in the United

States is materially injured and threatened with material injury by reason of subsidized and

less‐than‐fair‐value (“LTFV”) imports of hardwood plywood 1 from China. The tabulation on the

following page provides information relating to the background of these investigations.23  

Effective date Action 

September 27, 2012 Petition filed with Commerce and the Commission; 

institution of the Commission's investigation 

October 24, 2012 Commerce’s notice of initiation of countervailing duty 

investigation 

October 25, 2012 Commerce’s notice of initiation of antidumping 

investigation 

November 13, 2012 Commission’s preliminary determination 

March 14, 2013 Commerce’s preliminary countervailing duty 

determination (78 FR 16250, March 14, 2013) 

May 3, 2013 Commerce’s preliminary antidumping determination 

(78 FR 2594, May 3, 2013) 

June 11, 2013 Scheduling of final phase of Commission investigation 

(78 FR 36791, June 19, 2013) 

September 23, 2013 Commerce’s final determination of antidumping 

(78 FR 58273) 

September 23, 2013 Commerce’s final determination of countervailing duty 

(78 FR 58283) 

September 19, 2013 Commission’s hearing 

November 5, 2013 Commission’s vote 

November 25, 2013 Commission’s determinations and views transmitted to 

Commerce 

                                                      

1 See the section entitled “The Subject Merchandise” in Part I of this report for a complete

description of the merchandise subject to this/these investigation(s). 2 Pertinent Federal Register notices are referenced in app. A, and may be found at the Commission’s

website (www.usitc.gov).

3 App. B presents a list of hearing witnesses.
I‐2

STATUTORY CRITERIA AND ORGANIZATION OF THE REPORT

Statutory criteria

Section 771(7)(B) of the Tariff Act of 1930 (the “Act”) (19 U.S.C. § 1677(7)(B)) provides

that in making its determinations of injury to an industry in the United States, the Commission‐‐ 

shall consider (I) the volume of imports of the subject merchandise, (II) the

effect of imports of that merchandise on prices in the United States for

domestic like products, and (III) the impact of imports of such

merchandise on domestic producers of domestic like products, but only in

the context of production operations within the United States; and. . .

may consider such other economic factors as are relevant to the

determination regarding whether there is material injury by reason of

imports.

Section 771(7)(C) of the Act (19 U.S.C. § 1677(7)(C)) further provides that‐‐ 

In evaluating the volume of imports of merchandise, the Commission shall

consider whether the volume of imports of the merchandise, or any

increase in that volume, either in absolute terms or relative to production

or consumption in the United States is significant.

. . .

In evaluating the effect of imports of such merchandise on prices, the

Commission shall consider whether. . .(I) there has been significant price

underselling by the imported merchandise as compared with the price of

domestic like products of the United States, and (II) the effect of imports

of such merchandise otherwise depresses prices to a significant degree or

prevents price increases, which otherwise would have occurred, to a

significant degree.

. . .

In examining the impact required to be considered under subparagraph

(B)(i)(III), the Commission shall evaluate (within the context of the

business cycle and conditions of competition that are distinctive to the

affected industry) all relevant economic factors which have a bearing on

the state of the industry in the United States, including, but not limited to

. . . (I) actual and potential decline in output, sales, market share, profits,

productivity, return on investments, and utilization of capacity, (II) factors

affecting domestic prices, (III) actual and potential negative effects on

cash flow, inventories, employment, wages, growth, ability to raise

capital, and investment, (IV) actual and potential negative effects on the

existing development and production efforts of the domestic industry,

including efforts to develop a derivative or more advanced version of the

domestic like product, and (V) in {an antidumping investigation}, the

magnitude of the margin of dumping.
I‐3

Organization of report

Part I of this report presents information on the subject merchandise, subsidy and

dumping margins, and domestic like product. Part II of this report presents information on

conditions of competition and other relevant economic factors. Part III presents information on

the condition of the U.S. industry, including data on capacity, production, shipments,

inventories, and employment. Parts IV and V present the volume of subject imports and pricing

of domestic and imported products, respectively. Part VI presents information on the financial

experience of U.S. producers. Part VII presents the statutory requirements and information

obtained for use in the Commission’s consideration of the question of threat of material injury

as well as information regarding nonsubject countries.

MARKET SUMMARY

Hardwood plywood is generally used in the manufacturing of furniture, cabinetry, wall

paneling, and similar products.  The leading U.S. producers of hardwood plywood are ***.  

Member companies of the China National Forest Products Industry Association (CNFPIA)

accounted for the majority of total reported Chinese production.  The leading U.S. importers of

hardwood plywood from China are ***.

Apparent U.S. consumption of hardwood plywood totaled approximately 3.5 billion

square feet ($2.2 billion) in 2012.  Currently, 10 firms are known to produce hardwood plywood

in the United States.  U.S. producers’ U.S. shipments of hardwood plywood totaled

642.2 million square feet ($719.6 million) in 2012, and accounted for 18.4 percent of apparent

U.S. consumption by quantity and 32.3 percent by value.  U.S. imports from subject sources

totaled 1.7 billion square feet ($829.0 million) in 2012 and accounted for 47.9 percent of

apparent U.S. consumption by quantity and 37.2 percent by value.  U.S. imports from

nonsubject sources totaled 1.2 billion square feet ($677.2 million) in 2012 and accounted for

33.7 percent of apparent U.S. consumption by quantity and 30.4 percent by value.
I‐4

SUMMARY DATA AND DATA SOURCES

A summary of data collected in these investigations is presented in appendix C, tables

C‐1 (using imports compiled from official Commerce statistics), C‐2 (using imports from data

submitted in response to Commission questionnaires), and C‐3 (summary data concerning the

U.S. market with *** included).4

  Except as noted, U.S. industry data are based on

questionnaire responses of nine firms that accounted for the majority of U.S. production of

hardwood plywood during 2012.  U.S. imports are based on official Commerce statistics.

PREVIOUS AND RELATED INVESTIGATIONS

Hardwood plywood was subject to a Section 332 investigation in 2007‐08, Wood

Flooring and Hardwood Plywood:  Competitive Conditions Affecting the U.S. Industries, Inv. 332‐

487, USITC Pub. 4032 (August 2008), and has not been the subject of prior countervailing or

antidumping duty investigations in the United States.

NATURE AND EXTENT OF SUBSIDIES AND SALES AT LTFV

Subsidies

On September 23, 2013, Commerce published a notice in the Federal Register of its final

determination of countervailable subsidies for producers and exporters of hardwood plywood

from China.5 Table I‐1 presents Commerce’s findings of subsidization of hardwood plywood in

China.  Fifteen companies (listed in the following table at 27.16 percent) are non‐cooperative

companies to which an adverse facts available rate were applied.

                                                      

4 ***. The Commission excluded *** as a related party, but excluded no other U.S. producer as

related party. Hardwood Plywood from China, Inv. Nos. 701‐TA‐490 and 731‐TA‐1204 (Preliminary),

USITC Publication 4361, November 2012, p. 9. 5 Hardwood and Decorative Plywood from the People’s Republic of China:  Final Affirmative

Countervailing Duty Determination;, 78 FR 58283, September 23, 2013.
I‐5

Table I-1 

Hardwood plywood: Commerce’s final subsidy determination with respect to imports from China 

Entity 

Preliminary countervailable 

subsidy margin (percent) 

Linyi City Dongfang Jinxin Economic & Trade Co.,Ltd. de minimis

Linyi San Fortune Wood Co., Ltd. de minimis

Shanghai Senda Fancywood Inc. a/k/a Shanghai Senda Fancywood 

Industry Co. de minimis

Asia Dekor (Heyuan) Woods Co., Ltd. 27.16

Baishan Huafeng Wooden Product Co. 27.16 

China Friend Limited 27.16 

Feixian Guangyuan Plywood Factory 27.16 

Feixian Xinfeng Wood Co., Ltd. 27.16 

Huzhou Chen Hang Wood Co. Ltd. 27.16 

Jiafeng Wood (Suzhou) Co., Ltd. 27.16 

Linyi Guoxin Wood Co., Ltd. 27.16 

Linyi Huayuan Wood Co., Ltd. 27.16 

Linyi Sengong Wood Co., Ltd. 27.16 

Lizhong Wood Industry Limited Co. 27.16 

Shandong Lichen Group Co., Ltd. 27.16 

Wellmade Floor Industries Co. Ltd. 27.16 

Zhejiang Dadongwu GreenHome Wood Co. 27.16 

Zhejiang Desheng Wood Industry Co., Ltd. 27.16 

All others 13.58

Source: 78 FR 58283, September 23, 2013. 

Sales at LTFV

On September 23, 2013, Commerce published a notice in the Federal Register of its final

determination of sales at LTFV with respect to imports from China. 6

  Tables I‐2 present

Commerce’s dumping margins with respect to imports of product from China.

                                                      

6 Hardwood and Decorative Plywood From the People’s Republic of China:  Final Determination of

Sales at Less Than Fair Value, 78 FR 58273, September 23,  2013.
I‐6

Table I-2 

Hardwood plywood: Commerce’s final weighted-average LTFV margins with respect to imports 

from China 

Exporter Producer 

 Preliminary dumping margin 

(percent) 

Linyi San Fortune Wood Co., Ltd Linyi San Fortune Wood Co., Ltd 55.76

Jiangyang Group (consists of 

Xuzhou Jiangyang Wood 

Industries Co., Ltd. and Xuzhou 

Jiangheng Wood Products Co., 

Ltd.) Jiangyang Group 62.55

100 exporters 371 producers 59.46

PRC-Wide Entity 121.65

Source: 78 FR 58273, September 23, 2013. 

THE SUBJECT MERCHANDISE

Commerce’s scope

Commerce has defined the scope of this investigation as follows:

The merchandise subject to this investigation is hardwood and decorative

plywood. Hardwood and decorative plywood is a flat panel composed of

an assembly of two or more layers or plies of wood veneers in

combination with a core. The veneers, along with the core, are glued or

otherwise bonded together to form a finished product. A hardwood and

decorative plywood panel must have face and back veneers which are

composed of one or more species of hardwoods, softwoods, or bamboo.

Hardwood and decorative plywood may include products that meet the

American National Standard for Hardwood and Decorative Plywood,

ANSI/HPVA HP–1–2009.

All hardwood and decorative plywood is included within the scope of this

investigation, without regard to dimension (overall thickness, thickness of

face veneer, thickness of back veneer, thickness of core, thickness of inner

veneers, width, or length). However, the most common panel sizes of

hardwood and decorative plywood are 1219 x 1829 mm (48 x 72 inches),

1219 x 2438 mm (48 x 96 inches), and 1219 x 3048 mm (48 x 120 inches).  

A ‘‘veneer’’ is a thin slice of wood which is rotary cut, sliced or sawed from

a log, bolt or flitch. The face veneer is the exposed veneer of a hardwood

and decorative plywood product which is of a superior grade than that of

the back veneer, which is the other exposed veneer of the product (i.e., as  

opposed to the inner veneers). When the two exposed veneers are of

equal grade, either one can be considered the face or back veneer. For

products that are entirely composed of veneer, such as Veneer Core
I‐7

Platforms, the exposed veneers are to be considered the face and back

veneers, in accordance with the descriptions above.

The core of hardwood and decorative plywood consists of the layer or

layers of one or more material(s) that are situated between the face and

back veneers. The core may be composed of a range of materials,

including but not limited to veneers, particleboard, and medium‐density

fiberboard (‘‘MDF’’).

All hardwood and decorative plywood is included within the scope of this

investigation regardless of whether or not the face and/or back veneers

are surface coated, unless the surface coating obscures the grain, texture

or markings of the wood in a permanent manner. Examples of surface

coatings which may not obscure the grain, texture or markings of the

wood include, but are not limited to, ultraviolet light cured polyurethanes,

oil or oil‐modified or water based polyurethanes, wax, epoxy‐ester

finishes, and moisture‐cured urethanes. Hardwood and decorative

plywood that has face and/or back veneers which have a permanent and

opaque surface coating which obscures the grain, texture or markings of

the wood, are not included within the scope of this investigation.

Examples of permanently affixed surface coatings which may obscure the

grain, texture or markings of wood include, but are not limited to, paper,

aluminum, high pressure laminate (‘‘HPL’’), MDF, medium density overlay

(‘‘MDO’’), and phenolic film. Additionally, the face veneer of hardwood

and decorative plywood may be sanded, smoothed or given a

‘‘distressed’’ appearance through such methods as hand‐scraping or wire

brushing. The face veneer may be stained.

The scope of the investigation excludes the following items: (1) structural

plywood (also known as ‘‘industrial plywood’’ or ‘‘industrial panels’’) that

is manufactured and stamped to meet U.S. Products Standard PS 1–09, PS

2–09, or PS 2–10 for Structural Plywood (including any revisions to that

standard or any substantially equivalent international standard intended

for structural plywood), including but not limited to the ‘‘bond

performance’’ requirements set forth at paragraph 5.8.6.4 of that

Standard and the performance criteria detailed at Table 4 through 10 of

that Standard; (2) products which have a face and back veneer of cork;

(3 multilayered wood flooring, as described in the antidumping duty and

countervailing duty orders on Multilayered Wood Flooring from the

People’s Republic of China, Import Administration, International Trade

Administration, U.S. Department of Commerce Investigation Nos. A–570–

970 and C–570–971 (published December 8, 2011), and additionally,

multilayered wood flooring with a face veneer of bamboo or composed

entirely of bamboo; (4) plywood which has a shape or design other than a
I‐8

flat panel; (5) products made entirely from bamboo and adhesives (also

known as ‘‘solid bamboo’’). (‘‘HTSUS’’):  

4412.10.0500; 4412.31.0520; 4412.31.0540; 4412.31.0560;

4412.31.2510; 4412.31.2520; 4412.31.4040; 4412.31.4050;

4412.31.4060; 4412.31.4070; 4412.31.5135; 4412.31.5155;

4412.31.5165; 4412.31.5175; 4412.31.6000; 4412.31.9100;

4412.32.0520; 4412.32.0540; 4412.32.0560; 4412.32.2510;

4412.32.2520; 4412.32.3135; 4412.32.3155; 4412.32.3165;

4412.32.3175; 4412.32.3185; 4412.32.5600; 4412.39.1000;

4412.39.3000; 4412.39.4011; 4412.39.4012; 4412.39.4019;

4412.39.4031; 4412.39.4032; 4412.39.4039; 4412.39.4051;

4412.39.4052; 4412.39.4059; 4412.39.4061; 4412.39.4062;

4412.39.4069; 4412.39.5010; 4412.39.5030; 4412.39.5050;

4412.94.1030; 4412.94.1050; 4412.94.3111; 4412.94.3121;

4412.94.3131; 4412.94.3141; 4412.94.3160; 4412.94.3171;

4412.94.4100; 4412.94.6000; 4412.94.7000; 4412.94.8000;

4412.94.9000; 4412.99.0600; 4412.99.1020; 4412.99.1030;

4412.99.1040; 4412.99.3110; 4412.99.3120; 4412.99.3130;

4412.99.3140; 4412.99.3150; 4412.99.3160; 4412.99.3170;

4412.99.4100; 4412.99.5710; 4412.99.6000; 4412.99.7000;

4412.99.8000; 4412.99.9000; 4412.10.9000; 4412.31.4080;

4412.32.0570; 4412.32.2530; 4412.94.5100; 4412.94.9500;

4412.99.5115; and 4412.99.9500.

While HTSUS subheadings are provided for convenience and customs

purposes, the written description of the subject merchandise as set forth herein is

dispositive.7

Tariff treatment

Imports of the subject hardwood plywood are classified within several subheadings

covering plywood, veneered panels and similar laminated wood under heading 4412, chapter

44, of the Harmonized Tariff Schedule of the United States (HTSUS). The predominant

classifications are subheadings 4412.31 and 4412.32, HTSUS, which provide as follows:

4412.31 Other plywood {not of bamboo}, consisting solely of sheets of wood, each ply not

exceeding 6 mm in thickness; with at least one outer ply of tropical wood (general rates

of duty free or 8% ad valorem).

                                                      

7 Hardwood and Decorative Plywood From the People’s Republic of China:  Final Determination of

Sales at Less Than Fair Value, 78 FR 58273, September 23,  2013.
I‐9

4412.32 Other plywood {not of bamboo or in 4412.31} consisting solely of sheets of wood, each

ply not exceeding 6 mm in thickness; with at least one outer ply of nonconiferous wood

(general rates of duty free, 5.1% or 8% ad valorem)

4412.39 Other plywood {not of bamboo or in 4412.31‐4412.32} consisting solely of sheets of

wood, each ply not exceeding 6 mm in thickness; with both outer plies of coniferous

wood (general rates of duty free, 3.4%, 5.1% or 8% ad valorem).

4412.94 Blockboard, laminboard and battenboard (general rates of duty free, 3.4%, 5.1% or 8%

ad valorem).

4412.99 Other {plywood, veneered panels and similar laminated wood} (general rates of duty

free, 3.4%, 5.1% or 8% ad valorem).

THE PRODUCT

Description and applications

Hardwood and decorative plywood (hardwood plywood) is a wood panel product made

from gluing two or more layers of wood veneer to a core which may itself be composed of

veneers or other type of wood material such as medium density fiberboard (MDF),

particleboard, lumber, or oriented strand board (OSB).  The outer ply or face veneer is typically

the identifying species for the hardwood plywood product and is the side of the product that

will be visible in most uses.  A wide variety of hardwood species is used in hardwood plywood

manufacture including oak, birch, maple, poplar, and cherry.  However, hardwood plywood

includes plywood that may have a face veneer and/or other layers of veneer of softwood

species. The distinguishing characteristic of hardwood plywood products is that they are used in

interior and non‐structural applications.

Hardwood plywood is manufactured in a variety of thicknesses, with the most common

ranging from 1/8 inch (3.2 mm) to 1 inch (25.4 mm), depending upon customer requirements

and the intended end‐use.8

  The most common panel dimensions are 4 feet by 8 feet (1219 x

1829 mm), but hardwood plywood is also sold in smaller and larger sheet sizes.   

Hardwood plywood is commonly used in furniture, kitchen cabinets, architectural

woodwork, wall paneling, manufactured homes, and recreational vehicles (RVs).  The product is

almost always used in interior applications where moisture exposure is not an issue, although

some hardwood plywood is made specifically for marine applications.  Hardwood plywood is

also used in some construction‐related applications where structural strength and moisture

resistance is not a requirement, such as for providing a flat, stable underlayment for a finished

flooring product.  

Hardwood plywood products are differentiated by species, quality of veneer, thickness,

number of plies, type of core (veneer, particleboard, MDF, or other), and the type of adhesive

used in the manufacturing process.  Grades of hardwood plywood are determined by such

                                                      

8 Petition, p. 6.  
I‐10

things as number and size of knots, visible decay, splits or insect holes, surface roughness, and

other defects.  Grades are assigned to both the face and back veneer.  Plywood with the highest

face grades is used in applications where appearance is a primary consideration.  Most

hardwood plywood produced in the United States is graded according to a consensus‐based

voluntary standard developed by the Hardwood Plywood and Veneer Association (HPVA).9 The

highest and clearest grades of hardwood plywood carry an “AA” or “A’ face grade, followed by

“B,” “C,” etc. as more knots, blemishes or other defects are considered in the grading process.

The HPVA standard also assigns back veneers numerical grades from “1” to “4,” and certain

other letter grades to internal veneers. However, not all hardwood plywood sold in the United

States conforms to the HPVA standard.

Manufacturing processes

The production of hardwood plywood begins with the debarking of logs of a size and

quality suitable for peeling or slicing to make veneer.  Veneer is a thin sheet of wood that has

been rotary cut, sliced, or sawed from a log, bolt, or flitch.  Veneer quality logs, or peeler logs,

are generally of higher quality and value than those used for other wood products, although the

quality of veneer from any given log will vary. Petitioners indicated that approximately half or

more of a log peeled for veneer in the United States will yield C grade or below (45–60

percent), with the yield of A grade veneer in the range of 9–14 percent, and the balance in B

grade material.10 Respondents indicated that fast‐growing species of the kind used to

manufacture subject imports, such as poplar and eucalyptus, are smaller and yield a much

higher percentage of lower grade veneers.11

Rotary cut veneer is made using a lathe that spins a log against a blade at very high

speed.  This makes a continuous layer of thin veneer that is then cut to the desired length and

width, typically 50” by 100” in order to produce a finished panel of 48” by 96” (4x8 feet).  In

2012, approximately *** percent of U.S. hardwood plywood production was manufactured

using rotary‐cut veneer.12 In contrast, sliced or sawed veneers are thin sheets cut from lumber,

flitches, or blocks of wood. They are cut into variable lengths and widths depending upon the

form and dimension of the wood raw material.  Sliced veneer typically has a different grain

pattern than rotary‐cut veneer and is often utilized to make higher grades and specialty

plywood. Whether rotary produced or sliced, veneer is cut to thicknesses ranging from as thin

as 0.01 inch (0.25 mm) to greater than 1/4 inch (6.35 mm).  Veneer is graded and sorted by

quality, then dried prior to use in hardwood plywood manufacturing.  Face veneers are often,

                                                      

9 Hardwood Plywood and Veneer Association (HPVA), American National Standard for Hardwood and

Decorative Plywood, ANSI/HPVA HP‐1‐2009. Petition Supp, October 15, 2012, Supp. Exhibit I‐15.

10 Hearing transcript, p. 100 (Howlett). For birch, the average yield of “A” grade is 12 percent and “C”

grade and below is 60 percent; for maple, the average yield of “A” grade is 9 percent and “C” grade and

below is 52 percent; and for red oak, the average yield is 14 percent of “A” grade and 45 percent of “C”

grade and below. 11 AAHP posthearing brief, p. 13. 12 HPVA Annual Statistical Report for Calendar Year 2012.
I‐11

but not always, produced at a separate facility or by a different company than the

manufacturer of hardwood plywood.  

Some U.S. producers employ a "one‐step" process which is a fully automated,

continuous system from the log to the finished product.13  In the “one‐step” process, face and

back veneers are glued and pressed at the same time as the core veneers. The other prevalent

system, referred to as a “two‐step” process, takes face and back veneers and combines them

with a “core” or “platform” that is manufactured separately.  In many cases, face veneers that

are of a particular species and grade are purchased from other veneer producers and are then

glued onto the core material to complete the manufacturing process. Prior to pressing, the face

and core veneers are dried, sorted for defects, repaired or patched, taped or stitched to make

larger sheets from smaller pieces, and trimmed. The veneers are stacked with their grain in

alternating directions in order to provide strength and stability to the finished product.

Depending on the manufacturing process, a cold press may be used to fabricate the several

plies of veneer together prior to being hot pressed to glue the veneers together.14 The

thickness and number of plies depends upon the product.  

After pressing and trimming, panels are sanded and, in some cases, finished depending

on the end‐use.  Finishing can involve some degree of texturing for a particular appearance,

grooving, and/or staining or coloring.  The process will vary somewhat if a core of composite

wood (e.g., MDF or particleboard) or other material is used.  In the U.S. industry, in 2012,

veneer cores were used in approximately *** percent of production, MDF cores in *** percent,

particleboard in *** percent, and lumber, OSB, or combinations of materials in *** percent.15  

The adhesive formulation is a key factor in hardwood plywood manufacturing and

performance. Thermosetting adhesives are used to bond the veneer plies and/or core material.  

Urea‐formaldehyde (UF) based resins are the most common type of adhesives used in

hardwood plywood manufacture because they are suitable for interior use, have relatively fast

cure times, and do not bleed color through the plies.16  Currently, under California law,

formaldehyde emissions from hardwood plywood and other wood panel products sold in that

state are regulated under what is commonly called the CARB rule.17  Similar Federal regulations

restricting formaldehyde emissions from hardwood plywood and other wood products are

currently in the rule‐making process and will likely take effect within the next year. To meet

existing California and prospective Federal regulations limiting formaldehyde emissions,

manufacturers have changed the formulation of adhesives through the use of various additives

or by using no added UF soy‐based alternatives. Another type of adhesive formulated with

phenol‐formaldehyde (PF) resins emits less formaldehyde and is more moisture resistant, but

                                                      

13 Conference transcript, p. 110 (Thomson); Hearing transcript, AAHP Exhibit. 14 See Colombia Forest Products “Hardwood Plywood: How It’s Made” at:

http://columbiaforestproducts.com/CFPTV.

15 ***.

16 Conference transcript, p.70‐71 (Howlett). 17 CARB is an acronym for California Air Resources Board. The relevant rule is an airborne toxic

control measure (ATCM) promulgated to reduce formaldehyde emissions from composite wood

products.
I‐12

PF resins have color disadvantages and are typically used only if the plywood product is made

for exterior applications.18  

Generally, the basic steps in the manufacturing process are similar for both imported

and domestic hardwood plywood.  However, Chinese manufactures use thinner face and back

veneers that are laid up moist or wet ( in a “wet” process) to prevent splitting or breaking prior

to being pressed.19 According to Respondents, smaller logs are typically utilized to manufacture

veneer for the plywood core and the quality of veneer is typically lower.20 The Chinese product

is typically manufactured utilizing more labor and less automation, particularly for repairing

defects, preparing veneers, and laying up veneer sheets for pressing.21  

DOMESTIC LIKE PRODUCT ISSUES

The petitioner proposes that the Commission define the domestic like product co‐

extensive with the scope of the petitions.22  Respondents have not challenged this proposed

definition.

Physical Characteristics and Uses

The scope definition for hardwood and decorative plywood includes plywood that can

be made from hardwood or softwood species or bamboo in its face, back, or inner veneers.23  

Also included in the scope is hardwood plywood made with a core of lumber or composite

wood such as MDF or particleboard.  All thicknesses of veneer and finished panels are included.  

The scope specifically excludes structural plywood, plywood made with cork faces or backs,

multilayered wood flooring manufactured subject to a CVD/AD order, and plywood further

worked beyond basic finishing.

Hardwood and decorative plywood includes plywood that may be made of softwood

species. Respondents submit that softwood plywood that can be used in non‐structural

applications is covered within the scope of this investigation.24 However, petitioners maintain

that the structural and softwood plywood industry is a different industry with different

products, different standards, and different end uses.25 Structural or softwood plywood, in

contrast to the subject product, is made to meet a structural standard and is used in framing,

sheathing and other construction applications.26  The U.S. softwood plywood industry is

                                                      

18 Conference transcript, p.70‐71 (Howlett).

19 Hearing transcript, p. 177 (Simon).

20 Hearing transcript, p. 171‐172 (Dougherty). 21 Conference transcript, p. 108‐109 (Clausen); Hearing transcript, p. 175 (Simon) and p. 219 (Wu). 22 Petition, p. 19

23 Scope definition, I‐7, however, products made entirely of bamboo (“solid bamboo”) are excluded

in the scope.

24 Respondents’ prehearing brief, p. 29‐33.

25 Hearing transcript, p. 90 (Levin).

26 Structuaral plywood is manufactured to Department of Commerce Voluntary Product Standard

PS‐109 is the nationally recognized product standard for structural plywood. See Petitioner’s

Supplemental Submission, October 15, 2012, Exhibit Supp. I‐16.
I‐13

classified under a different North American Industrial Classification System (NAICS) code than is

hardwood plywood, is governed by different standards, and, in contrast to hardwood plywood,

typically uses adhesives designed to withstand use in exterior applications.27  

Certain other panel products may compete with hardwood plywood for some

applications.  These include MDF, hardboard, particleboard, and, to a lesser extent, OSB.  

Examples of similar uses are as cabinet back or side panels and drawer components.  Often,

these products have a printed or laminate surface to give an appearance similar to wood grain

in place of real wood veneer.  However, each of the alternatives has a particular cost, quality,

and appearance characteristic that distinguishes it from hardwood plywood.

Manufacturing Facilities and Production Employees

Unless a "one‐step" process is used, the "core" material used in hardwood plywood is

typically manufactured separately from the veneers used for the face and/or back plies.  

Whether veneers are produced by the hardwood manufacturer or purchased, the

manufacturing technique is similar. Producers that use cores made from MDF, HDF, or other

materials almost always purchase that material from other manufacturers.  Plants and

equipment used to manufacture hardwood plywood may also produce veneer or core material

for sale to others which, in turn, is used in manufacturing hardwood plywood panels.  In

hardwood plywood facilities that also manufacture veneer, the same employees may be

utilized.

Structural plywood is also fabricated from layers of veneers, commonly of softwood

species.  The manufacturing process is almost always a continuous process.  Different

formulations of glues are used for binding the plies together in manufacturing structural

plywood than for hardwood plywood.  In contrast to hardwood plywood, structural plywood is

made to meet strength and performance requirements needed for structural applications.  

Similar types of equipment may be used for manufacturing structural plywood and hardwood

plywood, but the two types of products are most often produced separately and at different

facilities.

MDF, hardboard, particleboard, and OSB (collectively, composite panels) are different

forms of panel products made by bonding wood fibers or small pieces of wood together with

adhesives under high heat and pressure.  The size and form of the wood particles differs in each

case, as does the type of bonding agent and the manufacturing process generally.  The

manufacturing processes for making MDF, hardboard, particleboard, and OSB are each

separate and distinct from manufacturing hardwood plywood, and they use different

equipment and employees.

Interchangeability

Petitioners submit that hardwood and decorative plywood products are interchangeable

in the market and in their end uses, distinguished by species, grade, appearance and quality.28  

                                                      

27 Petitioners’ post‐conference brief, response to question 2, p. 5‐7.
I‐14

Petitioners indicate that hardwood plywood products are perceived as the same class of

product by producers and consumers.29  

Hardwood and decorative plywood is generally not interchangeable with structural

plywood which has different characteristics and applications. However, MDF, particleboard,

and hardboard are sometimes used in the same applications as hardwood plywood such as for

cabinet back panels, drawer bottoms, or to fabricate laminated surfaces using imprinted (and

sometimes textured) paper or other material.

Channels of Distribution

Information provided by the petitioners indicates that U.S. hardwood plywood

manufacturers sell the majority of the product to wholesalers or directly to secondary

manufacturers (i.e., OEMs).30  Retail outlets, including “big box” stores represented

approximately 11 percent of U.S. producers' shipments in 2011, but petitioners suggest that

they have a significant impact on pricing and are purchasing large volumes of imports.31  

Manufacturers do not generally sell directly to consumers who instead are purchasing a

finished product utilizing hardwood plywood (such as a piece of furniture).  

The channels of distribution are similar for composite panels as for hardwood plywood,

but structural plywood is sold through a distribution network that serves home builders and

construction contractors directly as opposed to OEMs and other secondary manufacturers.

                                                      

(...continued)

28 Petition, p. 20.

29 Petition, p. 21.

30 Conference transcript, p. 47 (Malashavich) and exhibit 1.

31 Conference transcript, p. 46‐47 (Malashavich).
I‐15

Price

The price of hardwood plywood products is a function of the panel size, face species,

quality, thickness, and finish (i.e., whether stained, distressed, or otherwise treated).

Prices of other types of panel products also vary depending on grade, thickness,

application, and other characteristics.  However, each type of panel product is sold and priced

according to different standards.  For example, the grades and other characteristics by which

structural plywood is priced are different than for hardwood plywood.  Composite panels such

as MDF, particleboard, and hardboard are also priced and sold separately from hardwood

plywood.  Generally, but not always, structural plywood and composite panels are less

expensive than hardwood and decorative plywood of similar thickness and dimension.  Further

discussion of pricing is contained in Part V of this report.

II‐1

PART II: CONDITIONS OF COMPETITION IN THE U.S. MARKET

U.S. MARKET CHARACTERISTICS

Hardwood plywood is used in a variety of mostly indoor applications, particularly home

remodeling applications such as kitchen cabinets, RVs, manufactured homes, new homes, and

commercial buildings. Domestic producers supply less than 20 percent of the U.S. market with a

few domestic firms accounting for the large majority of U.S. production of hardwood plywood.1

   

Imports supply most of the U.S. market, with the largest share coming from China, but other

countries including Canada, Indonesia, and Russia, also ship large quantities to the U.S. market.   

Hardwood plywood is made from a variety of different wood species, in a variety of

thicknesses, and in a variety of different grades (i.e., AA, A, B, C, D, and E). Grades A and B are

used in visually important areas, while lower grades are often used as shelves and in the backs

of cabinets.2

   Most U.S. produced hardwood plywood is sold unfinished.3   

U.S. PURCHASERS  

The Commission sent purchasers’ questionnaires to 55 companies believed to have

purchased hardwood plywood since 2010. Questionnaire responses were received from 42

purchasers, with 40 reporting that they had purchased hardwood plywood since 2010.4  Fifteen

responding purchasers reported that they were end users, 12 characterized themselves as

distributors, seven reported being a “manufacturer” of some type, three reported being

retailers or in “retail sales/wholesale/reseller,” two characterized themselves as “laminators,”

and one reported being a “buying cooperative.” Of the responding firms, the two largest U.S.

purchasers of hardwood plywood in 2012 in terms of quantity were ***.  All responding

purchasers accounted for about 21 percent of U.S. apparent consumption in 2012.  

CHANNELS OF DISTRIBUTION

U.S. producers and importers sold hardwood plywood mainly to distributors (table II‐1).

According to petitioners, although big box stores account for only about 11 percent of domestic

sales, this channel currently wields a disproportionately severe impact on pricing at the margin

due to considerable market power and logistical support.5  Respondents indicate they do not  

 

1 The top four U.S. producers accounted for almost 80 percent of U.S. production during 2012.    2 Conference transcript, p. 32 (Oglesby).

3 Unfinished panels accounted for *** percent of North American production of hardwood plywood

in 2012. HPVA, Hardwood Stock Panels, Annual Statistical Report for Calendar Year 2012, p. 14. 4 Respondents indicated that the Commission ***. 5 Conference transcript, pp. 46‐47 (Malashevich).
II‐2

Table II-1 

Hardwood plywood: U.S. producers’ and importers’ U.S. shipments, by sources and channels of 

distribution, 2010-12, January-March 2012, and January-March 2013

 Period 

 Calendar year JanuaryMarch 

Item 2010 2011 2012 2012 2013 

 Share of reported shipments 

(percent) 

U.S. producers' U.S. shipments of hardwood plywood: 

 Distributors 86.9 83.3 85.7 85.2 85.5

 End users 13.1 16.7 14.3 14.8 14.5

U.S. importers' U.S. shipments of hardwood plywood from China: 

 Distributors *** *** *** *** ***

 End users *** *** *** *** ***

U.S. importers' U.S. shipments of hardwood plywood from all other 

countries: 

 

 Distributors *** *** *** *** ***

 End users *** *** *** *** ***

Source: Compiled from data submitted in response to Commission questionnaires. 

see the ripple effect out of big box stores alluded to by petitioners and that one of the

petitioners recently entered into an agreement with one of the big box stores that will take a

lot of capacity off of the market and has caused supply constraints for many distributors and  

end users.6

According to public data for the North American market, about *** percent of

shipments to distributors went to distributors with multiple warehouses in 2011 and 2012.   

Direct shipments (not through a distributor) to cabinet OEMs and retail OEMs each made up

just over *** of direct shipments to OEMs in 2012, with the remainder of direct shipments to

furniture and fixture OEMs.7

Respondents assert that the domestic industry “has a rigid distribution system where a

limited number of distributors are permitted to sell the product and no outside distributors

have the ability to purchase the domestic product.”  They further contend that Chinese

plywood is sold by a large number of distributors that can meet quick delivery schedules and

that many small distributors are unable to purchase from the petitioners.8

 

6 Hearing transcript, pp. 248‐250 (Grimson, Simon). 7 HPVA, Hardwood Stock Panels, Annual Statistical Report for Calendar Year 2012, p. 42 and 59.

8 AAHP postconference brief, pp. 32‐33. Hearing transcript, pp. 181‐182 (Simon).
II‐3

GEOGRAPHIC DISTRIBUTION

U.S. producers and importers reported selling hardwood plywood to all U.S. regions

(table II‐2). U.S. producers reported that in 2012, 4 percent of their sales were within 100 miles

of their production facilities, 61 percent were between 101 and 1,000 miles, and 35 percent

were over 1,000 miles. Importers sold *** percent within 100 miles of their U.S. points of

shipment, *** percent between 101 and 1,000 miles, and *** percent over 1,000 miles.

Table II-2 

Hardwood plywood: Geographic market areas in the United States served by U.S. producers and 

importers, by number of responding firms 

Region Number of firms 

U.S. Producers Importers 

Northeast 7 29 

Midwest 7 34 

Southeast 6 33 

Central Southwest 6 31 

Mountain 5 23 

Pacific Coast 5 31 

Other1 2 8 

All regions (except Other) 5 22 

Reporting firms 8 37 

1

 All other U.S. markets, including AK, HI, PR, and VI, among others. 

Source: Compiled from data submitted in response to Commission questionnaires. 

SUPPLY AND DEMAND CONSIDERATIONS

U.S. supply

Domestic production

Based on available information, U.S. hardwood plywood producers have the ability to

respond to changes in demand with moderate to large changes in the quantity of shipments of

U.S.‐produced hardwood plywood to the U.S. market. The main contributing factor to the

moderate to high degree of responsiveness of supply is the availability of unused capacity.

Responsiveness is constrained by the lack of significant alternate markets, low inventory levels,

and the inability of most producers to produce alternate products.

Industry capacity

Capacity utilization increased during 2010‐12, owing to the decrease in capacity and an

increase in production during 2010‐12. Capacity utilization increased to a little more than 50

percent in 2012. This relatively low level of capacity utilization suggests that U.S. producers may
II‐4

have substantial capacity to increase production of hardwood plywood in response to an

increase in prices.

Alternative markets

U.S. producers have a limited ability to divert shipments to or from alternative markets

in response to changes in the price of hardwood plywood. U.S. producers’ exports accounted

for only 3 to 4 percent of total shipments during 2010‐12.

Inventory levels

U.S. producers’ inventories as a ratio to total shipments were relatively stable over

2010‐12 at about 6 percent. These inventory levels suggest that U.S. producers may have a

limited ability to respond to changes in demand with changes in the quantity shipped from

inventories.

Production alternatives

Only two of nine responding producers manufacture other products on the same

equipment used to produce hardwood plywood. One firm reported producing *** on the same

equipment and another firm reported producing ***.

Supply constraints

One responding producer reported it had refused, declined, or was unable to supply

hardwood plywood during the period examined. *** indicated that ***. In addition, one U.S.

producer *** commented that it had refused, declined, or was unable to supply hardwood

plywood only when it would not lower its price “to meet cheap Chinese plywood prices.”

Subject imports from China

Based on available information, Chinese producers have the ability to respond to

changes in demand with moderate to large changes in the quantity of shipments of hardwood

plywood to the U.S. market. The main contributing factors to the moderate to large degree of

responsiveness of supply is the existence of alternate markets. Responsiveness is constrained

by the lack of unused capacity, low inventory levels, and the inability of most producers to

produce alternate products.

Industry capacity

With production rising faster than capacity, capacity utilization increased to over 85

percent in 2012. This relatively high level of capacity utilization suggests that Chinese producers

may have little additional capacity to increase production of hardwood plywood in response to

an increase in prices.
II‐5

Alternative markets

Between 2010 and 2012, more than one‐half of Chinese shipments were either to the

Chinese home market or export markets other than the United States. The existence of these

other large non‐U.S. markets indicates that Chinese producers likely have an ability to shift

shipments between markets in response to a change in price.

Inventory levels

Chinese producers‘ inventories as a ratio to total shipments were relatively stable

ranging between 5 and 7 percent during 2010 to 2012. These inventory levels suggest that

Chinese producers may have a limited ability to respond to changes in demand with changes in

the quantity shipped from inventories.

Production alternatives

All but three responding Chinese producers reported that they do not produce other

products on the same equipment used to produce hardwood plywood. One Chinese producer

reported making solid and engineered wood flooring on the same equipment and another

reporting making doorskins.

Supply constraints

About one‐third of responding importers of product from China indicated that it had

refused, declined, or was unable to supply hardwood plywood during the period examined.

Several importers indicated that they had production delays, delayed shipments, and difficulty

sourcing raw material at certain times.  Importer *** indicated that it strives for quality and,

therefore, cannot supply all of its customers’ requirements many months of the year. Several

importers indicated that they had supply constraints for imports from countries other than

China.  

Nonsubject imports

Nonsubject imports accounted for 45 percent of the landed value of total imports in

2012. The largest sources of nonsubject imports were Indonesia, Russia, and Canada.

Combined, these three countries accounted for 26 percent of the landed value of nonsubject

imports in 2012.

U.S. demand

Based on available information, the overall demand for hardwood plywood is likely to

change moderately in response to changes in price. The main contributing factors are the

availability of substitute products and the moderate cost share of hardwood plywood in most

of its end‐use products.  
II‐6

End uses

U.S. demand for hardwood plywood depends on the demand for U.S. produced

downstream products which include: kitchen cabinets, RVs, manufactured homes,

underlayment, and furniture. Petitioners estimate that 35 percent of U.S.‐produced hardwood

plywood is used for retail fixtures, 30 percent is used in cabinetry, and that 7 percent is used for

underlayment and in RV manufacturing (figure II‐1).9

   Respondents estimate that about one‐

third of imported Chinese hardwood plywood is used in producing cabinets, 30 percent is used

for underlayment and RV manufacturing, and 7 percent is used in store fixtures, (figure II‐1).10

Petitioners and respondents indicate that cabinets are the largest end use for both

domestic and imported products.11  Many producers, importers, and purchasers reported that

this end use was among their top three end uses. The next most commonly listed end use

reported by producers, importers, and purchasers was furniture.  

According to petitioners, demand for hardwood plywood is more closely tied to

remodeling activity, and construction of RVs, manufactured homes, and furniture cabinetry,

than to new home construction.12   

The Leading Indicator of Remodeling Activity (LIRA) (see figure II‐2), which measures the

value of homeowner improvements, increased by 24 percent between the first quarter of 2010

and the third quarter of 2013. Remodeling activity is expected to increase by about the same

amount over the next year, with the value of the LIRA projected to increase by 15 percent

between the second quarter of 2013 and the second quarter of 2014.

Seasonally adjusted housing starts increased by 46 percent between January 2010 and

August 2013, with most of the increase since latter part of 2011 (figure II‐3). Housing starts,

however, remain well below historic averages.

Kitchen cabinet sales declined from 2009 to 2011, but increased each month between

January 2012 and June 2013.13   Shipments of RVs and manufactured homes increased from

2010 to 2012 (table II‐3).  Domestic wood furniture shipments increased slightly from 2010 to

2011 as did flooring sales.14 Sales of hardwood and laminate flooring, both of which are

produced from wood, increased by 7 percent and 1 percent respectively between 2011 and  

 

9 Petitioners posthearing brief, Answers to Commissioners’ questions from the hearing, p. 13

However, in the preliminary conference petitioners estimate that 40 to 50 percent of hardwood

plywood production is used in kitchen cabinets. Conference transcript, p. 82 (Oglesby).

10 AAHP postconference brief, exh. 1, p. 12.  Respondents also reaffirmed that this is still an accurate

estimate of the share of end‐sues for imported hardwood plywood. AAHP posthearing brief, Questions

from Chairman Williamson, p. 2. 11 Conference transcript, (Clausen, Oglesby), pp. 82‐83 and AAHP postconference brief, exh. 1, p. 12. 12 Petitioners’ postconference brief, pp. 20‐21. Petitioners posthearing brief, Answers to

Commissioners’ questions from the hearing, p. 13.

13 AAHP postconference brief, p. 9. KCMA, June 2012 Trend of Business Press Release,  July 17, 2012.

KCMA, “18 consecutive months of growth in cabinet sales!”  August 1, 2013,

http://www.kcma.org/blog/?p=38 14 Domestic wood furniture shipments ***. AAHP postconference brief, p. 11.
II‐7

Figure II-1 

Hardwood plywood: Share of end uses for U.S.-produced and imported hardwood plywood 

Source: Petitioners posthearing brief, Answers to Commissioners’ questions from the hearing, p. 13 and 

AAHC postconference brief, exh. 1, p. 12. 
II‐8

Figure II-2 

Homeowner improvements: Leading indicator of remodeling activity, four quarter moving total 

and rate of change, estimated and projected: quarterly, January 2010-June 2014 

Source: Joint Center for Housing Studies of Harvard University http://www.jchs.harvard.edu/leadingindicator-remodeling-activity-lira (retrieved October 17, 2013). 

Figure II-3 

Housing starts: Seasonally adjusted housing starts, monthly, January 2010-August 2013 

Source: U.S. Census Bureau, New Residential Construction. http://www.census.gov/construction/nrc/historical_data/ 

(retrieved October 17, 2013). 
II‐9

Table II-3 

Manufactured homes and RVs: Annual shipments, thousands of units 2010-12, and January-June 

2013 

Item 2010 2011 2012 January-June 

2013 

Manufactured homes 50.0 51.6 54.9 29.1

Recreation Vehicles 242.3 252.3 285.9 174.9

Source: Recreational Vehicle Industry Association and U.S. Census Bureau. (Downloaded, August 16, 

2013). 

2012.15 Petitioners reported that the commercial building sector, where hardwood plywood is

used in office building foyers, libraries, and conference rooms, did not decline as much as did

the housing sector during the recession.16

Business cycles

A little more than one‐half of responding U.S. producers and importers, and just over 40

percent of responding purchasers indicated that the market was subject to business cycles or

distinctive conditions of competition, including seasonal demand that varied somewhat by

region and by end use product. Several producers noted seasonal trends such as high, demand

from January‐June or July, and slower demand in summer and in November and December.17   

Two of these producers also noted that hardwood plywood demand at least partially follows

housing demand. Some importers and purchasers also reported similar seasonal trends as well

as cyclical trends in the overall building industry based on new home construction, commercial

construction, and remodeling. One importer noted that seasonality is based on the weather

and can differ between regions. It noted for example, that demand in the Midwest is high in the

winter when people are inside doing winter projects, whereas demand is high in Texas during

summer when people prefer indoor projects because it is too hot to be outside. One importer

reported that demand for plywood for truck bodies is higher during the first half of the year

than during the second half of the year. Another importer reported that furniture sales are

higher in the fall and also that different end use markets exhibit different trends.18   

Several firms reported changes in conditions of competition. Two producers reported

that cheap Chinese hardwood plywood and furniture had reduced demand for domestic

product, and one also reported that housing starts had dropped. Importers and purchasers

reported changes, including the large decline in the housing market and the gradual recovery;

changes in input costs and ocean freight costs, and currency fluctuations; volume purchasing; a

shift in demand for product with thinner faced veneer, shifting product lines due to the AD/CVD

 

15 Floor Covering Weekly, July 22, 2013, p. 4.

16 Conference transcript, p. 82 (Howlett). 17 Remodeling activity is lower during October to December because of the Thanksgiving and

Christmas holidays. Conference transcript, p. 77 (Oglesby).

18 For example, its sales to the residential kitchen cabinet market dropped off markedly at the height

of the recession in 2009 while its sales to the luxury market were much more stable.
II‐10

orders, less kitchen remodeling (homeowners choosing to upgrade roofs and HVAC systems

rather than kitchens); and moderate improvement in demand in homebuilding, remodeling,

and RVs. One importer reported that Chilean supply was greatly reduced in 2010 and 2011 after

the largest Chilean plywood mill was destroyed in an earthquake in February 2010 and then the

rebuilt mill suffered a fire in 2011; and it reported that in 2012, Chilean supply was being

replaced by Chinese supply.  

Apparent consumption

The value of apparent U.S. consumption of hardwood plywood increased at a greater

rate than quantity between 2010 and 2012, suggesting that demand increased to some extent

during that period.  

Demand trends

Most U.S. producers reported a decrease in U.S. demand since 2010; however, most

importers reported that demand increased or fluctuated and most purchasers indicated that

demand increased (table II‐4). Firms reporting an increase cited an improving construction and

housing market and a slight upturn in the economy, while firms reporting decreased demand

cited weak demand in construction and housing as well as low consumer confidence.

Respondents assert that demand was especially strong for the products imported from

China, which are thinner overall and/or have a thin face veneer on top of a hardwood core.  

According to respondents, demand for these products grew as a result of the recession when

customers found that the thinner Chinese product was more efficient and more effective in

certain applications where the hardwood plywood is not visible or will be painted or

laminated.19

Substitute products

A majority of responding U.S. producers, importers, and purchasers reported that there

were no substitutes for hardwood plywood. Of the remaining firms, the most frequently named

substitutes were MDF, particleboard, and softwood plywood. Firms also reported substitutes

such as composites, hardboard, hardwood lumber, HPL, laminates, melamine, mende board,

OSB, solid wood, laminates, and softwood plywood. One producer, seven importers, and three

purchasers indicated changes in the price of some substitute products affect the price of

hardwood plywood. MDF and softwood plywood were the most frequently cited substitutes

that affect the price of hardwood plywood.

 

19 AAHP postconference brief, pp. 13‐15. Hearing transcript, pp. 178‐180 (Simon), pp. 188‐190

(Weaver).
II‐11

Table II-4 

Hardwood plywood: Firms’ perceptions regarding U.S. demand since 2010, by number of 

responding firms 

 Number of firms reporting 

Item Increase No change Decrease Fluctuate 

Demand in the United States 

U.S. producers 3 0 5 0 

Importers 18 3 6 13 

Purchasers 23 4 3 9 

Demand outside the United States 

U.S. producers 0 0 4 0 

Importers 3 5 7 9 

Purchasers 5 2 1 4 

Demand for purchasers' final products 

Purchasers 14 1 2 3 

Source: Compiled from data submitted in response to Commission questionnaires.

Cost share

Hardwood plywood typically accounts for a highly varied share of the cost of end‐use

products in which it is used. In their questionnaire responses, U.S. producers, importers, and

purchasers reported cost shares ranging from 6 to 55 percent for cabinets, 20 to 40 percent for

fixtures, 10 to 70 percent for furniture, 2 to 30 percent for RVs, and 80 percent for

underlayment.

SUBSTITUTABILITY ISSUES

The degree of substitution between domestic and imported hardwood plywood

depends upon such factors as relative prices, quality (e.g., grade standards, reliability of supply,

defect rates, et cetera), and conditions of sale (e.g., price discounts/rebates, lead times

between order and delivery dates, payment terms, product services, et cetera). Based on

available information, staff believes that there is a moderate degree of substitutability between

U.S. produced hardwood plywood and that imported from China.  

Lead times

U.S. producers reported selling almost all of their hardwood plywood produced to order

with lead times generally between 7 and 14 days. Importers reported that about three‐fourths

of their sales are from U.S. inventory with lead times typically in one month or less, and the

remaining sales produced to order with lead times of 60 to 180 days.
II‐12

Knowledge of country sources

*** purchasers indicated they had marketing/pricing knowledge of domestic product,

*** of Chinese product, and *** of nonsubject countries.

As shown in table II‐5, most purchasers and their customers at most “sometimes” make

purchasing decisions based on the producer or country of origin. Of the *** purchasers that

reported that they “always” make decisions based on the producer, firms cited price, quality,

purchasing from qualified suppliers, and using an exclusively developed grade of hardwood

plywood.

Factors affecting purchasing decisions

Available information indicates that purchasers consider a variety of factors when

purchasing hardwood plywood. While price and quality were cited most frequently as being top

factors in their purchase decisions, other factors such as availability, product consistency, and

reliability of supply were cited just as often as being very important purchasing factors.  

Quality was most frequently cited by purchasers as their top factor in purchasing plywood, and

33 of 40 purchasers indicated that quality was one of the three most important factors (see

table II‐6). Thirty‐four of 40 responding purchasers indicated that quality meeting industry

standards was a very important factor in their purchases (see table II‐7). All but four purchasers

indicated that quality exceeding industry standards was at least a somewhat important

purchasing factor. U.S. purchasers identified various principal factors they considered in

determining the quality of hardwood plywood including: strength, thickness; flatness; glue

bond; moisture content; veneer thickness; core integrity; lack of odor, delamination, mold,

voids, and warp; appearance; soundness; panel stability; smoothness; telegraphing; and grain

pattern.  

Six of 40 responding purchasers indicated that price was the most important factor in

considering a purchase and 35 of 40 purchasers indicated that price was one of the three most

important purchasing factors. All but five responding purchasers indicated that price is a very

important factor in purchasing hardwood plywood. All but four responding purchasers

indicated that they either “sometimes” or “usually” purchase the lowest price hardwood

plywood.

Seven of 40 responding purchasers indicated that availability was its most important

factor in purchasing hardwood plywood; over one‐half indicated that it was one of their top

three factors. All but two responding purchasers indicated that availability was a very important

purchasing factor.  

Six purchasers indicated that product consistency was one of its top three purchasing

factors and all responding purchasers indicated that it was a very important purchasing factor.

Thirty‐six of 40 responding purchasers indicated that reliability of supply is a very important

purchasing factor and two purchasers indicated that is one their top three purchasing factors.

Thirty‐three of 40 purchasers indicated that panel thickness is a very important factor in

their purchases and 25 of 39 purchasers indicated veneer thickness is a very important factor.  

About one‐half of responding purchasers indicated that there are product or utilization‐related

considerations that would limit the substitution between a thicker face veneer product with a  
II‐13

Table II-5 

Purchasing decisions based on producer and country of origin 

Purchaser / Customer Decision Always Usually Sometimes Never 

Purchaser makes decision based on 

producer 

9 9 14 9 

Purchaser's customers make decisions 

based on producer 

1 4 16 14 

Purchaser makes decision based on 

country 

6 6 12 15 

Purchaser's customers make decisions 

based on country 

0 4 13 17 

Source: Compiled from data submitted in response to Commission questionnaires. 

Table II-6 

Hardwood plywood: Ranking of factors used in purchasing decisions as reported by U.S. 

purchasers, by number of reporting firms 

Factor First Second Third Total 

Availability 7 8 8 23 

Delivery 0 1 1 2 

Price 6 13 16 35 

Product consistency 2 3 1 6 

Product line 1 0 1 2 

Quality 17 11 5 33 

Reliability of supply 1 1 0 2 

Service 0 0 1 1 

Supplier history 1 0 0 1 

Terms 0 0 1 1 

Traditional suppliers 1 0 1 2 

Other1 4 1 2 7 

1

 Other factors include: ”consistent performance including availability, timely delivery, support of 

products,” “adherence to product specifications (within tolerances),” certification,” method of plywood 

layup," warehousing consignment delivery program, continuous improvement of the grade level of the 

material, and “applicability to our needs.” 

Source: Compiled from data submitted in response to Commission questionnaires. 
II‐14

Table II-7 

Hardwood plywood: Importance of purchase factors, as reported by U.S. purchasers, by number 

of responding firms 

 Number of firms responding 

Factor Very important Somewhat important Not important 

Availability 38 2 0 

Core material species 19 18 3 

Delivery time 34 5 1 

Discounts offered 9 21 10 

Extension of credit 7 11 22 

Minimum qty requirements 5 18 17 

Packaging 9 23 8 

Panel thickness 33 7 0 

Price 35 4 1 

Product consistency 40 0 0 

Quality exceeds industry standards 13 22 4 

Quality meets industry standards 34 4 1 

Product range 10 23 5 

Reliability of supply 36 4 0 

Technical support/service 14 20 6 

U.S. transportation costs 20 16 4 

Veneer thickness 25 14 0 

Note: Does not include a response by *** that quality meeting industry standards is both “very and not 

important. 

Source: Compiled from data submitted in response to Commission questionnaires. 

thin faced veneer product.  Over one‐half of these purchasers cited suitability for sanding as a

limiting factor; a few cited lamination and appearance as limiting factors.

According to respondents, there is limited competition between imported and domestic

hardwood plywood since the domestic products contain a softwood core with thick outer

veneers of at least 0.5 mm while the Chinese products contain a hardwood core with outer

veneers of 0.22 mm to 0.28 mm.20  Respondents also indicate that domestic producers cannot

produce panels with overall thickness of less than 6 mm while a large proportion of Chinese

plywood has an overall thickness of 5.2 mm or less.21  They report that these thinner panels are

reportedly used as a flooring substrate (5.2 mm panels), and in RVs and manufactured homes

(2.7 mm and 3.4 mm panels).22  Petitioners, however, assert that the appearance of the panel,

 

20 AAHP postconference brief, p. 16. AAHP posthearing brief, exhibit 6, pp. 1‐5. Hearing transcript,

pp. 199‐201 (Spencer). 21 According to respondents, 40 percent of Chinese imports are thicknesses of 5.2 mm or less.

Conference transcript, p. 14 (Grimson).  Available data indicate that in 2012, ***. HPVA, Hardwood

Stock Panels, Annual Statistical Report for Calendar Year 2012, p. 16. 22 AAHP postconference brief, p. 19.
II‐15

rather than the thickness of the outer veneers (face thickness), is what is important to

customers.23   

Supplier certification

About one‐half of responding purchasers indicated that they require that their suppliers

be certified for at least some of their purchases. Certification procedures vary by purchaser

with some purchasers testing samples, visiting and auditing vendors, and relying on industry

standards such the California Air Resource Board (CARB) certification. Most suppliers reported

that certification takes from two weeks up to 4 months, although some purchasers report

shorter certification periods or certification taking up to one year. Eight purchasers reported

that a supplier failed in its attempt to be certified to supply hardwood plywood since 2010.  

***.

Lacey Act Procedures

The Lacey Act is a federal law dating back to 1900 (and amended several times) that

prohibits trafficking in “illegal” wildlife, fish, and plants. It was most recently amended in 2008

to make it a crime to enter into commercial transactions involving plant material (including

wood products) that is harvested or traded illegally.24  The Act also requires importers to file a

specific declaration upon importation of plant products (hardwood plywood in this case) that

contains information about the genus, species, country of harvest, and quantity of plant

material. When asked about procedures to comply with the Lacey Act, six U.S. producers

responded that they have some form of Lacey Act specific procedures in place. The majority of

purchasers also indicated that they check to ensure that suppliers are in compliance with the

Lacey Act and that the required Lacey Act import documentation is filed.  Some purchasers

indicated that they rely on their suppliers to ensure compliance with filing of the Lacey Act

declaration. Thirty‐eight importers responding to this question indicated that they have

procedures to file the necessary Lacey Act declaration upon importation.25 Some importers

noted that information for doing so is provided by the foreign supplier; some importers

commented that they additionally require suppliers to confirm or certify compliance to the

Lacey Act; some conduct visits to suppliers to verify source of raw materials; and some include

assurances of compliance as part of signed purchasing agreements. Two importers provided

detailed information on their management programs to implement the Lacey Act that include

conducting supplier risk assessments, quarterly and annual reviews and/or auditing, verification

of supplier information, third‐party verification and document controls.

 

23 Petitioners’ postconference brief, p. 17. Conference transcript, pp. 86‐87 (Thompson). Hearing

transcript p. 101 (Gonyea), pp. 101‐102 (Thompson).

24 See additional information on the 2008 Lacey Act amendments at:

http://www.aphis.usda.gov/plant_health/lacey_act/

25 Under the Lacey Act, the importer of record is required to file the Lacey Act declaration.
II‐16

Chain of Custody Certification and Certified Product

Seven domestic producers reported having a Chain of Custody (CoC) certification under

one or more of FSC, PEFC, and SFI certification programs. Domestic producers indicated that

approximately 10 percent of their production carried a SFI, PEFC, or FSC certification claim in

2012. While eighteen importers reported having a CoC certification under one or more of the

FSC, PEFC, or SFI systems, they also reported that very little of imported subject product carries

a certified content claim under one of the standards. On average, less than 3 percent of their

total imported volume carried a certification claim. Importers generally indicated that there is

very little demand for certified subject product. Eight purchasers indicated that they require

suppliers to have a CoC certification and they reported that, on average, 3 percent of the

volume they purchased in 2012 was certified.  Importers and purchasers generally stated that

they only supply certified material upon customer request.  

Changes in purchasing patterns

Most purchasers reported increasing their purchases of hardwood plywood from both

U.S. and subject sources since 2010 (table II‐8). Many purchasers reported that they had

increased sales due to increased demand. Over one‐half of responding purchasers reported

that they had changed suppliers since 2010. Specifically, firms dropped or reduced purchases

from various suppliers because of price and/or quality, but some purchasers also cited reasons

such as availability. About one‐fourth of responding purchasers reported new suppliers such as

American International, Dalin, Pavco, and Xuzhon Hansun.

Importance of purchasing domestic product

About one‐half of responding purchasers reported that purchasing U.S.‐produced

product was an important factor in some of their purchasing decisions.  Reported purchases of

domestic product that were required by law, regulation, customers, or other reasons

represented about 3 percent of apparent consumption of hardwood plywood from 2010 to

June 2013. The bulk of these purchases were required by purchasers’ customers and a very

small amount were required by law or regulation. Petitioners argue that the domestic industry

market share of 17 to 18 percent between 2010 and 2012 was not much greater than the

minimum level possible given the legal, regulatory, customer, or other requirements. They

estimate that total domestic purchases constitute *** percent of the U.S. market since the

responding purchasers represented *** percent of apparent consumption.26

 

26 Petitioners’ posthearing brief, Responses to questions from Commissioners, p. 19.
II‐17

Table II-8 

Hardwood plywood: Changes in purchase patterns from U.S., subject, and nonsubject countries 

Source of purchases Did not 

purchase 

Decreased Increased Constant Fluctuated

United States 3 4 22 6 5

China 5 5 24 4 2

Other 8 7 13 7 1

Source: Compiled from data submitted in response to Commission questionnaires. 

Comparisons of domestic products, subject imports, and nonsubject imports

At least one‐half of responding purchasers reported that U.S. and subject product were

comparable in terms of discounts offered, extension of credit, minimum quantity requirements,

packaging, panel thickness, quality meeting or exceeding industry standards, reliability of

supply, and U.S. transportation costs (tables II‐9 and II‐10). Over one‐half of responding

purchasers indicated that U.S.‐produced product was superior in terms of delivery time,

product range, technical support/service, and veneer thickness. One‐fourth of responding

purchasers indicated that imports from China were superior compared to U.S.‐produced

hardwood plywood with regards to price. At least three‐fourths of responding purchasers

indicated that U.S.‐produced hardwood plywood was comparable with nonsubject imports

from Canada for all attributes. In all but one case, 70 percent of responding purchasers

indicated that U.S‐produced hardwood plywood was either superior or comparable to imports

from other nonsubject countries for all attributes except for price. The exception was that

almost all responding purchasers indicated that imports from Russia were either superior or

comparable to U.S‐produced hardwood plywood with respect to core material species.    

While over one‐half of U.S. producers indicated that domestic hardwood plywood and

imported Chinese product are “always” interchangeable, more than 80 percent of importers

and 60 percent of purchasers characterized them as either “sometimes” or “never” comparable

(table II‐11). In comparing domestic hardwood plywood to nonsubject imports, close to a

majority of producers and a majority of importers and purchasers found the domestic and

Canadian products to be “always” or “frequently” interchangeable, but that imports from other

countries were “sometimes” or “never” interchangeable with domestic product.  

Importers and purchasers reported that interchangeability between various sources

including domestic and Chinese hardwood plywood is limited by the following: needed lengths

and widths not available domestically; differing characteristics such as wood species, core

construction, face and back veneer thicknesses, panel strength, tolerances for moisture

content, and glues; differing quality; smaller volumes available from importers; and availability

of product. Some importers and purchasers noted that Chinese product has a thinner veneer

face (0.25 mm to 0.35 mm) than domestic product (0.5 mm to 0.75 mm). They also reported

that domestic hardwood plywood consists of high quality decorative panels whereas imports

are typically used for non‐decorative uses.  
II‐18

Table II-9 

Hardwood plywood: Purchasers’ comparisons between U.S.-produced and imported product 

 U.S. vs. China U.S. vs. Canada U.S. vs. Indonesia 

Factor S C I S C I S C I 

Availability 11 13 10 2 16 0 13 4 6 

Core material species 12 16 6 0 18 0 7 12 4 

Delivery terms 17 14 3 1 17 0 13 9 1 

Delivery time 20 11 5 2 15 1 13 7 3 

Discounts offered 9 22 3 1 16 1 7 13 2 

Extension of credit 8 25 1 0 18 0 9 13 0 

Minimum qty requirements 14 20 1 1 17 0 11 11 1 

Packaging 17 18 0 2 16 0 11 11 1 

Panel thickness 13 17 5 1 17 0 9 12 2 

Price1 1 8 24 1 17 0 1 9 12 

Product consistency 16 16 3 1 17 0 11 10 2 

Quality exceeds industry standards 15 18 1 0 18 0 8 13 1 

Quality meets industry standards 8 24 1 1 17 0 6 16 0 

Product range 18 11 4 3 15 0 13 7 2 

Reliability of supply 14 18 3 1 17 0 13 7 3 

Technical support/service 23 12 0 1 16 1 16 6 1 

U.S. transportation costs1 12 22 1 3 14 1 6 15 2 

Veneer thickness 20 10 4 0 17 1 12 8 3 

1

 A rating of superior means that price/U.S. transportation costs is generally lower. For example, if a firm 

reported “U.S. superior,” it meant that the U.S. product was generally priced lower than the imported 

product. 

Note: S=first listed country’s product is superior; C=both countries’ products are comparable; I=first list 

country’s product is inferior. Does not include responses by *** that hardwood plywood produced in 

United States is both “superior” and “inferior” to hardwood plywood imported from China in terms of 

availability, price, product range, and veneer thickness. 

Source: Compiled from data submitted in response to Commission questionnaires. 
II‐19

Table II-10 

Hardwood plywood: Purchasers’ comparisons between U.S.-produced and imported product 

 U.S. vs. Russia U.S. vs. Other 

Factor S C I S C I 

Availability 13 4 4 6 5 0 

Core material species 1 11 9 4 7 0 

Delivery terms 12 8 1 7 4 0 

Delivery time 12 7 2 7 4 0 

Discounts offered 8 12 1 3 8 0 

Extension of credit 10 11 0 5 6 0 

Minimum qty requirements 8 13 0 3 8 0 

Packaging 5 15 1 4 7 0 

Panel thickness 4 16 1 5 6 0 

Price1 1 11 9 0 9 2 

Product consistency 4 16 1 3 7 1 

Quality exceeds industry standards 3 16 2 4 7 0 

Quality meets industry standards 2 18 1 4 7 0 

Product range 13 7 1 6 6 0 

Reliability of supply 12 7 2 6 5 0 

Technical support/service 14 7 0 6 5 0 

U.S. transportation costs1 5 15 1 2 8 1 

Veneer thickness 5 13 3 5 5 1 

1

 A rating of superior means that price/U.S. transportation costs is generally lower. For example, if a firm 

reported “U.S. superior,” it meant that the U.S. product was generally priced lower than the imported 

product. 

Note: S=first listed country’s product is superior; C=both countries’ products are comparable; I=first list 

country’s product is inferior. 

Source: Compiled from data submitted in response to Commission questionnaires. 
II‐20

Table II-11 

Hardwood plywood: Perceived interchangeability between hardwood plywood produced in the 

United States and in other countries, by country pairs 

 Number of U.S. 

producers reporting

Number of U.S. 

importers reporting 

Number of 

purchasers 

reporting 

Country pair A F S N A F S N A F S N 

U.S. vs. subject countries: 

 U.S. vs. China 4 2 1 0 3 4 24 9 2 11 18 4 

Non-subject countries 

comparisons: 

 

 U.S. vs. Canada 6 1 0 0 8 10 3 1 9 7 3 1 

 U.S. vs. Indonesia 1 2 2 1 1 4 15 11 2 4 9 7 

 U.S. vs. Russia 2 2 2 1 3 6 12 9 0 6 11 8 

 U.S. vs. other countries 1 0 1 1 0 2 4 2 0 1 5 2 

 China vs. Canada 3 3 1 0 2 1 15 2 0 4 11 2 

 China vs. Indonesia 2 1 1 1 2 7 18 1 2 7 6 3 

 China vs. Russia 2 1 2 0 2 2 17 6 2 3 10 5 

 China vs. other countries 1 0 1 0 0 2 5 2 0 2 5 0 

 Canada vs. Indonesia 1 2 2 1 1 4 9 6 1 1 8 4 

 Canada vs. Russia 2 2 2 0 1 4 8 6 0 3 9 5 

 Canada vs. other countries 1 0 1 0 0 1 4 0 0 0 3 0 

 Indonesia vs. Russia 1 0 2 1 0 2 7 12 0 2 7 8 

 Indonesia vs. other countries 1 0 0 1 0 2 7 0 0 1 6 0 

 Russia vs. other countries 1 0 1 0 0 2 2 4 1 0 3 2 

Note.—A=Always, F=Frequently, S=Sometimes, N=Never. 

Source: Compiled from data submitted in response to Commission questionnaires. 

One importer reported differences between domestic and Chinese product in the design

of the tongue and groove, the finishing, and the treatments. Another firm noted that Chinese

plywood is sized in millimeters while domestic plywood uses the Imperial System, and as a

result, the two cannot be mixed in the same application. Another importer reported that the

Chinese material is of adequate quality for certain finishing operations, but that higher end

cabinetry requires the thicker face veneer to achieve the required end quality on finish.27   One

importer reported that hardwood plywood from the United States, Canada, and Russia is of

higher quality and is more often interchangeable than product from other sources. This

 

27 It noted that it "does interchange U.S. and Chinese hardwood plywood for the purposes of supply

chain diversity and supply risk mitigation. However, the domestic supplier base does not offer a face

veneer in the 0.25 to 0.35 mm thickness range. Since the domestic producers do not slice veneer to the

lower spec, their veneer logs do not produce as many sheets of veneer. Unfortunately, this lowers the

amount of A grade faces available for sale by the domestic vendors, and forces face grade negotiations

(i.e, the kitchen cabinet manufacture is asked to sacrifice face grade versus the veneer thickness)."
II‐21

importer reported that product from China and Southeast Asia consistently lacks core

qualityleading to panels that warp and crackle when handled, and mold after use, and also

contain many holes and delaminate easily.  

U.S. producers reported that imports from nonsubject countries were not always

substitutable with domestic product because of differing wood species (Chile and Indonesia do

not have access to birch), densities, and prices. Another producer reported that Indonesian

product uses thin (3.0 mm to 5.2 mm) Luan Meranti plywood. Another producer reported that

Russian hardwood plywood has a different standard width and length and differing grade

standards than plywood from other sources.  

Importers and purchasers also reported differences in the type of product and wood

species of hardwood plywood from nonsubject countries and that available from U.S.

producers. One importer reported that Indonesian hardwood plywood uses tropical species

that are more stable and can be used to make thinner products (2.3 mm and 3.4 mm) than

what is produced in the United States. Another importer reported that Indonesian plywood is

mainly Meranti and complements domestic product, and that Russian plywood also

complements domestic product. Another importer reported that “South American products are

generally perceived to be well built structurally, but are always lacking in consistent face

quality.”   

As can be seen from table II‐12, just under one‐half of responding purchasers reported

that domestically‐produced product “always” met minimum quality specifications and almost

all responding producers indicated that it at least “usually” met minimum quality specifications.

Less than 20 percent of purchasers indicated that hardwood plywood imported from China

“always” met minimum quality specifications and over 80 percent of purchasers indicated that

it at least “usually” met minimum quality specification.   

More than two‐thirds of responding importers and purchasers, but less than half of U.S.

producers (3 of 7), found that differences other than price between U.S. and Chinese hardwood

plywood were “always” or “frequently” significant (table II‐13).  

Two U.S. producers noted that Chinese quality was lower than that of U.S. hardwood

lumber. Importers reported a number of differences other than price between domestic

products and Chinese products. Firms noted differences in sizes, veneer thickness, core species,

and quality (including Chinese lower quality). Several firms noted that customers may source

hardwood plywood offshore because domestic product is higher quality and has a thicker face

veneer than what is needed for certain applications, or conversely that Chinese thin‐veneered

product may not be suitable for some end users. One importer reported that China has a wide

range of product and makes timely deliveries while another reported that Chinese product is

shipped in containers rather than truckloads, with longer lead times, smaller product range, no

technical support, and no showrooms for builders/dealers. One importer reported that imports

from Chinese and Russian products are typically poplar and birch and are used for lower quality

applications such as apartments and rentals, whereas higher end applications use domestic red

oak, cherry, maple, fir, and pine. Other comments regarding comparisons with nonsubject

product include that the Russian and Indonesian products that are very different than domestic

product; Russian and Chinese have different cores and different sizes; and that Indonesian

panels are 2.7 mm to 3.4 mm thickness as a result of the tropical hardwood species used, and

that these products cannot be produced by domestic producers.
II‐22

Table II-12 

Hardwood plywood: Ability to meet minimum quality specifications, by source and number of 

reporting firms1 

 Number of firms reporting1

Source Always Usually Sometimes Rarely or never 

United States 15 18 1 0 

China 6 22 5 2 

Canada 7 10 1 0 

Indonesia 2 15 4 1 

Russia 9 10 3 0 

Other 1 0 7 0 0 

1

 Purchasers were asked how often domestically produced or imported hardwood plywood meets 

minimum quality specifications for their own or their customers’ uses.

Source: Compiled from data submitted in response to Commission questionnaires. 

Table II-13 

Hardwood plywood: Significance of differences other than price between hardwood plywood 

produced in the United States and in other countries, by country pair 

 Number of U.S. 

producers reporting 

Number of U.S. 

importers reporting 

Number of 

purchasers reporting 

Country pair A F S N A F S N A F S N 

U.S. vs. subject countries: 

 U.S. vs. China 3 0 4 0 20 11 7 0 14 10 10 0 

Non-subject countries 

comparisons: 

 

 U.S. vs. Canada 2 0 1 4 5 0 9 3 4 2 8 5 

 U.S. vs. Indonesia 1 1 4 0 12 6 11 0 7 5 6 2 

 U.S. vs. Russia 3 0 3 0 13 7 6 1 7 4 7 5 

 U.S. vs. other countries 0 0 2 0 3 3 2 0 4 0 3 0 

 China vs. Canada 1 1 4 0 7 4 6 0 5 4 5 1 

 China vs. Indonesia 0 1 4 0 5 6 15 1 2 1 10 4 

 China vs. Russia 1 0 3 0 9 2 12 0 5 2 10 2 

 China vs. other 

countries 

0 0 2 0 3 1 2 0 2 0 4 0 

 Canada vs. Indonesia 1 2 3 0 6 5 7 0 4 3 4 2 

 Canada vs. Russia 2 0 3 0 6 3 5 0 4 2 6 4 

 Canada vs. other 

countries 

0 0 2 0 1 1 1 0 0 0 4 0 

 Indonesia vs. Russia 0 0 3 0 6 2 8 0 5 2 7 2 

 Indonesia vs. other 

countries 

0 0 2 0 1 2 3 0 1 0 4 0 

 Russia vs. other 

countries 

0 0 2 0 1 2 1 1 1 0 4 0 

Note.--A = Always, F = Frequently, S = Sometimes, N = Never. 

Source: Compiled from data submitted in response to Commission questionnaires. 
II‐23

For the final phase of these investigations, the Commission collected data on U.S. and

Chinese production by type of material utilized for the face veneer and in the core and

shipments of U.S. and Chinese produced product and imports from China by thickness of the

product and the face veneer (See appendix D).  Chinese producers reported that almost 90

percent of exports to the United States in 2012 utilized hardwood veneer as the core material,

while U.S. producers indicated that about two‐thirds of domestically produced core material

utilized softwood veneers (table D‐1).  Domestic producers also used a greater proportion

(almost thirty percent) of “other” inputs such as MDF, lumber, etc. in 2012 as compared with 3

percent used by Chinese producers.  The data were similar for the other years and year‐to‐date

of the POI. According to public data, just over *** percent of North American produced panels

contain a veneer core (with most of the remainder split between an MDF or particleboard core

in 2012.28    

However, both U.S. and Chinese producers reported that they use hardwood as face

veneer for more than 90 percent of the hardwood plywood that they produce (table D‐2).

According to public data, in 2012 the most common species of the face veneer among panels

produced in North America were maple (*** percent), birch (*** percent), and red oak (***

percent).29    

U.S. producers reported that virtually all of domestically produced plywood utilized face

veneer thicknesses greater than 0.4 mm during the POI, with the vast majority (95 percent in

2012) manufactured with face veneers greater than 0.6 mm (table D‐3). In contrast, 99 percent

of Chinese importers’ commercial shipments utilized face veneers of less than 0.5 mm thick,

with the majority of shipments (93 percent) thinner than 0.4 mm. Chinese producers’ data also

indicate that over 90 percent of face veneer utilized in exports to the United States in 2012 was

less than 0.4 mm in thickness.   

U.S. market demand is also characterized by different thicknesses of plywood.30  

Typically, thicker plywood is used in cabinet fronts and sides whereas thinner plywood is used

for cabinet backs, drawer bottoms, paneling, and underlayment. In 2012, a greater proportion

of U.S. producers’ commercial shipments were reported to be in plywood thicknesses of at least

16 mm (58 percent) as compared with U.S. importers’ commercial shipments of imports from

China (21 percent) and Chinese producers’ U.S. exports (42 percent) (table D‐4).  U.S.

producers’ shipments of thin plywood of less than 6.5 mm in thickness accounted for 21

percent of the total in 2012 while U.S. importers’ commercial shipments of imports from China

represented 45 percent.  Chinese producers reported that plywood below 6.5 mm in thickness

represented 33 percent of exports to the United States.    

In commenting on whether the subject product is used differently than the domestic

product in the same applications, some purchasers indicated that hardwood plywood produced

in the United States and in China is not used differently while others indicated that it is often

used for different components, particularly in cabinets (see appendix E). Purchasers indicating

 

28 HPVA, Hardwood Stock Panels, Annual Statistical Report for Calendar Year 2012, p. 17.

29 Annual Statistical Report for Calendar Year 2012, p. 18.

30 Conference Transcript, p. 152 (Wilkinson); AAHP Postconference Brief, p. 12, 18‐19.
II‐24

that there is a difference noted that imports from China are typically used to produce the

interiors, backs and drawer bottoms of cabinets, while domestic product is used for cabinet

fronts and sides. Three purchasers pointed to differences in the core material and/or the

thinner veneer face of the subject product that make its more suitable for applications not

requiring sanding and finishing. Two purchasers noted that the subject product is better suited

for laminated applications. One purchaser commented that only domestic product is available

with no‐added formaldehyde.

Respondents assert that there is limited overlap in end‐uses between U.S‐produced

product and imports from China.  They indicate that although both U.S.‐and Chinese‐produced

product are both used to produce kitchen cabinets, the U.S.‐produced product serves the high‐

end segment and Chinese product serves a lower‐end market in which the wood is laminated or

painted.31 According to respondents, kitchen cabinet manufacturers use the domestic product

for the fronts of cabinets while the Chinese product may be used for cabinet backs, bottoms,

shelves, and drawer sides.32   Petitioners assert that although Chinese product was initially

present only in the low end of the market, in the last few years, imported Chinese product has

also competed in the high end of the market with panels made of walnut, oak, maple, and

cherry hardwood veneer from U.S. logs.33     

ELASTICITY ESTIMATES  

U.S. supply elasticity

The domestic supply elasticity34 for hardwood plywood measures the sensitivity of the

quantity supplied by U.S. producers to changes in the U.S. market price of hardwood plywood.

The elasticity of domestic supply depends on several factors including the level of excess

capacity, the ease with which producers can alter capacity, producers’ ability to shift to

production of other products, the existence of inventories, and the availability of alternate

markets for U.S.‐produced hardwood plywood. Analysis of these factors earlier indicates that

the U.S. industry is likely to be able to somewhat increase or decrease shipments to the U.S.

market; an estimate in the range of 4 to 8 is suggested.  

U.S. demand elasticity

The U.S. demand elasticity for hardwood plywood measures the sensitivity of the overall

quantity demanded to a change in the U.S. market price of hardwood plywood. This estimate

depends on factors discussed earlier such as the existence, availability, and commercial viability

of substitute products, as well as the component share of the hardwood plywood in the

 

31 AAHP postconference brief, pp. 27‐28.

32 AAHP postconference brief, p. 28.

33 Conference transcript, p. 37 (Clausen).

34 A supply function is not defined in the case of a non‐competitive market.
II‐25

production of any downstream products. Based on the available information, the aggregate

demand for hardwood plywood is likely to be inelastic; a range of ‐0.75 to ‐1.25 is suggested.  

Substitution elasticity

The elasticity of substitution depends upon the extent of product differentiation

between the domestic and imported products.35  Product differentiation, in turn, depends upon

such factors as quality (e.g., chemistry, appearance, et cetera) and conditions of sale (e.g.,

availability, sales terms/ discounts/ promotions, et cetera). Petitioners suggest that the

substitution elasticity should be higher, pointing to the nearly 48 percent Chinese share of

apparent consumption in 2012, the decline in market share following the filing of the

investigation, and the importance of price in response to purchaser questionnaires.36   

Substitutability is enhanced by the fact that price was a very important factor in

purchasing, but is constrained by quality being the most important factor for more purchasers.   

Also, there are clear differences in face thickness and core material between U.S.‐produced

product and subject imports from China. Veneer thickness is at least a somewhat important

purchasing factor for all responding purchasers and a very important factor for about 60

percent of purchasers.   Core material species was a very important factor to just under one‐

half of responding purchasers and at least a somewhat important factor to all but three

purchasers.  Also, over one‐half of responding purchasers indicated that U.S.‐produced product

was superior to Chinese imports in terms of delivery time, product range, technical

support/service, and veneer thickness. Therefore while the importance of price and some

overlap in panel thickness does suggest substitutability between U.S.‐produced product and

imports from China, this is moderated by the higher importance of quality and importance and

differences in veneer thickness and core material. Based on this information, the elasticity of

substitution between U.S.‐produced hardwood plywood and imported hardwood plywood is

likely to be in the range of 2 to 4.

 

35 The substitution elasticity measures the responsiveness of the relative U.S. consumption levels of

the subject imports and the domestic like products to changes in their relative prices. This reflects how

easily purchasers switch from the U.S. product to the subject products (or vice versa) when prices

change.

36 Petitioners’ prehearing brief, pp. 39‐40.

III‐1

PART III: U.S. PRODUCERS’ PRODUCTION, SHIPMENTS, AND

EMPLOYMENT

The Commission analyzes a number of factors in making injury determinations (see 19

U.S.C. §§ 1677(7)(B) and 1677(7)(C)). Information on the subsidies and sales at LTFV was

presented in Part I of this report and information on the volume and pricing of imports of the

subject merchandise is presented in Part IV and Part V. Information on the other factors

specified is presented in this section and/or Part VI and (except as noted) is based on the

questionnaire responses of nine firms that accounted for the nearly all of U.S. production of

hardwood plywood during 2012.

U.S. PRODUCERS

The Commission sent U.S. producer questionnaires to 21 firms based on information

contained in the petition.  Eight firms provided useable data on their manufacturing

operations.1 Staff believes that these responses represent nearly all of U.S. production of

hardwood plywood.  No tolling or production in foreign trade zones was reported.

Table III‐1 lists U.S. producers of hardwood plywood, their production locations,

positions on the petition, total production, and shares of total production.  

   

                                                      

1 ***.

As noted previously, ***.  *** as a related party, but excluded no other U.S. producer as related

party. Hardwood Plywood from China, Inv. Nos. 701‐TA‐490 and 731‐TA‐1204 (Preliminary), USITC

Publication 4361, November 2012, p. 9
III‐2

Table III‐1  

Hardwood plywood:  U.S. producers, positions on the petition, U.S. production locations, related

and/or affiliated firms, and shares of 2012 reported U.S. production

Firm

Position on

petition U.S. production location(s)

Related and/or

affiliated firms

Share of

reported

production

(percent)

Columbia Forest Products1 Petitioner

Old Fort, NC; Klamath Falls,

OR; Chatham, VA; Truman,

AR; Craigsville, WV *** ***

Commonwealth Plywood Co., Ltd.2 Petitioner Whitehall, NY *** ***

Darlington Veneer Company, Inc. *** Darlington, SC *** ***

Mt. Baker Products, Inc 3 *** Bellingham, WA *** ***

Murphy Plywood Petitioner Eugene, OR *** ***

Owl Hardwood Lumber & Plywood

Inc.4 *** Des Plaines, IL *** ***

Pittsburgh Forest Products, Inc.6 *** McMurray, PA; Vienna, OH *** ***

Roseburg Forest Products Co.7 Petitioner Roseburg, OR *** ***

S.J. Morse Company *** Capon Bridge, WV *** ***

States Industries LLC 8 Petitioner Eugene, OR *** ***

Timber Products Company 9 Petitioner

Corinth, MS; Grants Pass,

OR; Medford, OR *** ***

     1 “***."

     2 “***.”

     3 “***.”

     4 “***.”

     5 Less than 0.5 percent.

     6 “***.”  Have not produced any hardwood plywood since early 2011.  Pittsburgh’s producer questionnaire response from the preliminary

phase of these investigations.

     7 ***.

     8 “***.”

     9 “***”

Source:  Compiled from data submitted in response to Commission questionnaires.

   
III‐3

As indicated in table III‐1, two U.S. producers are related to foreign producers of

nonsubject merchandise and two are related to U.S. importers of hardwood plywood, as

discussed in greater detail later in this section.

U.S. PRODUCTION, CAPACITY, AND CAPACITY UTILIZATION

Table III‐2 presents U.S. producers’ production, capacity, and capacity utilization.  

Producers were asked to comment on constraints to their capacity and production levels and

their comments follow.

Table III-2 

Hardwood plywood: U.S. producers’ production, capacity, and capacity utilization, 2010-2012, 

January-June 2012 and January-June 2013

Item 

Year January-June 

2010 2011 2012 2012 2013 

Capacity (1,000 square feet) 1,325,400 1,326,713 1,310,545 658,356 645,470

Production (1,000 square feet) 587,674 619,820 669,339 338,138 383,296

Capacity utilization (percent). 44.3 46.7 51.1 51.4 59.4

Source: Compiled from data submitted in response to Commission questionnaires.

Columbia (***) stated, “***.”  Commonwealth (***) cited the ***.  Darlington Veneer

(***) stated, “***.”

Mt. Baker Products (*** stated, “***.”  Murphy (***) stated, “***.”  Owl (***, cited

***.  S.J. Morse (***) had ***.”  States (***) reported that it, “***.”  Roseburg *** did not  list

any constraints.  ***.  Timber Products (***) stated, “***.”  “***.”

U.S. PRODUCERS’ U.S. SHIPMENTS AND EXPORTS

Data on U.S. producers’ shipments of hardwood plywood are presented in table III‐3.  

Over the period of investigation, U.S. commercial shipments accounted for the vast majority of

U.S. producers' shipments.  Between 2010 and 2012, the quantity and value of U.S. producers'

U.S. shipments increased.

*** reported transfers to related firms.  *** reported exports to ***.
III‐4

Table III-3 

Hardwood plywood: U.S. producers’ U.S. shipments, exports shipments, and total shipments, 

2010 2012, January-June 2012 and January-June 2013

Item 

Calendar year January-June 

2010 2011 2012 2012 2013 

Quantity (1,000 square feet) 

Commercial shipments 551,962 577,270 615,301 312,669 345,476

Internal consumption 4,574 4,656 8,649 2,793 5,723

Transfers to related firms 8,945 12,822 18,252 8,383 14,974

 U.S. shipments 565,481 594,748 642,202 323,845 366,173

Export shipments 21,961 24,040 25,245 10,722 13,741

 Total 587,442 618,788 667,447 334,567 379,914

Value ($1,000) 

Commercial shipments 614,459 651,753 690,152 353,800 402,802

Internal consumption 5,017 5,048 9,025 3,090 6,458

Transfers to related firms 9,903 14,646 20,384 9,645 17,457

 U.S. shipments 629,379 671,447 719,561 366,535 426,717

Export shipments 24,327 28,180 29,160 13,802 16,010

 Total 653,706 699,627 748,721 380,337 442,727

Unit value (dollars per square foot) 

Commercial shipments $1.11 $1.13 $1.12 $1.13 $1.17

Internal consumption 1.10 1.08 1.04 1.11 1.13

Transfers to related firms 1.11 1.14 1.12 1.15 1.17

 U.S. shipments 1.11 1.13 1.12 1.13 1.17

Export shipments 1.11 1.17 1.16 1.29 1.17

 Average 1.11 1.13 1.12 1.14 1.17

Share of shipment quantity (percent) 

Commercial shipments 94.0 93.3 92.2 93.5 90.9

Internal consumption 0.8 0.8 1.3 0.8 1.5

Transfers to related firms 1.5 2.1 2.7 2.5 3.9

 U.S. shipments 96.3 96.1 96.2 96.8 96.4

Export shipments 3.7 3.9 3.8 3.2 3.6

 Total 100.0 100.0 100.0 100.0 100.0

Source: Compiled from data submitted in response to Commission questionnaires.

U.S. PRODUCERS’ INVENTORIES

Table III‐4 presents U.S. producers’ end‐of‐period inventories and the ratio of these

inventories to U.S. producers’ production, U.S. shipments, and total shipments over the period

examined.
III‐5

Table III-4 

Hardwood plywood: U.S. producers’ inventories, 2010-2012, January-June 2012 and January-June 

2013

Item 

Year January-June 

2010 2011 2012 2012 2013

Inventories (1,000 square feet) 34,495 35,478 37,350 39,186 41,046

Ratio to production (percent) 5.9 5.7 5.6 5.8 5.4

Ratio to U.S. shipments (percent) 6.1 6.0 5.8 6.1 5.6

Ratio to total shipments (percent) 5.9 5.7 5.6 5.9 5.4

Source: Compiled from data submitted in response to Commission questionnaires.

U.S. PRODUCERS’ IMPORTS AND PURCHASES

One firm reported imports of hardwood plywood from China , five firms reported

purchases of hardwood plywood from China and six reported purchases from nonsubject

sources that include Canada, Chile, Indonesia, and Russia.  U.S. producers’ imports and

purchases of hardwood plywood (as well as reasons for importing and purchasing) are

presented in table III‐5.

Table III-5 

Hardwood plywood: U.S. producers’ U.S. production, imports and purchases, 2010-2012, JanuaryJune 2012 and January-June 2013 

*            *            *            *            *            *            *

U.S. EMPLOYMENT, WAGES, AND PRODUCTIVITY

Table III‐6 shows U.S. producers’ employment‐related data during the period examined.

Table III-6 

Hardwood plywood: Average number of production and related workers, hours worked, wages 

paid to such employees, hourly wages, productivity, and unit labor costs, 2010-2012, JanuaryJune 2012 and January-June 2013

Item 

Year January-June 

2010 2011 2012 2012 2013

PRWs (number) 1,753 1,799 1,868 1,829 1,944

Hours worked (1,000) 3,768 3,937 4,101 2,086 2,202

Wages paid ($1,000) 65,108 66,193 72,170 35,597 38,999

Hourly wages $17.28 $16.81 $17.60 $17.06 $17.71

Productivity (square feet per hour) 156.0 157.4 163.2 162.1 174.1

Unit labor costs (per square foot) $0.11 $0.11 $0.11 $0.11 $0.10

Source: Compiled from data submitted in response to Commission questionnaires.

IV‐1

PART IV: U.S. IMPORTS, APPARENT U.S. CONSUMPTION, AND MARKET

SHARES

U.S. IMPORTERS

Importer questionnaires were sent to 150 firms believed to be importers of subject

hardwood plywood, as well as to all identified U.S. producers of hardwood plywood.  Usable

questionnaire responses were received from 42 companies, representing 66.3 percent of total

imports from China, as reported by official Commerce statistics, between January 2010 and

June 2013; nearly 70 percent in 2012.  One firm reported no imports from China, 9 firms

reported imports from China alone, and the remaining 32 firms reported subject imports from

China as well as the following countries: Brazil, Chile, Indonesia, Malaysia, Romania, Russia,

Uruguay, and Vietnam.

U.S. IMPORTS

Table IV‐1 presents data for U.S. imports of hardwood plywood from China and all other

sources.  During the POI, the amount of U.S. imports from China increased by nearly 300 million

square feet, or about 21 percent, while U.S. imports from nonsubject countries decreased by

163 million square feet, or about 13 percent.  However, the January‐June 2013 period shows a

decrease in imports from China by nearly 215 million square feet, and an increase in imports

from nonsubject countries by nearly 89 million square feet.
IV‐2

Table IV-1 

Hardwood plywood: U.S. imports by source, 2010-2012, January-June 2012, and January-June 

2013 

Item 

Year January-June 

2010 2011 2012 2012 2013 

Quantity (1,000 square feet) 

China 1,376,408 1,534,788 1,671,686 749,534 535,027

All other sources 1,339,454 1,218,331 1,175,958 623,447 712,119

 Total 2,715,863 2,753,119 2,847,644 1,372,982 1,247,146

 Value ($1,000)

1

China 735,648 707,283 828,974 390,662 265,003

All other sources 700,680 632,728 677,187 350,567 395,866

 Total 1,436,328 1,340,011 1,506,161 741,229 660,868

Unit value (dollars per square foot) 

China 0.53 0.46 0.50 0.52 0.50

All other sources 0.52 0.52 0.58 0.56 0.56

 Total 0.53 0.49 0.53 0.54 0.53

Share of quantity (percent)

China 50.7 55.7 58.7 54.6 42.9

All other sources 49.3 44.3 41.3 45.4 57.1

 Total 100.0 100.0 100.0 100.0 100.0

Share of value (percent) 

China 51.2 52.8 55.0 52.7 40.1

All other sources 48.8 47.2 45.0 47.3 59.9

 Total 100.0 100.0 100.0 100.0 100.0

Source: Compiled from official Commerce statistics. 

NEGLIGIBILITY

The statute requires that an investigation be terminated without an injury

determination if imports of the subject merchandise are found to be negligible.1 Negligible

imports are generally defined in the Tariff Act of 1930, as amended, as imports from a country

of merchandise corresponding to a domestic like product where such imports account for less

than 3 percent of the volume of all such merchandise imported into the United States in the

most recent 12‐month period for which data are available that precedes the filing of the

petition or the initiation of the investigation. However, if there are imports of such merchandise

from a number of countries subject to investigations initiated on the same day that individually

account for less than 3 percent of the total volume of the subject merchandise, and if the

imports from those countries collectively account for more than 7 percent of the volume of all

such merchandise imported into the United States during the applicable 12‐month period, then

imports from such countries are deemed not to be negligible.  Subject imports from China

 

1 Sections 703(a)(1), 705(b)(1), 733(a)(1), and 735(b)(1) of the Act (19 U.S.C. §§ 1671b(a)(1),

1671d(b)(1), 1673b(a)(1), and 1673d(b)(1)).
IV‐3

accounted for 56.5 percent of total hardwood plywood imports between September 2011 and

August 2012 and 58.7 percent of total imports of hardwood plywood by quantity during 2012.

APPARENT U.S. CONSUMPTION  

Table IV‐2 and figure IV‐1 presents data on apparent U.S. consumption and U.S. market

shares for hardwood plywood over the period examined.  Both U.S. producers’ U.S. shipments

and U.S. imports from China increased during the period of investigation, while imports from

nonsubject countries decreased.  Imports from nonsubject countries land U.S. producers’

shipments increased during the January‐June 2012‐13 periods, while subject imports from

China decreased.   Apparent US consumption has increased throughout the 2010‐12, but was

lower in interim 2013 than interim 2012.

Table IV-2 

Hardwood plywood: U.S. shipments of domestic product, U.S. shipments of imports, and apparent 

U.S. consumption, 2010-2012, January-June 2012, and January-June 2013

Item 

Year January-June 

2010 2011 2012 2012 2013 

Quantity (1,000 square feet) 

U.S. producers' shipments 565,481 594,748 642,202 323,845 366,173

U.S. imports from-- 

 China 1,376,408 1,534,788 1,671,686 749,534 535,027

 All other sources 1,339,454 1,218,331 1,175,958 623,447 712,119

 Total U.S. imports 2,715,863 2,753,119 2,847,644 1,372,982 1,247,146

Apparent consumption 3,281,344 3,347,867 3,489,846 1,696,827 1,613,319

Value ($1,000)

1

U.S. producers' shipments 629,379 671,447 719,561 366,535 426,717

U.S. imports from-- 

 China 735,648 707,283 828,974 390,662 265,003

 All other sources 700,680 632,728 677,187 350,567 395,866

 Total U.S. imports 1,436,328 1,340,011 1,506,161 741,229 660,868

Apparent consumption 2,065,707 2,011,458 2,225,722 1,107,764 1,087,585

Source: Compiled from data submitted in response to Commission questionnaires and official Commerce 

statistics. 
IV‐4

Figure IV-1 

Hardwood plywood: Apparent U.S. consumption, by sources, 2010-12, January-June 2012, and 

January-June 2013 

2010

2011

2012 Jan-Jun 2012

Jan-Jun 2013

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

3,000,000

3,500,000

All others China U.S. shipments

Source: Table IV-2.
IV‐5

U.S. MARKET SHARES  

U.S. market share data are presented in table IV‐3.  U.S. producers’ market share

increased 2010 to 2012 and then was higher in interim 2013 compared with interim 2012.  The

market share of imports from China increased steadily from 41.9 percent in 2010 to

47.9 percent in 2012.  Interim 2013 data indicate an decrease in market share for Chinese

imports compared with interim 2012, while imports from nonsubject sources show an increase

in market share for interim 2013.

Table IV-3 

Hardwood plywood: U.S. consumption and market shares, 2010-2012, January-June 2012, and 

January-June 2013 

Item 

Year January-June 

2010 2011 2012 2012 2013 

Quantity (1,000 square feet)

Apparent consumption 3,281,344 3,347,867 3,489,846 1,696,827 1,613,319

Value (1,000 dollars)

Apparent consumption 2,065,707 2,011,458 2,225,722 1,107,764 1,087,585

Share of quantity (percent) 

U.S. producers' shipments 17.2 17.8 18.4 19.1 22.7

U.S. imports from-- 

 China 41.9 45.8 47.9 44.2 33.2

 All other sources 40.8 36.4 33.7 36.7 44.1

 Total U.S. imports 82.8 82.2 81.6 80.9 77.3

Share of value (percent) 

U.S. producers' shipments 30.5 33.4 32.3 33.1 39.2

U.S. imports from-- 

 China 35.6 35.2 37.2 35.3 24.4

 All other sources 33.9 31.5 30.4 31.6 36.4

 Total U.S. imports. 69.5 66.6 67.7 66.9 60.8

Source: Compiled from data submitted in response to Commission questionnaires and official Commerce 

statistics. 
IV‐6

RATIO OF IMPORTS TO U.S. PRODUCTION

Table IV‐4 presents data on the ratio of U.S. imports to U.S. production.

Table IV-4 

Hardwood plywood: Ratio of U.S. imports to U.S. production, 2010-2012, January-June 2012, and 

January-June 2013 

Item 

Year January-June 

2010 2011 2012 2012 2013 

Quantity (1,000 square feet)

U.S. production 587,674 619,820 669,339 338,138 383,296

Imports from: 

 China 1,376,408 1,534,788 1,671,686 749,534 535,027

 All other sources 1,339,454 1,218,331 1,175,958 623,447 712,119

 Total 2,715,863 2,753,119 2,847,644 1,372,982 1,247,146

Ratio of imports to U.S. production quantity (percent) 

China 234.2 247.6 249.8 221.7 139.6

All other sources 227.9 196.6 175.7 184.4 185.8

 Total 462.1 444.2 425.4 406.0 325.4

Source: Compiled from data submitted in response to Commission questionnaires and official Commerce 

statistics. 
V‐1

PART V: PRICING DATA

FACTORS AFFECTING PRICES

Raw material costs

Raw material costs were close to 80 percent of U.S. producers’ total cost of goods sold

during 2010 to 2012. Logging prices increased by 16 percent over the period January 2010‐

August 2013, while hardwood veneer prices decreased by 1 percent (figure V‐1).

U.S. producers and importers reported that increases in raw material prices were the

result of various factors including increases in the prices of logs, MDF, imported platforms,

composite core materials, softwood veneers, veneer cores, and resin. Firms reported that rising

demand in the United States and abroad for raw materials, including increased Chinese demand

for logs, and curtailments in hardwood and softwood veneer availability, contributed to

increased raw material prices. Firms also reported increased costs for labor and freight.

U.S. inland transportation costs

All responding producers and most importers reported that they typically arrange

transportation to their customers. U.S. producers’ U.S. inland transportation costs ranged from

3 to 12 percent, while all but one importer reported costs ranging from less than one percent

up to 7 percent.1

PRICING PRACTICES

Pricing methods

All U.S. producers and most importers reported using transaction‐by‐transaction

negotiations to determine hardwood plywood prices (table V‐1). Some firms also reported

using contracts and set price lists. The majority of sales by both U.S. producers and importers of

Chinese product were on a spot basis (table V‐2).  Ten purchasers reported that they purchase

product daily, 20 purchase weekly, and nine purchase monthly and one purchases quarterly.  

                                                      

1 One importer reported costs of 15 percent.
V‐2

Figure V-1 

Logging and hardwood veneer and plywood: Producer price indices, monthly, January 2010-

August 2013 

Source: Bureau of Labor Statistics, http://data.bls.gov/cgi-bin/dsrv, retrieved October 23, 2013. 

Table V-1 

Hardwood plywood: U.S. producers and importers reported price setting methods, by number of 

responding firms1 

 Number of firms1

Method U.S. producers Importers 

Transaction-by-transaction 8 34 

Contract 4 14 

Set price lists 3 5 

Other 0 2 

1

The sum of responses down will not add up to the total number of responding firms, as each firm was 

instructed to check all applicable price setting methods employed. 

Source: Compiled from data submitted in response to Commission questionnaires.
V‐3

Table V-2 

Hardwood plywood: U.S. producers’ and importers’ shares of U.S. commercial shipments by type 

of sale, 2012 

 Share of 2012 commercial shipment (percent) 

Item U.S. producers Importers 

Long-term contract 1.9 ***

Short-term contract 18.4 ***

Spot sales 79.7 ***

Note.--Because of rounding, figures may not add to the totals shown. 

Source: Compiled from data submitted in response to Commission questionnaires.

Sales terms and discounts

U.S. producers and importers quote prices on both an f.o.b. and a delivered basis.  

About one‐half of responding producers (three of seven) reported no discounts, although 2

offered quantity discounts, 3 offered annual volume  discounts, and two offered other

discounts (for early payment). Most importers (28 of 38) reported no discounts, although two

reported quantity discounts, four reported annual volume discounts, and eight reported other

discounts (including early payment discounts and rebates to a single customer). About one‐half

or responding U.S. producers and importers reported sales terms of net 30 days.  Many of the

remaining U.S. producers and importers reported selling on sales terms of net 10 days, and

some reported selling on other terms varying from net 15 days to net 60 days.

Price leadership

Most purchasers reported that there are price leaders in the U.S. market for hardwood

plywood. Columbia Forest Products was named as a price leader most frequently by purchasers

and Far East American, Liberty, Roseburg, and Timber Products were also named by several

purchasers. Several purchasers distinguished between domestic and import price leader. One

purchaser (***) indicated that the six large producers in North American take turns as price

leaders, but that there are no price leaders among importers.    

PRICE DATA

The Commission requested U.S. producers and importers to provide quarterly data for

the total quantity and f.o.b. value of the following hardwood plywood products shipped to

unrelated U.S. customers during January 2010‐June 2013:

Product 1.‐‐ 12 mm (1/2") thickness (actual or nominal), 4x8 panel size, Birch face

(whether white birch, natural birch or artisan birch; whole piece), face Grade
V‐4

C/D+ or substantially equivalent, Birch back (whether white birch, natural birch

or artisan birch), back grade 2/3 or substantially equivalent, veneer core,

unfinished.

Product 2.‐‐ 12 mm (1/2") thickness (actual or nominal), 4x8 panel size, Birch face

(whether white birch, natural birch or artisan birch; whole piece), face Grade

C/D+ or substantially equivalent, Birch back (whether white birch, natural birch

or artisan birch), back grade 2/3 or substantially equivalent, veneer core,

prefinished.

Product 3.‐‐ 18 mm (3/4") thickness (actual or nominal), 4x8 panel size, Birch face

(whether white birch, natural birch or artisan birch), face Grade C/D+ or

substantially equivalent, Birch back (whether white birch, natural birch or artisan

birch), back grade 2/3 or substantially equivalent, veneer core, unfinished.  

Product 4.‐‐ 5.2 mm (1/4")  thickness (actual or nominal), 4x8 panel size, Maple face

(whether plain or rotary sliced), face Grade B or substantially equivalent, Maple

back (whether plain or rotary sliced), back grade 2/3 or substantially equivalent,

veneer core, unfinished.    

Product 5.‐‐ 18 mm (3/4") thickness (actual or nominal), 4x8 panel size, Birch face

(whether white birch, natural birch or artisan birch), face Grade C/D+ or

substantially equivalent, Birch back (whether white birch, natural birch or artisan

birch), back grade 2/3 or substantially equivalent, veneer core, prefinished.  

Product 6.‐‐ 5.2 mm (1/4”) thickness (actual or nominal), 4x8 panel size, Birch face

(whether plain or rotary sliced), face Grade C or substantially equivalent, back

face of Birch or other, Grade 2/3 or substantially equivalent, veneer core,

unfinished.

Five U.S. producers and 32 importers of Chinese hardwood plywood provided usable

pricing data for sales of the requested products, although not all firms reported pricing for all

products for all quarters. Pricing data reported by these firms accounted for 7 percent of U.S.

producers’ shipments of hardwood plywood and *** percent of U.S. shipments of subject

imports from China during January 2010‐June 2013.

Price data for domestic and subject import shipments of products 1‐6 are presented in

tables V‐3 to V‐8 and figure V‐2. Nonsubject country prices are presented in Appendix F.  
V‐5

Table V-3 

Hardwood plywood: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 11

 and margins of underselling/(overselling), by quarters, January 2010-June 2013 

Period 

United States China 

Price 

($ per square 

foot) 

Quantity

(1,000 square 

feet) 

Price

($ per square 

foot) 

Quantity 

(1,000 square 

feet) 

Margin 

(percent) 

2010: 

Jan.-Mar. 0.85 1,659 *** *** ***

Apr.-June 0.87 1,278 *** *** ***

July-Sept. 0.87 1,010 *** *** ***

Oct.-Dec. 0.90 1,087 *** *** ***

2011: 

Jan.-Mar. 0.88 1,348 *** *** ***

Apr.-June 0.86 1,382 *** *** ***

July-Sept. 0.87 1,709 *** *** ***

Oct.-Dec. *** *** *** *** ***

2012: 

Jan.-Mar. *** *** *** *** ***

Apr.-June *** *** *** *** ***

July-Sept. *** *** *** *** ***

Oct.-Dec. *** *** *** *** ***

2013: 

Jan.-Mar. 0.84 2,089 *** *** ***

Apr.-June 0.88 2,012 *** *** ***

1

 Product 1: 12 mm (1/2") thickness (actual or nominal), 4x8 panel size, Birch face (whether white birch, 

natural birch or artisan birch; whole piece), face Grade C/D+ or substantially equivalent, Birch back 

(whether white birch, natural birch or artisan birch), back grade 2/3 or substantially equivalent, veneer 

core, unfinished.

Source: Compiled from data submitted in response to Commission questionnaires.
V‐6

Table V-4 

Hardwood Plywood: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 21

 and margins of underselling/(overselling), by quarters, January 2010-June 2013 

Period 

United States China 

Price 

($ per square 

foot) 

Quantity

(1,000 square 

feet) 

Price

($ per square 

foot) 

Quantity 

(1,000 square 

feet) 

Margin 

(percent) 

2010: 

Jan.-Mar. 1.07 111 *** *** ***

Apr.-June *** *** *** *** ***

July-Sept. *** *** *** *** ***

Oct.-Dec. 1.05 85 *** *** ***

2011: 

Jan.-Mar. 1.34 114 *** *** ***

Apr.-June *** *** *** *** ***

July-Sept. *** *** *** *** ***

Oct.-Dec. 1.03 113 *** *** ***

2012: 

Jan.-Mar. *** *** *** *** ***

Apr.-June *** *** *** *** ***

July-Sept. *** *** *** *** ***

Oct.-Dec. *** *** *** *** ***

2013: 

Jan.-Mar. *** *** *** *** ***

Apr.-June *** *** *** *** ***

1

 Product 2: 12 mm (1/2") thickness (actual or nominal), 4x8 panel size, Birch face (whether white birch, 

natural birch or artisan birch; whole piece), face Grade C/D+ or substantially equivalent, Birch back 

(whether white birch, natural birch or artisan birch), back grade 2/3 or substantially equivalent, veneer 

core, prefinished. 

Source: Compiled from data submitted in response to Commission questionnaires.
V‐7

Table V-5 

Hardwood Plywood: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 31

 and margins of underselling/(overselling), by quarters, January 2010-June 2013 

Period 

United States China 

Price 

($ per square 

foot) 

Quantity

(1,000 square 

feet) 

Price

($ per square 

foot) 

Quantity 

(1,000 square 

feet) 

Margin 

(percent) 

2010: 

Jan.-Mar. 0.98 9,414 *** *** ***

Apr.-June 1.00 7,678 *** *** ***

July-Sept. 1.01 6,045 *** *** ***

Oct.-Dec. 1.00 7,661 *** *** ***

2011: 

Jan.-Mar. 1.01 8,348 *** *** ***

Apr.-June 1.01 7,254 *** *** ***

July-Sept. 1.00 7,906 *** *** ***

Oct.-Dec. 1.00 7,489 *** *** ***

2012: 

Jan.-Mar. 1.00 9,369 *** *** ***

Apr.-June 1.02 8,514 *** *** ***

July-Sept. 1.01 8,261 *** *** ***

Oct.-Dec. 1.01 7,815 *** *** ***

2013: 

Jan.-Mar. 1.03 7,524 *** *** ***

Apr.-June 1.10 7,461 *** *** ***

1

 Product 3: 18 mm (3/4") thickness (actual or nominal), 4x8 panel size, Birch face (whether white birch, 

natural birch or artisan birch), face Grade C/D+ or substantially equivalent, Birch back (whether white 

birch, natural birch or artisan birch), back grade 2/3 or substantially equivalent, veneer core, unfinished. 

Source: Compiled from data submitted in response to Commission questionnaires.
V‐8

Table V-6 

Hardwood Plywood: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 41

 and margins of underselling/(overselling), by quarters, January 2010-June 2013 

Period 

United States China 

Price 

($ per square 

foot) 

Quantity

(1,000 square 

feet) 

Price

($ per square 

foot) 

Quantity 

(1,000 square 

feet) 

Margin 

(percent) 

2010: 

Jan.-Mar. *** *** 0.55 235 ***

Apr.-June 0.59 637 0.58 273 2.7

July-Sept. *** *** 0.55 257 ***

Oct.-Dec. *** *** 0.53 286 ***

2011: 

Jan.-Mar. *** *** 0.57 203 ***

Apr.-June *** *** 0.53 614 ***

July-Sept. *** *** 0.54 299 ***

Oct.-Dec. 0.63 415 0.55 310 12.9

2012: 

Jan.-Mar. 0.61 599 0.61 249 0.9

Apr.-June 0.65 695 0.60 224 7.9

July-Sept. 0.65 551 0.54 398 17.4

Oct.-Dec. 0.67 599 0.47 395 30.1

2013: 

Jan.-Mar. 0.66 757 0.58 150 12.6

Apr.-June 0.68 686 0.73 123 (7.9)

1

 Product 4: 5.2 mm (1/4") thickness (actual or nominal), 4x8 panel size, Maple face (whether plain or 

rotary sliced), face Grade B or substantially equivalent, Maple back (whether plain or rotary sliced), back 

grade 2/3 or substantially equivalent, veneer core, unfinished. 

Source: Compiled from data submitted in response to Commission questionnaires.
V‐9

Table V-7 

Hardwood Plywood: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 51

 and margins of underselling/(overselling), by quarters, January 2010-June 2013 

Period 

United States China 

Price 

($ per square 

foot) 

Quantity

(1,000 square 

feet) 

Price

($ per square 

foot) 

Quantity 

(1,000 square 

feet) 

Margin 

(percent) 

2010: 

Jan.-Mar. *** *** *** *** ***

Apr.-June *** *** *** *** ***

July-Sept. *** *** *** *** ***

Oct.-Dec. *** *** *** *** ***

2011: 

Jan.-Mar. 1.40 377 *** *** ***

Apr.-June 1.32 582 *** *** ***

July-Sept. 1.32 358 *** *** ***

Oct.-Dec. 1.33 299 *** *** ***

2012: 

Jan.-Mar. 1.23 470 *** *** ***

Apr.-June 1.24 431 *** *** ***

July-Sept. 1.26 431 *** *** ***

Oct.-Dec. *** *** *** *** ***

2013: 

Jan.-Mar. 1.20 529 *** *** ***

Apr.-June 1.33 387 *** *** ***

1

 Product 5: 18 mm (3/4") thickness (actual or nominal), 4x8 panel size, Birch face (whether white birch, 

natural birch or artisan birch), face Grade C/D+ or substantially equivalent, Birch back (whether white 

birch, natural birch or artisan birch), back grade 2/3 or substantially equivalent, veneer core, prefinished. 

Source: Compiled from data submitted in response to Commission questionnaires.
V‐10

Table V-8 

Hardwood Plywood: Weighted-average f.o.b. prices and quantities of domestic and imported 

product 61

 and margins of underselling/(overselling), by quarters, January 2010-June 2013 

Period 

United States China 

Price 

($ per square 

foot) 

Quantity

(1,000 square 

feet) 

Price

($ per square 

foot) 

Quantity 

(1,000 square 

feet) 

Margin 

(percent) 

2010: 

Jan.-Mar. 0.69 67 *** *** ***

Apr.-June 0.71 81 *** *** ***

July-Sept. *** *** *** *** ***

Oct.-Dec. *** *** *** *** ***

2011: 

Jan.-Mar. *** *** *** *** ***

Apr.-June *** *** *** *** ***

July-Sept. *** *** *** *** ***

Oct.-Dec. *** *** *** *** ***

2012: 

Jan.-Mar. *** *** *** *** ***

Apr.-June 0.56 693 *** *** ***

July-Sept. 0.56 261 *** *** ***

Oct.-Dec. 0.60 520 *** *** ***

2013: 

Jan.-Mar. 0.58 582 *** *** ***

Apr.-June 0.57 505 *** *** ***

1

 Product 6: 5.2 mm (1/4”) thickness (actual or nominal), 4x8 panel size, Birch face (whether plain or 

rotary sliced), face Grade C or substantially equivalent, back face of Birch or other, Grade 2/3 or 

substantially equivalent, veneer core, unfinished. 

Source: Compiled from data submitted in response to Commission questionnaires.

Figure V-2 

Hardwood plywood: Weighted-average prices and quantities of domestic and imported product, 

by quarters, January 2010-June 2013 

*            *            *            *           *            *            *
V‐11

Price trends

Prices for products imported from China increased during 2010 through the middle of

2013, while trends for U.S. produced price products were mixed. As shown in Table V‐9,

domestic price increases for products 1, 3, and 4 ranged from *** percent during 2010 to the

middle of 2013 while price declines for products 2, 5, and 6 ranged from *** percent. Increases

for imports from China ranged from 18 to 57 percent. Product 3 was the highest volume of the

six pricing products for U.S. producers and product 6 was the largest volume product for

imports from China.  

Price comparisons

As shown in table V‐10, prices for hardwood plywood imported from China were below

those for U.S.‐produced hardwood plywood in 83 of 84 instances; margins of underselling

ranged from 0.9 to 56.5 percent. In the remaining instance, prices for hardwood plywood from

China were 7.9 percent above the price for the domestic product.

Respondents argue that the underselling margins show that U.S. sales are almost

entirely isolated from movements in Chinese prices and volumes because they are almost

universally higher than equivalent Chinese product yet exhibit no impact from the lower

Chinese prices.2 They attribute the price differences to physical differences in product such as

thinner face veneer typically found in imports from China.3 Respondents cite an estimate by

***.4 They also argue that there is no impact on domestic prices since there is no

“convergence” as would be expected in substitutable products exhibiting consistent pricing

differences.5

                                                      

2 AAHP’s prehearing brief, pp. 81‐82.

3 AAHP’s prehearing brief, pp. 84. Hearing transcript, pp. 280‐281 (Rogers). 4 AAHP’s posthearing brief, exhibit 9. 5 AAHP’s prehearing brief, pp. 78‐79.
V‐12

Table V-9 

Hardwood plywood: Summary of weighted-average f.o.b. prices for products 1-6 from the United 

States and China 

Item 

Number of 

quarters 

Low price 

($ per square 

foot) 

High price 

($ per square 

foot) 

Change in 

price1

 (percent) 

Product 1 

United States 14 *** *** 3.0 

China 14 *** *** *** 

Product 2 

United States 14 *** *** ***

China 14 *** *** *** 

Product 3 

United States 14 0.98 1.10 11.9 

China 14 *** *** *** 

Product 4 

United States 14 *** *** *** 

China 14 0.47 0.73 34.6 

Product 5 

United States 14 *** *** ***

China 14 *** *** *** 

Product 6 

United States 14 *** *** (16.4)

China 14 *** *** *** 

1

 Percentage change from the first quarter in which data were available to the last quarter in which price 

data were available, based on rounded data.

Source: Compiled from data submitted in response to Commission questionnaires.

Table V-10 

Hardwood plywood: Instances of underselling/overselling by subject imports from China and the 

range and average of margins, by product, January 2010-June 2013 

Source 

Underselling Overselling 

Number of 

instances 

Range 

(percent) 

Average 

margin 

(percent) 

Number of 

instances 

Range 

(percent) 

Average 

margin 

(percent) 

Product 1 14 *** *** 0 - - 

Product 2 14 *** *** 0 - - 

Product 3 14 *** *** 0 - - 

Product 4 13 *** *** 1 7.9 7.9 

Product 5 14 *** *** 0 - - 

Product 6 14 *** *** 0 - - 

 Total 83 0.9 to 56.5 31.7 1 7.9 7.9 

Source: Compiled from data submitted in response to Commission questionnaires.
V‐13

Petitioners indicate that there is no difference in production cost between hardwood

plywood with a face veneer thickness of 0.6mm and a face veneer thickness of 0.4mm that

comes close to accounting for the margins of underselling.6 Citing data from ***.7 Petitioners

also indicate that importers reporting product with a thinner veneer in their pricing data

indicate that they consider thin‐veneer product to be competitive with domestic producers’

merchandise that otherwise has identical (or near‐identical) physical characteristics.8

  They also

indicate that price competition from subject imports in lower grade hardwood plywood has

forced U.S. producers to increase prices on higher graded hardwood plywood.9 Petitioners also

claim that Chinese product is gradually penetrating high value categories of the hardwood

plywood market.10

LOST SALES AND LOST REVENUE

The Commission requested U.S. producers of hardwood plywood to report any

instances of lost sales or revenues they experienced due to competition from imports of

hardwood plywood from China since January 1, 2009. Five of the eight responding U.S.

producers reported that they had to reduce prices, but only one of the six responding U.S.

producers reported having to roll back announced price increases. Seven of the eight

responding U.S. producers reported that they lost sales to lower‐priced imports from China.

Three U.S. producers reported specific lost sales allegations. These lost sales allegations

involved 9 purchasers and totaled $44.6 million and involved 36 million square feet of

hardwood plywood.11 No firm reported specific lost revenue allegations. Staff contacted all nine

purchasers to verify the allegations; five purchasers submitted responses. The lost sales  

allegations and purchaser responses are shown in table V‐11 (responses to specific allegations)

and in table V‐12 (responses to general questions).12   In response to the general questions, all

five responding purchasers reported that they had shifted purchases of hardwood plywood

from U.S. producers to subject imports since 2009; three of these purchasers reported that

                                                      

6 Petitioners’ posthearing brief, Response to Commissioners’ questions, p. 1 7 Petitioners’ posthearing brief, Response to Commissioners’ questions, pp. 1‐2 and exhibit 3.  The

***.

8 Petitioners’ prehearing brief, pp. 30‐31.

9 Petitioners’ prehearing brief, pp. 32‐33.

10 Petitioners’ posthearing brief, Response to Commissioners’ questions, p. 12, Exhibits 1 and 8.  In

exhibit 3, ***. 11 There was one additional allegation involving *** square feet of hardwood plywood that could not

be verified because contact information was not provided by the U.S. producer. 12 Purchasers responding to the lost sales allegations also were asked whether they shifted their

purchases of hardwood plywood from U.S. producers to suppliers of hardwood plywood from China

since 2009, and whether U.S. producers had reduced their prices in order to compete with suppliers of

hardwood plywood from China.
V‐14

price was the reason for the shift. One of the five purchasers reported that the U.S. producers

had reduced their prices in order to compete with the prices of subject imports since 2009.

***.

***.

Table V-11 

Hardwood plywood: U.S. producers’ lost sales allegations 

*            *            *            *           *            *            *

Table V-12 

Hardwood plywood: Purchaser responses regarding purchase shifting 

*            *            *            *           *            *          

***.    

***.
VI‐1

PART VI: FINANCIAL EXPERIENCE OF U.S. PRODUCERS

BACKGROUND

Eight firms provided usable financial data on their operations producing hardwood

plywood.1 These reported data are believed to represent the majority of production of

hardwood plywood in the United States in 2012.2 Reportedly the industry producing hardwood

plywood is concentrated following restructuring, including bankruptcies and plant closures, in

that five firms have a combined 70 percent market share.3

OPERATIONS ON HARDWOOD PLYWOOD

Income‐and‐loss data for U.S. producers of hardwood plywood are presented in table

VI‐1, and are briefly described here. Generally speaking, total net sales in both quantity and

dollar terms rose between 2010 and 2012 and were higher in January‐June 2013 than in

January‐June 2012.4 Total cost of goods sold (“COGS”) increased in absolute dollars, as a per‐

unit of sales, and as a ratio to net sales between 2010 and 2012, but was *** lower as a ratio to

sales in January‐June 2013 than in the same period one year earlier. Raw materials, which

increased with the increase in quantity sold, was the apparent driver behind the increase in

 

1 Eight firms provided usable financial data, compared with 21 firms identified in the petition. The

firms are: ***. These data are less than those presented in the preliminary phase because they do not

include the data of two firms: ***, but they do include ***. Each of the firms is privately held. Each of

the firms reported on a calendar year basis, including ***. ***. There are ***. 2 The share of U.S. production accounted for by members of the petitioning coalition was estimated

at approximately 80 percent in the preliminary phase of the investigation, similar to that ***.

Conference transcript, p. 7 (Levin).   3 At the staff conference in the preliminary phase of these investigations a spokesman for the

Hardwood Plywood and Veneer Association stated that the industry has shrunk due to bankruptcies and

plant closures. He stated that there were approximately 20 U.S. producers. Conference transcript, pp. 16

and 18 (Howlett) and table VI‐1. With respect to restructuring, ***, and***. Preliminary phase

questionnaire response of ***, section I‐2 and of ***, section II‐2. ***. Data for ***. The Commission

excluded *** as a related party, but excluded no other U.S. producer as a related party. Hardwood

Plywood from China, Inv. Nos. 701‐TA‐490 and 731‐TA‐1204 (Preliminary), USITC Publication 4361,

November 2012, p. 9. 4 The average unit value of sales was relatively unchanged from 2010 to 2012 even as sales volume

increased. The relative lack of price change was ascribed by petitioners as a function of product mix and

a reaction by U.S. firms to imports’ distortion of the pricing structure. They stated that the “domestic

producers increased prices in their higher‐grade products to offset the price cuts necessary in the lower‐

grade products where they faced the most aggressive price competition from subject imports.” The

increase in sales volume was ascribed in part to purchasers who prefer to or are required to purchase

U.S. origin as well as to U.S. producers’ willingness to cut prices on lower‐grade products to hold market

share. Petitioners’ posthearing brief, answers to Commissioners’ questions, pp. 17‐19.  
VI‐2

COGS. Selling, general, and administrative (“SG&A”) expenses increased in dollar terms from

2010 to 2012, stayed the same on a per‐unit basis, but were slightly lower as a ratio to sales

between the full yearly periods. SG&A expenses were higher in dollar terms in January‐June

2013 compared with January‐June 2012 but were lower when expressed as a ratio to sales.

Operating income irregularly decreased from 2010 to 2012 and was much higher in January‐

June 2013 than in January‐June 2012. Net income and cash flows declined between 2010 and

2012 and were higher in January‐June 2013 compared to January‐June 2012.
VI‐3

Table VI-1 

Hardwood plywood: Results of operations of U.S. producers, 2010-12, January-June 2012, and 

January-June 2012 

Fiscal years January-June 

Item 2010 2011 2012 2012 2013 

Quantity (1,000 square feet) 

Net sales: 

 Commercial sales 534,013 559,639 595,680 301,708 334,639

 Internal consumption1 *** *** *** *** ***

 Company transfers2 *** *** *** *** ***

 Total net sales 547,532 577,117 622,581 312,884 355,336

Value ($1,000) 

Net sales: 

 Commercial sales 595,259 633,357 669,413 344,011 390,323 

 Internal consumption1 *** *** *** *** ***

 Company transfers2 *** *** *** *** ***

 Total net sales 610,179 653,051 698,822 356,746 414,238 

Cost of goods sold: 

 Raw materials 442,036 480,549 518,346 265,220 303,995 

 Direct labor 59,580 64,534 68,819 34,876 37,138 

 Other factory costs 48,176 46,340 46,326 23,132 26,565 

 Total COGS 549,792 591,423 633,491 323,228 367,698 

Gross profit 60,387 61,628 65,331 33,518 46,540 

SG&A expenses 47,877 51,247 54,342 25,318 26,727 

Operating income or (loss) 12,510 10,381 10,989 8,200 19,813 

Total other 

income/(expense), net3

 (7,086) (2,106) (4,067) (2,547) (2,218)

Net income or (loss) 5,424 8,275 6,922 5,653 17,595 

Depreciation/amortization 12,758 10,525 11,101 5,781 5,223 

Cash flow 18,182 18,800 18,023 11,434 22,818 

Ratio to net sales (percent) 

COGS: 

 Raw materials 72.4 73.6 74.2 74.3 73.4

 Direct labor 9.8 9.9 9.8 9.8 9.0

 Other factory costs 7.9 7.1 6.6 6.5 6.4

 Total COGS 90.1 90.6 90.7 90.6 88.8

Gross profit 9.9 9.4 9.3 9.4 11.2

SG&A expenses 7.8 7.8 7.8 7.1 6.5

Operating income or (loss) 2.1 1.6 1.6 2.3 4.8

Table continued on the next page. 
VI‐4

Table VI-1--Continued

Hardwood plywood: Results of operations of U.S. producers, 2010-12, January-June 2012, and 

January-June 2012

Fiscal years January-June 

Item 2010 2011 2012 2012 2013 

Average unit value (dollars per square foot)

 4

Net sales: 

 Commercial sales 1.11 1.13 1.12 1.14 1.17 

 Internal consumption1 *** *** *** *** *** 

 Company transfers2 *** *** *** *** *** 

 Total net sales 1.11 1.13 1.12 1.14 1.16 

COGS: 

 Raw materials 0.81 0.83 0.83 0.85 0.86 

 Direct labor 0.11 0.11 0.11 0.11 0.10 

 Other factory costs 0.09 0.08 0.07 0.07 0.07 

 Total COGS 1.00 1.02 1.02 1.03 1.03 

Gross profit 0.11 0.11 0.10 0.11 0.13 

SG&A expenses 0.09 0.09 0.09 0.08 0.08 

Operating income 0.02 0.02 0.02 0.03 0.06 

Number of firms reporting:5

Operating losses *** 4 *** *** ***

Data 8 8 8 8 8

1

 Accounted for by ***. 

2 Accounted for by ***. 

3 Category includes interest expense, other expense, and other income. Other expense exceeded interest expense in 

each period, accounted for by a few firms: ***. 

4 ***. 

5 Firms reporting operating losses were: ***. 

Note.--***. 

Source: Compiled from data submitted in response to Commission questionnaires. 

In the preliminary phase of these investigations petitioners stated that they restructured

in certain ways as a result of subject imports, including cutting costs, closing plants, curtailing

production, and reducing employment or restructuring labor agreements. Petitioners also

stated that data gathered by the Commission reflects the impact of survivor bias. 5 Respondents

argued that questionnaire data gathered in the preliminary phase indicate that production,

 

5 Petitioners’ postconference brief, pp. 26‐27. Petitioners stated they cut costs chiefly in the

categories of labor and factory overhead because they are unable to raise prices due to underselling by

imports. Also, see U.S. producers’ questionnaire responses of ***, section II‐2. Petitioners also indicated

that sales of the lesser quality grades of hardwood plywood, which account for the majority of

production volume, have been undercut because subject imports dominate in those grades.
VI‐5

shipments, prices (the average unit values of sales), and operating income increased;6 that the

imported subject product differs from the domestic like product;7 and that the effect of the

2008 recession, not imports, necessitated the actions taken.8  

Five of the U.S. domestic producers purchased imported subject product from China.

These firms were ***.9 In each instance and collectively, the purchases ***.

Selected company‐specific financial data are presented in table VI‐2.  

Table VI-2 

Hardwood plywood: Results of operations of U.S. producers, by firm, 2010-12, January-June 2012, 

and January-June 2013 

* * * * * * * 

The cost of raw materials used in the production of hardwood plywood increased during

the period for which data were gathered on a dollar‐basis, as a ratio to sales (except interim

2013 was slightly lower than interim 2012), and on a per‐unit basis, as depicted in table VI‐1.

Such costs also increased as a share of total COGS from *** percent in 2010 to *** percent in

2012, and were *** percent in January‐June 2013 compared to *** percent in the same time

period one year earlier. The increase in these indicators was due in large part to the higher

quantity of sales between 2010 and 2012 as well as between January‐June 2012 to January‐

June 2013. “Domestic manufacturers predominantly purchase face veneers of hardwood and

softwood species either in the open market or from related parties. Some domestic

manufacturers purchase logs in the open market from which they peel veneers used for core

material.”10 11 According to petitioners, the vast majority of veneer cores, representing 70

percent of total core usage, are manufactured by the firm producing the hardwood plywood

panel while MDF and particleboard cores, representing 20 to 25 percent of usage, are

purchased on the outside market.12 Timber Products is integrated in that the firm harvests its

own timber used in the production of hardwood plywood; a spokesman testified that Timber

Products is one of the low cost producers in the industry and that the cost of manufacturing

 

6 AAHP postconference brief, p. 43. Also, see Chinese Producers’ Association postconference brief,

pp. 11‐12. 7 AAHP postconference brief, pp. 15‐20.

8 Respondents cited public statements regarding closures related to the 2008 recession by officials at

two *** firms named; they also stated that domestic producers have achieved gains in production

efficiency. AAHP postconference brief, p. 48.

9 Questionnaire responses, section II‐14 in these final phase investigations. Neither direct imports nor

purchases of imports are included in either the trade data or the financial data of these firms.

10 Petitioners’ postconference brief, “Answers to Commission Staff Questions,” p. 1. 11 Among *** purchases logs as well as other upstream raw materials like hardwood veneer. ***

purchases logs (for the manufacture of cores) and veneer for inner plies to supplement production; the

firm also ***. *** purchases hardwood veneers as well as ***. ***. E‐mail attachment from counsel to

petitioners to staff, October 28, 2012. EDIS document 495769, October 31, 2012. 12 Petitioners’ postconference brief, “Answers to Commission Staff Questions,” p. 1.
VI‐6

Hardwood plywood is primarily composed of raw materials.13 Timber Products also purchases

logs from independent sources. Questionnaire data indicate that the raw material costs ***.

Variance analysis

A variance analysis for the operations of U.S. producers of hardwood plywood is

presented in table VI‐3.14 The information for this variance analysis is derived from table VI‐1.

This indicates that the decrease in operating income between 2010 and 2012 was attributable

to an unfavorable net cost/expense variance (higher unit costs in COGS and SG&A expenses)

that was greater than the favorable price variance (higher average unit prices). Operating

income was higher in January‐June 2013 than in January‐June 2012 because each of the

variances was favorable, particularly because average unit sales prices were higher in the later

period.

 

13 Conference transcript, p. 38 (Clausen). In an e‐mail to staff, counsel to Timber Products noted ***.

E‐mail attachment from counsel to petitioners to staff, October 28, 2012.  EDIS document 495769,

October 31, 2012. 14 The Commission’s variance analysis is calculated in three parts:  Sales variance, cost of sales

variance (COGS variance), and SG&A expense variance. Each part consists of a price variance (in the case

of the sales variance) or a cost or expense variance (in the case of the COGS and SG&A expense

variance), and a volume variance. The sales or cost/expense variance is calculated as the change in unit

price or per‐unit cost/expense times the new volume, while the volume variance is calculated as the

change in volume times the old unit price or per‐unit cost/expense. Summarized at the bottom of the

table, the price variance is from sales; the cost/expense variance is the sum of those items from COGS

and SG&A variances, respectively, and the volume variance is the sum of the volume components of the

net sales, COGS, and SG&A expense variances. The overall volume component of the variance analysis is

generally small.
VI‐7

Table VI-3 

Hardwood plywood: Variance analysis on the operations of U.S. producers, between fiscaly years 

2010-12, and January-June 2012-13

Value ($1,000) 

Between fiscal years Jan.-June 

Item 2010-12 2010-11 2011-12 2012-13 

Net sales: 

 Commercial sales: 

 Price variance 5,664 9,629 (4,584) 8,790 

 Volume variance 68,640 28,523 40,736 37,510 

 Trade sales variance 74,304 38,152 36,152 46,300 

 Internal consumption: 

 Price variance *** *** *** *** 

 Volume variance *** *** *** *** 

 Trade sales variance *** *** *** *** 

 Company transfers: 

 Price variance *** *** *** *** 

 Volume variance *** *** *** *** 

 Transfer variance *** *** *** *** 

 Total net sales: 

 Price variance 5,276 10,003 (5,515) 9,124 

 Volume variance 83,517 32,923 51,382 48,356 

 Total net sales variance 88,793 42,926 45,867 57,480 

Cost of sales: 

 Cost variance (8,480) (11,938) 4,399 (646)

 Volume variance (75,269) (29,672) (46,538) (43,814)

 Total cost variance (83,749) (41,610) (42,139) (44,460)

Gross profit variance 5,044 1,316 3,728 13,020 

SG&A expenses: 

 Expense variance (3) (783) 841 2,021 

 Volume variance (6,535) (2,576) (4,020) (3,428)

 Total SG&A variance (6,538) (3,359) (3,179) (1,407)

Operating income variance (1,494) (2,043) 549 11,613 

Summarized as: 

 Price variance 5,276 10,003 (5,515) 9,124 

 Net cost/expense variance (8,483) (12,721) 5,240 1,374 

 Net volume variance 1,713 675 824 1,114 

Note: Unfavorable variances are shown in parentheses; all others are favorable. The data are comparable to changes 

in operating income as presented in table VI-1. 

Source: Compiled from data submitted in response to Commission questionnaires. 
VI‐8

CAPITAL EXPENDITURES AND RESEARCH AND DEVELOPMENT EXPENSES

Table VI‐4 presents capital expenditures and R&D expenses15 by firm.

Table VI-4 

Hardwood plywood: Capital expenditures and R&D expenses of U.S. producers, by firm, 2010-12, 

January-June 2012, and January-June 2013 

Fiscal years January-June 

Item 2010 2011 2012 2012 2013 

 Value ($1,000) 

Capital expenditures: 

 *** *** *** *** *** ***

 *** *** *** *** *** ***

 *** *** *** *** *** ***

 *** *** *** *** *** ***

 *** *** *** *** *** ***

 *** *** *** *** -*** ***

 *** *** *** *** *** ***

 *** *** *** *** *** ***

 Total 4,129 7,325 7,435 2,669 8,770

R&D expenses: 

 *** *** *** *** *** ***

 *** *** *** *** *** ***

 *** *** *** *** *** ***

 Total *** *** *** *** ***

Source: Compiled from data submitted in response to Commission questionnaires. 

Total capital expenditures were less than total depreciation expenses reported by the

industry in each period except interim 2013. Net capital expenditures (capital expenditures

minus depreciation expenses) were a negative $8.6 million in 2010, negative $3.2 million in

2011, negative $3.7 million in 2012, and negative $3.1 million in January‐June 2012. Capital

 

15 Capital expenditures reflect the current cost incurred by a firm to acquire or upgrade physical

assets such as property, plant, and equipment that have a useful life that is greater than the current

fiscal year. In accounting terms, the expense is capitalized when the asset is a newly purchased capital

asset or an investment that improves the useful life, productivity, or capacity of an existing asset. The

cost of a capital expenditure is spread over the useful life of the asset and the periodic (noncash)

expense is called depreciation in the case of fixed assets; in the case of intangible assets expensing over

time is called amortization, which is a current noncash expense. Costs that are not eligible to be

capitalized are expensed in the period in which they are incurred (“operating costs”). Because the future

benefit of most R&D is uncertain, R&D costs are generally expensed.  
VI‐9

expenditures exceeded depreciation expenses by $3.5 million in January‐June 2013.16 As a ratio

to total sales revenue, total capital expenditures were 0.7 percent in 2010, 1.1 percent in 2011

and 2012, 0.7 percent in January‐June 2012, and 2.1 percent in January‐June 2013. Capital

expenditures represented a much higher ratio to total operating income, ranging from 33.0

percent in 2010 to 70.6 percent in 2011, and the ratio was 44.3 percent in interim 2013.17  

Reporting firms made capital expenditures to purchase new equipment, to refurbish

existing equipment, and, in the case of Columbia, that firm ***.18 Reported purchases by

Columbia, Commonwealth and Murphy included a “***. Timber Products listed its capital

expenditures by year: ***. On the other hand, Roseburg stated that ***, while States indicated

that ***.  

ASSETS AND RETURN ON INVESTMENT

Table VI‐5 presents data on the U.S. producers’ total assets and their return on

investment (“ROI”). Operating income or (loss) was divided by total net assets, resulting in ROI.

 

16 Calculated from the data presented in tables VI‐1 and VI‐4. As noted earlier, capital expenditures

reflect the current cost of acquiring tangible assets, which are reflected in the firm’s records at historical

cost, and depreciation allocates that historical cost as an expense over the asset’s useful life. Capital

expenditures are unlikely to equal depreciation in an inflationary environment (the cost to replicate

assets, reflected in capital expenditures, may exceed the historical cost of acquiring those assets,

reflected in depreciation); in a deflationary environment (replication cost is lower than depreciation); or

as replacement of a part of the plant or a selected piece of equipment (capital expenditures for a part

are less than depreciation of the entirety). Also, improvements in asset productivity could result in lower

asset replication costs to replace depreciating assets leading to a situation where capital expenditures

are lower than depreciation expenses. 17 Calculated from the data presented in tables VI‐1 and VI‐4.

18 Columbia’s ***.
VI‐10

Table VI-5 

Hardwood plywood: U.S. producers’ total assets and return on investment, by firm, 2010-12

Fiscal years 

Item 2010 2011 2012 

Total Assets Value ($1,000) 

 *** *** *** ***

 *** *** *** ***

 *** *** *** ***

 *** *** *** ***

 *** *** *** ***

 *** *** *** ***

 *** *** *** ***

 *** *** *** ***

 Total 238,515 245,020 234,997

ROI Ratio of operating income to total assets (percent) 

 *** *** *** ***

 *** *** *** ***

 *** *** *** ***

 *** *** *** ***

 *** *** *** ***

 *** *** *** ***

 *** *** *** ***

 *** *** *** ***

 Average 5.2 4.2 4.7 

Note: Negative ROI is indicated in parentheses.

Source: Compiled from data submitted in response to Commission questionnaires. 

CAPITAL AND INVESTMENT

The Commission requested U.S. producers of hardwood plywood to describe any actual

or potential negative effects of imports of hardwood plywood from China on their firms’

growth, investment, ability to raise capital, development and production efforts, or the scale of

capital investments. Their responses are shown as follows.

Actual Negative Effects  

***: “Yes. Reduction in the size of capital investments. Other‐pricing deterioration and loss of

jobs.”

***: “Yes. Reduction in the size of capital investments. Other‐significant lower selling volumes

and depressed prices.”

***: “Yes. Cancellation, postponement, or rejection of expansion projects; reduction in the size

of capital investments; rejection of bank loans. Other—loss of business.”

***: “No.”

***: “No.”
VI‐11

***: “Yes. Other‐ Lost sales due to competition of low cost Chinese imported hardwood

plywood panels.”

***: “Yes. Denial or rejection of investment proposal; rejection of bank loans; lowering of credit

rating.” ***.

***: “Yes. Cancellation, postponement, or rejection of expansion projects; reduction in the size

of capital investments.”

Anticipated Negative Effects

***: “Yes. Continued price deterioration and job reductions.”

***: “Yes. Chinese plywood is imported and sold at half of our production cost.”

***: ***.

***: “Yes. We expect that the thin panel market will be negatively impacted due to artificially

lower prices and that lower‐end hardwood plywood cabinet manufacturers will continue to

order from Chinese exporters due to lower than market prices. We provide products in both of

these spaces and anticipate lower sales returns due to the unfair competitive pricing provided

by Chinese hardwood exporters.”  

***: “No.”

***: “Yes. Lost sales and revenue are due to our inability to compete with Chinese imported

hardwood plywood panels which were presented into the market below our costs.”

***: “Yes. Increased competition for commodity hardwood plywood will lower margin

opportunities.”

***: “Yes. Continued slow business climate ‐ contracted sales ‐ substituted by imports.”

VII‐1

PART VII: THREAT CONSIDERATIONS AND INFORMATION ON

NONSUBJECT COUNTRIES

Section 771(7)(F)(i) of the Act (19 U.S.C. § 1677(7)(F)(i)) provides that—

In determining whether an industry in the United States is threatened

with material injury by reason of imports (or sales for importation) of the

subject merchandise, the Commission shall consider, among other

relevant economic factors1‐‐ 

(I)    if a countervailable subsidy is involved, such information as may

be presented to it by the administering authority as to the nature

of the subsidy (particularly as to whether the countervailable

subsidy is a subsidy described in Article 3 or 6.1 of the Subsidies

Agreement), and whether imports of the subject merchandise are

likely to increase,

(II) any existing unused production capacity or imminent, substantial

increase in production capacity in the exporting country indicating

the likelihood of substantially increased imports of the subject

merchandise into the United States, taking into account the

availability of other export markets to absorb any additional

exports,

(III) a significant rate of increase of the volume or market penetration

of imports of the subject merchandise indicating the likelihood of

substantially increased imports,

(IV) whether imports of the subject merchandise are entering at prices

that are likely to have a significant depressing or suppressing

effect on domestic prices, and are likely to increase demand for

further imports,

(V) inventories of the subject merchandise,

                                                            

1 Section 771(7)(F)(ii) of the Act (19 U.S.C. § 1677(7)(F)(ii)) provides that “The Commission shall

consider {these factors} . . . as a whole in making a determination of whether further dumped or

subsidized imports are imminent and whether material injury by reason of imports would occur unless

an order is issued or a suspension agreement is accepted under this title. The presence or absence of

any factor which the Commission is required to consider . . . shall not necessarily give decisive guidance

with respect to the determination. Such a determination may not be made on the basis of mere

conjecture or supposition.”
VII‐2

(VI) the potential for product‐shifting if production facilities in the

foreign country, which can be used to produce the subject

merchandise, are currently being used to produce other products,

(VII) in any investigation under this title which involves imports of both

a raw agricultural product (within the meaning of paragraph

(4)(E)(iv)) and any product processed from such raw agricultural

product, the likelihood that there will be increased imports, by

reason of product shifting, if there is an affirmative determination

by the Commission under section 705(b)(1) or 735(b)(1) with

respect to either the raw agricultural product or the processed

agricultural product (but not both),

(VIII) the actual and potential negative effects on the existing

development and production efforts of the domestic industry,

including efforts to develop a derivative or more advanced version

of the domestic like product, and

(IX) any other demonstrable adverse trends that indicate the

probability that there is likely to be material injury by reason of

imports (or sale for importation) of the subject merchandise

(whether or not it is actually being imported at the time).2

Information on the nature of the subsidies was presented earlier in this report,

information on the volume and pricing of imports of the subject merchandise is presented in

Parts IV and V; and information on the effects of imports of the subject merchandise on U.S.

producers’ existing development and production efforts is presented in Part VI. Information on

inventories of the subject merchandise; foreign producers’ operations, including the potential

for “product‐shifting;” any other threat indicators, if applicable; and any dumping in third‐

country markets, follows. Also presented in this section of the report is information obtained

for consideration by the Commission on nonsubject countries.  

THE INDUSTRY IN CHINA

The petition identified hundreds of alleged producers of hardwood plywood in China.  

The California Air Resources Board (“CARB”) website identifies over 300 approved hardwood

                                                            

2 Section 771(7)(F)(iii) of the Act (19 U.S.C. § 1677(7)(F)(iii)) further provides that, in antidumping

investigations, “. . . the Commission shall consider whether dumping in the markets of foreign countries

(as evidenced by dumping findings or antidumping remedies in other WTO member markets against the

same class or kind of merchandise manufactured or exported by the same party as under investigation)

suggests a threat of material injury to the domestic industry.”
VII‐3

plywood mills in China.3

  The Commission emailed and faxed questionnaire requests to 350

firms and 89 firms (accounting for about 52.4 percent of 2012 U.S. imports of hardwood

plywood as reported by official Commerce statistics) responded.  Table VII‐1 presents data for

these firms during 2010‐12, January‐June 2012, January‐June 2013, and forecasts for 2013 and

2014.

The responses of the members of CNFPIA were submitted from both trading companies

and Chinese producers.  Each of the responses states whether the company is a producer or

just a trading company.  Because a great deal of the volume of the shipments of hardwood

plywood to the United States comes through the trading companies, CNFPIA made diligent

efforts to avoid double counting, so the Commission would have clean data for its

determination.  CNFPIA wanted to avoid having the producer count a shipment to a trading

company as a U.S. sale and then have the trading company count that sale again as a U.S. sale.  

CNFPIA did the following to avoid double‐counting:

1). Where a producer sold to trading companies, it did not report

such sales as U. S. sales but rather as domestic sales since the sales

were internal in China (the producers did not always know the final

destination of the product); the producers did fully report capacity

and production for the review periods in the normal manner.

2). The trading companies reported their shipments to various

markets but did not report any production or capacity (they are not

producers).

3). To the extent that producers sold directly to the United States

and not through trading companies they reported their shipments

as U. S. sales in their own responses.

4). To some extent, trading companies may have bought from some

producers in addition to those  reporting so their shipments are not

going to match exactly the production being reported.

Chinese capacity and production of hardwood plywood increased from 2010 to 2012,  

and are projected to increase from 2013 and 2014.  In terms of volume, there was an increase

in exports to the United States, starting at 623.5 million square feet  in 2010 and going up to

875.2 million square feet in 2012, and are projected to decrease for 2013 and 2014.

                                                            

3 Mills identified by CARB‐approved Third Party Certifiers as producers of CARB compliant hardwood

plywood products. List downloaded from:  http://www.arb.ca.gov/toxics/compwood/tpc/listofmills.htm

(accessed October 21, 2013).
VII‐4

Table VII-1 

Hardwood plywood: Data for producers in China, 2010-12, January-June 2012, January-June 2013, 

and projected 2013-14 

Item 

January-June Projections 

2010 2011 2012 2012 2013 2013 2014 

Quantity (1,000 square feet) 

Capacity 1,904,413 1,975,659 2,005,282 1,197,668 1,039,329 1,995,490 2,011,579

Production 1,582,604 1,716,102 1,761,842 844,683 833,051 1,710,966 1,787,945

End-of-period inventories 115,294 123,967 110,430 132,529 109,047 102,327 86,089

Shipments: 

 Internal consumption/transfers 35,366 37,969 38,382 19,603 23,014 42,124 44,324

 Home market 657,796 728,350 749,033 367,502 403,746 823,681 847,808

 Exports to: 

 United States 623,582 725,779 875,161 399,508 274,946 608,210 663,449

 All other markets 454,762 540,122 527,960 242,246 270,935 568,913 579,075

 Total exports 1,078,344 1,265,901 1,403,121 641,753 545,882 1,177,123 1,242,524

 Total shipments 1,771,506 2,032,220 2,190,536 1,028,858 972,642 2,042,928 2,134,656

 Ratios and shares (percent) 

Capacity utilization 83.1 86.9 87.9 70.5 80.2 85.7 88.9

Inventories/production 7.3 7.2 6.3 7.8 6.5 6.0 4.8

Inventories/shipments 6.5 6.1 5.0 6.4 5.6 5.0 4.0

Share of total shipments: 

 Internal consumption/transfers 2.0 1.9 1.8 1.9 2.4 2.1 2.1

 Home market 37.1 35.8 34.2 35.7 41.5 40.3 39.7

 Exports to: 

 United States 35.2 35.7 40.0 38.8 28.3 29.8 31.1

 All other markets 25.7 26.6 24.1 23.5 27.9 27.8 27.1

 Total exports 60.9 62.3 64.1 62.4 56.1 57.6 58.2

Source: Compiled from data submitted in response to Commission questionnaires.

U.S. INVENTORIES OF IMPORTED MERCHANDISE

Reported inventories of U.S. imports are presented in table VII‐2.  Chinese hardwood

plywood inventories rose nearly 45 percent from 2010 to 2012 and inventories from all other

sources dipped 4 percent.  January‐June 2013 inventories were nearly 9 percent lower than

January‐June 2012 inventories for all hardwood plywood imports.
VII‐5

Table VII-2 

Hardwood plywood: U.S. importers’ inventories, 2010-12, January-June 2012, January-June 2013, 

and projected 2013-14 

Year January-June 

Item 2010 2011 2012 2012 2013 

Imports from China: 

 Inventories (1,000 square feet) 248,253 231,403 360,707 250,832 218,375

 Ratio to imports (percent) 26.7 24.9 30.4 23.2 25.6

 Ratio to U.S. shipments of imports 

 (percent) 30.7 24.8 34.6 24.4 19.8

Imports from all other sources: 

 Inventories (1,000 square feet) 286,762 252,974 275,987 268,345 251,692

 Ratio to imports (percent) 23.7 25.0 25.0 22.3 19.3

 Ratio to U.S. shipments of imports 

 (percent) 26.9 24.5 25.9 23.2 18.3

Imports from all sources: 

 Inventories (1,000 square feet) 535,015 484,377 636,694 519,177 470,067

 Ratio to imports (percent) 25.0 24.9 27.8 22.7 21.8

 Ratio to U.S. shipments of imports 

 (percent) 28.5 24.7 30.2 23.8 19.0

Source: Compiled from data submitted in response to Commission questionnaires.

U.S. IMPORTERS’ OUTSTANDING ORDERS

Thirty U.S. importers reported that they had placed orders for subject hardwood

plywood from China scheduled for entry into the United States after June 30, 2013.  The

quantities of these orders were reported in a variety of different ways (i.e., containers of

different sizes, square feet, cubic feet,  cubic meters, square meters, and a number reported by

value only); hence, an exact total quantity of the orders could not be established.

ANTIDUMPING INVESTIGATIONS IN THIRD‐COUNTRY MARKETS

In 2011, the Council of the European Union imposed a definitive antidumping duty on

imports of okoumé plywood originating in the Peoples Republic of China.4

  The duty levels

imposed ranged from 6.5 percent to 23.5 percent for four Chinese producers and 66.7 percent

for all others.5

  Antidumping duties have also been imposed by Turkey and Israel on certain

                                                            

4 Regulation No. 82/2011 of January 31, 2011. The definitive anti‐dumping duty on Chinese imports

of okoumé plywood followed a review of the original investigation that imposed the duties in 2004. See

Petition, Exhibit I‐27. 5 The duty rates on four Chinese producers were as follows: Zhejiang Deren Bamboo‐Wood

Technologies Co. Ltd. had a rate of duty of 23.5 percent, Zhonglin Enterprise (Dangshan) Co. Ltd. had 6.5

percent, and Jiaxing Jinlin Lumber Co. 17 percent.  All other companies had a rate of duty of 66.7

percent.
VII‐6

Chinese imports of plywood products.6 In 2013, South Korea reportedly imposed preliminary

antidumping duties on plywood imports from China, and Argentina and Colombia initiated

investigations on Chinese plywood imports.7

INFORMATION ON NONSUBJECT COUNTRIES

In assessing whether the domestic industry is materially injured or threatened with

material injury “by reason of subject imports,” the legislative history states “that the

Commission must examine all relevant evidence, including any known factors, other than the

dumped or subsidized imports, that may be injuring the domestic industry, and that the

Commission must examine those other factors (including non‐subject imports) ‘to ensure that it

is not attributing injury from other sources to the subject imports.’”8

Global Market

With respect to foreign industry data, the Commission sought publicly available

information regarding worldwide trade of hardwood plywood.  The Commission obtained

official Commerce data for U.S. imports by country and they are presented in table VII‐3.  

Hardwood and decorative plywood is manufactured in many countries in addition to the United

States and China. Other major producers include Malaysia, Indonesia, Russia, India, and Brazil.

However, publicly available data on global production and trade of hardwood plywood are

generally included in broader categories of plywood that also include nonsubject products such

as structural plywood, formed plywood, and multilayered wood flooring, among others.

According to FAO statistics, total global production of all types of plywood in 2012 was

86.2 million cubic meters, or approximately 90 million square feet.9 China is the world's largest

producer, accounting for over half of global production in 2012.10 While historically a large

producer for its domestic market, Chinese exports also increased significantly during the past

decade. China is currently the world’s largest exporter, accounting for 34.1 percent of 2012  

                                                            

6 WTO, Committee on Anti‐Dumping Practices, Semi‐Annual Report Under Article 16.4, Turkey

(G/ADP/N/223/TUR) and Israel (G/ADP/N/223/ISR), respectively. See Petition, Exhibit I‐27. 7 Petitioners’ Posthearing Brief, Responses to Commissioners’ Questions, Question 5, p. 14 and

Exhibit 9.

8 Mittal Steel Point Lisas Ltd. v. United States, Slip Op. 2007‐1552 at 17 (Fed. Cir., Sept. 18, 2008),

quoting from Statement of Administrative Action on Uruguay Round Agreements Act, H.R. Rep. 103‐316,

Vol. I at 851‐52; see also Bratsk Aluminum Smelter v. United States, 444 F.3d 1369 (Fed. Cir. 2006).

9 Cubic meters converted to square feet using a factor of 1,046 square feet per cubic meter.

10 FAO statistics rank China as the world’s largest producer, followed by the United States, Indonesia,

Malaysia, and Russia. The FAO statistics do not differentiate hardwood from softwood or structural

plywood. FAOSTAT, http://faostat.fao.org/site/626/default.aspx#ancor (accessed August 12, 2013).
VII‐7

Table VII-3 

Hardwood plywood: U.S. imports, by sources, 2010-12, January-June 2012, and January-June 

2013

Source

Calendar year January-June

2010 2011 2012 2012 2013

Quantity (1,000 square feet)

China 1,376,408 1,534,788 1,671,686 749,534 535,027 

 Russia 226,405 244,308 245,055 158,429 111,634 

 Chile 260,093 335,849 197,758 98,460 85,297 

 Canada 192,369 168,908 210,171 105,785 178,022 

 Indonesia 243,407 177,926 207,894 109,852 109,670 

 Malaysia 169,682 92,749 104,021 54,660 72,602 

 Brazil 59,773 29,171 48,593 17,028 68,032 

 Ecuador 59,339 46,348 56,122 27,713 31,360 

 Uruguay 16,149 8,359 14,183 3,154 26,357

 Italy 16,567 18,485 15,533 7,087 6,223

 Subtotal 2,620,191 2,656,890 2,771,014 1,331,701 1,224,224 

 All other 95,671 96,229 76,630 41,280 22,922 

 Total 2,715,863 2,753,119 2,847,644 1,372,982 1,247,146 

Value ($1,000)

1

China 735,648 707,283 828,974 390,662 265,003 

 Russia 106,931 107,107 121,467 70,442 63,887 

 Chile 100,873 135,439 91,264 43,241 44,704 

 Canada 112,952 90,724 114,604 57,833 78,957 

 Indonesia 157,347 132,586 159,927 86,499 76,630 

 Malaysia 95,660 63,958 77,500 41,949 51,024 

 Brazil 29,054 17,276 24,043 9,827 30,205

 Ecuador 29,915 24,167 29,381 14,451 16,746 

 Uruguay 5,524 2,879 5,044 1,177 9,635 

 Italy 8,237 9,499 9,709 4,654 4,407 

 Subtotal 1,382,142 1,290,917 1,461,913 720,734 641,197 

 All other 54,186 49,094 44,248 20,495 19,671 

 Total 1,436,328 1,340,011 1,506,161 741,229 660,868 

Unit value (per square foot)

China $0.53 $0.46 $0.50 $0.52 $0.50

 Russia 0.47 0.44 0.50 0.44 0.57

 Chile 0.39 0.40 0.46 0.44 0.52

 Canada 0.59 0.54 0.55 0.55 0.44

 Indonesia 0.65 0.75 0.77 0.79 0.70

 Malaysia 0.56 0.69 0.75 0.77 0.70

 Brazil 0.49 0.59 0.49 0.58 0.44

 Ecuador 0.50 0.52 0.52 0.52 0.53

 Uruguay 0.34 0.34 0.36 0.37 0.37

 Italy 0.50 0.51 0.63 0.66 0.71

 Subtotal 0.53 0.49 0.53 0.54 0.52

 All other 0.57 0.51 0.58 0.50 0.86

 Total 0.53 0.49 0.53 0.54 0.53

 1

 Landed, duty-paid. 

Source: Compiled from official Commerce statistics using HTS reporting lines included in the subject 

product scope.
VII‐8

global exports of Harmonized System plywood product classifications that include the subject

product.11  The next three largest exporters were Indonesia, Malaysia, and Russia which

together represented 32.2 percent of world exports. Data for the major global exporters of

hardwood plywood are presented in table VII‐4.

Table VII‐4

Hardwood plywood: Reporting countries’ exports 2010-12

Source

Calendar year

2010 2011 2012

Value (Dollars)

China 3,401,235,958 4,339,424,397 4,796,825,167

Indonesia 1,638,695,231 1,953,470,098 2,010,052,865

Malaysia 1,597,569,848 1,729,594,341 1,665,278,373

Russia 696,116,101 910,246,312 858,781,594

Finland 538,013,574 620,771,814 575,400,980

United States 400,153,165 398,040,599 435,802,354

Brazil 418,294,399 370,372,551 408,106,634

Chile 332,665,049 415,037,769 282,122,869

Germany 288,399,001 338,137,567 264,747,738

Austria 248,206,709 300,466,731 263,978,993

Latvia 171,123,527 237,450,587 230,317,561

Belgium 220,537,481 231,457,841 195,675,176

Italy 201,537,819 218,220,567 191,051,387

Spain 151,469,094 204,101,536 171,727,894

Canada 182,695,926 179,300,972 171,217,712

France 169,287,629 182,123,535 158,629,463

Poland 105,796,431 130,537,196 138,794,311

New Zealand 93,237,519 111,476,758 108,012,052

Ghana 40,089,372 49,892,877 98,582,229

Czech Republic 72,223,469 111,593,965 88,051,503

Vietnam 65,394,473 82,326,327 74,000,000

 All others (62 countries) 763,509,281 881,585,659 875,640,285

 Total World Exports 11,796,251,056 13,995,629,999 14,062,797,140

Source: Compiled from Global Trade Information Service (4412.10, 4412.31, 4412.32, 4412.39, 4412.94, 4412.99).

                                                            

11 Table VII‐4 (data sourced from GTIS).
A‐1

APPENDIX A

FEDERAL REGISTER NOTICES  

A‐3

The Commission makes available notices relevant to its investigations and reviews on its

website, www.usitc.gov.  In addition, the following tabulation presents, in chronological order,

Federal Register notices issued by the Commission and Commerce during the current

proceeding.

Citation Title Link

77 FR 71017

November 28,

2012

Hardwood Plywood From China:  

Preliminary determinations

http://www.gpo.gov/fdsys/pkg/FR‐

2012‐11‐28/pdf/2012‐28818.pdf

78 FR 16250,

March 14, 2013

Hardwood and Decorative Plywood

From the People’s Republic of China:  

Amended Preliminary Countervailing

Duty Determination; and Alignment

of Final Determination With Final

Antidumping Determination

http://www.gpo.gov/fdsys/pkg/FR‐

2013‐03‐14/pdf/2013‐05929.pdf

78 FR 25946,

May 3, 2013

Hardwood and Decorative Plywood

From the People’s Republic of China:  

Antidumping Duty Investigation

http://www.gpo.gov/fdsys/pkg/FR‐

2013‐05‐03/pdf/2013‐10532.pdf

78 FR 36791, June

19, 2013

Hardwood Plywood From China;

Institution of Antidumping and

Countervailing Duty Investigations

and Scheduling of Final Phase

Investigations

http://www.gpo.gov/fdsys/pkg/FR‐

2013‐06‐19/pdf/2013‐14525.pdf

78 FR 58273,

September 23,

2013

Hardwood and Decorative Plywood

From China:  Final Determination of

sales at less than fair value

http://www.gpo.gov/fdsys/pkg/FR‐

2013‐09‐23/pdf/2013‐23088.pdf

78 FR 58283,

September 23,

2013

Hardwood and Decorative Plywood

From China:  Final Affirmative

Countervailing Duty  Determination

http://www.gpo.gov/fdsys/pkg/FR‐

2013‐09‐23/pdf/2013‐23077.pdf

B‐1

APPENDIX B

HEARING CALENDAR

‐ 3 ‐ 

CALENDAR OF PUBLIC HEARING

Those listed below appeared as witnesses at the United States International Trade

Commission’s hearing:

Subject: Hardwood Plywood from China

Inv. Nos.: 701‐TA‐490 and 731‐TA‐1204 (Final)

Date and Time: September 19, 2013 ‐ 9:30 a.m.

Sessions were held in connection with these investigations in the Main Hearing Room

(room 101), 500 E Street, S.W., Washington, D.C.

CONGRESSIONAL WITNESSES:

The Honorable Ron Wyden, U.S. Senator, Oregon

The Honorable Peter A. DeFazio, U.S. Representative, 4th District, Oregon

The Honorable Peter Welch, U.S. Representative, At‐Large, Vermont

In Support of the Imposition of    

Antidumping and Countervailing Duty Orders:

Levin Trade Law, P.C.                        

Bethesda,  MD

on behalf of

The Coalition for Fair Trade of Hardwood Plywood

    Clifford T. (“Kip”) Howlett, Jr., President, Hardwood

    Plywood and Veneer Association

    Bradley Louis (“Brad”) Thompson, President and Chief

    Executive Officer, Columbia Forest Products

Joseph (“Joe”) Gonyea III, Chief Operating Officer, Timber

    Products Company

      
‐ 4 ‐ 

In Support of the Imposition of   

Antidumping and Countervailing Duty Orders (continued):

Joseph (“Joe”) Gonyea III, Chief Operating Officer, Timber

    Products Company

Patrick (“Pat”) Lynch, Plywood Business Director,

    Roseburg Forest Products

    Dennis Waverly (“Wave”) Oglesby, Vice President

    for Sales and Marketing, Columbia Forest Products

    Michael (“Mike”) Clausen, Vice President of Sales,

    Domestic/International, Timber Products Company

    Norman (“Norm”) Roberts, President and Chief Executive Officer,

    Roberts Plywood, Inc.

    Terry Awalt, President and Chief Executive Officer, JSI Store

    Fixture Incorporated

    Mike Taylor, President and Chief Executive Officer, States Industries

Bruce Malashevich, President and Chief Executive Officer,

    Economic Consulting Services, LLC

    James Dougan, Senior Economist, Economic Consulting

    Services, LLC

      Jeffrey S. Levin    ) – OF COUNSEL
‐ 5 ‐ 

In Opposition to the Imposition of   

Antidumping and Countervailing Duty Orders (continued):

Mowry & Grimson , PLLC

Washington,  D.C.

on behalf of

The American Alliance of Hardwood Plywood (“AAHP”)

    Shawn Dougherty, Director‐Asia, Northwest Hardwoods, Inc.

    Greg Simon, Executive Vice President, Far East America, Inc.

   

    Gregg Wilkinson, Senior Vice President, Liberty Woods International

Carl Spencer, Co‐Owner, Spencer Cabinetry

Bill Weaver, Chief Executive Officer, Canyon Creek Cabinet Company

    Peter Bendix, Vice President Operations, StarMark Cabinetry

Thomas L. Rogers, Principal, Capital Trade, Inc.

      Jeffrey S. Grimson    )

          ) – OF COUNSEL

      Kristin H. Mowry    )

Barnes, Richardson & Colburn, LLP

Washington, D.C.

on behalf of

China National Forest Products Industry Association (“CNFPA”)

    Shengfu Wu, Director, Marketing Department, CNFPA

    Du Bo, Export Manager, Zhejiang Dehua TB Import & Export Co., Ltd.

    Chen Hao, Officer, Ministry of Commerce of the People’s Republic of China

   

         Jeffrey S. Neeley     )

                   ) – OF COUNSEL

         Stephen W. Brophy     )

C‐1

APPENDIX C

SUMMARY DATA

Table C-1

Hardwood plywood: Summary data concerning the U.S. market, 2010-12, January to June 2012, and January to June 2013

Jan-June

2010 2011 2012 2012 2013 2010-12 2010-11 2011-12 2012-13

U.S. consumption quantity:

Amount........................................................... 3,281,344 3,347,867 3,489,846 1,696,827 1,613,319 6.4 2.0 4.2 (4.9)

Producers' share (fn1).................................... 17.2 17.8 18.4 19.1 22.7 1.2 0.5 0.6 3.6

Importers' share (fn1):

China........................................................... 41.9 45.8 47.9 44.2 33.2 6.0 3.9 2.1 (11.0)

All others sources, nonsubject..................... 40.8 36.4 33.7 36.7 44.1 (7.1) (4.4) (2.7) 7.4

Total imports.......................................... 82.8 82.2 81.6 80.9 77.3 (1.2) (0.5) (0.6) (3.6)

U.S. consumption value:

Amount........................................................... 2,065,707 2,011,458 2,225,722 1,107,764 1,087,585 7.7 (2.6) 10.7 (1.8)

Producers' share (fn1).................................... 30.5 33.4 32.3 33.1 39.2 1.9 2.9 (1.1) 6.1

Importers' share (fn1):

China........................................................... 35.6 35.2 37.2 35.3 24.4 1.6 (0.4) 2.1 (10.9)

All others sources, nonsubject..................... 33.9 31.5 30.4 31.6 36.4 (3.5) (2.5) (1.0) 4.8

Total imports.......................................... 69.5 66.6 67.7 66.9 60.8 (1.9) (2.9) 1.1 (6.1)

U.S. Imports from:

China CDE FG

## Quantity....................................................... 1,376,408 1,534,788 1,671,686 749,534 535,027 # 21.5 11.5 8.9 (28.6)

## Value........................................................... 735,648 707,283 828,974 390,662 265,003 # 12.7 (3.9) 17.2 (32.2)

## Unit value..................................................... $0.53 $0.46 $0.50 $0.52 $0.50 # (7.2) (13.8) 7.6 (5.0)

## Ending inventory quantity............................. 248,253 231,403 360,707 250,832 218,375 # 45.3 (6.8) 55.9 (12.9)

All other sources, non-subject:

## Quantity....................................................... 1,339,454 1,218,331 1,175,958 623,447 712,119 (12.2) (9.0) (3.5) 14.2

## Value........................................................... 700,680 632,728 677,187 350,567 395,866 # (3.4) (9.7) 7.0 12.9

## Unit value..................................................... $0.52 $0.52 $0.58 $0.56 $0.56 # 10.1 (0.7) 10.9 (1.1)

## Ending inventory quantity............................. 286,762 252,974 275,987 268,345 251,692 # (3.8) (11.8) 9.1 (6.2)

Total imports:

## Quantity....................................................... 2,715,863 2,753,119 2,847,644 1,372,982 1,247,146 # 4.9 1.4 3.4 (9.2)

## Value........................................................... 1,436,328 1,340,011 1,506,161 741,229 660,868 # 4.9 (6.7) 12.4 (10.8)

## Unit value..................................................... $0.53 $0.49 $0.53 $0.54 $0.53 # 0.0 (8.0) 8.7 (1.8)

## Ending inventory quantity............................. 535,015 484,377 636,694 519,177 470,067 # 19.0 (9.5) 31.4 (9.5)

U.S. producers':

## Average capacity quantity............................... 1,325,400 1,326,713 1,310,545 658,356 645,470 # (1.1) 0.1 (1.2) (2.0)

## Production quantity......................................... 587,674 619,820 669,339 338,138 383,296 # 13.9 5.5 8.0 13.4

## Capacity utilization (fn1).................................. 44.3 46.7 51.1 51.4 59.4 # 6.7 2.4 4.4 8.0

U.S. shipments:

## Quantity....................................................... 565,481 594,748 642,202 323,845 366,173 # 13.6 5.2 8.0 13.1

## Value........................................................... 629,379 671,447 719,561 366,535 426,717 # 14.3 6.7 7.2 16.4

## Unit value..................................................... $1.11 $1.13 $1.12 $1.13 $1.17 0.7 1.4 (0.8) 3.0

Export shipments:

## Quantity....................................................... 21,961 24,040 25,245 10,722 13,741 # 15.0 9.5 5.0 28.2

## Value........................................................... 24,327 28,180 29,160 13,802 16,010 # 19.9 15.8 3.5 16.0

## Unit value..................................................... $1.11 $1.17 $1.16 $1.29 $1.17 # 4.3 5.8 (1.5) (9.5)

## Ending inventory quantity................................ 34,495 35,478 37,350 39,186 41,046 # 8.3 2.8 5.3 4.7

## Inventories/total shipments (fn1)..................... 5.9 5.7 5.6 5.9 5.4 # (0.3) (0.1) (0.1) (0.5)

## Production workers......................................... 1,753 1,799 1,868 1,829 1,944 # 6.6 2.6 3.8 6.3

## Hours worked (1,000s).................................... 3,768 3,937 4,101 2,086 2,202 # 8.8 4.5 4.2 5.6

## Wages paid ($1,000)...................................... 65,108 66,193 72,170 35,597 38,999 # 10.8 1.7 9.0 9.6

## Productivity (square foot per hour) . . . . . . . . . 156.0 157.4 163.2 162.1 174.1 # 4.6 0.9 3.7 7.4

## Unit labor costs............................................... $0.11 $0.11 $0.11 $0.11 $0.10 # (2.7) (3.6) 1.0 (3.4)

Net Sales:

## Quantity....................................................... 547,532 577,117 622,581 312,882 355,336 # 13.7 5.4 7.9 13.6

## Value........................................................... 610,179 653,051 698,822 356,746 414,238 # 14.5 7.0 7.0 16.1

## Unit value (dollars per square foot).............. $1.11 $1.13 $1.12 $1.14 $1.16 # 0.8 1.6 (0.8) 2.3

## Cost of goods sold (COGS)............................ 549,792 591,423 633,491 323,228 367,698 # 15.2 7.6 7.1 13.8

## Gross profit of (loss)....................................... 60,387 61,628 65,331 33,518 46,540 # 8.2 2.1 6.0 38.9

## SG&A expenses.............................................. 47,877 51,247 54,342 25,318 26,727 # 13.5 7.0 6.0 5.6

## Operating income or (loss).............................. 12,510 10,381 10,989 8,200 19,813 # (12.2) (17.0) 5.9 141.6

## Capital expenditures....................................... 4,129 7,325 7,435 2,669 8,770 # 80.1 77.4 1.5 228.6

## Unit COGS...................................................... $1.00 $1.02 $1.02 $1.03 $1.03 # 1.3 2.1 (0.7) 0.2

## Unit SG&A expenses...................................... $0.09 $0.09 $0.09 $0.08 $0.08 # (0.2) 1.6 (1.7) (7.0)

## Unit operating income or (loss)....................... $0.02 $0.02 $0.02 $0.03 $0.06 # (22.7) (21.3) (1.9) 112.8

## COGS/sales (fn1)........................................... 90.1 90.6 90.7 90.6 88.8 # 0.5 0.5 0.1 (1.8)

## Operating income or (loss)/sales (fn1)............ 2.1 1.6 1.6 2.3 4.8 # (0.5) (0.5) (0.0) 2.5

 (1) "Reported data" are in percent and "period changes" are in percentage points.

Note.--Financial data are reported on a fiscal year basis and may not necessarily be comparable to data reported on

a calendar year basis. Because of rounding, figures may not add to the totals shown. Unit values and shares are

calculated from the unrounded figures.

Source: Compiled from data submitted in response to Commission questionnaires and official Commerce statistics

C-3

(Quantity=1,000 square feet; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per square foot; Period changes=percent--exceptions noted)

Report data Period changes

Calendar year January to June Calendar year
Table C-2

Hardwood plywood: Summary data concerning the U.S. market, 2010-12, January to June 2012, and January to June 2013

Jan-June

2010 2011 2012 2012 2013 2010-12 2010-11 2011-12 2012-13

U.S. consumption quantity:

Amount............................................................. 2,440,747 2,558,996 2,749,455 1,415,504 1,604,847 12.6 4.8 7.4 13.4

Producers' share (fn1)....................................... 23.2 23.2 23.4 22.9 22.8 0.2 0.1 0.1 (0.1)

Importers' share (fn1):

China............................................................. 33.2 36.4 37.9 36.3 34.4 4.8 3.2 1.6 (1.9)

All others sources, nonsubject....................... 43.7 40.4 38.7 40.8 42.8 (5.0) (3.3) (1.7) 2.0

Total imports............................................ 76.8 76.8 76.6 77.1 77.2 (0.2) (0.1) (0.1) 0.1

U.S. consumption value:

Amount............................................................. 1,392,779 1,490,728 1,642,792 840,246 960,035 18.0 7.0 10.2 14.3

Producers' share (fn1)....................................... 45.2 45.0 43.8 43.6 44.4 (1.4) (0.1) (1.2) 0.8

Importers' share (fn1):

China............................................................. 28.1 29.0 31.7 29.9 29.7 3.6 0.9 2.7 (0.2)

All others sources, nonsubject....................... 26.7 26.0 24.5 26.5 25.9 (2.2) (0.8) (1.5) (0.6)

Total imports............................................ 54.8 55.0 56.2 56.4 55.6 1.4 0.1 1.2 (0.8)

U.S. importers' U.S. shipments of Imports from:

China CDE FG

200 Quantity......................................................... 809,600 931,260 1,043,188 514,141 552,136 # 28.9 15.0 12.0 7.4

200 Value............................................................. 391,020 432,342 520,814 251,074 284,845 # 33.2 10.6 20.5 13.5

200 Unit value....................................................... $0.48 $0.46 $0.50 $0.49 $0.52 # 3.4 (3.9) 7.5 5.6

200 Ending inventory quantity............................... 248,253 231,403 360,707 250,832 218,375 # 45.3 (6.8) 55.9 (12.9)

All other sources, non-subject:

200 Quantity......................................................... 1,065,666 1,032,988 1,064,065 577,518 686,538 # (0.2) (3.1) 3.0 18.9

200 Value............................................................. 372,380 386,939 402,417 222,637 248,473 # 8.1 3.9 4.0 11.6

200 Unit value....................................................... $0.35 $0.37 $0.38 $0.39 $0.36 # 8.2 7.2 1.0 (6.1)

200 Ending inventory quantity............................... 286,762 252,974 275,987 268,345 251,692 # (3.8) (11.8) 9.1 (6.2)

Total imports:

200 Quantity......................................................... 1,875,266 1,964,248 2,107,253 1,091,659 1,238,674 # 12.4 4.7 7.3 13.5

200 Value............................................................. 763,400 819,281 923,231 473,711 533,318 # 20.9 7.3 12.7 12.6

200 Unit value....................................................... $0.41 $0.42 $0.44 $0.43 $0.43 # 7.6 2.5 5.0 (0.8)

200 Ending inventory quantity............................... 535,015 484,377 636,694 519,177 470,067 # 19.0 (9.5) 31.4 (9.5)

U.S. producers':

100 Average capacity quantity................................. 1,325,400 1,326,713 1,310,545 658,356 645,470 # (1.1) 0.1 (1.2) (2.0)

100 Production quantity........................................... 587,674 619,820 669,339 338,138 383,296 # 13.9 5.5 8.0 13.4

100 Capacity utilization (fn1).................................... 44.3 46.7 51.1 51.4 59.4 # 6.7 2.4 4.4 8.0

U.S. shipments:

100 Quantity......................................................... 565,481 594,748 642,202 323,845 366,173 # 13.6 5.2 8.0 13.1

100 Value............................................................. 629,379 671,447 719,561 366,535 426,717 # 14.3 6.7 7.2 16.4

100 Unit value....................................................... $1.11 $1.13 $1.12 $1.13 $1.17 0.7 1.4 (0.8) 3.0

Export shipments:

100 Quantity......................................................... 21,961 24,040 25,245 10,722 13,741 # 15.0 9.5 5.0 28.2

100 Value............................................................. 24,327 28,180 29,160 13,802 16,010 # 19.9 15.8 3.5 16.0

100 Unit value....................................................... $1.11 $1.17 $1.16 $1.29 $1.17 # 4.3 5.8 (1.5) (9.5)

100 Ending inventory quantity.................................. 34,495 35,478 37,350 39,186 41,046 # 8.3 2.8 5.3 4.7

100 Inventories/total shipments (fn1)....................... 5.9 5.7 5.6 5.9 5.4 # (0.3) (0.1) (0.1) (0.5)

100 Production workers........................................... 1,753 1,799 1,868 1,829 1,944 # 6.6 2.6 3.8 6.3

100 Hours worked (1,000s)...................................... 3,768 3,937 4,101 2,086 2,202 # 8.8 4.5 4.2 5.6

100 Wages paid ($1,000)......................................... 65,108 66,193 72,170 35,597 38,999 # 10.8 1.7 9.0 9.6

100 Productivity (square foot per hour) . . . . . . . . . . . 156.0 157.4 163.2 162.1 174.1 # 4.6 0.9 3.7 7.4

100 Unit labor costs................................................. $0.11 $0.11 $0.11 $0.11 $0.10 # (2.7) (3.6) 1.0 (3.4)

Net Sales:

100 Quantity......................................................... 547,532 577,117 622,581 312,882 355,336 # 13.7 5.4 7.9 13.6

100 Value............................................................. 610,179 653,051 698,822 356,746 414,238 # 14.5 7.0 7.0 16.1

100 Unit value (dollars per square foot)................. $1.11 $1.13 $1.12 $1.14 $1.16 # 0.8 1.6 (0.8) 2.3

100 Cost of goods sold (COGS)............................... 549,792 591,423 633,491 323,228 367,698 # 15.2 7.6 7.1 13.8

100 Gross profit of (loss)......................................... 60,387 61,628 65,331 33,518 46,540 # 8.2 2.1 6.0 38.9

100 SG&A expenses................................................ 47,877 51,247 54,342 25,318 26,727 # 13.5 7.0 6.0 5.6

100 Operating income or (loss)................................ 12,510 10,381 10,989 8,200 19,813 # (12.2) (17.0) 5.9 141.6

100 Capital expenditures......................................... 4,129 7,325 7,435 2,669 8,770 # 80.1 77.4 1.5 228.6

100 Unit COGS........................................................ $1.00 $1.02 $1.02 $1.03 $1.03 # 1.3 2.1 (0.7) 0.2

100 Unit SG&A expenses........................................ $0.09 $0.09 $0.09 $0.08 $0.08 # (0.2) 1.6 (1.7) (7.0)

100 Unit operating income or (loss).......................... $0.02 $0.02 $0.02 $0.03 $0.06 # (22.7) (21.3) (1.9) 112.8

100 COGS/sales (fn1).............................................. 90.1 90.6 90.7 90.6 88.8 # 0.5 0.5 0.1 (1.8)

100 Operating income or (loss)/sales (fn1)............... 2.1 1.6 1.6 2.3 4.8 # (0.5) (0.5) (0.0) 2.5

 (1) "Reported data" are in percent and "period changes" are in percentage points.

Note.--Financial data are reported on a fiscal year basis and may not necessarily be comparable to data reported on

a calendar year basis. Because of rounding, figures may not add to the totals shown. Unit values and shares are

calculated from the unrounded figures.

Source: Compiled from data submitted in response to Commission questionnaires.

C-4

(Quantity=1,000 square feet; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per square foot; Period changes=percent--exceptions noted)

Calendar year January to June

Report data

Calendar year

Period changes
C‐5

Table C‐3

Hardwood plywood:  Summary data concerning the U.S. market (including ***),

2010‐12, January to June 2012, and January to June 2013

* * * * * * *

D‐1

APPENDIX D

U.S. AND CHINESE HARDWOOD PLYWOOD BY TYPE OF MATERIAL UTILIZED  

IN THE CORE AND THICKNESS OF PRODUCT AND FACE VENEER

D‐3

Tables D‐1 and D‐2 present U.S. and Chinese hardwood plywood producers’ hardwood

plywood production by materials used in the cores and faces of the hardwood plywood

produced.

Table D-1 

Hardwood plywood: U.S. producers’ and Chinese producers’ production by type of material 

utilized in core, 2010-2012, January-June 2012 and January-June 2013 

Item 

Year January-June 

2010 2011 2012 2012 2013 

Quantity (1,000 square feet) 

U.S. producers: 

 Hardwood veneer 24,961 26,418 25,312 14,704 13,683

 Softwood veneer 384,620 410,029 450,146 225,816 255,506

 Bamboo 0 0 0 0 0

 Other Inputs 172,021 179,285 185,653 93,663 104,300

 All 581,602 615,732 661,111 334,183 373,489

Chinese producers: 

Hardwood veneer 1,413,169 1,490,135 1,554,641 743,614 742,510

Softwood veneer 122,832 162,658 146,752 76,507 70,392

Bamboo 0 0 0 0 0

Other Inputs 45,712 50,206 56,811 28,164 23,894

 All 1,581,713 1,702,999 1,758,204 848,285 836,796

Share of quantity (percent) 

U.S. producers: 

 Hardwood veneer 4.3 4.3 3.8 4.4 3.7

 Softwood veneer 66.1 66.6 68.1 67.6 68.4

 Bamboo 0.0 0.0 0.0 0.0 0.0

 Other Inputs 29.6 29.1 28.1 28.0 27.9

 All 100.0 100.0 100.0 100.0 100.0

Chinese producers: 

 Hardwood veneer 89.3 87.5 88.4 87.7 88.7

 Softwood veneer 7.8 9.6 8.3 9.0 8.4

 Bamboo 0.0 0.0 0.0 0.0 0.0

 Other Inputs 2.9 2.9 3.2 3.3 2.9

 All 100.0 100.0 100.0 100.0 100.0

Source: Compiled from data submitted in response to Commission questionnaires. 

 
D‐4

Table D-2 

Hardwood plywood: U.S. producers’ and Chinese producers’ production by type of material 

utilized for face veneer, 2010-2012, January-June 2012 and January-June 2013 

Item 

Year January-June 

2010 2011 2012 2012 2013

Quantity (1,000 square feet) 

U.S. Producers: 

 Hardwood 575,403 608,628 648,959 331,599 365,021

 Softwood 5,292 5,578 7,705 3,428 9,157

 Other 952 1,186 1,707 380 712

 All 581,647 615,392 658,371 335,407 374,890

Chinese producers: 

 Hardwood veneer 1,394,160 1,494,765 1,549,724 757,159 744,905

 Softwood veneer 23,237 32,095 33,731 14,272 20,181

 Bamboo 92,016 98,974 80,268 39,578 32,080

 Other Inputs 1,509,413 1,625,834 1,663,723 811,009 797,166

Share of quantity (percent) 

U.S. producers: 

 Hardwood veneer 98.9 98.9 98.6 98.9 97.4

 Softwood veneer 0.9 0.9 1.2 1.0 2.4

 Other 0.2 0.2 0.3 0.1 0.2

 All 100.0 100.0 100.0 100.0 100.0

Chinese producers: 

 Hardwood veneer 92.4 91.9 93.1 93.4 93.4

 Softwood veneer 1.5 2.0 2.0 1.8 2.5

 Other 6.1 6.1 4.8 4.9 4.0

 All 100.0 100.0 100.0 100.0 100.0

Source: Compiled from data submitted in response to Commission questionnaires. 

 
D‐5

Tables D‐3 and D‐4 present U.S. importers’ hardwood plywood commercial shipments

by thickness of veneer and overall plywood thickness, respectively.

Table D-3 

Hardwood plywood: U.S. producers’, U.S. importers’, and Chinese producers’ commercial 

shipments by thickness of veneer, 2010-2012, January-June 2012 and January-June 2013

Item 

Year January-June 

2010 2011 2012 2012 2013

Quantity (1,000 square feet) 

U.S. producers: 

 0.6 mm and above 523,292 553,992 590,799 298,515 330,701

 0.5 mm to 0.59 mm 31,378 30,236 31,906 17,649 16,722

 0.4 mm to 0.49 mm 1,215 1,065 737 407 102

 Below 0.4 mm 0 0 0 0 0

 All 555,885 585,293 623,442 316,571 347,525

U.S. importers: 

 0.6 mm and above 45,688 7,985 4,369 2,083 1,463

 0.5 mm to 0.59 mm 8,391 5,363 5,814 2,871 5,589

 0.4 mm to 0.49 mm 27,555 8,483 9,044 4,627 3,782

 Below 0.4 mm 633,761 790,454 904,265 456,169 467,988

 Total 715,395 812,285 923,492 465,750 478,822

Chinese producers: 

 0.6 mm and above 599 2,135 3,563 2,429 2,002

 0.5 mm to 0.59 mm 18,329 16,030 54,335 13,774 9,999

 0.4 mm to 0.49 mm 8,719 12,685 16,977 8,447 7,404

 Below 0.4 mm 585,762 687,202 808,653 371,834 251,092

 Totals 613,409 718,052 883,528 396,484 270,497

Share of quantity (percent) 

U.S. producers: 

 0.6 mm and above 94.1 94.7 94.8 94.3 95.2

 0.5 mm to 0.59 mm 5.6 5.2 5.1 5.6 4.8

 0.4 mm to 0.49 mm 0.2 0.2 0.1 0.1 0.0

 Below 0.4 mm 0.0 0.0 0.0 0.0 0.0

 All 100.0 100.0 100.0 100.0 100.0

U.S. importers: 

 0.6 mm and above 6.4 1.0 0.4 0.4 0.3

 0.5 mm to 0.59 mm 1.2 0.7 0.5 0.6 1.1

 0.4 mm to 0.49 mm 3.9 1.0 15.9 1.0 5.3

 Below 0.4 mm 88.6 97.3 83.2 97.9 93.3

 Total 100.0 100.0 100.0 100.0 100.0

Chinese producers: 

 0.6 mm and above 0.1 0.3 0.4 0.6 0.7

 0.5 mm to 0.59 mm 3.0 2.2 6.1 3.5 3.7

 0.4 mm to 0.49 mm 1.4 1.8 1.9 2.1 2.7

 Below 0.4 mm 95.5 95.7 91.5 93.8 92.8

 Totals 100.0 100.0 100.0 100.0 100.0

Source: Compiled from data submitted in response to Commission questionnaires.
D‐6

Table D-4 

Hardwood plywood: U.S. producers’, U.S. importers, and Chinese producers’ commercial 

shipments by thickness of overall plywood, 2010-2012, January-June 2012 and January-June 2013

Item 

Year January-June 

2010 2011 2012 2012 2013

Quantity (1,000 square feet) 

U.S. producers: 

 20.0 mm and above 10,369 11,101 10,869 5,231 5,228

 16.0 mm to 19.99 mm 310,744 327,035 351,662 181,205 199,871

 6.5 mm to 15.99 mm 109,849 124,484 133,370 65,066 70,646

 Below 6.5 mm 124,923 122,671 127,542 65,060 71,610

 All 555,885 585,291 623,443 316,562 347,355

U.S. importers: 

 20.0 mm and above 2,168 2,220 3,346 1,761 1,525

 16.0 mm to 19.99 mm 198,846 220,960 233,947 124,968 121,067

 6.5 mm to 15.99 mm 144,792 169,841 400,996 96,114 185,359

 Below 6.5 mm 352,927 440,878 521,235 252,990 274,167

 Total 698,733 833,899 1,159,524 475,833 582,118

Chinese producers: 

 20.0 mm and above 2,819 4,849 9,287 6,457 3,541

 16.0 mm to 19.99 mm 253,672 292,594 354,923 164,452 102,023

 6.5 mm to 15.99 mm 136,153 173,672 227,316 98,836 82,182

 Below 6.5 mm 228,725 246,616 284,397 136,579 84,330

 Total 621,368 717,731 875,922 406,324 272,075

Share of quantity (percent) 

U.S. producers: 

 20.0 mm and above 1.9 1.9 1.7 1.7 1.5

 16.0 mm to 19.99 mm 55.9 55.9 56.4 57.2 57.5

 6.5 mm to 15.99 mm 19.8 21.3 21.4 20.6 20.3

 Below 6.5 mm 22.5 21.0 20.5 20.6 20.6

 All 100.0 100.0 100.0 100.0 100.0

U.S. importers: 

 20.0 mm and above 0.3 0.3 0.3 0.4 0.3

 16.0 mm to 19.99 mm 28.5 26.5 20.2 26.3 20.8

 6.5 mm to 15.99 mm 20.7 20.4 34.6 20.2 31.8

 Below 6.5 mm 50.5 52.9 45.0 53.2 47.1

 Total 100.0 100.0 100.0 100.0 100.0

Chinese producers: 

 20.0 mm and above 0.5 0.7 1.1 1.6 1.3

 16.0 mm to 19.99 mm 40.8 40.8 40.5 40.5 37.5

 6.5 mm to 15.99 mm 21.9 24.2 26.0 24.3 30.2

 Below 6.5 mm 36.8 34.4 32.5 33.6 31.0

 Total 100.0 100.0 100.0 100.0 100.0

Source: Compiled from data submitted in response to Commission questionnaires. 
E‐1

APPENDIX E

APPLICATIONS OF DOMESTIC VERSUS SUBJECT PRODUCT  

(Question IV‐3‐Purchasers’ questionnaire)

E‐3

Table E-1 

Hardwood plywood: Applications of domestic versus subject product (Question IV-3) 

* * * * * * *

F‐1

APPENDIX F

NONSUBJECT COUNTRY PRICE DATA

F‐3

Twelve importers reported price data for nonsubject countries Canada, Indonesia, and

Russia for products 1‐6. Price data reported by these firms accounted for 1 percent of U.S.

imports from all nonsubject countries. These price items and accompanying data are

comparable to those presented in tables V‐3 to V‐8. Price and quantity data for Canada,

Indonesia, and Russia are shown in tables F‐1 to F‐5 and in figure F‐1 (with domestic and subject

sources).

In comparing nonsubject country pricing data with U.S. producer pricing data, prices for

product imported from Canada, Indonesia, and Russia were lower than prices for U.S.‐produced

product in 108 instances and higher in 16 instances. In comparing nonsubject country pricing

data with subject country pricing data, prices for product imported from Canada, Indonesia,

and Russia were lower than prices for product imported from China in 25 instances and higher

in 99 instances.  
F‐4

Table F-1 

Hardwood plywood: Weighted-average f.o.b. prices and quantities of imported product 11

, by 

quarters, January 2010-June 2013 

Period 

Canada Indonesia Russia 

Price 

($ per 

square 

foot) 

Quantity 

(1,000 

square feet)

Price 

($ per 

square 

foot) 

Quantity 

(1,000 square 

feet) 

Price 

($ per 

square foot) 

Quantity 

(1,000 

square feet) 

2010: 

Jan.-Mar. *** *** *** *** *** ***

Apr.-June *** *** -- 0 *** ***

July-Sept. *** *** *** *** *** ***

Oct.-Dec. *** *** *** *** *** ***

2011: 

Jan.-Mar. *** *** -- 0 *** ***

Apr.-June *** *** *** *** *** ***

July-Sept. *** *** -- 0 *** ***

Oct.-Dec. *** *** -- 0 *** ***

2012: 

Jan.-Mar. *** *** -- 0 *** ***

Apr.-June *** *** -- 0 *** ***

July-Sept. *** *** -- 0 *** ***

Oct.-Dec. *** *** -- 0 *** ***

2013: 

Jan.-Mar. *** *** -- 0 *** ***

Apr.-June *** *** *** *** *** ***

1

 Product 1: 12 mm (1/2") thickness (actual or nominal), 4x8 panel size, Birch face (whether white birch, 

natural birch or artisan birch; whole piece), face Grade C/D+ or substantially equivalent, Birch back 

(whether white birch, natural birch or artisan birch), back grade 2/3 or substantially equivalent, veneer 

core, unfinished. 

Source: Compiled from data submitted in response to Commission questionnaires. 
F‐5

Table F-2 

Hardwood plywood: Weighted-average f.o.b. prices and quantities of imported product 21

, by 

quarters, January 2010-June 2013 

Period 

Canada 

Price 

($ per square foot) 

Quantity 

(1,000 square feet) 

2010: 

Jan.-Mar. -- 0

Apr.-June *** ***

July-Sept. *** ***

Oct.-Dec. -- 0

2011: 

Jan.-Mar. *** ***

Apr.-June *** ***

July-Sept. *** ***

Oct.-Dec. *** ***

2012: 

Jan.-Mar. *** ***

Apr.-June *** ***

July-Sept. *** ***

Oct.-Dec. *** ***

2013: 

Jan.-Mar. *** ***

Apr.-June *** ***

1

 Product 2: 12 mm (1/2") thickness (actual or nominal), 4x8 panel size, Birch face (whether white birch, 

natural birch or artisan birch; whole piece), face Grade C/D+ or substantially equivalent, Birch back 

(whether white birch, natural birch or artisan birch), back grade 2/3 or substantially equivalent, veneer 

core, prefinished. 

Source: Compiled from data submitted in response to Commission questionnaires. 
F‐6

Table F-3 

Hardwood plywood: Weighted-average f.o.b. prices and quantities of imported product 31

, by 

quarters, January 2010-June 2013 

Period 

Canada Indonesia Russia 

Price 

($ per 

square 

foot) 

Quantity 

(1,000 

square feet)

Price 

($ per 

square 

foot) 

Quantity 

(1,000 square 

feet) 

Price 

($ per 

square foot) 

Quantity 

(1,000 

square feet) 

2010: 

Jan.-Mar. *** *** *** *** *** ***

Apr.-June *** *** *** *** *** ***

July-Sept. *** *** -- 0 *** ***

Oct.-Dec. *** *** -- 0 *** ***

2011: 

Jan.-Mar. *** *** -- 0 *** ***

Apr.-June *** *** -- 0 *** ***

July-Sept. *** *** -- 0 *** ***

Oct.-Dec. *** *** -- 0 *** ***

2012: 

Jan.-Mar. *** *** -- 0 *** ***

Apr.-June *** *** -- 0 *** ***

July-Sept. *** *** -- 0 *** ***

Oct.-Dec. *** *** -- 0 *** ***

2013: 

Jan.-Mar. *** *** -- 0 *** ***

Apr.-June *** *** *** *** *** ***

1

 Product 3: 18 mm (3/4") thickness (actual or nominal), 4x8 panel size, Birch face (whether white birch, 

natural birch or artisan birch), face Grade C/D+ or substantially equivalent, Birch back (whether white 

birch, natural birch or artisan birch), back grade 2/3 or substantially equivalent, veneer core, unfinished. 

Source: Compiled from data submitted in response to Commission questionnaires. 
F‐7

Table F-4 

Hardwood plywood: Weighted-average f.o.b. prices and quantities of imported products 41

 and 52, 

by quarters, January 2010-June 2013 

Period 

Product 4 Product 5 

Canada Canada Russia 

Price 

($ per 

square 

foot) 

Quantity 

(1,000 

square feet)

Price 

($ per 

square 

foot) 

Quantity 

(1,000 square 

feet) 

Price 

($ per 

square foot) 

Quantity 

(1,000 

square feet) 

2010: 

Jan.-Mar. -- 0 -- 0 -- 0

Apr.-June *** *** *** *** -- 0

July-Sept. -- 0 -- 0 -- 0

Oct.-Dec. -- 0 -- 0 -- 0

2011: 

Jan.-Mar. -- 0 *** *** -- 0

Apr.-June -- 0 *** *** -- 0

July-Sept. -- 0 *** *** -- 0

Oct.-Dec. -- 0 *** *** -- 0

2012: 

Jan.-Mar. *** *** *** *** -- 0

Apr.-June -- 0 *** *** -- 0

July-Sept. -- 0 *** *** -- 0

Oct.-Dec. -- 0 *** *** *** ***

2013: 

Jan.-Mar. -- 0 *** *** -- 0

Apr.-June -- 0 *** *** *** ***

1

 Product 4: 5.2 mm (1/4") thickness (actual or nominal), 4x8 panel size, Maple face (whether plain or 

rotary sliced), face Grade B or substantially equivalent, Maple back (whether plain or rotary sliced), back 

grade 2/3 or substantially equivalent, veneer core, unfinished. 

2

 Product 5: 18 mm (3/4") thickness (actual or nominal), 4x8 panel size, Birch face (whether white birch, 

natural birch or artisan birch), face Grade C/D+ or substantially equivalent, Birch back (whether white 

birch, natural birch or artisan birch), back grade 2/3 or substantially equivalent, veneer core, prefinished. 

Source: Compiled from data submitted in response to Commission questionnaires. 
F‐8

Table F-5 

Hardwood plywood: Weighted-average f.o.b. prices and quantities of imported product 61

, by 

quarters, January 2010-June 2013 

Period 

Canada Indonesia Russia 

Price 

($ per 

square 

foot) 

Quantity 

(1,000 

square feet)

Price 

($ per 

square 

foot) 

Quantity 

(1,000 square 

feet) 

Price 

($ per 

square foot) 

Quantity 

(1,000 

square feet) 

2010: 

Jan.-Mar. *** *** *** *** -- 0

Apr.-June *** *** *** *** -- 0

July-Sept. *** *** *** *** -- 0

Oct.-Dec. *** *** *** *** -- 0

2011: 

Jan.-Mar. *** *** *** *** *** ***

Apr.-June *** *** -- 0 *** ***

July-Sept. *** *** -- 0 *** ***

Oct.-Dec. *** *** -- 0 *** ***

2012: 

Jan.-Mar. *** *** *** *** *** ***

Apr.-June *** *** *** *** *** ***

July-Sept. *** *** *** *** *** ***

Oct.-Dec. *** *** *** *** *** ***

2013: 

Jan.-Mar. *** *** *** *** -- 0

Apr.-June *** *** *** *** -- 0

1

 Product 6: 5.2 mm (1/4”) thickness (actual or nominal), 4x8 panel size, Birch face (whether plain or 

rotary sliced), face Grade C or substantially equivalent, back face of Birch or other, Grade 2/3 or 

substantially equivalent, veneer core, unfinished. 

Source: Compiled from data submitted in response to Commission questionnaires. 

Figure F-1 

Hardwood plywood: Weighted-average f.o.b. prices and quantities of domestic and imported 

product, by quarters, January 2010-June 2013 

* * * * * * *