Personal Communication with BIFMA. 2010. Brad Miller's (BIFMA) Written Responses to 

Questions about FSCWPA Impacts on Members. November 23, 2011. 

1) Number of Fabricators 

a) What percentage of office furniture manufacturers would you estimate use composite wood 

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

i) 100% 

b) Of these manufacturers, what percentage would you estimate produce at least some product 

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

follow the CARB recordkeeping and labeling requirements? 

i) 100% 

c) Do the manufacturers that are producing CARB compliant product lines also carry product lines 

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

volume would you estimate are product lines that are not compliant with CARB because they do 

not use CARB certified panels or component parts or do not follow the CARB recordkeeping and 

labeling requirements? 

i) Yes, only if the manufacturer is outside of North America and not selling to US; Not 

likely within the US. 

ii) N/A or 0 (in the U.S., unknown internationally). 

2) Impact of Labeling Requirements 

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

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

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

for each manufacturer that uses composite wood materials? 

i) This could be huge, easily in the millions for large manufacturers, depending on the 

definition of “separate item”. Smaller manufacturers would also be significantly 

burdened if new labeling requirements, beyond what they are already doing for CARB, 

were instituted. Also, for some parts it is just not feasible to label every individual part 

because there is no space on the part. 

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

may items would be included in a typical shipment? 

i) A single “shipment” could contain anywhere from one to hundreds (maybe thousands) 

items. If bulk packaging could be labeled, you could divide the “millions” by 15 

(approximation based on 15 parts per bulk pack). 

3) Number of Wood Veneer “Laminator Product” Manufacturers 

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

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

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

laminated products by affixing wood veneer themselves? Please do not include other types of 

laminates (such as high pressure laminates, thermally fused papers, vinyl films, decorative foils, 

or polypropylene films) in your answer. 

i) Many, if not most, BIFMA manufacturers produce office desk and storage products 

with wood veneer. It is estimated 75% of those would laminate their own products. 

Those who do not manufacture their own buy veneered components from suppliers. 

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

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

finished with a wood veneer or other decorative finish? 

i) It ranges from zero to 100% between individual companies. While the majority of 

companies apply their own veneer to products, we believe it is not uncommon for 

companies to also purchase veneered components. 
c) What percentage of the production of wood veneer laminated products are produced using 

formaldehyde-based resins to affix wood veneers to purchased platforms? 

i) Very little, if any. 

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

be the likely resin choice? 

i) PVA 

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

common adhesives used? 

i) PVA 

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

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

manufacturer? 

i) This would impact veneer on MDF, veneer on PB, and veneer on plywood. These 

categories would represent materials that are pervasive within the industry and 

account for thousands if not tens of thousands of individual product types. Further, 

the ASTM E1333 testing method is designed for four-foot by eight-foot sheets of 

material while office furniture veneered parts vary widely in size and shape. Veneers 

may also be applied to steel, aluminum, and other substrates but these are outside of 

this legislation.