Personal Communication with KCMA.

Notes on phone conversation between Matthew LaPenta (Abt Associates) and Richard Titus 

(Kitchen Cabinet Manufacturers Association). 10.28.2010. Questions were forwarded in advance. 

Responses highlighted in green are from Matt LaPenta’s hand written notes of the conversation.

 Number of “Fabricators”

 Roughly what percentage of all U.S. cabinet manufacturing firms are members of your association? 5% 

of firms, 70% of production. 60% of members have less than 10 million in sales. 200 cabinet 

manufacturers. There are about 5,000 manufacturers total. Are there any characteristics that may be 

typical of firms not represented by your organization? No, Diverse. For example, a specific area of the 

country, or a type of kitchen cabinet or cabinet construction. 

 What percentage of cabinet makers would you estimate use composite wood products (hardwood 

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

 Of these manufacturers using composite wood products, what percentage would you estimate produce 

at least some product lines that are CARB compliant because they use CARB certified panels or 

component parts and follow the CARB recordkeeping and labeling requirements? These are ballpartk 

estimates. About 50% of members and 50% of total U.S. cabinet production is CARB compliant 

product lines. The KCMA Environmental Stewardship Program requires this. In 2011, ESP products 

will all be CARB 2 compliant.

 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? No. Confident that cabinet manufacturers do not carry 2 product lines. It would be too 

hard to avoid mixing the many components for cabinets.

 Impact of Labeling Requirements

 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?

Clarified that “item” means unit (e.g., cabinet) and not, for example, component. Could not say for sure. But 

possible to estimate assuming 15-17 cabinets per job in new housing and fact that new housing accounts for

about 30% of sales. In neighborhood of several, 3? 5? 10? Million?

 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? Did not answer, but above says 15-17 cabinets per job.

 Number of Wood Veneer “Laminator Product” Manufacturers

 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.

11 members said they did this. 5% or less of manufacturers do this. It is not common.
 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? They would do both.

 What percentage of the production of wood veneer laminated products are produced using formaldehydebased resins to affix wood veneers to purchased platforms? 6-NAF, 5-UF

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

likely resin choice? In order from most likely: PVA, MUF, Soy, PF

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

adhesives used? In order from most likely: PVA and Soy

 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?

Don’t know, but there is a lot of variation because cabinets use a large number of components. Different 

price points, species, fashion changes, and durability requirements dictate this variation.

General comments:

 KCMA ESP program requires CARB compliance and verifies it.

 Cabinet makers have historically not done the veneering themselves. KCMA is concerned that the

suppliers of their members who are laminated product manufacturers under CARB would be 

adversely affected by the rule. 

 KCMA wants federal rule to be as close to CARB as possible

 The HWPW manufacturers are trying to set up a trade barrier by pushing for a regulation on 

laminated product manufacturers, but this would hurt domestic cabinet manufacturers

 Concerned about IRIS – this will be a big deal.

 Suggested contacting him to get input on third party testing requirements, especially finished product 

testing. Suggested that finished product testing may be a good tool to identify bad actors for further 

investigation.