Personal Communication with KCMA. 2010. Conversation between Richard Titus (Kitchen Cabinet 

Manufacturers Association) and Abt Associates Inc. regarding written questions about FSCWPA Impacts. 

October 28, 2010. Matt LaPenta spoke with Bill Perdue on 11.02.2010.

1. Number of Fabricators

a. What percentage of furniture manufacturers would you estimate use composite wood products (hardwood 

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

Hundreds of fabricators worldwide. There are many offshore fabricators. 90% of wood-based 

furniture manufacturers use composite wood products. Wood based furniture is the lion’s share of the 

market. For Home furnishings 80% of furniture is wood based. 

i. 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?

All are complying with CARB. All are following recordkeeping and labeling 

requirements. This is true for AHFA members and non-members. Sources of noncompliant product are not available.

ii. 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 – separate inventory would be too difficult. 

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?

All products have a manufacturing label with product number and SKU. CARB compliance is also 

indicated on this label. This system works well because manufacturers use the existing labels. 

Labels are on the boxes and the products. There are millions of labels.

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? 

This would not work for furniture. Lot labeling would make it harder to track it back to the board 

manufacturer. AHFA says lot labeling of panels makes it harder for the fabricators because it 

makes their recordkeeping more difficult. .

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.

All domestic manufacturers do this. There are about 250 domestic manufacturers who are 

laminators. 

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?

Common. Laminators would also use purchased panels.

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

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

Some use cold press PVA. Typically use UF.

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

the likely resin choice?

Not sure. Dictated by market.

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

adhesives used? 

Not sure. Dictated by market.

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?

Not sure. Would be a burden but not as many products as a custom panel manufacturer.

 General comments

o Worlds largest home furniture association

o 450 members

o Represents all levels of supply chain

o International and domestic members

o Was @ table with CARB

o Was active with Klobuchar

o Has engaged with EPA

o Performance questions associated with CARB 2 resins. More boards seem to have mold 

problems.