Personal Communication with NALFA. 2010. Conversation between Dennis Bradway (Mannington 

Floors and North American Laminate Floor Association) and Abt Associates Inc. regarding written 

questions about FSCWPA Impacts. November 22, 2010.

1. Number of “Fabricators”

a. What percentage of laminate flooring manufacturers would you estimate use composite wood 

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

95% or greater

i. 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? 95% or greater are fully compliant. 100% have some compliant 

product lines.

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? Very few if 

any would not comply with CARB – less than 5% of domestic.

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? Not sure.

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? Not sure.

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.

Did not have a good answer about number of mills that are laminated product manufacturers. 

Did say that EWF manufacturers typically lay up the cores themselves, which is not really 

consistent with what we heard during our survey screenings and other sources, such as 

evergreen.

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? Laminators are 

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

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

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

would be the likely resin choice? 

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

most common adhesives used? PVAC and soy are used.

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?

 Imports are 40% to 50% of domestic consumption.

 Rule should require NAF or ULEF glue for laminated product manufacturers without 

the same testing requirements

 EWF is 18-25% of ALL flooring

 10% of product is laminated product

 Says that product imported under laminated product exemption is often made using 

UF resins. Says this displaces CARB compliant product. Says 15% of high emitting 

imports would turn into domestic production if they had to use low emitting glues. 

 EWF standard includes a formaldehyde emissions test on finished product

 Want level playing field from an emissions standpoint

 Does not think frequent testing of laminated products is necessary

Thinks infrequent testing of finished product, for example, once a year, is sufficient