Market Profile of the Composite Wood Products Industry

Market Profile for Industries Potentially Affected 

by the Proposed Formaldehyde Standards for 

Composite Wood Products Rule

Economic and Policy Analysis Branch

Economics, Exposure and Technology Division

Office of Pollution Prevention and Toxics

Office of Chemical Safety and Pollution Prevention

U.S. Environmental Protection Agency

May 2011
Market Profile of the Composite Wood Products Industry

Acknowledgment

EPA acknowledges the analytical and draft preparation support of Abt Associates Inc. of 

Cambridge, Massachusetts in the preparation of this report, provided under Contract No. EP-W08-10.

Notice

Mention of the names of specific companies, organizations, or entities does 

not constitute an endorsement by EPA.
Market Profile of the Composite Wood Products Industry

Table of Contents

1 Introduction ................................................................................................................................................ 1

2 Hardwood Plywood, Particleboard, and Medium Density Fiberboard Manufacturing................................. 3

2.1 Production Processes..........................................................................................................................................3

2.2 Adhesives..........................................................................................................................................................21

2.3 Product Characteristics, Uses, and Substitutes.................................................................................................24

2.4 Domestic Production and International Trade .................................................................................................28

3 Laminated Product Manufacturing ............................................................................................................ 32

4 Hardboard Manufacturers......................................................................................................................... 42

4.1 Production Process ...........................................................................................................................................42

4.2 Product Uses.....................................................................................................................................................45

4.3 Domestic Production and International Trade .................................................................................................45

4.4 Comparisons Between Hardboard and MDF ....................................................................................................46

5 Reconstituted Wood Products and Hardwood Veneer and Plywood Manufacturing Industry................... 49

5.1 Value of Shipments...........................................................................................................................................50

5.2 Production Costs...............................................................................................................................................51

5.3 International Trade ...........................................................................................................................................53

5.4 Industry Organization .......................................................................................................................................57

6 Composite Wood Product Fabricators....................................................................................................... 66

6.1 Value of Shipments...........................................................................................................................................67

6.2 Production Costs...............................................................................................................................................68

6.3 International Trade ...........................................................................................................................................81

6.4 Industry Organization .....................................................................................................................................100

7 Composite Wood Product Wholesalers and Importers............................................................................ 110

7.1 Value of Sales..................................................................................................................................................110

7.2 Wholesale Operating Costs.............................................................................................................................115

7.3 Industry Organization .....................................................................................................................................124

8 Composite Wood Product Retailers......................................................................................................... 132

8.1 Value of Sales..................................................................................................................................................132

8.2 Retail Payroll and Sales...................................................................................................................................138

8.3 Industry Organization .....................................................................................................................................140

9 Third Party Certifiers (TPCs)..................................................................................................................... 146

10 Composite Wood Products Market Outlook ............................................................................................ 150

10.1 Outlook for MDF and Particleboard Consumption .........................................................................................150

10.2 Housing Market Summary ..............................................................................................................................152

10.3 Market for Housing Renovation Activities......................................................................................................153

10.4 Market for Furniture Manufacturing ..............................................................................................................154

11 Number of Affected Entities by Small Business Status............................................................................. 156

12 Baseline Formaldehyde Emissions Levels................................................................................................. 158

12.1 Baseline Emissions for Domestically Produced Products ...............................................................................158

12.2 Composite Wood Product Consumption by Product Type and Trade Status.................................................162

12.3 Summary of Baseline Emission Levels ............................................................................................................163

13 References............................................................................................................................................... 167
Market Profile of the Composite Wood Products Industry 1

1 Introduction

In July 2010, Congress passed the Formaldehyde Standards for Composite Wood 

Products Act (Title VI of the Toxic Substances Control Act (TSCA)). TSCA Title VI directs EPA to 

promulgate regulations that: set emission standards for composite wood products, ultra lowemitting formaldehyde resins, and no-added formaldehyde resins; determine whether 

laminated products should be included or excluded in the definition of hardwood plywood and 

therefore subject to the applicable emission requirements; define “hardboard;” establish the 

number and frequency of tests required to demonstrate compliance with the emission 

standards; establish labeling requirements, chain of custody requirements, third-party testing 

and certification requirements, auditing requirements and reporting of third-party certifiers, 

recordkeeping requirements, provisions relating to finished goods, requirements for exceptions 

for products containing de minimis amounts of composite wood products, sell-through 

provisions, and requirements to prevent stockpiling of product inventory.

The purpose of this document is to provide an overview of the industries that are 

potentially directly affected by the proposed rule to implement TSCA Title VI. Manufacturers of 

hardwood plywood, medium density fiberboard (MDF), and particleboard are the entities that 

are potentially affected by the applicable emissions requirements of TSCA Title VI under all 

regulatory options. TSCA Title VI also requires the agency to determine whether laminated 

products should be excluded from the definition of hardwood plywood.

1

 Thus, laminated 

product manufactures may also be directly affected by the applicable emissions requirements of

TSCA Title VI. In addition, TSCA Title VI requires that hardboard be defined through the 

rulemaking process. Hardboard is a composite wood product that is similar to thin MDF and the 

recent voluntary industry standard definitions for these two products overlap. In addition to the 

manufacturers of products directly affected by the applicable emissions requirements, 

manufacturers that use composite wood products as raw materials (hereafter referred to as 

fabricators), wholesalers or distributers (including importers) of composite wood products, and 

retailers of composite wood products will be subject to chain of custody and labeling 

requirements. Third party certifiers (TPCs) will also potentially be affected by the TSCA Title VI 

TPC rule.

This document begins with a profile of hardwood plywood, MDF, and particleboard 

manufacturers presented in Section 2. Section 3 profiles the manufacturers of wood veneer 

laminated products. Section 4 presents a profile of hardboard manufacturers and a discussion 

of the differences between thin MDF and hardboard. Section 5 presents an overview of the 

sectors more broadly defined by U.S. Census as the Reconstituted Wood Products industry and 

the Hardwood Veneer and Plywood industry. These sectors as defined by U.S. Census include 

hardwood plywood, MDF, particleboard, laminated product, and hardboard manufacturers as 

well as some manufactures that fabricate composite wood products. Sections 6, 7, and 8 profile 

composite wood product fabricators, wholesalers (including importers), and retailers, 

 1 In TSCA Title VI, the term “laminated product” means a product in which a wood veneer is affixed to a composite wood 

platform, and that is a component part used in the construction or assembly of a finished good, and is produced by the 

manufacturer or fabricator of the finished good in which the product is incorporated. These products are referred to as 

“wood veneer laminated products” in this report in order to differentiate them from other products (such as high pressure 

laminates, thermally fused melamine, light weight basis papers, decorative foils, and film overlays) that are often referred 

to in the industry as laminated products, but that are not included in the statutory term because they do not include wood 

veneer. 
Market Profile of the Composite Wood Products Industry 2

respectively. Section 9 profiles TPCs. Section 10 summarizes the market outlook for the new 

housing and renovation industries which are the key drivers of demand for composite wood 

products. Section 11 presents an overview of the number of affected entities by type and small 

business status. Finally, Section 12 presents the estimated baseline emissions levels for 

composite wood products.
Market Profile of the Composite Wood Products Industry 3

2 Hardwood Plywood, Particleboard, and Medium Density 

Fiberboard Manufacturing 

This section describes the manufacturing of hardwood plywood, medium density 

fiberboard (MDF), and particleboard. Laminated product manufacturing is described separately 

in Section 3.

This section first presents information on the production processes (section 2.1) and the 

adhesives used in production (section 2.2). Then product end uses, product characteristics and 

product substitutes are discussed (section 2.3). Information on domestic production, domestic 

consumption and international trade are presented in section 2.4.

2.1 Production Processes

This section describes the production process for composite wood products that have 

historically been manufactured using urea-formaldehyde (UF) resins: hardwood plywood, 

particleboard, and MDF. While the production processes for the manufacture of these products 

are similar, there are several important differences. Hardwood plywood is generally made by 

applying a hardwood veneer to the face and back of a core of veneer, lumber, MDF, 

particleboard, or other material. Particleboard is a composite panel product made by bonding 

wood particles with resin under heat and pressure and molding them into panels. Typically, 

particleboard is made in three layers – two external layers and an internal core. The production 

process for MDF is similar to that of particleboard. Wood residues are heated under pressurized 

steam, bonded with resin, and then shaped into panels. The remainder of this section describes 

the production of the three types of composite wood products in greater detail.

2.1.1 Hardwood Plywood Manufacturing

The hardwood plywood industry is very diverse, with a number of large and small 

manufacturers utilizing a variety of manufacturing processes. Products that fall within the 

definition of hardwood plywood include industrial stock panels, architectural or custom panels, 

wall paneling, engineered flooring, and flush doors. The demand for hardwood plywood is 

derived from demand for products containing hardwood plywood, including cabinets, furniture, 

store fixtures, recreational vehicles, and manufactured homes as well as residential housing 

construction and remodeling. Appearance tends to be a major factor for a majority of 

hardwood plywood products (U.S. ITC 2008). 

In general, hardwood plywood manufacturers use processes similar to those employed 

by particleboard and MDF manufacturers: the wood components are prepared, assembled, and 

bonded together using resin, heat, and pressure. Some smaller architectural panel 

manufacturers press the components together without heat. The outer layer of hardwood 

veneers may then be applied to a core of veneer, lumber, particleboard, MDF, a combination of 

these materials, or other special cores. It is important to note that the majority of plants in the 

industry typically only make hardwood veneer or hardwood plywood, not both. 

This analysis divides hardwood plywood plants into three categories with similar 

manufacturing characteristics in order to describe how those characteristics may influence a 

mill’s choice of strategies to comply with formaldehyde emissions requirements. Those 
Market Profile of the Composite Wood Products Industry 4

categories are: 1) log-based mills whose manufacturing process starts with the conversion of 

logs into veneer and ends with the production of hardwood plywood; 2) purchased veneerbased mills which purchase all the components needed to assemble their products, tend to be 

simpler to operate since they do not convert logs to veneer, and are usually relatively large, 

making products targeted for the industrial stock panel market; and 3) 3-Ply mills which buy 

cores and finish them with hardwood face veneers in a 2-step process. It is likely that this third 

category constitute the largest hardwood plywood manufacturing category based on the overall 

number of facilities.

The manufacture of hardwood plywood begins with the selection of logs, which are 

steam-heated and then debarked. Once debarked, the logs are cut into veneer lengths in a 

process known as bucking. The logs, now referred to as “flitches”, are heated to improve 

cutting, and sliced into veneers ranging in thickness from 0.024 to 0.125 inches thick (EPA 2000). 

Sheets of the cut veneer are placed side-by-side and glued together in order to make larger 

panels, in a process known as composing. Hardwood plywood panels are generally fabricated in 

one of two ways: 1) a line-by-line process, which involves coating the components with 

adhesives, laying them into an assembly of inner plys, facings, and backs, and pressing them all 

at once into a panel; or 2) a 2-step process, in which inner plys are assembled and pressed into a 

platform, sanded to the desired thickness, coated on both sides with an adhesive, mated with 

face and back veneers, and then pressed into a panel. Most of all hardwood plywood mills, 

regardless of size, use roll coaters or “spreaders” to apply adhesive, and manually lay-up their 

assemblies.2 Finally, the hardwood plywood panel is conditioned to normalize moisture 

content, before being trimmed, sanded, and finished to meet final product specifications (EPA 

2000). 

Section 2.1.1.1 examines the hardwood plywood manufacturing process in greater 

detail, Table 2-1 outlines the steps involved in manufacturing hardwood plywood. Figure 2-1

provides a diagram of the general steps involved in hardwood veneer and hardwood plywood 

manufacturing. Section 2.1.1.2 provides a brief summary of the engineered veneer 

manufacturing process. 

2.1.1.1 Hardwood Plywood Manufacturing

Steaming of Logs (Peeler block preconditioning)

After wood is selected based on the desired physical characteristics of the finished 

product, steam, water spray, or hot water immersion is used to preheat logs. This makes logs 

easier to peel, reduces breakage and splitting, reduces knife-wear, reduces glue spread, and 

gives the veneer greater strength (Baldwin 1995).

Veneer cutting

The logs, now referred to as blocks or flitches, are heated using hot water baths, steam 

heat, or hot water sprays, to ensure that the blades used to cut them provide the best possible 

surface finish. Cutting tools generally work in the same way, compressing the wood as the knife 

cuts the flitches into veneers ranging in thickness from around 0.024 to 0.125 inches thick. 

 2 This is in contrast with softwood plywood plants that may use extruders or spray systems for adhesive application, and 

more automated assembly lines. 
Market Profile of the Composite Wood Products Industry 5

Depending on the type of equipment used, different visual effects in the grain of the wood can 

be achieved (EPA 2000). 

Clipping and Stacking

A veneer clipper cuts the veneer ribbons to specified widths, usually 54 inches to allow 

for shrinkage resulting from the drying process (EPA 2000). Depending on the technological 

basis of the plant, two choices are available for stacking: manual and automatic. With manually 

assisted stacking, workers sort veneer by size and type and load it into clipping and stacking 

machines. Automatic stacking machines sort wood using electronic scanners and vacuums to 

move and sort veneers along a conveyor belt. Moisture detectors sort wood into heartwood 

and sapwood piles. Timers allow automatic clippers to clip wood at proper lengths. Wood is 

sorted into bin stackers by type of wood (fishtails, sapwood, and heartwood) and width (half 

sheets and full sheets) (Baldwin 1995).
Market Profile of the Composite Wood Products Industry 6

Table 2-1: Manufacturing Steps: Hardwood Plywood

Process Step Process Description

Wood 

Selection

Logs are selected based on various physical characteristics that determine their ability 

to be peeled, glued, and used in a finished product.

Preconditioni

ng

Logs are heated by steam, hot water spray, or hot water immersion; this makes logs 

easier to peel, gives greater strength to the veneer, and reduces log splitting, knifewear, and glue spread.

Veneer 

Cutting

The preconditioned block is positioned on a lathe and cut into veneer sheets, usually 

by a rotary slicer. 

Clipping and 

Stacking

Veneers are sorted by size, wood type, and moisture content and clipped to a 

predetermined size; sorting can be performed manually or automatically.

Veneer 

Drying

Cut veneer or the entire veneer ribbon (before clipping) is dried in a conditioning 

chamber to reduce moisture content.

Dry Clipping After drying, the veneer is clipped to reduce veneer width and remove defects.

Compose 

Veneer

Veneer panels are attached together, edge to edge, to make larger panels from 

multiple veneers; in the process, two panels are clipped, glue is applied to the edges, 

the panels are pressed together and held by tape until the glue is cured.

Glue Mixing Glue is prepared in vats and mixed with fillers and extenders to make the resin that 

will be used in bonding veneer sheets together.

Veneer 

Assembly and 

Glue 

Application

Veneer sheets are laid up onto an assembly line; glue is applied to each ply by means 

of roller coater, curtain coater, spray coater, or extrusion; plies are arranged by back 

plies, face plies, and core plies and layered after glue application.

Pre-Pressing In some instances, plywood is cold pressed for 3-4 minutes prior to hot-pressing.

Hot-Pressing Plywood is separated by caul plates and loaded into the hot press; in a two-step 

process, pressure of around 200 ppi is applied to the wood for a short duration, 

followed by a pressure of 100-130 ppi for a longer pressing time; temperature of the 

press is dependent on the resin used.

Conditioning Pressed plywood is stacked to ensure that the moisture content of the wood equalizes 

with the surrounding air.

Trimming, 

Sanding, 

Finishing

Circular saws are used to make plywood rectangular and straight-edged; filler material 

is applied to wood to patch chipped areas; belt sanders are used to adjust the final 

board thickness and provide a finished surface.

Sources: Baldwin 1995,EPA 2000,Washington State Department of Ecology 1998
Market Profile of the Composite Wood Products Industry 7

Figure 2-1: General steps in hardwood veneer and plywood 

manufacturing

Blocking/

Debarking

Log steaming or 

soaking Veneer cutting

Veneer drying

Green Veneer

Glue spreading and 

veneer layup Dry Veneer

Resin

Press Sanding Hardwood Plywood

Hardwood plywood and veneer plant

Hardwood veneer plant Hardwood plywood plant

Core material

Logs

Veneer drying

Veneer must be dried in order to reduce the wood’s moisture content for glue 

application. Furthermore, moisture content affects veneer size. There are three types of 

practices used for veneer drying: 1) open-air drying, 2) kiln drying, and 3) mechanical drying. 

Open-air drying is generally only used in climates that are favorable to drying. Kiln drying is 

Source: U.S. EPA 2000
Market Profile of the Composite Wood Products Industry 8

done in a conditioning chamber where multiple stacks of wood are dried by convection. The 

most common drying procedure is mechanical drying, a process in which wood is moved 

longitudinally through a drying chamber by conveyor belt, although veneer transport can occur 

by conventional transport (cut veneer is transported to separate drying lines) or the in-line 

system (entire veneer ribbon is fed directly from lathe to dryer and then clipped). Steam heat is 

the most common heat source, as air is heated efficiently at temperatures above 375 degrees

(Baldwin 1995). With steam heat, exchangers warm the air and then apply it to the wood. Gas, 

direct-fired oil, and wood-waste burners are also used (Washington State Department of 

Ecology 1998). Other systems preheat veneer on a ceramic surface which speeds drying time. 

Microwave and radio wave energy are also sometimes used to dry wood from the inside out. 

The circulation of hot air can be longitudinal (parallel to veneer movement), by cross-circulation 

(across the width of the dryer, direction switches from section to section), or by jet dryer (like 

cross-circulation, but is the same direction in all sections and blasts air at the veneer by a jet 

tube). Jet drying is the most common because it takes away a surface layer of moisture and is 

efficient at transferring heat to the veneer. (Baldwin 1995). 

Dry Clipping

Veneer jointing is the process of attaching veneer panels together by their edges using a 

resin (sometimes UF resin) to make a larger panel. Veneer sheets that are too small or oddly 

shaped can be jointed to make a useable veneer panel. In this process, the jointer clips the 

leading veneer panel with an angled knife and applies glue and fiberglass string to the angled 

edge. The trailing veneer panel is also clipped with an angled knife. Both panels are then 

“crowded” together and continue down the conveyor line to be clipped to a predetermined size. 

Tape can be used to hold veneer joints together while in the press. Once the crowded veneer 

ribbon is cut, it is stacked and ready for veneer assembly.

Veneer Assembly

Veneer assembly involves taking the prepared veneer sheets and stacking them into 

glue-bonded layers. Veneer assembly can be performed manually or automatically, depending 

on the system. In both manual and automatic lines, the layers consist of back plies, face plies, 

center plies, and core plies (also called cross bands, the grain of which runs perpendicular to the 

grain in the back and face plies). Most hardwood plywood mills manually lay-up their 

assemblies. The veneer assembly process begins with a back or face ply moving downstream on 

a conveyor. A layer of glue is applied to the ply and a core piece is laid onto the ply. Most all 

hardwood plywood mills, regardless of their size, use roll coaters or “spreaders” to apply the 

adhesive. The layer then goes to the next glue applicator, and the cycle repeats until the last ply 

is in place. The bundle then moves to a prepress or hot press pre-loader (EPA 2000).

Adhesive Mixing

Adhesives are substances capable of holding materials together, primarily through use 

of mechanical interlocking which takes place below the surface of the wood. The most 

prevalent adhesives in the composite wood industry have historically been resins containing 

formaldehyde (California Air Resources Board 2007). 

Adhesive is less expensive if bought in bulk and mixed at the facility. Adhesive mixers 

consist of a mechanical paddle that stirs the mixture. Adhesive is generally mixed on a weight 
Market Profile of the Composite Wood Products Industry 9

basis. The working life of the adhesive is taken into consideration (shorter life means mixing in 

smaller batches). When switching between adhesives, even a small residual of one type of

adhesive may adversely affect the physical properties of another (EPA 2000). 

Adhesive Application in the Assembly Process

Adhesives can be applied to each ply in a number of ways, depending on the layup line 

type. In the majority of hardwood plywood mills (regardless of size), roll coaters are used to 

apply adhesive. Roll coaters are hard or soft rollers that coat the veneer as it passes; they are 

composed of a roller bar and a doctor roller that can be adjusted to determine the amount of 

resin applied. Hard rollers are made of Neoprene or Buna rubber in varying thicknesses. “Soft”

rolls (40-45 Durometer) are especially suited to phenolic resins. Sponge rolls also fall in this 

category and are composed of either Insolate or Neoprene soft closed-cell sponge. An 

alternative to roller coaters is curtain coaters, devices that apply a thin film or “curtain” of 

adhesive to the passing veneer. There are two types of curtain coater: pressure head and 

gravity feed. The pressure head coater uses a pump to feed resin into a V-shaped reservoir; 

application is controlled by the pump speed, width of the knife gap, and glue viscosity. Unused 

glue is trapped and reused. The gravity feed system works like the pressure head system but 

uses gravity (instead of a pump) to move the resin to the applicator; curtain velocity cannot be 

controlled with gravity feed. Another alternative is spray coaters, devices that apply adhesive to 

the veneer as a spray. The glue is either mixed with atomized air or directly atomized using high 

pressure. Spray is controlled by the speed of the veneer, flow rate of the resin to the spray tip,

height of the spray tip, spray pattern, and the glue viscosity (controlled by mixing and 

temperature). Lastly, extrusion can be used to apply the resin. Here, glue is turned into foam at 

5 times its original volume. The foam is laid on the veneer surface in beads or “rods.” During 

pressing, the rods of glue expand to completely cover the veneer (Baldwin 1995).

Fillers and Extenders

Fillers are added to resin to adjust viscosity, reduce the penetration into the wood, and 

fill small cavities. Filler is added in the mixing stage of the resin. Fillers can come in the form of 

corn residue, tree bark, wood flour, clay, nutshells, or other. Problems arise because filler 

material and mix can be variable from shipment to shipment. This is especially a problem with 

curtain and spray coaters, which require a precise glue viscosity. Fillers can also affect moisture 

content. Filler type can affect the final glue bond. 

Extenders are generally cereal flours, which function to minimize the amount of resin 

necessary in the mix. They can also affect the viscosity of the mixture, which in turn affects the 

glue spread, penetration, and moisture. Problems also occur with extenders, usually due to 

using inferior products (Baldwin 1995).

Pre-Pressing

Glued sheets can be put into the cold pre-press prior to hot pressing, which generally 

takes three to four minutes (Young 1996). Pre-pressing transfers glue between the coated and 

uncoated veneer surfaces, reducing the panel to its final thickness before entering the hot press. 

This can reduce the amount of space between platens (called “daylight”) and slippage between 

veneers (USDA 1964). Since heat transfer requires more time for thicker panels, this may 
Market Profile of the Composite Wood Products Industry 10

reduce hot-pressing times and increase energy efficiency. Pre-pressing can also help to spread 

the glue uniformly and protect the panel from warping (Uniply Industries 2010).

Hot-Pressing

Panels are assembled with caul plates (protective metal or wood sheets) between them 

and loaded into the hot press. The hot press uses steam, hot water, or hot oil to heat the press. 

Since wood becomes stronger as it dries, the initial moisture content and glue mix will affect the 

pressing cycle. Wood also becomes more pliable when heated, so the amount of pressure 

applied, the pressing cycle duration, and the heat applied need to be adjusted in relation to 

each other. Pressure between 150-175 ppi is recommended for average mill conditions 

(Baldwin 1995). Press times for hardwood plywood panels range from 1 to 45 minutes, with the 

average around 6 minutes (EPA 2000). In a two-step pressing process, the press applies 200 ppi 

for 1-2 minutes followed by a reduction to 100-130 ppi for the remainder of the pressing time. 

The initial pressure ensures glue contact on all surfaces while the lower pressure allows the glue 

to cure under less compression. Interior glue mixes (like UF) require heat of no more than 212 

degrees F; exterior mixes (like PF) require heat of 220 degrees F for 2 and 1/4 minutes. Wood

type and thickness, as well as resin choice, can affect pressure, duration, and heat requirements. 

If the wood is cold, this will also affect pressing times. It is also possible that UF bonded wood 

can be exclusively cold-pressed (Baldwin 1995). 

Conditioning

Plywood loses moisture during the pressing process. Before processing, the wood is 

stacked to equalize moisture content. This can range from one hour to overnight (EPA 2000).

Trimming, Sanding, Finishing

Wood panels are passed through two sets of parallel gauged circular saws and trimmed 

to be rectangular and straight-edged. Patches can also be applied to appearance-grade panels, 

which come in the form of replaced wood areas or synthetic filler material. Belt sanders are 

used to bring the panel down to final thickness and provide a finished surface (Baldwin 1995).

2.1.1.2 Engineered Veneer Manufacturing

Engineered veneer (also known as reconstituted, composite, or “green” veneer) is a 

man-made product in which more common or inexpensive species of wood are manipulated to 

look like veneer from exotic or expensive wood species. It tends to be made from light colored 

tree species, which are conducive to taking on the distinctive colors and patterns of the end 

product. 

Once selected, the logs are trimmed, sawed to length, and then debarked (World Panel 

Products 2010). The rotary method slices the prepared logs into continuous sheets of veneer, 

which are then cut into wide strips called leaves, and dried. Once dry, the leaves are sorted into 

light and dark groups then dyed in a vat under high temperature and pressure. The dyed leaves 

are unloaded and dried. Glue is then applied between each leaf to bind the leaves into stacks 

and to create grain definition. The stacks go through a press, which uses a shaped mold to 

create reproducible grain-like patterns on the top and bottom leaves (Shopnotes 2010). The 

stacks are placed under high pressure to form large rectangular blocks. The blocks are sliced 
Market Profile of the Composite Wood Products Industry 11

into new leaves; the shape of the block and the angle of the cut control the grain pattern (WPI 

undated). The resulting leaves are typically 26” wide and 99” long (although can range to 135” 

long) and can be backed, or spliced together to make wider sheets (Shopnotes 2010). 

2.1.2 Particleboard Manufacturing

The particleboard industry grew out of a need to dispose of the residual material 

produced by other members of the wood industry (USDA 1999). It is a small and diverse 

industry with mills using different raw materials (largely dependent on their geography) and 

equipment configurations, and selling their products to different markets. These markets 

include, but are not limited to, cabinets, vanities, furniture, floorboards and underlayment. In 

applications where the final product’s aesthetics are concerned, particleboard may be overlaid 

with other materials. Because of many site-specific factors, a mill’s choice of CARB Phase 2

emissions control technology may not be optimal for, or transferable to, other mills. 

In general, particleboard manufacturing includes five steps: 1) The material is 

mechanically separated into particles (known as furnish); 2) resin and other additives are 

applied; 3) mats are formed; 4) hot pressed; and, 5) finished (i.e., cut to size and sanded) 

(California Air Resources Board 2007). Although single layer particleboard can be manufactured, 

it tends to be made in three or five layers (two face layers, and one or three core layers, 

respectively). This layered construction approach increases the efficacy of the curing process 

(California Air Resources Board 2007). By altering the properties of the different layers, the 

characteristics of resulting product can be changed (EPA 2000). The reduction of wood 

materials to particle form (as required in particleboard manufacturing) requires less energy than 

reducing the same material to fibers (as required in MDF manufacturing). However, because 

particles don’t utilize the lignocellulosic bonds of wood materials as well as fibers do, 

particleboard is generally not as strong as MDF (USDA 1999). 

Table 2-2 outlines the steps involved in manufacturing particleboard. Figure 2-2

provides a diagram of the general steps involved in particleboard manufacturing.
Market Profile of the Composite Wood Products Industry 12

Table 2-2: Manufacturing Steps: Particleboard 

Process Step Process Description

Raw material 

handling

Chips, sawdust, planer shavings, and other recycled materials are received, stored, 

cleaned, mixed and conveyed.

Additive 

handling

Resin, wax, and other additives are received, stored, and prepared for use by mixing, 

heating, and/or dilution with water.

Milling Raw materials and recycled board trim are processed through mechanical hammermills, 

flakers, or refiners. All plants have multiple milling machines and prepare Face and Core 

layer materials separately. This is sometimes done in multiple steps, both before and 

after drying, and may incorporate screening. 

Drying Milled material is passed through a heated rotary drum or flash tube dryers to evaporate 

moisture. Drying may be separated into “Green” and “Final” dryer stages. Roughly 

milled material may be dried in a single Green Dryer, but Final Drying of Face and Core 

materials is usually done separately.

Dry Storage Dry materials are held in separate Face and Core storage bins or silos to create surge 

capacity in the production process, or supply multiple production lines.

Blending Resin and wax is missed with the dry materials. Most mills use single-stage, water 

cooled, high-speed mechanical blenders that distribute the resin through intimate 

particle to particle contact and high energy input. Some mills employ two-stage 

blenders. Separate blending systems are always used for Face and Core materials. Some 

plants will add recycled sanderdust back into the material at the blender.

Forming Line A variety of different technologies are used to form a continuous fiber mat of the proper 

Face/Core construction for the desired product. Resinated mat trim and rejected mats 

are recycled by careful mixing with fresh Core material in the Core forming station. Most 

modern plants form on a continuous solid belt. Many older plants form on either hard 

aluminum or soft cloth or wire screen “cauls” that support the mat as it is conveyed to, 

and possibly through, the press. Most Forming Lines include either single opening prepresses or continuous precompressors to improve mat integrity.

Pressing Mats are consolidated into rough boards under heat and pressure. A variety of press 

types are employed, including multi-opening platen presses, single opening platen 

presses, steam injection platen presses, continuous steel belt presses, and continuous 

drum (Mende) presses.

Trimming Rough boards are sawn around the perimeter.

Cooling Rough boards are held apart to air-cool before stacking.

Finishing Rough boards are converted to finished product dimensions by sawing and sanding. The 

portion of rough board volume that is converted into saw trim and sanderdust varies 

with the mill and product, but can range from 8% to 25%.

Residual 

Management

The saw trim and sanderdust are either burned to generate process heat, recycled back 

into the board, or disposed of elsewhere.

Thermal 

energy 

generation

All plants must generate process heat. Presses are heated with either steam or thermal 

oil. Dryers may be heated indirectly with either steam or thermal oil, or by direct firing. 

Natural gas, oil, and board residuals are all used as fuel in different mills.
Market Profile of the Composite Wood Products Industry 13

Figure 2-2: General steps in Particleboard manufacturing

Process Flow

Optional Process

Slashing Debarking Cutting Milling Shipping

Screening/ 

Classifying

Surface 

Material 

Storage

Core 

Material 

Storage

Drying Drying

Onsite particle generation Offsite particle generation

Direct/

Indirect 

Heating

Cyclone Cyclone

Surface 

Material 

Storage

Screening

Blending Resin, wax, 

other additives

Core 

Material 

Storage

Blending Resin, wax, other 

additives Forming

Trimming

Pressing

Prepressing

Cooling Sanding Trimming Finishing

Steam/ hot oil/ 

hot water Heat, pressure

Raw Material Handling

As indicated in Figure 2-2, the raw material used to make particleboard can either be 

prepared on- or offsite. The majority of furnish is derived from softwood species; although, a 

mix of soft- and hardwood species can be used. Alternatively, the furnish can be shipped from 

offsite and stored until needed (EPA 2000). 

Source: U.S. EPA 2000
Market Profile of the Composite Wood Products Industry 14

Additive Handling

The resin, wax, and other additives are received, stored, and prepared for use by mixing, 

heating, and/or dilution with water. Mills transitioning to a new control technology may need 

to enhance their additive handling ability to incorporate the variety of necessary components in 

the precise proportions required.

Milling

If the furnish is prepared onsite, the raw material and recycled board trim is typically 

milled to size through some combination of the following equipment: hogs, chippers, 

hammermills, ring flakers, ring mills, and attrition mills (USDA 1999). Alternately, if it is 

necessary, material prepared offsite can be further milled with this equipment (EPA 2000). 

Because both undersized and oversized particles can adversely affect the final product, the 

furnish is screened through use of air streams or, more commonly, vibrating screens (USDA 

1999). 

Drying

In order to ensure that the resin bonds correctly with the particles, which affects both 

the board’s structural characteristics and final HCHO emissions, it is important that the furnish 

attain a specific moisture content (California Air Resources Board 2007). The moisture content 

of furnish arriving at the mill can range from 10% to 200% and generally needs to be dried to 

levels between of 2% to 7% (USDA 1999, EPA 2000). Depending on the mill, rotary dryers, flash 

tube dryers, or direct wood-fired dryers can be used to dry the furnish (EPA 2000). Triple-pass 

rotary dryers, in which a series of flights move the material from one end to the other three 

times, are the most common (USDA 1999, EPA 2000). For wet (“green”) furnish, inlet 

temperatures can be as high as 1600°F, while for dry furnish inlet temperatures are between 

500° to 600°F. Because of the discrepancy between inlet temperatures for wet and dry furnish, 

and the resulting chance of fires, particleboard dryers tend to be assigned to drying either green 

or dry furnish (EPA 2000). Drying may be affected at mills transitioning to an alternate resin 

technology since many of the alternate resins have higher moisture content levels (i.e., 

enhanced UF, MUF, and soy/polyamide epichlorohydrin (PAE), potentially requiring increased 

moisture control technology or additional dryer capacity.

Dry Storage

Dry materials are held in separate storage bins or silos (for Face and Core) to create 

surge capacity in the production process, or supply multiple production lines.

Blending

Blending is the process of mixing resin, wax, and other additives to the furnish, by 

means of spray nozzles, tubes, or atomizers (EPA 2000).

3

 While some mills use two-stage 

blenders, most use single-stage water cooled, high-speed mechanical blenders. Mills always use 

separate blending devices for face and core layers. Depending on the desired properties of the 

particleboard, the board’s resin content can range from between 4% to 10%, but is more 

 3 Wax is added to increase water resistance. Other additives include catalysts to increase curing speed, scavengers to 

decrease formaldehyde emissions, etc.
Market Profile of the Composite Wood Products Industry 15

typically between 6% and 9%. More resin tends to be used on face than core layers (USDA 

1999). Blending may be affected at mills transitioning to an alternate resin technology; for 

example, uncured polydiphenylmethane diisocyanate (pMDI) and the resulting resinated 

material are hazardous so facilities adopting pMDI will need to address cleaning and exposurerelated issues.

Forming Line

Once blended, the resinated particles need to be “formed” into an even and consistent 

mat. Most modern plants form on a continuous solid belt (older plants tend to use either hard 

aluminum or soft cloth or wire screen “cauls” that form the mat through back-and-forth 

movements). Depending on the desired number of layers, multiple formers may be used. Most 

forming lines include either single opening pre-presses or continuous pre-compressors to reduce 

the mat height and consolidate the material (USDA 1999). Forming may be affected at mills 

transitioning to an alternate resin technology; for example, PF, pMDI and soy/PAE resins 

produce much less “tack”4 than UF or MUF resins and so can have issues creating the structural 

integrity to bridge small gaps between forming conveyors and press loaders without fracturing.

Pressing

Once pre-pressed, the mat is consolidated into rough boards through heat and pressure. 

This activates the resin and causes the bonds to form. Depending on the mill, a variety of 

presses may be used, including: multi-opening platen presses, single opening platen presses, 

steam injection platen presses, continuous steel belt presses, and continuous drum (Mende) 

presses. Most plants use multi-opening batch presses that generate steam-heat from a boiler 

burning residual wood. Presses typically reach temperatures ranging from 260° to 450°F, and 

achieve final particleboard densities ranging from 29 to 72 pounds per cubic foot (EPA 2000).

Pressing may be affected at mills transitioning to an alternate resin technology. For 

example, enhanced UF resins have higher moisture content, which can create de-gassing 

problems at the end of the press cycle for mills with wide (>6’) presses. Similar (albeit 

potentially less severe) problems may result from mills transitioning to MUF or MF resins. PF 

requires higher temperature settings and longer press times than UF and so mills with Mende 

drum presses may not be able to manufacture acceptable quality particleboard panels with PF 

(or pMDI). pMDI bonds with steel so mills utilizing steel surfaced presses may face challenges 

unless a release treatment is also adopted. Soy/PAE resins may result in extra moisture added 

in the production process, causing mills with wider or older presses difficulty in transition.

Trimming

Rough boards are sawn around the perimeter.

Cooling

Rough boards are held apart to air-cool before stacking. Boards are cooled to ensure 

that the desired physical properties are achieved (EPA 2000). Cooling may be affected by a 

mill’s transition to an alternate resin technology; for example, some alternate resins require 

 4 The property that allows the adhesive to adhere to another surface on immediate contact.
Market Profile of the Composite Wood Products Industry 16

higher temperatures for activation. The cooling technology will need to be adjusted accordingly 

to prevent thermal degradation.

Finishing

Once cool, the rough boards are sanded and trimmed to their final dimensions. 

Depending on the mill and product, the rough board volume that is converted into saw trim and

sanderdust varies between 8% and 25%. Particleboard can be overlaid with veneers or other 

material, lacquered, or painted for decoration (USDA 1999).

Residual Management

The saw trim and sanderdust are either burned to generate process heat, recycled back 

into the board, or disposed of elsewhere. Since the recycling of resinated materials has been 

shown to influence board emissions, a mill’s choice of CARB Phase 2 compliance strategy will be 

affected accordingly.

Thermal Energy Generation

All plants must generate process heat. Presses are heated with either steam or thermal 

oil. Dryers may be heated indirectly with either steam or thermal oil, or by directly firing. 

Natural gas, oil, and board residuals are all used as fuel in different mills. Depending on the 

adopted resin control technology, mills that do not burn all of their residuals may need to 

acquire the capability to do so, requiring the modification of their air emissions permits. 

2.1.3 Medium-Density Fiberboard Manufacturing

Medium density fiberboard (MDF) is a composite panel manufactured from cellulosic 

fibers that have been combined with a synthetic resin or other suitable binder and joined under 

heat and pressure. MDF panels have a surface that is flat, smooth, of uniform density and free

of knots and grain patterns, and thus do not require veneers or laminates. Further, this quality 

allows for intricate and precise equipment to be used to more easily produce high-quality 

finishes. MDF is used in the production of furniture, cabinets, moulding and shelving (CPA 

2009a, EPA 2000).

The MDF manufacturing industry is small and diverse with manufacturing processes at 

various mills differentiated by their supply of raw materials, equipment set-up, and target 

market. In general, MDF manufacturing includes the mechanical pulping of raw material (chips, 

sawdust, shavings, etc.) into fibers, drying, fiber blending (where resin and wax are added, 

typically through the use of a blowline), forming of material into a continuous fibrous mat, 

pressing into consolidated boards, trimming and finally finishing. In general, MDF 

manufacturing is very similar to particleboard manufacturing, but with several key differences. 

For example, prior to refining, the raw material is “cooked” in a stream pressurized refiner 

(digester), a process that makes the lignin soften and the resulting material less brittle. Also, 

unlike particleboard production where the raw material is mechanically separated into particles, 

during the MDF refining process, the raw material is “rubbed” apart into fiber strands. Since the 

resulting fibrous material is of roughly the same size, no further screening is necessary (CPA 

2001). 
Market Profile of the Composite Wood Products Industry 17

The remainder of this subsection examines this process in greater detail. Where 

possible, the text highlights issues that may potentially arise depending on a mill’s choice of 

adhesive system. Table 2-3 outlines the steps involved in manufacturing MDF. Figure 2-3

provides a diagram of the general steps involved in MDF manufacturing.

Table 2-3: Manufacturing Steps: Medium Density Fiberboard (MDF)

Process Step Process Description

Raw material 

handling

Chips, sawdust, planer shavings, and other recycled materials are received, stored, 

cleaned, mixed, and conveyed.

Additive 

handling

Resin, wax, and other additives are received, stored, and prepared for use by mixing, 

heating, and/or dilution with water.

Refining Raw material is processed through a stream pressurized refiner and converted into 

fiber. Some mills have multiple refiners and prepare Face and Core layer fibers 

separately, others have only one refiner and don’t differentiate between Face and 

Core.

Blending Resin and wax is mixed with the fibers. Most mills use the blowline blending 

technique where the additives are mixed with the fiber prior to drying. Some mills use 

mechanical blending that applies the additives to the dry fiber.

Drying Wet fiber is passed through a heated flash tube dryer to evaporate moisture. Layered 

board mills dry Face and Core fibers separately.

Fiber Storage Dry resinated fibers are held in surge bins, and mixed with recycled fiber. These 

systems are more complicated in layered board mills than in those that make 

homogenous board.

Forming line A variety of different technologies are used to form a continuous fiber mate of the 

proper construction for the desired product. Mat trim and rejected mats are mixed 

with fresh fiber and recycled through the fiber storage area.

Pressing Mats are consolidated into rough boards under heat and pressure. A variety of press 

types are employed, including multi-opening platen presses, single opening platen 

presses, steam injection platen presses, continuous steel belt presses, and continuous 

drum (Mende) presses.

Trimming Rough boards are sawn around the perimeter.

Cooling Rough boards are held-apart to air-cool before stacking.

Finishing Rough boards are converted to finished product dimensions by sawing and sanding. 

The portion of rough board volume that is converted into saw trim and sanderdust 

varies with the mill and product, but can range from 8% to 25%.

Residual 

Management

The saw trim and sanderdust are either burned to generate process heat, recycled 

back into the board, or disposed elsewhere.

Thermal 

energy 

generation

All plants must generate steam for refining. Presses are heated with either steam or 

thermal oil. Dryers may be heated indirectly with either steam or thermal oil, or by 

direct firing. Natural gas, oil, and board residuals are all used as fuel in different mills.
Market Profile of the Composite Wood Products Industry 18

Figure 2-3: Process Flow Diagram for a Typical Medium Density Fiberboard (MDF) Manufacturing 

Facility

Wood chips Chip storage Chip washing 

(optional)

Digester

Refiner

Pressurized Refiner

Dryer Blowpipe

Dryer

Fiber 

Recovery 

Cyclone

Blender

Fiber 

Recovery 

Cyclone

Dry fiber 

storage

Resin, Wax, Additives

Drying and Blending Area

Forming Prepressing Mat trimming Hot pressing

Board cooling

Wood Recycle

Trimming, 

sanding, 

sawing

Painting/

laminating 

(optional)

Packaging/

shipping

Wood Recycle

OR

Resin, Wax, Additives

Raw Material Handling

Generally, the raw material used in MDF production is hardwood or softwood chips. 

However, MDF can also use sawdust, planer shavings and other recycled material (CPA 2009a, 
Market Profile of the Composite Wood Products Industry 19

EPA 2000). The wood chips may come from off-site locations as byproducts of other processes 

(sawmills, plywood plants, etc.) or as final products from satellite chip mills, tree chipping 

operations, etc. The chips can also be prepared on-site through use of a tree debarker and disk 

chipper (EPA 2000). The resulting chipper output is screened to ensure the chips meet size 

requirements; overly large chips are re-chipped and smaller chips may be used as fuel. Since 

chips generated on-site may contain the dirt and grit that prevents optimum processing, the 

chips may be cleaned (Suchsland and Woodson 1991). 

Additive Handling

Resin, wax, and other additives are received, stored, and prepared for use by mixing, 

heating, and/or dilution with water. Mills transitioning to a new control technology may need 

to enhance their ability to receive, store, meter, and blend the variety of necessary components 

in the precise proportions required.

Refining

Wood chips are passed through a steam pressurized refiner, consisting of two separate 

stages: 1) a digester which uses steam to soften the raw material and weaken the lignin bonds 

that connect the chips; and 2), a disk refiner, a machine using one or two revolving disks to 

mechanically pulp (refine) the chips into fibers (EPA 2000, Suchsland and Woodson 1991). Mills 

that prepare face and core fibers separately may have more than one refiner, while others may 

not. Most of the chip breakdown occurs in the primary refiner, with secondary refiners 

requiring a tenth or less of the total pulping energy (Suchsland and Woodson 1991). 

Blending

As indicated in Figure 2-3, the sequence of drying and blending operations depends on 

the MDF plant. However, most mills blend the fibers with resin, wax, and other additives prior 

to the drying process. Certain mills do use a mechanical blending process that applies the 

additives to the dry fiber. Problems can arise in the latter process if the binder has enough tack 

to cause the fibers to lump together, making uniform furnish distribution difficult (Suchsland 

and Woodson 1991). 

Most MDF plants use a blowline system to apply the adhesive, although some inject 

resins into a short-retention blender (EPA 2000). While the principles of blowline mechanics are 

straightforward (resin and additives are pumped into a refiner’s discharge pipe, using the steam 

turbulence to coat the wet fiber before the material is dried), blowline systems can be 

configured in numerous ways. As reported in a 1998 survey of U.S. and Canadian MDF plants 

conducted by Evergreen Engineering, most blowlines were between 60’ and 100’ long, and more 

than half were described as “crooked” (i.e., composed of more than one ninety degree curve). 

Additionally, over 60 percent of the mills applied the resin through one nozzle, while the 

remainder used multiple addition points. There was no consensus on nozzle orifice size either, 

ranging from under 1/8” to over 1” (Smith 1998). Depending on the adopted resin control 

technology, mills that use blowline systems may need to modify their configurations to reduce 

issues associated with blockage and increase resin performance.
Market Profile of the Composite Wood Products Industry 20

Drying

MDF plants use either single-stage or multiple stage tube dryers, and these are typically 

used to reduce the moisture content from around 47 percent to 9 percent. The tube dryers may 

be fueled with wood residuals from the raw handling process. The fibers are separated from the 

dryer exhaust in fiber recovery cyclones and then passed into dry storage bins (EPA 2000). 

Since additives typically are applied to the wet fiber before drying, potential changes in 

the resin used may increase the water load on the fiber dryer and could potentially decrease 

throughput.

Fiber Storage

Dry resinated fibers are held in surge bins and mixed with recycled fiber. These systems 

are more complicated in layered board mills than in those that manufacture homogenous 

board. Depending on the adopted control technology, precautions may need to be adopted to 

reduce or prevent worker’s exposure to potentially hazardous resinated fiber (pMDI, for 

example). 

Forming Line

MDF is dry-formed, using air to distribute the fibers onto a continuously moving screen 

in the form of a mat (Suchsland and Woodson 1991). Methods of depositing furnish can vary 

between gravity, mid-air fiber filtration system, and some combination thereof. Currently, the 

standard dry-forming device is a vacuum former. To improve the uniformity of mat thickness, 

furnish may be applied in excess quantity and shaved off later (Suchsland and Woodson 1991). 

Layered board mills shifting to an alternate control technology may be detrimentally 

affected when slower-curing low-emitting face formulations are mixed into the core layer 

through mat and trim recycling, decreasing throughput.

Pressing

Mats coming off the forming line need to be pressed to increase their density. Before 

being loaded into the main press, the hot press, mats may be pre-pressed on band presses, 

doubling or tripling their density. A variety of press types may be employed, including multiopening platen presses, single-opening platen presses, steam injection platen presses, 

continuous steel belt presses, and continuous drum (Mende) presses. The heat (ranging from 

240° to 450°F) and pressure generated by these devices activate the resin, bonding the fibers 

into a continuous mat (U.S. EPA 2000). Press cycles are important since many applications 

require MDF with a specific density profile; short closing times heat only the surface layer and 

result in higher face compressions, while longer press times allow for more uniform final 

densities. Depending on the initial moisture content, single- or multi-phase presses can be used 

(Suchsland and Woodson 1991). 

Since throughput is limited by the press’s ability to transfer heat and cure the resin, 

output may be affected in situations with slower curing alternate control technologies. Further, 

should a mill adopt pMDI as part of its formaldehyde-control technology, provisions will need to 

be adopted to ensure proper application since this material bonds with steel.
Market Profile of the Composite Wood Products Industry 21

Trimming

After they are pre-pressed, mats are trimmed around the perimeter and the waste 

material is recycled to the forming line (EPA 2000).

Cooling

Rough boards are held apart to air-cool before stacking. Depending on the adopted 

adhesive system, different methods of cooling may have to be adopted; the increased press 

heat required by some resins results in hotter MDF panels and increased cooling times.

Finishing

The cooled boards are made into finished products by sawing and sanding. Depending 

on the mill and choice of final product, between 8% and 25% of the rough board volume is 

converted into saw trim and sanderdust. Trademarks, grade stamps, and flame retardants are 

applied before the boards are packaged for shipping (EPA 2000).

Residual Management

The saw trim and sanderdust can be burned to generate heat, recycled back into the 

board-making process, or disposed of elsewhere. Since the recycling of resinated materials has 

been shown to influence board emissions, a mill’s choice of CARB phase 2 compliance strategy 

will be affected accordingly. 

Thermal Energy Generation

All MDF mills need to generate steam as part of the refining process. Presses are heated 

with either steam or thermal oil. Dryers may be heated indirectly with either steam or thermal 

oil, or by direct firing. Natural gas, oil, and board residuals are all used as fuel in different mills. 

Depending on the adopted resin control technology, mills that do not burn all their residuals 

may need to acquire the capability to do so, requiring the modification of their air emissions 

permits.

2.2 Adhesives

This section discusses the advantages and disadvantages of the adhesives currently used 

in the manufacture of composite wood products, particularly the newer resin formulations that 

are being used to lower formaldehyde emission levels of composite wood products. Factors 

influencing an adhesive’s use include the materials to be bonded together, moisture content at 

the time of bonding, mechanical property and durability requirements of the composite 

products, anticipated end-use of the product, and resin system costs (USDA 2010). Adhesives 

currently being used in the manufacture of composite wood products include traditional and 

enhanced urea-formaldehyde (UF) resins, phenol-formaldehyde (PF) resins, melaminecontaining formaldehyde resins (MUF and MF), polydiphenylmethane diisocyanate (pMDI) 

resins, polyvinyl acetate (PVA) resins, emulsion polymeric isocyanate (EPI), soy-, and tanninbased resins. 
Market Profile of the Composite Wood Products Industry 22

Urea- Formaldehyde (UF) Resins

Hardwood plywood, particleboard, and MDF have historically been manufactured with 

UF resins. They are made by adding urea to formaldehyde under basic conditions, followed by 

condensation reactions in an acidic environment, and polymerization as the pH is raised and the 

temperature is lowered (California Air Resources Board 2007). UF resins are easy to use, 

inexpensive, fast curing, tolerant of process variability, and have a neutral color after curing. 

They are not water resistant, so they are only used for interior applications. In addition, 

traditional UF resins emit larger amounts of formaldehyde when used in composite wood.

Most plants transitioning to meet CARB Phase 1 emission limits have been able to do so 

by using enhanced UF resins such as lower formaldehyde to urea mole ratio formulations;5

external and internal scavengers that bind to free formaldehyde, such as a urea in water 

solution; and/or two-part systems, where a base resin and scavenger resin are blended just prior 

to the point of application. This variety of options has allowed manufacturers to tailor their 

emissions reduction strategies to their plant’s particular capabilities and requirements. These 

enhanced UF resins are also less forgiving to process variation, require higher press 

temperatures and/or longer press times to cure, which can lead to higher reject rates, 

decreased plant productivity, and can require equipment upgrades and/or procedural changes

compared with traditional UF resins. Enhanced UF resins are currently being used to meet CARB 

Phase 2 emission requirements. According to Hexion Specialty Chemicals (as reported in 

PanelWorld 2010b), although the latest enhanced UF resins make it more critical to make 

adjustments for mill to mill variations in wood furnish and manufacturing parameters, with the 

continued optimization of the new resin systems the final costs of using the new lower emitting 

enhanced UF resins are only slightly higher than historical manufacturing costs. 

Phenol-Formaldehyde (PF) Resins

Because of their water resistance, PF resins are primarily used in oriented strandboard 

(OSB) and softwood plywood designed for exterior applications (California Air Resources Board 

2007). PF resins have several performance disadvantages, including slow curing times and 

higher press temperatures (which can reduce throughput) and dark color, which makes them 

less suitable for some aesthetic applications. Their bonds are sometimes referred to as “boilproof” because of their ability to maintain composite dimensional and mechanical properties 

under wet conditions (Stark et al. 2010). However, they also produce more brittle and less 

dimensionally stable particleboard. 

Some companies make both hardwood plywood and softwood plywood on the same 

site or even in the same facility, so are already familiar with PF resin. It is also not uncommon 

for hardwood plywood mills to use softwood veneers for inner plys, so these mills can also use 

PF resin to build their cores. Overall hardwood plywood panel emissions can be reduced 

significantly by replacing the multiple inner-ply glue lines with low-emitting PF resin. Several 

companies are already marketing Phase 2 compliant products made by the 2-step process, 

where veneer or composite platforms with PF glue lines are pressed before receiving decorative

face and back veneers bonded with PVA. These products are significantly more costly than 

products currently made with enhanced UF resins.

 5 Although if the formaldehyde to urea mole ratio becomes less than one, the resin loses some of its physical 

characteristics and must undergo further modification.
Market Profile of the Composite Wood Products Industry 23

Melamine-containing Formaldehyde Resins

Melamine-formaldehyde (MF) and melamine-urea-formaldehyde (MUF) resins are 

typically used for decorative laminating, paper treating, and paper coating (Stark et al. 2010). 

However, because of their strength, durability, and water-resistance, they can be used in 

bonding composite wood products (historically exterior and semi-exterior plywood and 

particleboard). MUF resins are less expensive and less durable than MF resins. Both are lighter 

in color than PF resins (California Air Resources Board 2007). MUF and MF resins exhibit 

handling and cure characteristics similar to UF. MF resins can be used in combination with UF to 

attain greater water resistance than UF alone (Stark et al. 2010).

Polydiphenylmethane diisocyanate (pMDI) Resins

pMDI resins have been used since the 1970s and although they are commercially 

available for MDF and particleboard, their primary current use is in OSB and strawboard 

manufacturing (California Air Resources Board 2007). pMDI resins are strong,6 fast curing, 

moisture tolerant, have long storage lives, and are formaldehyde free. However, pMDI has a 

strong affinity for bonding to steel pressing surfaces, so must be used in conjunction with a 

release agent treatment. Uncured pMDI is toxic, so special precautions must be taken to 

control worker exposure to uncured resin. Cured pMDI resin poses no recognized health 

concerns (Stark et al. 2010). In addition, because most particleboard forming lines are “caulless,” they rely on resin tack to provide the mat with enough integrity to bridge small gaps 

between forming conveyors and press loaders without fracturing. There has been some 

concern among these plants that pMDI resins fail to develop the tack needed to hold the mat 

together during this process. Similarly, there is concern in MDF plants employing blowline 

blending technology about build-up and blocking problems from pMDI resins.

Polyvinyl Acetate (PVA) Resins

PVA, also known as “white glue,” is a self-polymerizing resin that is initiated under free 

radical conditions of the monomer vinyl acetate. While PVA sets quickly at room temperature, 

has a high dry strength, and is formaldehyde free, it is susceptible to moisture, humidity and 

high temperatures. As a result, PVA is used mainly for interior applications such as hardwood 

plywood veneers and wood bonding in furniture. However, cross-linking agents can be added to 

the resin to increase its ability to withstand higher moisture contents and temperature 

(California Air Resources Board 2007). 

Most hardwood plywood mills transitioning to PVA resins as a result of CARB are smaller 

operations that make higher-value specialty or custom products for which resin costs have a less 

significant impact on the total than for stock panel products. While PVA resins are more 

expensive to purchase than UF resins, they are equally easy to use. They are supplied either as 

ready-to-use formulations, or with a catalyst. The viscosity of PVA and UF is similar, so the same 

pumps and glue spreads can be used. Tack development (the property that allows an adhesive 

to adhere to another surface on contact), and cure speeds are similar, so assembly procedures 

and press times are not impacted. 

 6 The chemical bonds in pMDI are stronger and more stable than the chemical bonds of UF or PF (CARB 2007).
Market Profile of the Composite Wood Products Industry 24

Soy-based Resins

While soy has been used in resins since the 1900s, it has only recently begun to undergo 

extensive development due to concerns about formaldehyde (California Air Resources Board 

2007). Soy resins are formaldehyde free, so are capable of meeting Phase 2 emission limits and 

claim to be cost and performance competitive with current UF products. 

Tannin-based Resins

Tannins are naturally occurring compounds derived from plants, particularly the bark of 

mangroves, mimosa, quebracho, hemlock, and sumac (California Air Resources Board 2007). 

They can be reacted with formaldehyde to form a durable low-emitting plywood adhesive 

similar to PF. Although they make excellent adhesives, their high cost, limited availability, dark 

color, and special processing requirements make them an unlikely choice for composite wood 

product manufacturers.

Emulsion Polymeric Isocyanate (EPI)

EPI is formulated by emulsifying diphenylmethane diisocyanate (MDI) resin with waterbased PVA. EPI is waterproof, has a fast cure rate, and forms strong bonds with wood, so it is 

primarily used in marine and other applications where high strength and exterior durability are 

required. It is a very expensive formulation, and unlikely to be selected solely for CARB 

compliance reasons. 

2.3 Product Characteristics, Uses, and Substitutes

This section of the market profile describes the physical characteristics of hardwood 

plywood, particleboard, and MDF (Section 2.3.1), the uses for these products (Section 2.3.2), 

and the potential substitutes for these products (Section 2.3.3). 

2.3.1 Product Physical Characteristics

A major benefit of composite wood over solid wood is that products composed of these 

materials tend to be manufactured more uniformly, reducing the natural variations that arise 

amongst wood species, trees of the same species, and even wood from the same tree. Unlike 

solid wood, which is evaluated at a cellular level, composite wood is evaluated at the level of 

fibers, particles, flakes, or veneers - these elements are the building blocks used to produce

composite wood products with predetermined properties; end products can be changed by 

combining, reorganizing, or stratifying them (Stark et al. 2010).

Strength is a crucial factor in determining the applicability of composite wood products 

for manufacturing uses. The strength of a wood product depends primarily on its constituents. 

The basic wood elements can be made in a great variety of sizes and shapes, and may utilize any 

number of wood species. As a result, the choices available for composite wood products are 

almost unlimited. The types of adhesives and bonding-agents used in the manufacture of a 

composite wood product play an important role in its strength properties (Stark et al. 2010). 

The most commonly used resin has historically been urea-formaldehyde (UF). UF is easy to use, 

inexpensive, fast curing, tolerant of process variability, and is neutral colored post-curing. 
Market Profile of the Composite Wood Products Industry 25

Durability is a factor for composite wood products. Panels used for exterior applications 

must have a fully waterproof bond and be designed for permanent exposure to weather. 

Interior panels do not require waterproof bonds and can be manufactured with adhesives

designed for interior use.

Depending on the composite wood product, a range of sizes and thicknesses is available. 

The range of applications for which these products are used requires production of several 

standardized sizes as well as custom-made pieces. Sizes and thicknesses will depend on the type 

of composite wood product and the market for which it is primarily produced.

Composite wood products structures are subject to performance-type standards as

outlined by various industry organizations.7

 A number of organizations including Composite 

Panel Association (CPA) and the Hardwood Plywood and Veneer Association (HPVA) monitor 

products produced by their member firms to assure high-quality production and industry 

conformity with testing and performance standards (Stark et al. 2010).

2.3.2 Product Uses

This section presents data on the quantity and value of the particleboard and MDF 

annually sold in the United States, by product end use. The major end uses for hardwood 

plywood are discussed since sufficient end-use data are not available. The data for 

particleboard and MDF end uses are from a Composite Panel Association (CPA) document 

entitled “2005 North American Shipments and Downstream Market Report,” which provides 

information on particleboard and MDF panel shipments from both CPA members and non 

members (CPA 2006a). The report, however, does not include data on the manufacture and 

sales of hardwood plywood products. 

Table 2-4 presents the quantities of composite wood shipped in 2005 by product 

category and composite wood type. CPA reports that non-reporting mills represented only eight 

percent of the total particleboard volume, and less than two percent of the total MDF volume. 

 7 The standards for hardwood plywood, MDF, and particleboard are respectively numbered (1) ANSI/HPVA HP–1–2009, 

(2) ANSI A208.2–2009, and (3) ANSI A208.1–2009.
Market Profile of the Composite Wood Products Industry 26

Table 2-4: Quantity of Composite Wood Product Shipments by North 

American Producers in 2005, by Product Category and Composite 

Wood Type

Product Category

Medium Density 

Fiberboard (MDF)

Particleboard

MSF % MSF %

Door Components

155,

044

6

%

311,28

9

6

%

Electronic Cabinets

14,4

07

1

% 13,748

0.

2

%

Laminate Flooring

341,

175

1

3

%

<64,73

9

<1

.2

%

Mobile Home Decking

<6,3

95

<

0

.

2

%

<64,73

9

<1

.2

%

Underlayment

<6,3

95

<

0

.

2

%

142,61

5

3

%

Household Furniture

442,

428

1

7

%

1,189,

364

21

%

Office Furniture

63,2

59

2

%

545,49

5

10

%

Kitchen Cabinets and 

Vanities

381,

812

1

4

%

1,716,

936

31

%

Counter Tops

18,2

72

1

%

268,76

3

5

%

Millwork

265,

385

1

0

% 63,538

1

%

Moulding

346,

348

1

3

%

<64,73

9

<1

.2

%

Prefinished Paneling

97,7

58

4

%

115,32

3

2

%

Retail

70,7

46

3

% 32,618

1

%

Shelving

19,3

00

1

%

244,90

9

4

%

Store Fixtures

117,

880

4

%

226,48

2

4

%

Other

307,

365

1

2

%

690,26

1

12

%

Total

2,64

7,57

4

5,626,

080
Market Profile of the Composite Wood Products Industry 27

Sources: CPA 2006a

As indicated in Table 2-4, household furniture was the largest end use for MDF (17%) 

followed by kitchen cabinets and vanities (14%) and Moulding (13%). Kitchen cabinets and 

vanities were the largest end use for particleboard (31%) with household and office furniture 

combined also accounting for about 31 percent of particleboard end uses. 

According to a November 2010 personal communication with HPVA, engineered wood 

flooring accounts for about one third of total hardwood plywood production in North America, 

while hardwood plywood panels account for the other two thirds. According to the U.S. ITC 

(2008), cabinet manufacturers were the largest market for U.S. direct manufacturer sales of 

hardwood plywood panels (16% of total sales), followed by retail building materials dealers (6% 

of total sales), furniture manufacturers (4% of total sales), and fixture manufacturers (2% of 

total sales). About 70 percent of total sales by U.S. plywood manufacturers are to wholesale 

distributers. 

2.3.3 Substitute Products

In addition to switching to products made with lower formaldehyde emitting resins, 

consumers of composite wood products may instead choose to use different products entirely. 

There are several products that are capable of filling some of the roles of MDF, particleboard, 

and hardwood plywood in furniture and construction. 

2.3.3.1 Solid Wood

Solid wood could replace some composite wood products in some applications. However, solid 

wood can have imperfections on its surface and is more expensive than many composite wood 

products (CPA 2007). In addition, it is more susceptible to warping than composite wood (CPA 

1997).

2.3.3.2 Oriented Strand-Board (OSB)

Oriented strand-board (OSB) is currently widely used in flooring, wall paneling, and 

roofing underlayment and sheathing, as well as for furniture in a more limited capacity. OSB is 

made out of wood chips or flakes that are manufactured into panels in a similar method to that 

of other wood composites. PF and pMDI are the most common resins used in the manufacture 

of OSB (APA 2009). However, OSB is only a suitable substitute for some composite wood 

products because of its rough surface (APA 2009). OSB is also waterproof, has a similar strength 

to other composite wood products, and is cost-competitive with other composite wood 

products (APA 2009).

2.3.3.3 Hardboard

Hardboard is a composite wood product made from wood fibers held together with 

resin. Hardboard is used in furniture, wall paneling, and flooring, and mostly for aesthetic 

purposes due to its uniform thickness and density. It is also easy to work with (CPA 2009b). 

However, its lack of strength and appearance make it unsuitable for some applications. 
Market Profile of the Composite Wood Products Industry 28

2.3.3.4 Softwood Plywood 

Softwood plywood is mostly used for structural purposes in residential and industrial 

situations. It has strong structural integrity and is water-resistant; however its rough surface and 

dark color renders it unsuitable for some aesthetic end uses. It is also more expensive to 

manufacture than other composite wood products due to its use of raw timber as a starting 

material. 

2.3.3.5 Gypsum Board

Gypsum board, also known as drywall or plasterboard, is made of a core of gypsum 

surrounded by paper on the surface and edges. Gypsum, a mineral found in sedimentary rock, 

is mined, combined with water and additives to make gypsum plaster, and bonded with the core 

to form a board (Gypsum Association 2009). The manufacturing of gypsum is inexpensive but 

has high installation costs. It cannot substitute for all end products of manufactured wood but 

rather works best in construction and paneling in residential buildings.

2.3.3.6 Alternative Composites 

There is a small industry that produces composite boards made from recycled paper and 

agricultural wastes such as straw or wheat. These products vary in their characteristics, but they 

have been used in some furniture, surface, and cabinet applications. These alternatives are 

produced in a way similar to wood composites; however, the straw or wheat can adhere to itself 

under heat and pressure so only a limited amount of resins are necessary. These composites are 

generally more expensive and not as widely available compared to traditional wood composite 

products.

2.4 Domestic Production and International Trade

Table 2-5 presents the domestic production, international trade, and domestic 

consumption for composite wood products. Data from 2005 were used in Table 2-5 since that 

was the most recent data available for all categories when the table was prepared. According to 

PanelWorld 2010b, citing a 2009 Composite Panel Association report, U.S. particleboard and 

MDF shipments have experienced substantial declines since 2009, and were about 2.5 and 3.9 

million cubic meters for MDF and particleboard in 2009, respectively. Domestic hardwood 

plywood production has likely experienced similar declines, but data are not available. While 

imports of hardwood plywood and particleboard have also declined substantially, MDF imports 

have increased over 40 percent since 2005. These figures do not include imports of composite 

wood as part of fabricated goods such as furniture.
Market Profile of the Composite Wood Products Industry 29

Table 2-5: 2005 U.S. Production, Trade, and Consumption of Composite Wood

Panels

(Cubic Meters); does not include imports as part of fabricated goods

Product Type

Dom

estic 

Prod

uctio

n

E

x

p

o

rt

s

Domestic Consumption Percen

t of 

Consu

mption 

from 

Import

s

Im

por

ted

D

o

m

es

tic

T

ot

al

Hardwood 

Plywood

1,84

4,00

0

2

4

3

,

7

6

3

4,0

20,

331

1,

60

0,

23

7

5,

6

2

0,

5

6

8

72%

Medium 

Density 

Fiberboard

3,25

6,91

2

1

6

3

,

8

8

9

966

,96

7

3,

09

3,

02

3

4,

0

5

9,

9

9

0

24%

Particleboard

7,27

5,39

9

2

5

8

,

8

2

7

1,3

46,

903

7,

01

6,

57

2

8,

3

6

3,

4

7

5

16%

Notes: MDF and particleboard production are from CPA (2005) data. Hardwood plywood production is from Table 2.2 from U.S. 

ITC 2008. Imports and Exports data are from U.S. ITC 2010 and include the following HTS codes: (1) hardwood plywood: 4412.13, 

4412.14, 4412.22, 4412.23, 4412.29; (2) MDF: 4411.21, (3) particleboard: 4410.31, 4410.32, 4410.33, 4410.39.

Table 2-6, Table 2-7, and Table 2-8 present the quantity and value of U.S. imports and 

exports of hardwood plywood, medium density fiberboard, and particleboard panels 

respectively. Imports and export amounts are provided for the four largest trading countries of 

each product. Again, these figures do not include imports of composite wood as part of 

fabricated goods such as furniture.

Over half of the country’s imports of hardwood plywood come from China, with Canada 

and Indonesia also supplying a significant quantity of the product. The majority of exports from 

the U.S. are sent to Canada, although the quantity of exports is minor in comparison to imports. 

International trade data for hardwood plywood is illustrated in Table 2-6 below.
Market Profile of the Composite Wood Products Industry 30

Table 2-6: Hardwood Plywood Panels: Quantity and Value of International Trade 

by Country of Origin, 2009; does not include imports as part of fabricated goods

Country

Quantity 

(Cubic 

Meters)

Percent of 

Total 

Quantity

Customs 

Value 

($1,000)

Percent of 

Total Value

Imports

China 1,120,385 54.98% 596,423 53.95%

Canada 181,619 8.91% 143,555 12.98%

Indonesia 171,867 8.43% 92,964 8.41%

Russia 173,714 8.53% 65,977 5.97%

All Others 390,098 19.14% 206,673 18.69%

Total 2,037,683 100.00% 1,105,592 100.00%

Exports

Canada 72,974 35.27% 44,543 39.61%

Mexico 20,579 9.95% 11,489 10.22%

Sweden 2,420 1.17% 1,268 1.13%

Bahamas 2,314 1.12% 1,161 1.03%

All Others 108,639 52.50% 53,980 48.01%

Total 206,926 100.00% 112,442 100.00%

Source: U.S. ITC 2010

Medium density fiberboard likewise has an uneven trade balance, with much greater 

imports (1.38 million m3

) than exports (0.4 million m3). China and Canada are the primary MDF 

providers, while a majority of exports are to either Canada or Mexico. Table 2-7 below gives 

summary information about U.S. international trade of MDF.

Table 2-7: Medium Density Fiberboard Panels: Quantity and Value of International 

Trade by Country of Origin, 2009; does not include imports as part of fabricated 

goods

Country

Quantity 

(Cubic 

Meters)

Percent of 

Total 

Quantity

Customs 

Value 

($1,000)

Percent of 

Total Value

Imports

China 551,254 40.07% 157,200 34.55%

Canada 422,862 30.74% 119,863 26.35%

Chile 171,597 12.47% 68,564 15.07%

Germany 76,575 5.57% 23,608 5.19%

All Others 153,403 11.15% 85,714 18.84%

Total 1,375,691 100.00% 454,949 100.00%

Exports

Canada 208,269 58.02% 53,918 53.81%

Mexico 130,794 36.43% 40,697 40.62%

Russia 2,597 0.72% 672 0.67%

Belgium 1,972 0.55% 490 0.49%

All Others 15,354 4.28% 4,422 4.41%

Total 358,986 100.00% 100,199 100.00%

Source: U.S. ITC 2010

Table 2-7 on the next page presents imports and exports data for particleboard in both 

actual quantity and customs value. Canada is responsible for over 90 percent of particleboard
Market Profile of the Composite Wood Products Industry 31

imports into the U.S. as well as receiving over half of particleboard exports. Compared to the 

other two major composite wood products listed above, particleboard has relatively low volume 

of trade with only 592,618 m3 imports and 174,790 m3

exports.

Table 2-8: Particleboard Panels: Quantity and Value of International Trade by 

Country of Origin, 2009; does not include imports as part of fabricated goods

Country

Quantity 

(Cubic 

Meters)

Percent of 

Total 

Quantity

Customs 

Value 

($1,000)

Percent of 

Total Value

Imports

Canada 544,392 91.86% 129,168 90.29%

Mexico 29,211 4.93% 8,030 5.61%

Switzerland 4,223 0.71% 2,911 2.04%

China 4,522 0.76% 1,576 1.10%

All Others 10,270 1.73% 1,366 0.96%

Total 592,618 100.00% 143,051 100.00%

Exports

Canada 99,320 56.82% 31,092 57.30%

Mexico 58,730 33.60% 16,768 30.90%

Russia 4,122 2.36% 1,597 2.94%

United 

Kingdom 1,660 0.95% 811 1.50%

All Others 10,958 6.27% 3,994 7.36%

Total 174,790 100.00% 54,262 100.00%

Source: U.S. ITC 2010
Market Profile of the Composite Wood Products Industry 32

3 Laminated Product Manufacturing

Wood veneer laminated product producers are considered composite wood product 

fabricators rather than hardwood plywood producers under the CARB ATCM, and they are not 

required to meet the ATCM’s emissions standards. TSCA Title VI includes laminated products in 

the definition of hardwood plywood, and directs EPA to conduct a rulemaking process to 

determine whether to exempt any of these products from the definition. If EPA does not 

exempt laminated products from the definition of hardwood plywood, then laminated products 

will have to meet TSCA Title VI’s emissions standards (in addition to being made with certified 

platforms). 

The estimated number of wood veneer laminated product producers is based on 

discussions with industry associations and a series of interviews with hardwood veneer 

manufacturers and wholesalers. The information gathered from discussions with industry 

associations indicated that there are relatively few wood veneer laminated product producers, 

with the exception of business and household furniture manufacturing. To gather more 

information EPA conducted interviews with veneer manufacturers and wholesalers in order to 

learn more about their customers that are wood veneer laminated product producers. 

The firms that were interviewed were selected from a Hardwood Veneer and Plywood 

Association (HPVA) list8 and the companies listed as “Face Veneer Suppliers” at 

www.veneernet.com. Based on information gathered from company and third party websites, 

firms on this list were categorized into four types: (1) specialized in hardwood veneer 

manufacture, (2) specialized in hardwood veneer and plywood manufacture, (3) specialized in 

hardwood veneer wholesale, and (4) wholesalers of hardwood veneer and other wood products. 

Firms on each of these four lists were sorted in random order and phone calls were placed until 

two entities in each category participated in an interview.9

 One additional set of calls was 

placed until one additional entity on the hardwood veneer wholesale list participated in an 

interview. This group was selected for the extra interview because the prior interviews 

indicated that this group appeared to have more small customers, a group where little 

information was available.

There was wide disagreement over the number of businesses in the U.S. that are wood 

veneer laminated product producers. Three respondents thought this number was less than 

1,000; two estimated that it was between 1,000 and 10,000; and three estimated it was tens of 

thousands. One respondent did not provide an estimate. Of those respondents that put the 

number in the tens of thousands, one suggested that it was more than 50,000, and another 

suggested this number was about 100,000. 

Based on the interviews, the number of potential wood veneer laminated product 

producers is likely to be between 7,000 and 14,000. The respondents that estimated that there 

 8 HPVA Veneer Manufacturer/Sales Members. Available at: http://www.hpva.org/sites/default/files/HPVAVeneer.pdf 

(Accessed April 18, 2011)

9 Note that one of the respondents on the veneer manufacturer list identified themselves as a re-manufacturer of 

veneer and was categorized as the second veneer manufacturer for the purpose of selecting the sample. A 

respondent on the veneer and plywood manufacturer list identified themselves as a manufacturer of hardwood 

veneer and other wood products and was categorized as the second veneer and plywood manufacturer for the 

purpose of selecting the sample.
Market Profile of the Composite Wood Products Industry 33

were fewer businesses may not be aware of these smaller operations because they do not cater 

to these smaller customers. Part of the reason that some respondents estimated that there 

were more wood veneer laminated product producers may be because these respondents were 

thinking of businesses that would be exempt from the rule’s requirements (e.g., veneering 

something to create a product that would not be considered a composite panel10, veneering to 

substrates (such as metal) that do not qualify as composite wood products, using veneer to 

make products that are statutorily exempt from the rule (such as boats, autos, products not 

intended for interior use, etc.). Nevertheless, publically available data and other information

that EPA has obtained from industry associations is not consistent with more than about 14,000 

businesses making wood veneer laminated products.

The following NAICS have been identified as the primary consumers of hardwood 

veneer (i.e., they consume enough veneer such that the value of raw veneer material is 

reported in Economic Census data):

• 321211 Hardwood veneer and plywood manufacturing

• 321911 Wood window and door manufacturing

• 337211 Wood office furniture manufacturing

• 337110 Wood kitchen cabinet and countertop manufacturing

• 337121 Upholstered household furniture manufacturing

• 337122 Nonupholstered wood household furniture manufacturing

• 337127 Institutional furniture manufacturing

• 337129 Wood television, radio, and sewing machine cabinet manufacturing

• 337212 Custom architectural woodwork and millwork manufacturing

• 337215 Showcase, partition, shelving, and locker manufacturing

In addition, businesses in the following industries may also do their own veneering 

(although many of them – indicated with a “*” – would be statutorily exempt from the TSCA 

Title VI rule even if they do their own veneering11:

• 321920 Wood container and pallet manufacturing*

• 336111 Automobile manufacturing*

• 336411 Aircraft manufacturing*

• 336611 Ship building and repairing*

• 336612 Boat building*

• 321999 All other miscellaneous wood product manufacturing 

• 339920 Sporting and athletic goods manufacturing

• 339932 Game, toy, and children's vehicle manufacturing

• 339992 Musical instrument manufacturing

• 811420 Reupholstery and furniture repair 

 10 Where a panel means a flat or raised rectangular piece of composite wood product.

11 Section 601(a)(3)(i) of TSCA limits the term “hardwood plywood” to panels that are intended for interior use. Section 

601(c)(9) exempts packaging products. And Section 601(c)(10) exempts certain vehicles (other than recreational 

vehicles), rail cars, boats, aerospace craft, and aircraft. 
Market Profile of the Composite Wood Products Industry 34

There are 35,846 employer establishments and 46,704 nonemployer establishments in 

these industries. Thus, it is estimated that the total number of establishments, including 

nonemployers, in these industries is 82,550.

3.1 Assumptions for High End and Low End Estimates of Wood Veneer 

Laminated Product Producers

Two sets of estimates, a high end estimate and a low end estimate, were made for the 

number of entities that make wood veneer laminated products and thus are potentially subject 

to the TSCA Title VI rule as hardwood plywood producers. Table 3-1 presents the underlying 

data, assumptions and resulting estimates for the high end estimate of the number of wood 

veneer laminated product producers. These assumptions are described in more detail below.

Windows and Doors. There are about 1,500 employer establishments and 2,200 

nonemployer establishments in this industry (NAICS 321911). Because no information was 

available about how many companies making wood windows or doors affix veneer to platforms 

themselves (as opposed to buying veneered components from suppliers), the economic analysis 

assumes all producers affix veneer. This assumption may overestimate the number of entities 

potentially subject to the rule as panel producers.12 

Furniture. There are about 6,300 employer establishments in the furniture industry 

(NAICS 337211, 337121, 337122, and 337127) and about 5,000 nonemployer establishments. 

Note that the Census does not report the number of nonemployer establishments at the 6-digit 

NAICS level, so the number of establishments reported here is estimated by applying the 

proportions of the 6-digit NAICS as a share of the broader NAICS for employer establishments to 

the number of nonemployers in the broader NAICS. 

The furniture industry is the only sector where trade associations reported that it is 

common for companies to affix veneer to their products. The Business and Institutional 

Furniture Manufacturing Association (BIFMA) indicated that “many if not most” business and 

institutional furniture producers would make products that were made with wood veneer and 

about 75 percent of those would affix the veneer themselves (BIFMA 2010). The American 

Home Furnishing Alliance (AHFA) indicated that most domestic furniture producers would affix 

wood veneer themselves, but estimated that there were about 250 firms that do this (AHFA 

2010). To develop a high end estimate for the number of wood furniture producers that affix 

veneer and thus make wood veneer laminated products, the economic analysis assumed that 50 

percent of establishments in these industries manufacture products that contain veneer and 75 

percent of those establishments do the laminating themselves. 

Kitchen Cabinets. There are about 9,700 employer establishments and 7,800 

nonemployer establishments in this industry (NAICS 337110). It is worth noting that NAICS 

337110, and thus these establishment counts, includes both cabinet manufacturers (who may 

laminate hardwood veneer) and countertop manufacturers (who do not use hardwood veneer). 

The Cabinet Makers Association, which generally represents smaller custom cabinet 

 12 Note that depending on the process for laminating the hardwood veneer, window manufacturers in particular may 

not be producing what the rule defines as a “panel,” in which case they would only be subject to the requirements for 

fabricators. However, windows containing less than 5% by volume of composite wood product and exterior doors 

containing less than 3% by volume of composite wood product are statutorily exempt from the rule’s requirements. 
Market Profile of the Composite Wood Products Industry 35

manufacturers, said “very, very few” would do their own veneering (CMA 2010). The Kitchen 

Cabinet Manufacturers Association (KCMA), which generally represents larger stock cabinet 

manufacturers, said 5 percent or less of cabinet manufacturers would do their own veneering 

(KCMA 2010). The Architectural Woodwork Institute (AWI) did not think any of its members 

would do their own veneering.13 Thus, the economic analysis assumes that 5 percent of these 

establishments affix veneers and thus make wood veneer laminated products. 

Other Products. Because the other manufacturing sectors that may include 

establishments that laminate their own hardwood veneers consist of a very diverse group of 

manufacturers, including establishments that do not even use composite wood products let 

alone laminate their own hardwood veneer, the economic analysis assumes that 5 percent of 

these establishments laminate their own hardwood veneers.

High End Estimate. The assumptions about the percentages of establishments in 

different industries that are laminating their own hardwood veneer results in a high end 

estimate that as many as 14,000 establishments might laminate hardwood veneer, as shown in 

Table 3-1. However, this estimate conflicts with information provided in the interviews with 

nine companies that sell hardwood veneer, described earlier. That information indicated that 

no more than 30 percent of businesses laminating their own hardwood veneer are nonemployer 

operations. However, the estimate of 14,000 businesses that do their own veneering is based 

on about 7,000 nonemployer operations (50% of the total). Therefore, the high end estimate of 

14,000 establishments may overestimate the number of wood veneer laminated product 

manufacturers. 

Low End Estimate. To derive a low end estimate for the number of domestic entities 

that laminate hardwood veneer, the economic analysis extrapolated to the total number of 

wood veneer laminated product establishments from the employer establishments by assuming 

that 30 percent of the total are nonemployer establishments, based with information provided 

in the interviews with nine companies that sell hardwood veneer, described earlier. In addition, 

it was assumed that 1 percent of manufacturers in the miscellaneous manufacturing sectors 

laminate their own veneer as compared to the 5 percent that was assumed for the upper bound 

estimate. Other assumptions were the same as for the upper bound estimate. Table 3-2

presents the underlying data, assumptions and resulting estimates for the lower bound estimate 

of domestic entities that laminate hardwood veneer.

 13 Note that participants in the veneer sales interviews did think this was common for architectural woodwork and 

millwork manufacturers, but there are only about 4,000 entities in this sector.
Market Profile of the Composite Wood Products Industry 36

Table 3-1: High End Estimate for Entities that Laminate Hardwood Veneer

Employer NAICS

None

mploy

er 

NAICS

Establishments 

in Affected 

NAICS

Entities Doing Own 

Veneering

Description of Assumptions

Emp

loye

rs

N

o

ne

m

pl

o

y

e

rs

E

m

pl

oy

er

s

N

o

ne

m

pl

o

y

er

s

A

ll 

E

n

ti

ti

e

s

321211: Hardwood veneer and plywood 

manufacturing

321: 

Wood 

produ

ct 

manuf

acturi

ng

3

0

3

4

5

6

6

8 - 6

8

50 Custom panel producers and 

18 engineered wood flooring 

producers.

321911: Wood window and door 

manufacturing

1

,

4

9

3

2

,

2

4

6

1

,

4

9

3

2

,

2

4

6

3

,

7

3

9

Assume all wood window and 

door producers do their own 

veneering.

321920: Wood container and pallet 

manufacturing

2

,

9

1

8

4

,

3

9

0

- - -

Assume statutorily exempt.

321999: All other miscellaneous wood 

product manufacturing

1

,

9

7

1

2

,

9

6

5

7

3

9

1

,

1

1

2

1

,

8

5

1

Assume 50 percent use veneer 

and 75 percent of those laminate 

the veneer themselves.

337110: Wood kitchen cabinet and 

countertop manufacturing

337: 

Furnit

ure 

and 

relate

d 

produ

ct 

manuf

9

,

7

0

1

7

,

7

6

9

4

8

5

3

8

8

8

7

3

Assume 5 percent do their own 

veneering.

337211: Wood office furniture 

manufacturing

4

5

7

3

6

6

1

7

1

1

3

7

3

0

8

Assume 50 percent use veneer 

and 75 percent of those laminate 

the veneer themselves. 337121: Upholstered household furniture 1 1 6 4 1
Market Profile of the Composite Wood Products Industry 37

manufacturing acturi

ng

,

6

4

1

,

3

1

4

1

5

9

3

,

1

0

8

337122 Nonupholstered wood household 

furniture manufacturing

3

,

4

1

4

2

,

7

3

4

1

,

2

8

0

1

,

0

2

5

2

,

3

0

5

337127: Institutional furniture 

manufacturing

7

7

6

6

2

1

2

9

1

2

3

3

5

2

4

337129: Wood television, radio, and sewing 

machine cabinet manufacturing

2

6

5

2

1

2

9

9

8

0

1

7

9

337212: Custom architectural woodwork 

and millwork manufacturing

2

,

2

3

5

1

,

7

9

0

8

3

8

6

7

1

1

,

5

0

9

337215: Showcase, partition, shelving, and 

locker manufacturing

1

,

3

7

5

1

,

1

0

1

5

1

6

4

1

3

9

2

9

336111: Automobile manufacturing

336: 

Transp

ortatio

n 

equip

ment 

manuf

acturi

ng

1

8

8

9

8 - - - Assume statutorily exempt.

336411: Aircraft manufacturing 2

6

5

1

3

8

- - -

Assume statutorily exempt.

336611: Ship building and repairing 6

7

4

3

5

0

- - -

Assume statutorily exempt.

336612: Boat building 1

,

1

1

7

5

8

0

- - -

Assume statutorily exempt.

339920: Sporting and athletic goods 

manufacturing

339: 

Miscel

laneou

1

,

8

3

,

9

9

4

1

9

6

2

9

0

Assume 5% do their own 

veneering.
Market Profile of the Composite Wood Products Industry 38

s 

manuf

acturi

ng 

8

1

2

5

339932: Game, toy, and children's vehicle 

manufacturing 6

3

9

1

,

3

3

3

3

2

6

7

9

9

Assume 5% do their own 

veneering.

339992: Musical instrument manufacturing

6

0

0

1

,

2

5

2

3

0

6

3

9

3

Assume 5% do their own 

veneering.

811420: Reupholstery and furniture repair 4

,

6

9

3

2

2

,

5

4

9

- - - Assume statutorily exempt.

Total 3

6

,

6

0

6

5

6

,

1

8

9

6

,

7

5

1

7

,

1

2

4

1

3

,

8

7

5
Market Profile of the Composite Wood Products Industry 39

Table 3-2: Low End Estimate for Entities that Laminate Hardwood Veneer

NAICS

None

mploy

er 

NAICS

Establishments 

in Affected 

NAICS

Entities Doing Own 

Veneering

Description of Assumptions

Emp

loye

rs

N

o

ne

m

pl

o

y

e

rs

E

m

pl

oy

er

s

N

o

ne

m

pl

o

y

er

s

A

ll 

E

n

ti

ti

e

s

321211: Hardwood veneer and plywood 

manufacturing

321: 

Wood 

produ

ct 

manuf

acturi

ng

3

0

3

4

5

6

6

8

6

8

50 Custom panel producers 

and 18 engineered wood 

flooring producers.

321911: Wood window and door 

manufacturing

1

,

4

9

3

2

,

2

4

6

1

,

4

9

3

6

4

0

2

,

1

3

3

Assume all wood window and 

door producers do their own 

veneering.

321920: Wood container and pallet 

manufacturing

2

,

9

1

8

4

,

3

9

0

Assume statutorily exempt.

321999: All other miscellaneous wood 

product manufacturing

1

,

9

7

1

2

,

9

6

5

9

9

4

2

1

4

1

Assume 50 percent use veneer 

and 75 percent of those 

laminate the veneer 

themselves.

337110: Wood kitchen cabinet and 

countertop manufacturing

337: 

Furnit

ure 

and 

relate

d 

produ

ct 

manuf

9

,

7

0

1

7

,

7

6

9

4

8

5

2

0

8

6

9

3

Assume 5 percent do their own 

veneering.

337211: Wood office furniture 

manufacturing

4

5

7

3

6

6

1

7

1

7

3

2

4

4

Assume 50 percent use veneer 

and 75 percent of those 

laminate the veneer 

337121: Upholstered household furniture 1 1 6 2 8 themselves.
Market Profile of the Composite Wood Products Industry 40

manufacturing acturi

ng

,

6

4

1

,

3

1

4

1

5

6

4

7

9

337122 Nonupholstered wood household 

furniture manufacturing

3

,

4

1

4

2

,

7

3

4

1

2

8

0

5

4

9

1

,

8

2

9

337127: Institutional furniture 

manufacturing

7

7

6

6

2

1

2

9

1

1

2

5

4

1

6

337129: Wood television, radio, and sewing 

machine cabinet manufacturing

2

6

5

2

1

2

9

9

4

2

1

4

1

337212: Custom architectural woodwork 

and millwork manufacturing

2

,

2

3

5

1

,

7

9

0

1

1

2

4

8

1

6

0

337215: Showcase, partition, shelving, and 

locker manufacturing

1

,

3

7

5

1

,

1

0

1

5

1

6

2

2

1

7

3

7

336111: Automobile manufacturing

336: 

Transp

ortatio

n 

equip

ment 

manuf

acturi

ng

1

8

8

9

8 0 - Assume statutorily exempt.

336411: Aircraft manufacturing 2

6

5

1

3

8

0 -

Assume statutorily exempt.

336611: Ship building and repairing 6

7

4

3

5

0

0 -

Assume statutorily exempt.

336612: Boat building 1

,

1

1

7

5

8

0

0 -

Assume statutorily exempt.

339920: Sporting and athletic goods 

manufacturing

339: 

Miscel

laneou

1

,

8

3

,

9

1

9 8 2

7

Assume 1% do their own 

veneering.
Market Profile of the Composite Wood Products Industry 41

s 

manuf

acturi

ng 

8

1

2

5

339932: Game, toy, and children's vehicle 

manufacturing 6

3

9

1

,

3

3

3

6 3 9

Assume 1% do their own 

veneering.

339992: Musical instrument manufacturing

6

0

0

1

,

2

5

2

6 3 9

Assume 1% do their own 

veneering.

811420: Reupholstery and furniture repair 4

,

6

9

3

2

2

,

5

4

9

- - - Assume exempt.

Total 3

6

,

6

0

6

5

6

,

1

8

9

5

,

2

6

0

2

,

2

2

6

7

,

4

8

6
Market Profile of the Composite Wood Products Industry 42

4 Hardboard Manufacturers

This section presents a summary of the hardboard manufacturing industry. Section 4.1

presents information on the hardboard production process. Section 4.2 describes the end uses 

for hardboard. Section 4.3 presents information on domestic production and international 

trade. 

4.1 Production Process

Both MDF and hardboard fall into a broader category classified as “fiberboard” 

products, sharing many common elements of the production process. In hardboard

manufacturing, as in MDF manufacturing, wood chips are softened in pressurized steam vessels, 

refined into wood fibers, generally mixed with a resin (and other additives), formed into mats, 

and pressed into panels. What differentiates hardboard from MDF manufacturing are the 

additional steps of heat treatment and humidification, to improve the physical characteristics of 

the board. Furthermore, unlike MDF, which is only manufactured using dry processing, 

hardboard can be manufactured by dry processing, wet processing, or wet/dry processing (EPA 

2000). This section discusses dry process manufacturing and then wet process manufacturing; 

because wet/dry processing does not use resin it is not discussed here.14 

Figure 4-2 provides a diagram of the general steps involved in dry process hardboard

manufacturing (EPA 2002). 

 14 Wet-process boards are made under much higher heats and pressures than dry-process boards. The higher pressures 

result in higher density panels. The higher temperatures are extreme enough to re-polymerize the lignin resins found 

in the wood. It is the woods own lignin resins which bond the fibers of wet-process boards together. "Wet-process" 

boards are smooth on one side, textured on the other. A large majority of hardboard is manufactured using the wet 

process (Suchsland and Woodson 1991).
Market Profile of the Composite Wood Products Industry 43

The primary raw material used in the manufacture of hardboard is hardwood or 

softwood chips.15 Chips can be prepared on site through the use of tree-debarkers and wood 

chippers, or they can be purchased from off-site and shipped to the facility. The chips are 

screened for size, re-chipped if necessary, and then stored. After they have been cleaned, the 

wood chips are sent to a pressurized refiner or are softened in a digester and then sent to an 

atmospheric refiner, a device which uses revolving disks to mechanically pulp the fibers.16 At 

this stage, resin (generally PF), wax, and other additives are mixed with the fibers.17 Like MDF, 

most hardboard manufacturing facilities use a blowline system to apply the adhesive, using 

steam turbulence from the refiner’s discharge pipe to coat the wet fiber before the material is 

dried. Most mills use single- or multiple-stage tube dryers to dry the resinated wood fibers. 

Primary tube dryers dry the fibers from around 51 percent moisture to around 20 percent 

moisture at temperatures ranging between 145° to 475°F; secondary tube dryers are used to 

reduce the moisture to around 6 percent. Rotary dryers may also be used, but are less common. 

Dryers may be heated indirectly with either steam or thermal oil, or by direct firing. Having 

passed through the dryers, the fibers are stored in a cyclonic collector. From here they are 

deposited onto a continuously moving conveyor belt to be formed into mats. The mats are prepressed, trimmed, and loaded into the hot press, where the average press temperature is about 

 15 Although some plants use shavings and sawdust as well (EPA 2000). 16 Atmospheric refiners are different from pressurized refiners in that in the former steam pressure is not maintained 

throughout the entire refining process, while in the latter it is. 17 Wax is used to make the board more water resistant. 

Figure 4-1: Process Flow Diagram for a Hardboard manufacturing facility

On-site chip 

preparation

Chip Washer 

(optional)

Off-site chip 

preparation

Digester/

Refiner Wax

Blowline Resin, Additives

Primary tube 

dryer

Secondary 

tube dryer 

(optional)

Dry fiber 

storage bin

Dry former Hot press Cooler 

(optional)

Baking/

Tempering 

Oven

Humidification 

kiln Finishing
Market Profile of the Composite Wood Products Industry 44

410°F, for about 4 minutes to activate the resin and bond the fibers. Most hardboard mills use a 

multi-opening batch press. The main difference between dry process MDF and dry process 

hardboard occurs here, as hardboard is heat treated (at temperatures up to 340°F) and 

humidified, with the former used to improve the board’s dimensional stability and mechanical 

properties, and the latter necessary to bring the board moisture content back to equilibrium 

(EPA 2000). Humidification kilns are often integrated with the hardboard ovens (EPA 2002). 

Finally, the hardboard is finished and packaged for shipping (EPA 2000). 

Wet Process Hardboard

Figure 4-2 provides a diagram of the general steps involved in wet process hardboard

manufacturing (EPA 2002). 

Like the dry process, wet process hardboard uses wood chips (hardwood or softwood) 

generated on site or purchased off-site (EPA 2000). The wood chips are cleaned and steam 

cooked in digesters to soften the chips and release the wood sugars. The chips are ground into 

fibers using a single- or double-disc atmospheric refiner. The fibers pass through stock washers 

to wash away the wood sugars, which may otherwise detrimentally affect the board’s final 

quality. Secondary refiners may be used. Water, alum, resin (generally PF) and other additives 

are mixed with the fibers in a mixing chest. Alum is used to control the pH levels and help 

precipitate the bond between the resin and the fibers. The resulting slurry passes through a wet 

forming machine, a moving wire screen where the water drains first by gravity and then suction. 

Figure 4-2: Process Flow Diagram for a Hardboard manufacturing facility

On-site chip 

preparation

Steam 

digester 

(optional)

Off-site chip 

preparation

Refiner

Washer 

(optional) Mixing chest

Wet former

Water, additives

Fiberboard 

Board Dryer

Finishing
Market Profile of the Composite Wood Products Industry 45

At some plants the forming machine separates the material into a top layer (overlay) and 

bottom layer (substrate); the overlay is further refined to ensure a smoother finish. The fiber 

mats are transported to a hot press, typically a multi-opening, steam-heated batch press. The 

mats are pressed at around 390°F for about 8 minutes. As with the dry process, at this stage the 

wet process hardboard may be heat treated and humidified. Finally, the hardboard is finished 

and packaged for shipping (EPA 2000).

4.2 Product Uses

Approximately 94 percent of all reported basic hardboard shipments were value-added. 

Door skins (moulded and flush) comprised the greatest share and coated panels comprised the 

smallest share of these shipments. Specifically, 57.6 percent of shipments were door skins, 18.0

percent pre-finished paneling, 16.1 percent coated panels, and the remaining 8.3 percent not 

specified (CPA 2006a).

The most significant downstream application of hardboard during 2005 was textured 

siding, with 35 percent or 282 million square feet (3/4” basis) of total North American 

hardboard shipments dedicated to this application. The second most frequently applied use of 

hardboard was door components, capturing 28 percent or 220 million square feet of total 

hardboard shipments. Exterior trim accounted for a significant 18 percent of shipments, 

followed by prefinished paneling at 9 percent of shipments. The remaining applications (smooth 

siding and retail) each accounted for less than 3 percent of shipments (CPA 2006a). 

4.3 Domestic Production and International Trade

4.3.1 Domestic Production

North American hardboard shipments totaled 4.79 billion square feet (1/8” basis) in 

2005, an increase of 3.8 percent from 2004. However, hardboard shipments have declined 

steeply since 2005, and were reported to be only 2.5 billion square feet (1/8” basis) in 2009 

according to an article in PanelWorld 2010b citing a CPA report. 

4.3.2 International Trade

Trade data specific to hardboard were not available, so Table 4-1 presents the quantities 

and values of fiberboard imports and exports, excluding MDF, by the country of origin or 

destination. Canada is the largest trading partner by a wide margin, but China, Germany, and 

Brazil are also significant sources of imports. 
Market Profile of the Composite Wood Products Industry 46

Table 4-1: Hardboard and High Density Fiberboard: Quantity and Value 

of International Trade by Country of Origin or Destination, 2009

Country

Quantity 

(Cubic 

Meters)

Percent 

of Total 

Quantity

Customs 

Value 

(thousands, 

2009$)

Percent 

of Total 

Value

Imports

Canada 137,435 27.10% $117,903 43.59%

China 137,191 27.05% $46,253 17.10%

Germany 91,392 18.02% $34,205 12.65%

Brazil 74,965 14.78% $21,174 7.83%

All Others 66,244 13.06% $50,954 18.84%

Total 507,227 100.00% $270,491 100.00%

Exports

Canada 295,629 82.66% $80,041 79.33%

Mexico 13,834 3.87% $4,356 4.32%

France 6,632 1.85% $3,040 3.01%

Australia 3,181 0.89% $2,251 2.23%

All Others 38,360 10.73% $11,207 11.11%

Total 357,636 100.00% $100,895 100.00%

Source: U.S. ITC 2010 (HTS Codes: 4411.92, 4411.93 )

4.4 Comparisons Between Hardboard and MDF

The ANSI standards for hardboard are: “Basic Hardboard” (ANSI A135.4-2004), 

“Prefinished Hardboard Paneling” (ANSI A135.5-2004), or “Hardboard Siding” (ANSI A135.6-

2006). Basic hardboard is a panel manufactured primarily from inter-felted lignocellulosic fibers 

which are consolidated under heat and pressure in a hot-press to a density of 500 kg/m3 (31 

lbs/ft3) or greater. Other materials may be added to improve certain board properties, and 

these panels are available with either one or two smooth sides (CPA 2004a). Prefinished 

hardboard paneling is paneling manufactured meeting certain requirements for the finishing of 

the product and using a hardboard substrate meeting the described standards of basic 

hardboard (CPA 2004b). Hardboard siding is a wood-based product used for exterior wall 

covering. It is manufactured as panel or lap sidings in smooth and textured surfaces, unfinished, 

factory primed for painting, or prefinished (CPA 2006b).

The ANSI standard for MDF is ANSI A208.2-2009. MDF density is typically between 500 

kg/m3 (31 lbs/ft3) and 1000 kg/m3 (62 lbs/ft3) (CPA 2002). Fiberboards are categorized into 

three main categories by density: medium density fiberboard (MDF), high density fiberboard 

(HDF or thin MDF), and hardboard. As can be seen from the ANSI standards given above, board 

density does not provide a clear distinction between MDF and hardboard. Furthermore, 

different sources report different density thresholds for MDF and hardboard, although this 

information may not represent products produced in the U.S.

18 

 18 Kües 2007 reports that MDF typically has density between 600 kg/m3 and 900 kg/m3, that thin MDF is expected to 

have a density on the higher end of this range, and that hardboard typically has a higher density of between 900.
Market Profile of the Composite Wood Products Industry 47

Fiberboard can be manufactured using a wet process, a dry process, or a wet/dry 

process. Wet- and dry-formed fiberboard processes differ drastically from one another, 

although many of the initial processing steps are common to both. Although there are 

significant differences between wet and dry fiberboard processing in practically all steps, 

beginning with cooking and refining, a more visible and fundamental differentiation begins with 

the forming and carries through the pressing operation (Suchsland and Woodson 1991).

4.4.1.1 Wet-Process Boards

The term "wet-process" refers to one of the two methods used to make wooden 

fiberboards. (The other is the "dry-process".) Wet-process hardboard uses large amounts of 

water in the process, similar to the manufacture of insulating board. Fiberized wood and water 

are made into a slurry. The slurry is formed into sheets on belts or screens, much as in the 

process of paper-making. After some of the water is removed, the wet sheets are put into 

presses where, under extreme heat and pressure, the remainder of the water is removed and 

the fibers are compressed into boards. Wet-process boards are made under much higher heats 

and pressures than dry-process boards. The higher pressures result in higher density panels. The 

higher temperatures are extreme enough to re-polymerize the lignin resins found in the wood. It 

is the wood’s own lignin resins which bond the fibers of wet-process boards together. "Wetprocess" boards are smooth on one side, textured on the other. A large majority of hardboard is 

manufactured using the wet process (Maloney 1996).

4.4.1.2 Dry-Process Boards

The term "dry-process" refers to the second method of producing wooden fiberboards. 

Dry wood fibers are mixed with strong and stable synthetic resins. Piles, or "mats", of this 

mixture, usually several feet thick, are placed in massive presses. The mats are compressed 

under high heat and pressure. The resins melt, binding the fibers together into hard, dense 

panels. The fibers in the panels are tightly interlocked and oriented randomly in three 

dimensions. The panels are prized for their internal bond strength, dimensional stability, and 

resistance to warping, as well as their long-term durability. All MDF and HDF production utilizes 

the "dry-process", as does a small percentage of hardboard production. Dry-process hardboard 

can be confused with thin MDF because the processes used for each are quite similar. The 

board usually has poorer properties under wet conditions than does wet-process hardboard 

because hemicelluloses19 are retained in the furnish rather than partially washed away 

(Maloney 1996).

4.4.1.3 Wet/Dry-Process Boards

Production of wet/dry process hardboard includes pulping of softwood or hardwood 

chips, wet forming, drying, pressing, heat treatment, humidification and finishing. Wet/dry 

process hardboard production is similar to fiberboard production until the pressing step of the 

process is reached. The pressing, heat treatment, and humidification steps in wet/dry 

 

kg/m3 and 1,200 kg/m3 English et al. 1994 state that MDF typically has densities ranging from 600 – 800 kg/m3, and 

hardboard density ranges from 500 -1,450 kg/m3. Gardziella et al. 2000 has an MDF range of 600-800 kg/m3 and 

hardboard range of 900-1200 kg/m3. Hudson Highland 2004 defines MDF as less than roughly 960 kg/m3, thin MDF 

as 960-1,100 kg/m3, and hardboard as greater than 1,100 kg/m3. 19 A constituent of woods that is, like cellulose, a polysaccharide, but less complex and easily hydrated.
Market Profile of the Composite Wood Products Industry 48

hardboard production are similar to the same steps in wet hardboard production. No resin is 

used in the production of wet/dry hardboard (EPA 2002).

As described above, hardboard products can be manufactured through dry processing, 

wet processing, or wet/dry processing. Resin usage in hardboard and other fiberboard products 

varies by manufacturing process. Phenol-formaldehyde (PF) resins are typically used in both 

wet-process and dry-process hardboard manufacturing; they are added to the wood fiber during 

or immediately following refining. No resin is used in the production of wet/dry hardboard

(EPA 2002).
Market Profile of the Composite Wood Products Industry 49

5 Reconstituted Wood Products and Hardwood Veneer and Plywood 

Manufacturing Industry

This section presents information on the value of shipments, international trade, 

industry organization, and market outlook for the broader Reconstituted Wood Products 

Manufacturing and Hardwood Plywood and Veneer Manufacturing industries as defined by the 

North American Industry Classification System (NAICS). These broader industry categories 

include some manufacturers that are not subject to any requirements under the proposed TSCA 

Title VI rule. North American Industry Classification System (NAICS) codes for the potentially 

affected manufacturing industries were indentified through a review of information reported by 

the United States Census Bureau. Table 5-1 provides a list of the relevant NAICS codes, their 

descriptions, and cross-referenced product categories.

In addition to hardwood plywood, the Hardwood Plywood and Veneer Manufacturing 

industry (NAICS 321211) includes manufacturers of the hardwood veneers. These veneers are 

typically not manufactured at the same facilities that manufacture hardwood plywood. Facilities 

that only manufacture veneer would not be subject to the proposed TSCA Title VI rule.

The Reconstituted Wood Product Manufacturing industry (NAICS 321219) includes 

manufacturers of structural composite panels which are not regulated under the TSCA Title VI 

rule (including chipboard, flakeboard, insulation board, oriented strandboard, and waferboard). 

This industry category also includes manufacturers that produce finished panels from regulated 

stock panels (e.g., manufacturers that apply high pressure laminates, thermally fused melamine, 

light weight basis papers, decorative foils, film overlays, etc.). Such manufacturers would be 

regulated as fabricators under the proposed TSCA Title VI rule, and thus subject to the 

recordkeeping and labeling requirements, but the finished panels are not subject as such to the 

emissions standards in TSCA Title VI.
Market Profile of the Composite Wood Products Industry 50

Table 5-1: NAICS Codes, Descriptions, and Cross-Referenced Product 

Categories

Product 

Description NAICS Cross-Referenced Product Categories

Hardwood 

Veneer and 

Plywood 

Manufacturing

321211

Hardwood plywood composites manufacturing

Hardwood veneer or plywood manufacturing

Panels, hardwood plywood, manufacturing

Plywood, faced with nonwood materials, hardwood, 

manufacturing

Plywood, hardwood faced, manufacturing

Plywood, hardwood, manufacturing

Prefinished hardwood plywood manufacturing

Veneer mills, hardwood

Reconstituted 

Wood Products 321219

Board, bagasse, manufacturing

Board, particle, manufacturing

Chipboard (i.e., particle core, wood chip face), 

manufacturing

Compression modified wood manufacturing

Densified wood manufacturing

Fiberboard manufacturing

Flakeboard manufacturing

Hardboard manufacturing

Insulation board, cellular fiber, manufacturing

Lath, fiber, manufacturing

MDF (medium density fiberboard) manufacturing

Oriented strandboard (OSB) manufacturing

OSB (oriented strandboard) manufacturing

Particleboard manufacturing

Reconstituted wood panels manufacturing

Reconstituted wood sheets and boards manufacturing

Strandboard, oriented, manufacturing

Waferboard manufacturing

Sources: U.S. Census 2008

5.1 Value of Shipments

This section presents information on the value of shipments by domestic manufacturers. 

Over 90 percent of the $3.4 billion in shipments for the Hardwood Veneer and Plywood 

Manufacturing industry is associated with hardwood veneer and plywood (see Table 5-2). These 

shipments include both hardwood veneers and the hardwood plywood products produced using 

the hardwood veneers, whereas only the hardwood plywood manufacturing operations would 

be directly affected by the proposed rule. Particleboard shipments accounted for about 22 

percent of the $6.7 billion in shipments for the Reconstituted Wood Product Manufacturing 

industry (see Table 5-2). The value of MDF shipments was not available from the U.S. Census 

data.
Market Profile of the Composite Wood Products Industry 51

Table 5-2: Value of Shipments by Domestic Manufacturers

NAICS 

Description NAICS Shipment Type

Value of Shipments 

(thousands, 2007$)

Hardwood 

Veneer and 

Plywood 

Manufacturing

321211

Hardwood veneer and 

plywood manufacturing $3,155,728

Softwood veneer and 

plywood manufacturing $97,722

Wood Chips $12,548

Other secondary 

products $12,963

Resales - Sales of 

products bought/sold 

without further mfg $71,634

Contract work -

Receipts for work done 

for others on their 

materials $27,831

Miscellaneous receipts, 

including receipts for 

repair work, and 

scrap/refuse sales $12,670

Total Value of 

Shipments $3,391,096

Reconstituted 

Wood Products 

Manufacturing

321219

Particleboard $1,453,310

Cellulosic fiberboard 

(insulating board) $182,459

Hardboard products $643,322

Other reconstituted 

wood products $4,267,338

Resales - Sales of 

products bought/sold 

without further mfg $84,243

Other secondary 

products and other 

secondary receipts $88,435

Total Value of 

Shipments $6,719,107

Sources: U.S. Census 2010f

5.2 Production Costs

This section discusses the costs of production associated with the manufacture of 

composite wood products. Data from the 2007 Economic Census are used to estimate an 

average cost-to-shipment ratio for the potentially affected NAICS groups. 

Table 5-3 uses data drawn from the 2007 Economic Census to summarize annual costs 

and shipments by NAICS code in 2007. From these data, it is possible to estimate an industrywide ratio of production costs (an aggregation of the cost of materials, capital expenditures, and 

payroll costs) to the overall value of shipments (VOS), which provides an approximate measure 

of how much cash, at a gross level, the industries are generating to cover all operating expenses, 
Market Profile of the Composite Wood Products Industry 52

use for capital investment, and provide a return to owners.20 A higher ratio of costs to 

shipments could indicate a greater vulnerability to regulatory impacts. As indicated in Table 5-3, 

the cost to shipment ratio is about 83 percent for these industries.

Table 5-3: Summary of Annual Costs and Shipments, 2007 (thousands, 2007$)

NAICS NAICS Description Industry 

Shipments

Cost of 

Materials

Capital 

Expenditure Payroll

Ratio 

Costs 

Shipme

321211 Hardwood Veneer and 

Plywood Manufacturing $3,425,676 $2,205,161 $71,100 $594,847 8

321219 Reconstituted Wood 

Products $6,896,468 $4,445,566 $327,970 $890,935 8

Sources: U.S. Census 2009c

Table 5-4 presents the material costs by material type for the Hardwood Veneer and 

Plywood Manufacturing and Reconstituted Wood Product Manufacturing industries. Veneers 

account for the largest share of the materials costs for the Hardwood Veneer and Plywood 

Manufacturing industry. Note that glues and adhesives appear to account for only a very small 

percentage of the Hardwood Veneer and Plywood Manufacturing material costs, but these costs 

are likely to make up a higher percentage of the materials cost for hardwood plywood 

manufacturers because hardwood veneer manufacturers do not use glues or adhesives in their 

manufacturing process.

Wood materials account for the largest share (33 percent) of the material costs for the 

Reconstituted Wood Product Manufacturing industry. Resins and wax material costs account for 

about 25 percent of the total materials costs for the industry. 

 20 While the costs to shipment ratio does indicate the proportion of revenues received for the goods produced that are 

associated with production expenses (materials, capital expenditures, and payroll), it does not reflect other operating 

expenses such as electrical costs, employment expenses, taxes, interest, or depreciation. Nor does it indicate whether 

the expenses are variable or fixed.
Market Profile of the Composite Wood Products Industry 53

Table 5-4: Material Costs by Materials Type (thousands, 2007$)

Material Type Materials 

Cost

Percent 

of 

Materials 

Cost

Hardwood Veneer and Plywood Manufacturing

Hardwood logs and bolts $331,471 16.1%

Stumpage and Softwood logs and bolts $41,804 2.0%

Logs and Bolts Subtotal $373,275 18.1%

Hardwood veneer $626,244 30.3%

Softwood veneer $187,062 9.1%

Veneer Subtotal $813,306 39.4%

Glues and adhesives $49,565 2.4%

Hardwood plywood $158,002 7.7%

Particleboard (wood) $69,367 3.4%

Medium density fiberboard (MDF) $67,892 3.3%

Panel Subtotals $295,261 14.3%

Other Materials $532,502 25.8%

Total $2,063,909

Reconstituted Wood Product Manufacturing

Logs and bolts $446,597 11.8%

Pulpwood $376,893 9.9%

Chips, slabs, edgings, sawdust, and other wood waste $316,508 8.4%

Planer shavings $125,569 3.3%

Wood Materials Subtotal $1,265,567 33.4%

Urethane adhesives $120,261 3.2%

Urea and melamine resins $390,526 10.3%

Phenolic and other tar acid resins $183,297 4.8%

Petroleum wax $99,648 2.6%

All other plastics resins consumed in the form of granules, 

etc. $173,912 4.6%

Resins and Wax Subtotal $967,644 25.5%

Paints, varnishes, stains, lacquers, shellacs, japans, etc. $41,633 1.1%

Overlays, vinyl and paper $148,232 3.9%

Finishes Subtotals $189,865 5.0%

Hardboard $160,646 4.2%

Medium density fiberboard (MDF) $146,384 3.9%

Particleboard (wood) $211,734 5.6%

Panel Subtotals $518,764 13.7%

Other Materials $846,295 22.3%

Total $3,788,135

Sources: U.S. Census 2009d

5.3 International Trade

Table 5-5 presents data on the U.S. imports and exports of hardwood veneer and 

plywood and reconstituted wood products for the 2009 top five trading partners in each 

category. Again, this data does not include composite wood imported or exported as part of 
Market Profile of the Composite Wood Products Industry 54

fabricated goods such as furniture. Canada is the top 2009 trading partner for exports of both 

products and for imports of Reconstituted Wood Products. China has been the largest source of 

Hardwood Veneer and Plywood imports since 2005 and the second largest source of 

reconstituted wood product imports since 2007. 

Table 5-5: International Trade in Hardwood Veneer and Plywood and Reconstituted Wood Panel P 

does not include trade as part of fabricated goods

Country 2000 2001 2002 2003 2004 2005

Hardwood Veneer and Plywood Imports

China $34 $50 $105 $168 $429 $613 

Canada $382 $354 $377 $349 $407 $422 

Indonesia $232 $193 $212 $189 $213 $194 

Russia $86 $101 $127 $113 $166 $162 

Malaysia $108 $94 $129 $118 $207 $174 

Other 

countries $300 $265 $315 $326 $431 $370 

Total $1,143 $1,057 $1,265 $1,262 $1,853 $1,935 

Hardwood Veneer and Plywood Exports

Canada $151 $147 $168 $184 $191 $188 

Mexico $26 $19 $28 $23 $35 $38 

Germany $72 $54 $49 $65 $63 $59 

Spain $43 $41 $46 $41 $43 $45 

Italy $18 $23 $24 $25 $24 $27 

Other 

countries $157 $142 $159 $146 $184 $157 

Total $467 $425 $474 $485 $539 $514 

Reconstituted Wood Products Imports

Canada $1,714 $1,488 $1,560 $2,488 $3,450 $3,210 

China $1 $2 $1 $3 $13 $56 

Chile $47 $51 $59 $89 $134 $143 

Germany $84 $130 $125 $97 $187 $201 

Spain $11 $9 $42 $45 $102 $119 

Other 

countries $200 $201 $255 $382 $508 $614 

Total $2,057 $1,882 $2,042 $3,104 $4,395 $4,343 

Reconstituted Wood Products Exports

Canada $169 $137 $152 $146 $189 $201 

Mexico $78 $94 $99 $84 $79 $82 

Russia $0 $0 $1 $1 $1 $1 

France $6 $7 $5 $4 $4 $4 

United 

Kingdom $38 $33 $12 $9 $9 $9 

Other 

countries $68 $50 $42 $32 $37 $35 

Total $360 $322 $311 $275 $318 $331 

* 2010 data is for January through September.

Sources: U.S. ITC 2010

The value of imports of Hardwood Veneer and Plywood was equal to nearly 75 percent 

of the value of shipments by domestic manufacturers in 2007 (see Table 5-3 and Table 5-5). The 
Market Profile of the Composite Wood Products Industry 55

value of imports of reconstituted wood products was equal to about 35 percent of the value of 

shipments by domestic manufacturers in 2007 (see Table 5-3 and Table 5-5). The values of 

Hardwood Veneer and Plywood and Reconstituted Wood Product exports were about 17 

percent and 6 percent, respectively, of the value of shipments by domestic manufacturers in 

2007 (see Table 5-3 and Table 5-5). Figure 5-1 presents the trends in the imports for 

consumption of reconstituted wood products and hardwood veneer and plywood over time, by 

top 2009 trading partners.
Market Profile of the Composite Wood Products Industry 56

Figure 5-1: Imports of Panel products for Consumption 2000-2010, by 

Country; does not include imports as part of fabricated goods

Hardwood Veneer and Plywood

$0

$200

$400

$600

$800

$1,000

$1,200

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010*

Year

Imports (millions $)

China

Canada

Indones

Russia

Malaysi

Other co

Reconstituted Wood Products

$0

$500

$1,000

$1,500

$2,000

$2,500

$3,000

$3,500

$4,000

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010*

Year

Imports (millions $)

Canada

China

Chile

German

Spain

Other c

Source: U.S. ITC 2010
Market Profile of the Composite Wood Products Industry 57

5.4 Industry Organization

The following section describes the organization of the Hardwood Veneer and Plywood 

Manufacturing and Reconstituted Wood Products Manufacturing industries. Information is 

presented on:

• The industry structure

• The characteristics of the manufacturing facilities

• The characteristics of the firms that own the manufacturing facilities

In addition, this section provides detailed information about facilities and firms that are 

key inputs to the economic analysis.

5.4.1 U.S. Census Data on Industry Structure

5.4.1.1 Specialization and Market Concentration

To determine the extent to which Census data on the Hardwood Veneer and Plywood 

Manufacturing and Reconstituted Wood Products Manufacturing industries adequately describe 

the manufacturers of composite wood products, industry-wide specialization and coverage 

ratios are examined. Products shipped from one establishment to another within the same 

industry are considered “primary”, while all other products shipped by the establishment are 

considered “secondary”. The primary products specialization ratio is the ratio of total primary 

product shipments to total product shipments (primary and secondary) for all establishments 

classified in the industry. The coverage ratio indicates the extent to which the primary industry 

products are manufactured by establishments classified in that industry. The coverage ratio is 

the ratio of primary products shipped by the establishments classified in the industry to the total 

shipments of these products shipped by all establishments classified in all industries. Table 5-6

provides specialization and coverage ratios for the two potentially affected NAICS industries. 

Table 5-6: Primary Products Specialization and Coverage 

Ratio, by NAICS, 2007

NAICS Description

Primary 

Product 

Specialization 

Ratio (max 

value 100)

Coverage 

Ratio 

(max 

value 

100)

321211

Hardwood 

Veneer and 

Plywood 

Manufacturing

96 99

321219

Reconstituted 

Wood 

Products

99 99

Source: U.S. Census 2009c

As indicated in Table 5-6, both NAICS codes have specialization and coverage ratios 

above 95. Ratios this high imply that most establishments within these NAICS codes are highly 

specialized, and that product shipments tend to originate in establishments within these NAICS 
Market Profile of the Composite Wood Products Industry 58

codes. Therefore, the Census data on these NAICS provide information on the primary 

production of facilities engaged in plywood and wood composite manufacturing.

Table 5-7 presents market concentration ratios and Herfindahl-Hirschman (HH) index 

values for the potentially affected NAICS codes in 2002. M-firm concentration ratios are equal 

to the sum of the market shares for the largest m number of firms in the industry; the higher the 

ratio the more concentrated the industry. HH index values equal to the sum of the squares of 

the market shares for the 50 largest firms in the industry; the higher the HH index, the more 

concentrated the industry. 

Table 5-7: Concentration Ratios by NAICS Code, 2002

Number of 

Companies 

in Industry

Percent of value of industry shipments shipped by the largest (in terms of 

shipment value)

HerfindahlHirschman 

Index for 50 

largest 

companies

4 

Companies

8 

Companies

20 

Companies

50 

Companies

321211 - Hardwood Veneer and Plywood Manufacturing

304 33.1% 44.8% 61.5% 77.4% 468.2

321219 - Reconstituted Wood Product Manufacturing

180 35.2% 50.5% 73.1% 90.6% 497.9

Note: A market is generally considered highly concentrated if the 4-firm concentration ratio is greater than 50 percent. 

The United States Department of Justice use an HH value of 1,000 as a ceiling for market competitiveness; an HH between 1,000 and 1,800 is 

considered to be moderately concentrated; and anything above 1,800 is considered to be highly concentrated (U.S. DOJ 1997).

Source: U.S. Census 2006

Table 5-7 indicates that neither the hardwood veneer and plywood manufacturing 

industry (NAICS 321211) or the reconstituted wood products industry (NAICS 321219) had 4-firm 

ratios above 50 (33.1 and 35.2 respectively) or HH index values over 1000 (468.2 and 497.9 

respectively) and so cannot be considered uncompetitive by these standards (U.S. Census 

Bureau 2006).

5.4.1.2 Vertical and Horizontal Integration

The high specialization and coverage ratios presented in the preceding section indicate 

that the Hardwood Veneer and Plywood Manufacturing and Reconstituted Wood Products 

Manufacturing industries do not have a high degree of vertical integration. Vertical integration 

is when companies maintain operations at multiple levels of the supply chain. For example, a 

company that harvests logs, manufactures veneers, adhesives, hardwood plywood panels, and 

hardwood plywood cabinets would be vertically integrated. A vertically integrated industry 

would tend to have lower specialization and coverage ratios since vertical integration implies 

less specialization in a single product type.

Horizontal integration is when a company expands in the same industry and stage of the 

production line. Thus, a horizontally integrated industry is characterized by fewer firms and less 

competition. The HH index values presented in the preceding section indicate that the 

Hardwood Veneer and Plywood Manufacturing and Reconstituted Wood Product Manufacturing 

industries are not uncompetitive and therefore are not highly horizontally integrated.
Market Profile of the Composite Wood Products Industry 59

5.4.1.3 Production Capacity and Utilization

Capacity utilization rates are the ratio of observed output to maximum potential output. 

Table 5-8 provides capacity utilization rates for the potentially affected NAICS codes, all wood 

products manufacturing (NAICS 321), and all manufacturing industries (NAICS 31-33) between 

2000 and 2009.

Table 5-8: Full Production Capacity Utilization Rates by NAICS Codes, Fourth Quarters, 2000 - 20

NAICS Description 2000 2001 2002 2003 2004 20

3212

Veneer, 

Plywood, and 

Engineered 

Wood Product 

Manufacturing 

75% 66% 66% 76% 78% 80

321 Wood Product 

Manufacturing 69% 66% 67% 70% 73% 70

31-33

All 

Manufacturing 

Industries

71% 64% 63% 64% 70% 71

Note: A capacity utilization rate under 100 indicates that, for a given existing capital stock, a firm or industry has the potential for greater output without in 

Sources: U.S. Census 2002-2010

As indicated in Table 5-8, the 2009 capacity utilization rate for the Veneer, Plywood, and 

Engineered Wood Product Manufacturing industry was 42 percent. The average was 49 percent 

for all wood product manufacturing (NAICS 321) and 64 percent for all manufacturing industries 

(NAICS 31-33). The veneer and plywood manufacturing industry (NAICS 3212) experienced a 

capacity utilization rate decrease of 44 percent between 2000 and 2009. Over the same period, 

the wood product manufacturing industry (NAICS 321) and the manufacturing industry overall 

(NAICS 31-33) saw decreases in capacity utilization rates of 29 percent and 10 percent, 

respectively.

Figure 5-2 presents a graphical representation of production capacity utilization rates 

between 2007 and 2010 for the potentially affected NAICS groups, as well as all wood product 

manufacturing and all manufacturing industries. 
Market Profile of the Composite Wood Products Industry 60

Figure 5-2: Full Production Capacity Utilization Rates, Quarterly, 2007-2010

0

10

20

30

40

50

60

70

80

90

2007

Q1

2007

Q2

2007

Q3

2007

Q4

2008

Q1

2008

Q2

2008

Q3

2008

Q4

2009

Q1

2009

Q2

2009

Q3

2009

Q4

2010

Q1

2010

Q2

Quarter

Capacity Utilization %

Veneer,

plywood, and

engineered

wood product

mfg. 

Wood

Product

Manufacturing

All

manufacturing

Source: U.S. Census 2002-2010

Table 5-9 provides a breakdown of capital expenditures for the potentially affected 

NAICS in 2008. The data are broken down into total capital expenditures for permanent 

additions and major alterations to establishments, as well as new and used machinery and 

equipment for replacement or addition to a plant’s capacity, which is divided into 1) 

automobiles, trucks, etc. for highway use; 2) computer and data processing equipment; and, 3) 

all other machinery and equipment. 

ary of Capital Expenditures (New and Used) (thousands, 2007$)

NAICS 

scription

Buildings and Other 

Structures

Machinery and Equipment

Autos, Trucks, etc. for 

Highway Use

Computer and Data 

Processing Equipment

All Other Machiner 

Equipment

Value Percent Value Percent Value Percent Value

dwood 

eer and 

wood 

nufacturing

$11,549 16.24% $3,913 5.50% $1,935 2.72% $53,703 

onstituted 

od Product 

nufacturing

$22,778 6.95% $6,478 1.98% $6,673 2.03% $292,041 

9c

As indicated in Table 5-9, total capital expenditures in 2008 ranged from about $71

million in the hardwood veneer and plywood manufacturing industry to about $328 million 

dollars in the reconstituted wood products industry. Expenditures for other machinery and 

equipment accounted for the largest proportion of these totals, ranging from 76 percent in the
Market Profile of the Composite Wood Products Industry 61

hardwood veneer and plywood manufacturing industry to 89 percent in the reconstituted wood 

product manufacturing industry (U.S. Census 2002-2010).

Employment

Table 5-10 summarizes the employment statistics for the potentially affected NAICS in 

2007. As indicated in Table 5-10, the potentially affected NAICS groups were composed of 566 

establishments, employed nearly 39 thousand people (or about 69 employees per 

establishment), and had total payroll amounting to approximately 1.5 billion dollars in 2007. 

The hardwood veneer and plywood manufacturing industry had the most establishments (304), 

while the reconstituted wood product manufacturing industry employed the most people 

(20,426) and had the highest payroll (about $891 million) (U.S. Census 2009c). Note that these 

NAICS groups include establishments (such as veneer manufacturers and oriented strandboard 

manufacturers) that do not manufacture hardwood plywood, MDF or particleboard, and that 

would not be defined as panel producers under the proposed TSCA Title VI rule. 

Table 5-10: Summary of Employment Statistics, By NAICS (2007)

NAICS NAICS Description Total 

Establishments

Total 

Employees

Average 

Employees 

Per 

Establishment

Total 

Payroll 

(thousands, 

2008$)

321211

Hardwood Veneer 

and Plywood 

Manufacturing

304 18,501 

60.9 $594,847 

321219

Reconstituted 

Wood Product 

Manufacturing

262 20,426 78 $890,935 

Total 566 38,927 

68.8 $1,485,782 

Note that these NAICS codes include establishments that do not manufacture hardwood plywood, MDF, or particleboard, and that would not be 

defined as panel producers under the proposed TSCA Title VI rule. 

Source: U.S. Census 2009c

5.4.2 U.S. Census Data on Firm Characteristics

Several factors will likely be of importance in determining the distribution of impacts on 

companies generated by the proposed regulation. Size may play a role in a company’s ability to 

absorb an increase in compliance costs. Ownership is a second factor that may play a role. 

Because firms have different legal and financial guidelines based on ownership, their 

approaches to complying with the proposed regulation may vary. Lastly, the overall financial 

condition of the various composite wood industries of concern is assessed, attempting to 

determine the industry’s ability to withstand adverse conditions.

5.4.2.1 Size Distribution

United States Census Bureau

Table 5-11 summarizes establishments in the composite wood product manufacturing 

industries by the number of employees. 
Market Profile of the Composite Wood Products Industry 62

Table 5-11: Number of Establishments by Employee Size Category, 2007

NAICS Description

Establishment Employee Size Category T 

Estab 1 to 19 20 to 99 100+

Value % Value % Value %

321211

Hardwood Veneer 

and Plywood 

Manufacturing 

136 45% 114 38% 54 18%

321219

Reconstituted Wood 

Product 

Manufacturing

79 30% 90 34% 93 35%

Note that these NAICS codes include establishments that do not manufacture hardwood plywood, MDF, or particleboard, and that would not be defined as panel produ 

under the proposed TSCA Title VI rule.

Source: U.S. Census 2009c

5.4.2.2 Ownership for Wood Products Manufacturing Industry

Different forms of firm ownership are associated with different sets of legal and 

financial characteristics that may influence a firm’s regulatory compliance strategy. The legal 

form of ownership impacts the cost of capital, availability of capital, and effective tax rate faced 

by the firm. Debt-equity issues for these firm types will play a role in financing capital-intensive 

controls. Firm ownership is generally one of three types:

• Sole proprietorships (companies with a private single-owner)

• Partnerships (non-corporate firms with more than one owner)

• Corporations (publically or privately owned companies formed through incorporation)

Table 5-12 provides summary information on manufacturers in the wood product 

manufacturing industry, by type of firm ownership. While data aren’t available at the 5- or 6-

digit NAICS code level, the table provides a general sense of the distribution of ownership types, 

assuming that the ownership structure for the two industries profiled is similar to that of the 

overall wood product manufacturing industry.
Market Profile of the Composite Wood Products Industry 63

Table 5-12: Summary Information for Wood Product Manufacturing (NAICS 321) 

by Type of Firm Ownership, 2007

Legal Form of 

Organization Companies All 

Establishments

Number of 

employees

Total Value 

of Shipments 

(thousands, 

2007$)

Corporate Ownership

Subtotal, 

Corporate 10,670 12,574 464,685 $90,998,636

Noncorporate Ownership

Individual 

Proprietorship 2,337 2,343

10,000 -

24,999 Withheld

Partnership 1,809 1,950 43,706 $8,505,000

Other 

noncorporate 

and unknown 1 1 0 - 19 Withheld

Subtotal, 

Noncorporate 4,147 4,294 59,214 $10,713,281

Total 14,817 16,868 523,899 $101,711,917

Sources: U.S. Census 2010i

As indicated in Table 5-12 the majority (around 72 percent) of the companies in the 

wood product manufacturing industry are organized as corporations; the remainder are noncorporate, of which 16 percent are individual proprietorships, 12 percent are partnerships, and 

the remaining companies are classified as “other non-corporate and unknown”.

5.4.3 Industry-Wide Indicators of Financial Condition

The financial condition of an industry’s firms will affect the incidence of cost impacts 

associated with complying with the proposed regulation. While information necessary to 

determine which specific firms might experience adverse impacts is not available, one can 

examine industry-wide indicators of financial condition. 

5.4.3.1 Profitability Ratios

The return on sales ratio, also known as the net profit margin, is an indicator of a firm’s 

ability to withstand adverse conditions such as falling prices, rising costs, and declining sales. It is 

calculated by dividing net operating profit before interest and taxes by annual net sales.

Return on assets is calculated by dividing a firm’s net profit before taxes by its total 

assets. This ratio is a key indicator of both profitability and operating efficiency, as it compares

operating profits to the assets available to earn a return. Companies that use their assets 

efficiently will have a relatively higher return on assets than those firms that do not use their 

assets efficiently.

The return on equity shows the profitability of the company’s operations as a 

percentage of stockholders’ equity, before income taxes, and is calculated by dividing net profit

for the year, before taxes, by stockholders’ equity at the end of the period. 
Market Profile of the Composite Wood Products Industry 64

5.4.3.2 Solvency Ratios

The current ratio is calculated by dividing a firm’s current assets by its current liabilities. 

This is a measure of liquidity that gauges the ability of a company to cover its short-term 

liabilities. The standard guideline for financial health is two (Dun & Bradstreet n.d.). The quick 

ratio is slightly different than the current ratio, because it does not include inventories, 

advances on inventories, marketable securities, or notes receivable. The quick ratio measures 

the protection afforded creditors in cash or near-cash assets. Any time this ratio is one or 

greater, the firm is said to be in a liquid condition (Dun & Bradstreet n.d.). The quick ratio 

shown in Table 5-13 compares total cash, government securities, and other liquid securities to 

total current liabilities.

Table 5-13 shows various measures of the financial condition of the wood products 

industry. 

Table 5-13: Indicators of Financial Condition for the Wood Product 

Industry, Quarterly 2009-2010

2

0

0

9 

Q

1

2

0

0

9 

Q

2

2

0

0

9 

Q

3

2

0

0

9 

Q

4

2

0

1

0 

Q

1

2

0

1

0 

Q

2

Return on 

Sales

-

1

.

7

3

%

2

.

2

1

%

4

.

5

0

%

2

.

0

4

%

2

.

3

3

%

5

.

5

2

%

Return on 

Assets

-

4

.

5

9

%

-

1

.

0

5

%

1

.

0

0

%

-

3

.

7

8

%

-

0

.

2

7

%

2

.

6

7

%

Return on 

Equity

-

1

3

.

1

3

%

-

3

.

2

5

%

2

.

9

2

%

-

1

1

.

5

8

%

-

0

.

8

5

%

8

.

1

4

%

Current 

Ratio

3

.

2

0

3

.

3

0

3

.

3

0

3

.

4

7

3

.

3

9

3

.

2

8

Quick 

Ratio

1

.

6

8

1

.

7

6

1

.

7

6

1

.

8

4

1

.

8

0

1

.

7

0

Sources: U.S. Census 2009a
Market Profile of the Composite Wood Products Industry 65

The data shown in Table 5-13 indicate that, with the exception of the third quarter of 

2009 and the second quarter of 2010, the wood product manufacturing industry has 

experienced negative returns on assets and equity. This is the result of losses of income in the 

three other quarters of 2009 and the first quarter of 2010. These values, ranging from -1.73 to 

5.52 percent for return on sales, -4.59 to 2.67 percent for return on assets, and -13.13 to 2.67

percent for return on equity, demonstrate a struggling industry. The data for the current and 

quick ratios are more promising, with numbers suggesting financial health and liquidity in all 

quarters.
Market Profile of the Composite Wood Products Industry 66

6 Composite Wood Product Fabricators

This section presents information on the value of shipments, international trade, 

industry organization, and market outlook for the manufacturing industries that use composite 

wood products as raw materials. The industry categories defined by NAICS are likely to include 

some manufacturers that are not subject to any requirements under the proposed TSCA Title VI 

rule. 

NAICS codes for the potentially affected manufacturing industries were indentified 

through a review of information reported by the United States Census Bureau. Table 6-1

provides a list of the relevant NAICS codes and their descriptions. As indicated in Table 6-1, the 

fabricators using these wood products include seventeen NAICS codes: 321211/321219 

(decorative and custom panel producers), 321911 (windows and doors), 321918 (other 

millwork), 321991 (mobile homes), 321992 (prefabricated wood building manufacturing), 

321999 (other miscellaneous products), 336213 (motor homes), 336214 (trailers and campers), 

337110 (kitchen cabinetry), 337121 (upholstered household furniture), 337122 (nonupholstered household furniture), 337124 (metal furniture), 337127 (institutional furniture), 

337129 (television, radio, and sewing machine cabinetry), 337211 (wood office furniture), 

337212 (custom architectural woodwork), 337215 (non-wood office furniture), 337215 

(showcases, partitions, shelving, and lockers), and 339950 (signs). These industries comprise the 

manufacturing sectors that use hardwood veneer and plywood and reconstituted wood 

products as raw materials according to U.S. Economic Census data (U.S. Census 2008).

Table 6-1: NAICS Codes and Descriptions

Product Description NAICS

Decorative and custom panel producers 321211 / 

321219

Wood window and door manufacturing 321911

Other millwork including flooring manufacturing 321918

Manufactured home (mobile home) manufacturing 321991

Prefabricated wood building manufacturing 321992

Other miscellaneous wood product manufacturing 321999

Motor home manufacturing 336213

Travel Trailer and Campers manufacturing 336214

Wood kitchen cabinets and countertop manufacturing 337110

Upholstered household furniture manufacturing 337121

Nonupholstered wood household furniture manufacturing 337122

Metal household furniture manufacturing 337124

Institutional furniture manufacturing 337127

Wood television, radio, and sewing machine cabinet manufacturing 337129

Wood office furniture manufacturing 337211

Custom architectural woodwork and millwork manufacturing 337212

Office furniture (non-wood) manufacturing 337214

Showcase, partition, shelving, and locker manufacturing 337215

Sign manufacturing 339950

Section 6.1 presents information on the value of shipments by industry and product 

type. Section 6.2 describes industry production costs. Section 6.3 describes international trade 

by industry and section 6.4 summarizes the industry organization for the composite wood 

product fabricators.
Market Profile of the Composite Wood Products Industry 67

6.1 Value of Shipments

This section presents information on the value of shipments by domestic manufacturers. 

Table 6-2 provides the value of shipments data for each NAICS code. The Wood Kitchen Cabinets 

and Countertops industry has the largest value of shipments, about $18 billion or approximately 

13.4% of the total value of shipments across all related industries. The smallest sector in terms 

of value of shipments is the wood television, radio and sewing machine cabinet manufacturing 

industry, with $460 million in total shipments, or about 0.3% of total value of shipments. The 

average value of shipments for the remaining 15 industries is approximately $8 billion.

Table 6-2: Value of Shipments by Domestic Manufacturers

NAICS Description

NAI

CS

Value of 

Shipments 

(thousands

, 2007$)

Wood Window and Door Manufacturing 321

911

$14,398,17

6 

Other Millwork (including Flooring) 321

918 $7,435,665 

Manufactured Home (Mobile Home) Manufacturing 321

991 $6,052,691 

All Other Miscellaneous Wood Products Manufacturing 321

999 $6,077,231 

Motor Home Manufacturing 336

213 $5,782,329 

Travel Trailer and Camper Manufacturing 336

214

$10,594,61

8 

Wood Kitchen Cabinet and Countertop Manufacturing 337

110

$18,225,26

3 

Upholstered Household Furniture Manufacturing 337

121

$11,060,66

8 

Non-Upholstered Wood Household Furniture Manufacturing 337

122 $8,652,637 

Metal Household Furniture Manufacturing 337

124 $2,275,581 

Institutional Furniture Manufacturing 337

127 $6,467,361 

Wood Television, Radio, and Sewing Machine Cabinet 

Manufacturing

337

129 $234,028 

Wood Office Furniture Manufacturing 337

211 $2,978,968 

Custom Architectural Woodwork and Millwork 337

212 $6,730,164 

Office Furniture (except wood) Manufacturing 337

214 $8,756,670 

Showcase, Partition, Shelving, and Locker Manufacturing 337

215 $8,014,645 

Sign Manufacturing 336

650

$13,021,90

3 

Overall Total Value of Shipments $136,758,5

98

Source: U.S. Census 2009c
Market Profile of the Composite Wood Products Industry 68

6.2 Production Costs

This section discusses the costs of production associated with the manufacture of goods 

using pressed wood products. Data from the 2007 Economic Census are used to estimate an 

average cost-to-shipment ratio for the potentially affected NAICS groups. 

Table 6-3 uses data drawn from the 2007 Economic Census to summarize annual costs 

and shipments by NAICS code in 2007. From these data, it is possible to estimate an industrywide ratio of production costs (an aggregation of the cost of materials, capital expenditures, and 

payroll costs) to the overall value of shipments (VOS), which provides an approximate measure 

of how much cash, at a gross level, the industries are generating to cover all operating expenses, 

use for capital investment, and provide a return to owners.21 A higher ratio of costs to shipments

could indicate a greater vulnerability to regulatory impacts. As indicated in Table 6-3, the cost to 

shipment ratio ranges from 54 to 82 percent for these industries.

 21 While the costs to shipment ratio does indicate the proportion of the revenues received for the goods produced that 

are associated with production expenses (materials, capital expenditures, and payroll), it does not reflect other 

operating expenses such as electrical costs, employment expenses, taxes, interest, or depreciation. Nor does it 

indicate whether the expenses are variable or fixed.
Market Profile of the Composite Wood Products Industry 69

Table 6-3: Summary of Annual Costs and Shipments, 2007 (thousands, 2007$)

NAICSa NAICS Descriptiona Industry 

Shipmentsa

Cost of 

Materialsa

Capital 

Expenditurea Payrollb

Rati 

Cost 

Shipm

321911 Wood Window and Door 

Manufacturing $14,398,176 $7,453,938 $349,492 $2,786,366

321918 Other Millwork 

(including Flooring) $7,435,665 $4,060,826 $161,205 $1,436,648

321991

Manufactured Home 

(Mobile Home) 

Manufacturing

$6,052,691 $3,454,812 $85,855 $1,300,118

321999

Other Miscellaneous 

Wood Product 

Manufacturing

$6,077,231 $2,954,048 $209,812 $1,105,084

336213 Motor Home 

Manufacturing $5,782,329 $3,894,164 $41,371 $725,478

336214 Travel Trailer and 

Camper $10,594,618 $6,716,570 $113,735 $1,824,130

337110

Wood Kitchen Cabinet 

and Countertop 

Manufacturing

$18,225,263 $7,250,204 $424,770 $4,479,039

337121 Upholstered Household 

Furniture Manufacturing $11,060,668 $5,836,840 $107,483 $2,265,630

337122

Non-upholstered Wood 

Household Furniture 

Manufacturing

$8,652,637 $4,397,734 $130,961 $1,769,657

337124 Metal Household 

Furniture Manufacturing $2,275,581 $1,136,757 $20,967 $387,230

337127 Institutional Furniture 

Manufacturing $6,467,361 $2,792,105 $122,831 $1,313,375

337129

Wood Television, Radio, 

and Sewing Machine 

Cabinet Manufacturing

$234,028 $108,969 $7,879 $85,719

337211 Wood Office Furniture 

Manufacturing $2,978,968 $1,215,929 $55,898 $669,959

337212 Custom Architectural 

Woodwork and Millwork $6,730,164 $2,559,114 $162,820 $2,001,015

337214 Office Furniture (except 

Wood) Manufacturing $8,756,670 $3,231,627 $137,939 $1,348,739

337215

Showcase, Partition, 

Shelving, and Locker 

Manufacturing

$8,014,645 $3,980,215 $166,564 $1,606,858

339950 Sign Manufacturing $13,021,903 $5,096,327 $361,034 $3,480,360

Note: Value of shipments data differs between each table for all NAICS codes except 336213 due to delays in census updates. 

Sources: (a) U.S. Census 2009c; (b) U.S. Census 2010j

Table 6-4 through Table 6-20 present the material costs by material type for each of the 

industries. The materials are grouped, and the costs are demonstrated for each subcategory 

along with the individual material and the overall materials total.
Market Profile of the Composite Wood Products Industry 70

Table 6-4: Material Costs by Materials Type for the Wood Window and Door 

Manufacturing Industry (NAICS Code 321911)

Material Type

Materials 

Cost

(thousands, 

2007$)

Percent 

of 

Materials 

Cost

Total logs and bolts $30,975 0.46%

Total rough lumber $376,081 5.57%

Total dressed lumber $244,876 3.63%

Total cut stock $1,041,074 15.42%

 Hardwood plywood $34,687 0.51%

 Softwood plywood $32,015 0.47%

Total plywood $66,702 0.99%

 Hardwood Veneer $91,989 1.36%

 Particleboard (wood) $64,509 0.96%

 Hardboard $130,526 1.93%

 Medium Density Fiberboard (MDF) $60,981 0.90%

Total other wood types $348,005 5.16%

Total miscellaneous $4,642,182 68.77%

Total Material Cost $6,749,895 100%

Sources: U.S. Census 2009d

Table 6-4 displays cost information for the Wood Window and Door industry. 

Miscellaneous parts account for the largest share of the cost, followed by cut stock. Wood 

products are represented in the subcategories: logs and bolts, rough lumber, dressed lumber, 

cut stock, plywood, and other wood types. The sum of these subcategories represents about 31

percent of the total material costs for the industry. Hardwood plywood, particleboard and MDF 

account for 0.51%, 0.96%, and 0.90% of materials costs, respectively, for the entire NAICS code. 

Hardwood veneer (which is not a regulated product but which could be used to manufacture a 

laminated product that may be subject to regulation) represents 1.3% of total materials costs.
Market Profile of the Composite Wood Products Industry 71

Table 6-5: Material Costs by Materials Type for the Other Millwork (including 

Flooring) Industry (NAICS Code 321918)

Material Type

Material 

Cost

(thousands, 

2007$)

Percent 

of 

Materials 

Cost

Total logs and bolts $56,083 1.56%

Total rough lumber $700,136 19.43%

Total dressed lumber $210,849 5.85%

Total cut stock $163,556 4.54%

 Hardwood plywood $63,941 1.77%

 Softwood plywood withheld -

Total plywood $63,941 1.77%

 Hardwood Veneer $86,130 2.39%

 Particleboard (wood) $37,033 1.03%

 Hardboard $38,549 1.07%

 Medium Density Fiberboard (MDF) $158,510 4.40%

Total other wood types $320,222 8.89%

Total miscellaneous $2,064,133 57.29%

Total Withheld $24,087 0.67%

Total Material Cost $3,603,007 100%

Sources: U.S. Census 2009d

Table 6-5 displays the material costs for the Other Millwork (including Flooring) industry. 

The miscellaneous group represents the largest material cost for the industry because it 

encompasses all non-wood materials. For this industry, the non-wood materials cost over $2 

billion, or about 57 percent of the total material costs. The wood materials are comprised of: 

logs and bolts, rough lumber, dressed lumber, cut stock, plywood, and other wood types. These 

subcategories sum to a material cost of about $1.5 billion, or about 42 percent of the total 

material costs for the industry. Hardwood plywood, particleboard and MDF account for 1.77%, 

1.03%, and 4.40% of materials costs, respectively, for the entire NAICS code. Hardwood veneer 

(which is not a regulated product but which could be used to manufacture a laminated product 

that may be subject to regulation) represents 2.39% of total materials costs.
Market Profile of the Composite Wood Products Industry 72

Table 6-6: Material Costs by Materials Type for the Manufactured Home 

(Mobile Home) Manufacturing Industry (NAICS Code 321991)

Material Type

Material 

Cost

(thousands, 

2007$)

Percent 

of 

Materials 

Cost

Total metal parts (including vinyl siding) $407,952 12.16%

 Plywood $99,462 2.96%

 Particleboard (wood) $26,899 0.80%

 Oriented strandboard (OSB) and waferboard $60,064 1.79%

 Gypsum building board: 5/16 inches thick $59,527 1.77%

 Gypsum building board: greater than 5/16 inches thick $42,689 1.27%

 Lumber, dressed $435,945 12.99%

 Wood millwork, including molding, doors and windows $54,489 1.62%

 Kitchen cabinets, wood $71,509 2.13%

Total Wood parts $850,584 25.35%

Total Household Items $146,121 4.35%

Total miscellaneous $1,950,594 58.14%

Total Material Cost $3,355,251 100%

Sources: U.S. Census 2009d

Table 6-6 shows the material cost distribution for the Mobile Home industry

Miscellaneous parts account for the largest share of material costs. Wood parts for the mobile 

home industry cost $851 million, or 25 percent of all material costs.

Table 6-7: Material Costs by Materials Type for All Other Miscellaneous Wood 

Product Manufacturing Industry (NAICS Code 321999)

Material Type

Material 

Cost

(thousands, 

2007$)

Percent 

Materials 

Cost

Total logs and bolts $293,578 11.54%

Total rough lumber $608,172 23.91%

Total dressed lumber $140,435 5.52%

 Hardwood plywood $72,630 2.85%

 Softwood plywood $21,144 0.83%

Total plywood $93,774 3.69%

 Hardwood cut stock and dimension, excluding furniture 

frames $37,716 1.48%

 Chips, Slabs, Edgings, Shavings, Sawdust and Other Wood 

Waste $100,783 $2,544,107 

 Reconstituted Wood Products (particleboard, hardboard, etc) $30,703 1.21%

Total other wood types $169,202 6.65%

Total miscellaneous $1,238,946 48.70%

Total Material Cost $2,544,107 100%

Sources: U.S. Census 2009d

Table 6-7 describes the Miscellaneous Wood Product Manufacturing industry. The 

products produced by this industry are displayed in Table 6-1. The material cost for the industry 

lies primary in wood products, at about 51 percent of all material costs. 
Market Profile of the Composite Wood Products Industry 73

Table 6-8: Material Costs by Materials Type for the Motor Home Manufacturing 

Industry (NAICS Code 336213)

Material Type

Materials 

Cost

(thousands, 

2007$)

Percent 

of 

Materials 

Cost

Total metal parts $329,278 8.87%

 Plywood, lumber (dressed), and millwork wood $143,254 3.86%

Total wood parts $143,254 3.86%

Total miscellaneous $3,241,318 87.28%

Total Material Cost $3,713,850 100%

Sources: U.S. Census 2009d

Table 6-8 discusses the Motor Home manufacturing industry. Wood parts comprise the 

smallest subcategories for this industry, at just 4 percent of all material costs. The wood parts 

are made up of plywood, dressed lumber, and millwork wood. These materials cost $143,254.

Table 6-9: Material Costs by Materials Type for the Travel Trailer and Camper 

Manufacturing Industry (NAICS Code 336214)

Material Type

Materials 

Cost

(thousands, 

2007$)

Percent 

of 

Materials

Cost

Total metal parts $1,700,116 26.66%

 Plywood, lumber (dressed), and millwork wood $255,055 4.00%

Total wood parts $255,055 4.00%

Total miscellaneous $4,421,614 69.34%

Total Material Cost $6,376,785 100%

Sources: U.S. Census 2009d

Table 6-9 breaks down the Travel Trailer and Camper manufacturing industry by 

material cost. Wood parts comprise only 4 percent of the overall material costs for this industry. 

The cost of the parts is $255,055. 
Market Profile of the Composite Wood Products Industry 74

Table 6-10: Material Costs by Materials Type for the Wood Kitchen Cabinet 

and Countertop Manufacturing Industry (NAICS Code 337110)

Material Type

Material 

Cost

(thousands, 

2007$)

Percent 

of 

Materials 

Cost

 Hardwood plywood $492,995 7.55%

 Hardwood veneer $95,058 1.46%

Total hardwood plywood and veneer $588,053 9.01%

 Particleboard (wood) $791,312 12.12%

 Medium density fiberboard (MDF) $117,262 1.80%

 Hardboard $75,654 1.16%

Total reconstituted wood products $984,228 15.07%

Total other wood products $1,560,275 23.90%

Total miscellaneous $3,396,481 52.02%

Total Material Cost $6,529,037 100%

Sources: U.S. Census 2009d

Table 6-10 shows the material cost distribution of the Wood Kitchen Cabinet and 

Countertop manufacturing industry. Hardwood plywood and veneer materials for the industry 

cost just under $600 million (9%) and reconstituted wood products cost nearly $1 billion 

(15.1%). The remaining wood products consist of lumber, cut stock, and furniture frames. These 

materials sum to $1.6 billion or 24 percent of total material cost.

Table 6-11: Material Costs by Materials Type for Upholstered Household 

Furniture Manufacturing Industry (NAICS Code 337121)

Material Type

Material 

Cost

(thousands, 

2007$)

Percent 

Materials 

Cost

Total lumber $86,550 1.74%

 Plywood, hardwood and softwood $141,589 2.84%

 Hardwood veneer $11,737 0.24%

Total plywood and veneer $153,326 3.08%

 Particleboard (wood) $5,889 0.12%

 Medium density fiberboard (MDF) $6,377 0.13%

 Hardboard $17,492 0.35%

Total reconstituted wood products $29,758 0.60%

Total other wood products $757,264 15.20%

Total fabrics and fillers $2,287,221 45.91%

Total plastics parts $37,868 0.76%

Total metal parts $167,312 3.36%

Total miscellaneous $1,449,581 29.09%

Total Withheld $13,524 0.27%

Total Material Cost $4,982,404 100%

Sources: U.S. Census 2009d

Table 6-11 presents the material costs for the Upholstered Household Furniture 

manufacturing industry. Plywood and veneer make up 3.1% of total cost, while reconstituted 

wood products make up less than one percent. 
Market Profile of the Composite Wood Products Industry 75

Table 6-12: Material Costs by Materials Type for Non-upholstered Wood 

Household Furniture Manufacturing Industry (NAICS Code 337122)

Material Type

Material 

Cost

(thousands, 

2007$)

Percent 

Materials 

Cost

Total lumber $406,066 14.72%

 Plywood, hardwood and softwood $104,337 3.78%

 Hardwood veneer $69,525 2.52%

Total plywood and veneer $173,862 6.30%

 Particleboard (wood) $186,818 6.77%

 Medium density fiberboard (MDF) $146,405 5.31%

 Hardboard $30,305 1.10%

Total reconstituted wood products $363,528 13.18%

Total other wood products $246,895 8.95%

Total fabrics and fillers $192,822 6.99%

Total plastics parts $46,441 1.68%

Total metal parts $36,765 1.33%

Total miscellaneous $1,286,543 46.63%

Total Withheld $5,968 0.22%

Total Material Cost $2,758,890 100%

Sources: U.S. Census 2009d

Table 6-12 presents production costs for the Non-upholstered Wood Household 

Furniture manufacturing industry. Plywood and veneer account for 6 percent of material costs, 

or $173,862. Reconstituted wood products make up 13 percent, or $363,528 of costs. 

Table 6-13: Material Costs by Materials Type for Metal Household Furniture 

Manufacturing Industry (NAICS Code 337124)

Material Type

Material 

Cost

(thousands, 

2007$)

Percent 

Materials 

Cost

Total lumber $5,091 0.52%

 Plywood, hardwood and softwood $2,512 0.26%

Total plywood and veneer $2,512 0.26%

 Particleboard (wood) $1,909 0.20%

 Medium density fiberboard (MDF) withheld -

Total reconstituted wood products $1,909 0.20%

Total other wood products $7,127 0.73%

Total fabrics and fillers $98,450 10.12%

Total plastics parts $12,520 1.29%

Total metal parts $593,385 60.98%

Total miscellaneous $222,644 22.88%

Total Withheld $29,472 3.03%

Total Material Cost $973,110 100%

Sources: U.S. Census 2009d
Market Profile of the Composite Wood Products Industry 76

Table 6-13 presents material costs for Metal Household Furniture. Plywood/veneer and 

reconstituted wood products comprise 0.3 percent and 0.2 percent of the total materials costs, 

respectively. 

Table 6-14: Material Costs by Materials Type for Institutional Furniture 

Manufacturing Industry (NAICS Code 337127)

Material Type

Material 

Cost

(thousands, 

2007$)

Percent 

Materials 

Cost

Total lumber $75,225 3.30%

 Plywood, hardwood and softwood $52,040 2.28%

 Hardwood veneer $24,948 1.10%

Total plywood and veneer $76,988 3.38%

 Particleboard (wood) $48,999 2.15%

 Medium density fiberboard (MDF) $10,351 0.45%

 Hardboard $5,206 0.23%

Total reconstituted wood products $64,556 2.83%

Total other wood products $80,481 3.53%

Total fabrics and fillers $113,363 4.98%

Total plastics parts $218,033 9.57%

Total metal parts $445,576 19.56%

Total miscellaneous $1,203,364 52.84%

Total Material Cost $2,277,586 100%

Sources: U.S. Census 2009d

Institutional furniture, as shown in Table 6-14, has material costs of $2,277,586, 3.4

percent of this is plywood and veneer and 2.8 percent is reconstituted wood products. 

Table 6-15: Material Costs by Materials Type for Wood Television, Radio, 

and Sewing Machine Cabinet Manufacturing Industry (NAICS Code 

337129)

Material Type

Material 

Cost

(thousands, 

2007$)

Percent 

Materials 

Cost

Total lumber $2,685 3.29%

 Plywood, hardwood and softwood $2,000 2.45%

 Hardwood veneer $1,262 1.55%

Total plywood and veneer $3,262 4.00%

 Particleboard (wood) $8,036 9.85%

 Medium density fiberboard (MDF) $12,411 15.21%

 Hardboard $3,822 4.68%

Total reconstituted wood products $24,269 29.74%

Total other wood products $13,696 16.78%

Total fabrics and fillers $132 0.16%

Total plastics parts $2,067 2.53%

Total miscellaneous $35,410 43.40%

Total Withheld $208 0.25%

Total Material Cost $81,597 100%

Sources: U.S. Census 2009d
Market Profile of the Composite Wood Products Industry 77

Table 6-15 shows that plywood and veneer comprise 4 percent of the Wood Television, 

Radio, and Sewing Machine Cabinet manufacturing industry material cost. About 30 percent of 

the material cost comes from reconstituted wood products. The total material costs for this 

industry is just over $81 million.

Table 6-16: Material Costs by Materials Type for Wood Office Furniture 

Manufacturing Industry (NAICS Code 337211)

Material Type

Material 

Cost

(thousands, 

2007$)

Percent 

Materials 

Cost

Total lumber $37,529 3.37%

 Plywood, hardwood and softwood $87,345 7.84%

 Hardwood veneer $37,840 3.40%

Total plywood and veneer $125,185 11.23%

 Particleboard (wood) $34,451 3.09%

 Medium density fiberboard (MDF) $18,931 1.70%

 Hardboard $6,089 0.55%

Total reconstituted wood products $59,471 5.34%

Total other wood products $150,282 13.48%

Total fabrics and fillers $104,804 9.40%

Total plastics parts $58,902 5.28%

Total metal parts $45,682 4.10%

Total miscellaneous $532,692 47.79%

Total Material Cost $1,114,547 100%

Sources: U.S. Census 2009d

Miscellaneous products are the greatest material cost for the Wood Office Furniture 

industry, as shown in Table 6-16. However, plywood and veneer comprise 11 percent of the over 

$1 billion dollars of material cost. Reconstituted wood products account for about 5 percent of 

the material costs. 
Market Profile of the Composite Wood Products Industry 78

Table 6-17: Material Costs by Materials Type for the Custom Architectural 

Woodwork and Millwork Industry (NAICS Code 337212)

Material Type

Material 

Cost

(thousands, 

2007$)

Percent 

Materials 

Cost

Total lumber $167,507 8.86%

 Plywood, hardwood and softwood $144,303 7.63%

 Hardwood veneer $53,149 2.81%

Total plywood and veneer $197,452 10.45%

 Particleboard (wood) $125,121 6.62%

 Medium density fiberboard (MDF) $91,613 4.85%

 Hardboard $12,722 0.67%

Total reconstituted wood products $229,456 12.14%

Total other wood products $28,452 1.51%

Total fabrics and fillers $4,247 0.22%

Total plastics parts $135,655 7.18%

Total metal parts $86,554 4.58%

Total miscellaneous $1,035,326 54.78%

Total Withheld $5,442 0.29%

Total Material Cost $1,890,091 100%

Sources: U.S. Census 2009d

Miscellaneous parts form the greatest share of the material cost for the Custom 

Architecture Woodwork and Millwork industry. As Table 6-17 shows, plywood and veneer and 

reconstituted wood products comprise 11 percent and 12 percent of the total material costs, 

respectively. 

Table 6-18: Material Costs by Materials Type for Office Furniture (except Wood) 

Manufacturing Industry (NAICS Code 337214)

Material Type

Material 

Cost

(thousands, 

2007$)

Percent 

Materials 

Cost

Total lumber withheld -

 Plywood, hardwood and softwood $38,305 1.40%

 Hardwood veneer withheld -

Total plywood and veneer $38,305 1.40%

 Particleboard (wood) $92,248 3.38%

 Medium density fiberboard (MDF) $8,965 0.33%

 Hardboard $1,963 0.07%

Total reconstituted wood products $103,176 3.78%

Total other wood products $27,547 1.01%

Total fabrics and fillers $287,343 10.53%

Total plastics parts $520,526 19.08%

Total metal parts $764,306 28.01%

Total miscellaneous $713,685 26.16%

Total Withheld $273,753 10.03%

Total Material Cost $2,728,641 100%

Sources: U.S. Census 2009d
Market Profile of the Composite Wood Products Industry 79

The Non-Wood Office Furniture industry naturally has lower material costs for wood 

products, as shown in Table 6-18. Plywood and veneer are 1.4 percent of the total material cost, 

while reconstituted wood products are 3.8 percent. 

Table 6-19: Material Costs by Materials Type for the Showcase, Partition, 

Shelving, and Locker Manufacturing Industry (NAICS Code 337215)

Material Type

Material 

Cost

(thousands, 

2007$)

Percent 

Materials 

Cost

Total lumber $92,665 2.78%

 Plywood, hardwood and softwood $49,262 1.48%

 Hardwood veneer $10,626 0.32%

Total plywood and veneer $59,888 1.79%

 Particleboard (wood) $49,381 1.48%

 Medium density fiberboard (MDF) $74,087 2.22%

 Hardboard $37,989 1.14%

Total reconstituted wood products $161,457 4.84%

Total other wood products $21,749 0.65%

Total fabrics and fillers $9,537 0.29%

Total plastics parts $126,138 3.78%

Total metal parts $1,300,698 38.96%

Total miscellaneous $1,525,930 45.70%

Total Withheld $40,595 1.22%

Total Material Cost $3,338,657 100%

Sources: U.S. Census 2009d

Showcase, Partition, Shelving, and Locker manufacturing rely very little on wood 

products as well, with total wood products equaling just over 10 percent of total material costs. 

Wood costs are broken down to 1.8 percent for plywood and veneer, and 4.8 percent for 

reconstituted wood products. 

Table 6-20: Material Costs by Materials Type for the Sign Manufacturing 

Industry (NAICS Code 339950)

Material Type

Materials 

Cost

(thousands, 

2007$)

Percent 

of 

Materials 

Cost

 Veneer and plywood $57,055 1.50%

 Wood other than veneer and plywood $36,759 0.97%

Total wood products $93,814 2.47%

Total plastics products $356,010 9.36%

Total metal products $614,953 16.17%

Total miscellaneous $2,737,529 72.00%

Total Material Cost $3,802,306 100%

Sources: U.S. Census 2009d

As shown in Table 6-20, all wood materials comprise 2.5 percent of the total $3.8 billion 

in total material costs for the sign manufacturing industry.
Market Profile of the Composite Wood Products Industry 80

Figure 6-1: Reconstituted Veneer, Hardwood Veneer and Plywood, and Wood Products as 

a Percent of Total Material Costs by Industry

0%

10%

20%

30%

40%

50%

60%

Wood TV, Radio, &

Sewing Machine CabinetWood Kitchen Cabinet &

Counter Tops

Custom Architectural

Woodwork & Millwork

Non-upholstered

Furniture

Wood Office Furniture

Other Millwork &

Flooring

Mobile Homes

Showcase, Partition,

Shelving & Locker

Institutional Furniture

Wood Window & Door

Office Furniture

All Other Miscellaneous

Wood Product

Upholstered Household

Furniture

Sign

Metal Household

Furniture

Motor Homes

Travel Trailer & Camper

337129337110337212337122337211321918321991337215337127321911337214321999337121339950337124336213336214

NAICS Codes and Descriptions

Percentage

Other Wood

Products

Reconstitute

d Wood

Products &

Hardwood

Plywood and

Veneer

As shown in Figure 6-1, reconstituted wood products play a much larger role in 

industries such as wood kitchen cabinet and counter tops manufacturing, non-upholstered 

furniture manufacturing, wood TV, radio and sewing machine cabinet manufacturing, wood 

office furniture manufacturing, and custom architectural woodwork. Reconstituted wood 

products represent a minor cost for industries such as metal household furniture manufacturing 

and sign manufacturing. There is no reconstituted wood product cost displayed for motor home 

and travel trailer and camper manufacturing because the material cost data grouped all wood 

products into one category rather than distinguishing which products were reconstituted wood 

products or hardwood veneer or plywood.

Figure 6-2 shows how industries compare to one another in their use of plywood, 

veneer, and reconstituted wood products. Industries with a larger fraction of the graph use a 

higher total dollar value of these products in their production process. 
Market Profile of the Composite Wood Products Industry 81

Figure 6-2: Percent of all Reconstituted Veneer and Hardwood Veneer and Plywood 

Material Costs Consumed, by NAICS

2%

11%

32%

9%

9%

8%

7%

5%

4%

4%

3%

3% 3%

337110 Wood Kitchen Cabinet and Counter Tops

337122 Non-upholstered Household Furniture

337212 Custom Architectural Woodwork and Millwork

321911 Wood Window and Door Manufacturing

321918 Other Millwork (incl. flooring)

321991 Manufactured (mobile) Homes

337215 Showcase, Partition, Shelving & Locker

337211 Wood Office Furniture

337121 Upholstered Household Furniture

337127 Institutional Furniture

337214 Office Furniture

321999 All Other Miscellaneous Wood Product Manufacturing

337124, 337129, 339950 <2% Combined

As shown in Figure 6-2, the wood kitchen cabinet and counter top manufacturing 

industry consumes the greatest amount of composite wood products, 32 percent of the 

composite wood products consumed across all industries. Non-upholstered household furniture 

consumes about 11 percent of the composite wood products. As shown in Figure 6-1, composite

wood products represent a significant amount of the total material cost in many of these 

industries. Though reconstituted wood products are a large percentage (34%) of the material 

costs within the wood television, radio, and sewing machine cabinet manufacturing industry, 

because it is a small industry it accounts for a very small percentage of the total composite 

wood products consumed by composite wood product fabricators.

6.3 International Trade

In recent years, the U.S. has been involved in a significant amount of international trade 

of products manufactured using composite wood products, with variation among the level of 

trade activity for different fabricator industries. Table 6-21 summarizes domestic production, 

domestic consumption, and imports and exports for all NAICS industries considered to be 

fabricators of composite wood products.
Market Profile of the Composite Wood Products Industry 82

Table 6-21: Summary of Domestic Consumption and International Trade for all 

Fabricator Industries (2007$)

NAICS

Dom

estic 

Prod

uctio

n

E

x

p

o

rt

s

Domestic Consumption Percen

t of 

Consu

mption 

from 

Import

s

Im

por

ted

D

o

m

es

tic

T

ot

al

Wood 

Windows and 

Doors 

(321911),

$14,

398 

$

2

2

2 

$91

4 

$1

4,

17

6 

$

1

5,

0

9

0 

6.06%

Other 

Millwork 

including 

Flooring 

(321918)

$7,4

36 

$

2

6

6 

$1,

121 

$7

,1

70 

$

8,

2

9

1 

13.52%

Manufactured 

Homes 

(Mobile 

Homes) 

(321991)

$6,0

53 

$

3

3 

$20 

$6

,0

20 

$

6,

0

4

0 

0.33%

Motor Homes 

(336213)

$5,7

82 

$

5

2

5 

$19

3 

$5

,2

57 

$

5,

4

5

0 

3.54%

Travel Trailers 

and Campers 

(336214)

$10,

595 

$

2

,

1

0

4 

$55

5

$8

,4

91 

$

9,

0

4

6 

6.14%

Wood Kitchen 

Cabinets and 

Countertops 

(337110)

$18,

225 

$

1

1

2 

$82

7 

$1

8,

11

3 

$

1

8,

9

4

0 

4.37%

Upholstered 

Household 

Furniture 

(337121)

$11,

061 

$

4

1

4 

$2,

842 

$1

0,

64

7 

$

1

3,

4

8

9 

21.07%

Metal 

Household 

Furniture 

(337124)

$2,2

76 

$

7

6 

$2,

623 

$2

,2

00 

$

4,

8

2

3 

54.39%

Institutional 

Furniture 

(337127)

$6,4

67 

$

1

,

3

$14

,13

5 

$5

,1

00 

$

1

9,

2

73.48%
Market Profile of the Composite Wood Products Industry 83

6

7 

3

5 

Wood 

Television, 

Radio, and 

Sewing 

Machine 

Cabinets 

(321911)

$14,

398 

$

2

2

2 

$91

4 

$1

4,

17

6 

$

1

5,

0

9

0 

6.06%

Wood Office 

Furniture 

(337211)

$2,9

79 

$

1

0

7 

$96

7 

$2

,8

72 

$

3,

8

3

9 

25.19%

Office 

Furniture 

(except 

Wood) 

(337214)

$8,7

57 

$

2

2

6 

$46

3 

$8

,5

31 

$

8,

9

9

4 

5.15%

Showcases, 

Partitions, 

Shelving, and 

Lockers 

(337215)

$8,0

15 

$

1

,

0

3

2 

$4,

603 

$6

,9

83 

$

1

1,

5

8

6 

39.73%

Signs (339950) $13,

022 

$

9

6 

$20

9 

$1

2,

92

6 

$

1

3,

1

3

5 

1.59%

Sources: U.S. Census 2009c; U.S. ITC 2010

The products of some industries, such as Manufactured Homes (321991), Motor Homes 

(336213), and Wood Kitchen Cabinets and Countertops, are produced almost entirely 

domestically, as can be seen from the percent of consumption from imports in Table 6-21. 

Domestic consumption within other industries such as Institutional Furniture (337127) and 

Metal Household Furniture (337124) relies very heavily on imports from other countries. In 

Figure 6-3 below, percent of consumption from imports is shown by NAICS industry. 
Market Profile of the Composite Wood Products Industry 84

Figure 6-3: Percent of Consumption from Imports, by Industry

0%

10%

20%

30%

40%

50%

60%

70%

80%

321911321918321991336213336214337110337121337124337127321911337211337214337215339950

NAICS Code

Sources: CPA 2006a,U.S. ITC 2010

There have been notable shifts in the trade balance for fabricator industries in the past 

decade, as well as shifts in the U.S.’s significant trade players. Table 6-22 through Table 6-36

present data on the U.S. imports and exports of products manufactured using composite wood 

products for the 2009 top five trading partners in each category. 

Table 6-22: International Trade Wood Windows and Doors (321911), by top 2009 trading partners 

Country 2000 2001 2002 2003 2004 2005 2006

Millwork (including Flooring) Imports

Canada $295 $321 $342 $361 $429 $478 $493

China $2 $3 $8 $14 $33 $59 $101

Brazil $34 $48 $55 $48 $64 $85 $90

Chile $21 $32 $39 $38 $50 $44 $51

Mexico $47 $43 $41 $41 $44 $41 $43

Other 

countries $118 $125 $141 $152 $171 $190 $184

Total $517 $571 $626 $653 $790 $898 $963

Note: Number may not add due to rounding, 2010 is for January through August

Sources: U.S. ITC 2010
Market Profile of the Composite Wood Products Industry 85

Figure 6-4: Imports for Consumption in Wood Windows and Doors (321911), by top 2009 trading 

partners (millions, current$)

$0

$100

$200

$300

$400

$500

$600

2000200120022003200420052006200720082009

2010*

Year

Imports (millions $)

Canada

China

Brazil

Chile

Mexico

Other countries

Source: U.S. ITC 2010

As shown in Table 6-22, Wood Windows and Doors are traded with Canada in the 

highest volume. Imports experienced a great deal of fluctuation over the period, rising to $963 

million in value in 2006 and then dropping again to $484 million in 2008 (See Table 6-22).

Table 6-23: International Trade in Other Millwork including Flooring (321918), by top 2009 trading 

Country 2000 2001 2002 2003 2004 2005 2006

Millwork (including Flooring) Imports

China $44 $53 $74 $117 $222 $309 $30

Brazil $107 $130 $171 $184 $361 $344 $40

Chile $140 $176 $193 $177 $302 $270 $33

Canada $139 $119 $122 $133 $131 $126 $12

Mexico $90 $68 $62 $55 $90 $78 $8

Other 

countries

$289 $227 $256 $266 $317 $353 $33

Total $810 $773 $879 $931 $1,423 $1,479 $1,58

Note: Number may not add due to rounding, 2010 data is for January through August

Sources: U.S. ITC 2010
Market Profile of the Composite Wood Products Industry 86

Figure 6-5: Imports for Consumption in Other Millwork including Flooring (321918), by top 2009 

trading partners (millions, current$)

$0

$50

$100

$150

$200

$250

$300

$350

$400

$450

2000200120022003200420052006200720082009

2010*

Year

Imports (millions $)

China

Brazil

Chile

Canada

Mexico

Other countries

Source: U.S. ITC 2010

For Other Millwork (including Flooring), Brazil, Chile, and China were the greatest source 

of imports, as displayed in Table 6-23. From 2000 through 2006 total trade volume grew 

regularly; in 2007 through the present, imports of these products experienced a substantial 

decline (see Table 6-23).

Table 6-24: International Trade in Manufactured Homes (Mobile Homes) (321991), by top 2009 trad 

Country 2000 2001 2002 2003 2004 2005 2006

Mobile Home Imports

Canada $5 $9 $18 $14 $12 $18 $14

China $0 $0 $0 $0 $0 $0 $0

United 

Kingdom $0 $0 $0 $0 $0 $0 $0

Germany $0 $0 $0 $0 $0 $0 $0

Italy $0 $0 $0 $0 $0 $0 $0

Other 

countries $0 $0 $0 $0 $0 $0 $1

Total $5 $9 $18 $14 $12 $19 $15

Note: Numbers may not add due to rounding, 2010 data is for January through August

Sources: U.S. ITC 2010
Market Profile of the Composite Wood Products Industry 87

Figure 6-6: Imports for Consumption in Manufactured Homes (Mobile Homes) (321991), by top 2009 

trading partners (millions, current$)

$0

$2

$4

$6

$8

$10

$12

$14

$16

$18

$20

2000200120022003200420052006200720082009

2010*

Year

Imports (millions $)

Canada

China

United Kingdom

Germany

Italy

Other countries

Source: U.S. ITC 2010

Table 6-24 shows that Canada is the greatest trading partner for the Mobile Home 

manufacturing industry; the next four largest sources of mobile home imports have import 

values below 1 million dollars (see Table 6-24). Imports and exports overall represent a small 

portion of the manufactured homes industry.
Market Profile of the Composite Wood Products Industry 88

Table 6-25: International Trade in Miscellaneous Wood Products (321999), by top 2009 trading pa 

Country 2000 2001 2002 2003 2004 2005

Miscellaneous Wood Products Imports

China $634 $655 $757 $797 $846 $909

Canada $417 $401 $435 $513 $570 $613

Portugal $136 $148 $152 $159 $166 $169

Indonesia $80 $81 $81 $69 $72 $74

Mexico $27 $21 $27 $37 $41 $59

Other 

countries $472 $431 $442 $454 $457 $448

Total $1,765 $1,737 $1,895 $2,030 $2,151 $2,272

Note: Numbers may not add due to rounding, 2010 data is for January through August

Sources: U.S. ITC 2010

Figure 6-7: Imports for Consumption in Miscellaneous Wood Products (321999), by top 2009 trading 

partners (millions, current$)

$0

$200

$400

$600

$800

$1,000

$1,200

2000200120022003200420052006200720082009

2010*

Year

Imports (millions $)

China

Canada

Portugal

Indonesia

Mexico

Other countries

Source: U.S. ITC 2010
Market Profile of the Composite Wood Products Industry 89

As shown in Table 6-25,China and Canada are major sources of imports to the United 

States, making up over half of total imports to the U.S. There was steady growth of trade 

activity until the 2008 recession (see Table 6-25).

Table 6-26: International Trade in Motor Homes (336213) by top 2009 trading partners 

(millions, current$)

Country 2000 2001 2002 2003 2004 2005 2006

Motor Home Imports

Canada $90 $74 $97 $104 $105 $104 $118

Germany $27 $36 $39 $18 $17 $41 $60

Japan $0 $0 $0 $0 $0 $0 $0

Korea $0 $0 $0 $0 $0 $0 $0

China $0 $0 $0 $0 $0 $0 $0

Other 

countries

$1 $1 $0 $0 $0 $0 $0

Total $118 $111 $137 $123 $122 $146 $178

Note: Numbers may not add due to rounding, 2010 data is for January through August

Sources: U.S. ITC 2010

Figure 6-8: Imports for Consumption in Motor Homes (336213), by top 2009 trading partners 

(millions, current$)

$0

$20

$40

$60

$80

$100

$120

$140

$160

2000200120022003200420052006

2007

20082009

2010*

Year

Imports (millions $)

Canada

Germany

Japan

Korea

China

Other countries

Source: U.S. ITC 2010

Table 6-26 shows that Canada is the largest trading partner of sales in Motor Homes.

Canada and Germany are the only two countries supplying motor home imports with a value 

equal to or exceeding $1 million. 
Market Profile of the Composite Wood Products Industry 90

Table 6-27: International Trade in Travel Trailers and Campers (336214), by top 2009 trading partn 

Country 2000 2001 2002 2003 2004 2005 2006

Travel Trailer and Camper Imports

China $548 $77 $79 $105 $134 $185 $192

Canada $195 $234 $220 $230 $274 $247 $236

Japan $67 $73 $68 $33 $60 $80 $85

Mexico $3 $2 $3 $3 $8 $11 $14

Taiwan $146 $25 $15 $17 $12 $10 $9

Other 

countries $33 $24 $23 $25 $27 $25 $31

Total $991 $435 $408 $412 $516 $558 $568

Note: Numbers may not add due to rounding, 2010 data is for January through August

Sources: U.S. ITC 2010

Figure 6-9: Imports for Consumption in Travel Trailers and Campers (336214), by top 2009 trading 

partners (millions, current$)

$0

$100

$200

$300

$400

$500

$600

2000200120022003200420052006200720082009

2010*

Year

Imports (millions $)

China

Canada

Japan

Mexico

Taiwan

Other countries

Source: U.S. ITC 2010

For Travel Trailers and Campers, China has been the greatest source of imports, 

followed Canada (see Table 6-27).
Market Profile of the Composite Wood Products Industry 91

Table 6-28: International Trade in Wood Kitchen Cabinets and Countertops (337110), by top 2009 

Country 2000 2001 2002 2003 2004 2005 2006

Wood Kitchen Cabinet and Countertop Imports

China $11 $16 $38 $56 $89 $145 $195

Canada $422 $459 $494 $531 $584 $543 $538

Italy $5 $8 $15 $20 $30 $38 $43

Germany $14 $18 $12 $11 $13 $17 $18

Mexico $10 $13 $9 $9 $13 $13 $19

Other 

countries $12 $11 $11 $18 $25 $40 $38

Total $474 $526 $579 $644 $754 $796 $850

Note: Numbers may not add due to rounding, 2010 data is for January through August

Sources: U.S. ITC 2010

Figure 6-10: Imports for Consumption in Wood Kitchen Cabinets and Countertops (337110), by top 

2009 trading partners (millions, current$)

$0

$100

$200

$300

$400

$500

$600

$700

2000

2001

20022003

200420052006

2007

2008

2009

2010*

Year

Imports (millions $)

China

Canada

Italy

Germany

Mexico

Other countries

Source: U.S. ITC 2010

In recent years, as shown by Table 6-28, China has been the largest source of Wood 

Kitchen Cabinets and Countertops, although prior to 2008 Canada had been the largest supplier. 

Imports rose between 2000 and 2006 and then fell between 2007 and 2009.
Market Profile of the Composite Wood Products Industry 92

Table 6-29: International Trade in Upholstered Household Furniture (337121), by top 2009 trading 

Country 2000 2001 2002 2003 2004 2005

Upholstered Household Furniture Imports

China $141 $201 $378 $573 $850 $1,225

Mexico $182 $182 $218 $253 $332 $338

Italy $563 $533 $536 $565 $472 $335

Vietnam $1 $1 $7 $13 $20 $31

Malaysia $28 $20 $29 $37 $52 $60

Other 

countries $337 $332 $371 $436 $461 $460

Total $1,251 $1,269 $1,539 $1,878 $2,187 $2,449

Note: Numbers may not add due to rounding, 2010 data is for January through August

Sources: U.S. ITC 2010

Figure 6-11: Imports for Consumption in Upholstered Household Furniture (337121), by top 2009 

trading partners (millions, current$)

$0

$200

$400

$600

$800

$1,000

$1,200

$1,400

$1,600

$1,800

$2,000

2000200120022003200420052006200720082009

2010*

Year

Imports (millions $)

China

Mexico

Italy

Vietnam

Malaysia

Other countries

Source: U.S. ITC 2010

Table 6-29 shows that China, followed by Mexico, is the largest source of imports for 

Upholstered Household Furniture. The value of the imports from China has been increasing 

considerably over the past decade. 
Market Profile of the Composite Wood Products Industry 93

Table 6-30: International Trade in Metal Household Furniture (337124), by top 2009 trading partne 

Country 2000 2001 2002 2003 2004 2005

Metal Household Furniture Imports

China $869 $950 $1,140 $1,502 $1,666 $1,859

Taiwan $246 $143 $143 $170 $158 $125

Mexico $140 $105 $94 $85 $87 $60

Italy $72 $74 $69 $71 $62 $68

Korea $1 $2 $2 $1 $0 $0

Other 

countries $214 $207 $218 $203 $209 $213

Total $1,542 $1,480 $1,666 $2,032 $2,182 $2,325

Note: Numbers may not add due to rounding, 2010 data is for January through August

Sources: U.S. ITC 2010

Figure 6-12: Imports for Consumption in Metal Household Furniture (337124), by top 2009 trading 

partners (millions, current$)

$0

$500

$1,000

$1,500

$2,000

$2,500

2000200120022003200420052006200720082009

2010*

Year

Imports (millions $)

China

Taiwan

Mexico

Italy

Korea

Other countries

Source: U.S. ITC 2010

China has been the largest source of imported Metal Household Furniture for the past 

decade, as shown in Table 6-30. Imports rose each year except 2008-2009 (see Table 6-30).
Market Profile of the Composite Wood Products Industry 94

Table 6-31: International Trade in Institutional Furniture (337127), by top 2009 trading partners (m 

Country 2000 2001 2002 2003 2004 2005

Institutional Furniture Imports

China $2,550 $2,869 $4,006 $4,688 $5,570 $6,492

Vietnam $8 $11 $64 $146 $324 $604

Canada $1,761 $1,616 $1,604 $1,606 $1,647 $1,651

Malaysia $389 $341 $389 $419 $500 $602

Indonesia $421 $440 $475 $467 $483 $547

Other 

countries $3,177 $2,979 $3,117 $3,106 $3,313 $3,283

Total $8,306 $8,255 $9,653 $10,433 $11,837 $13,180

Note: Numbers may not add due to rounding, 2010 data is for January through August

Sources: U.S. ITC 2010

Figure 6-13: Imports for Consumption in Institutional Furniture (337127), by top 2009 trading 

partners (millions, current$)

$0

$1,000

$2,000

$3,000

$4,000

$5,000

$6,000

$7,000

$8,000

2000200120022003200420052006200720082009

2010*

Year

Imports (millions $)

China

Vietnam

Canada

Malaysia

Indonesia

Other countries

Source: U.S. ITC 2010

Table 6-31 illustrates that China is the largest source of imports of Institutional 

Furniture. Recently Vietnam has been the second largest source, but prior to 2008, the value of 

imports from Canada was much greater than from Vietnam. 
Market Profile of the Composite Wood Products Industry 95

Table 6-32: International Trade in Wood Television, Radio, and Sewing Machine Cabinets (321911 

current$)

Country 2000 2001 2002 2003 2004 2005 2006

Wood Television, Radio, and Sewing Machine Cabinet Imports

Canada $4 $4 $4 $4 $4 $3 $3

China $0 $0 $0 $0 $0 $0 $1

Taiwan $0 $0 $0 $0 $0 $0 $1

Japan $0 $0 $0 $0 $0 $0 $0

Germany $1 $0 $0 $0 $0 $0 $0

Other 

countries $3 $4 $3 $3 $3 $3 $3

Total $8 $9 $7 $8 $7 $7 $7

Note: Numbers may not add due to rounding, 2010 data is for January through August

Sources: U.S. ITC 2010

Figure 6-14: Imports for Consumption in Wood Television, Radio, and Sewing Machine Cabinets 

(321911), by top 2009 trading partners (millions, current$)

$0

$1

$1

$2

$2

$3

$3

$4

$4

$5

200020012002200320042005

2006

200720082009

2010*

Year

Imports (millions $)

Canada

China

Taiwan

Japan

Germany

Other countries

Source: U.S. ITC 2010

The Wood Television, Radio, and Sewing Machine Cabinet industry is much smaller than 

the other industries, both in value of shipments and in trade values, as shown in Table 6-2 and 

Table 6-32. Canada is the largest source of imports for the industry. 
Market Profile of the Composite Wood Products Industry 96

Table 6-33: International Trade in Wood Office Furniture (337211), by top 2009 trading partners (m 

Country 2000 2001 2002 2003 2004 2005 2006

Wood Office Furniture Imports

Canada $443 $384 $367 $395 $403 $419 $454

China $71 $44 $91 $138 $160 $243 $308

Mexico $28 $19 $21 $15 $21 $26 $25

Indonesia $2 $3 $3 $6 $4 $4 $3

Italy $7 $10 $10 $10 $11 $13 $14

Other 

countries $127 $95 $114 $130 $134 $146 $162

Total $677 $555 $606 $694 $733 $850 $967

Note: Numbers may not add due to rounding, 2010 data is for January through August

Sources: U.S. ITC 2010

Figure 6-15: Imports for Consumption in Wood Office Furniture (337211), by top 2009 trading 

partners (millions, current$)

$0

$50

$100

$150

$200

$250

$300

$350

$400

$450

$500

2000200120022003200420052006200720082009

2010*

Year

Imports (millions $)

Canada

China

Mexico

Indonesia

Italy

Other countries

Source: U.S. ITC 2010

Wood Office Furniture is primarily traded with Canada, as shown in Table 6-33. In recent 

years, values of imports from China have nearly reached the level of imports coming from 

Canada. 
Market Profile of the Composite Wood Products Industry 97

Table 6-34: International Trade in Office Furniture (except Wood) (337214), by top 2009 trading pa 

Country 2000 2001 2002 2003 2004 2005 2006

Non-wood Office Furniture Imports

Canada $489 $387 $273 $241 $217 $232 $243

China $37 $34 $42 $47 $72 $86 $104

Mexico $16 $15 $16 $25 $29 $34 $34

Taiwan $32 $28 $30 $44 $39 $24 $26

Italy $7 $7 $4 $10 $14 $9 $12

Other 

countries $55 $45 $36 $40 $47 $53 $44

Total $636 $516 $402 $407 $419 $438 $462

Note: Numbers may not add due to rounding, 2010 data is for January through August

Sources: U.S. ITC 2010

Figure 6-16: Imports for Consumption in Office Furniture (except Wood) (337214), by top 2009 

trading partners (millions, current$)

$0

$100

$200

$300

$400

$500

$600

20002001

20022003200420052006

2007

20082009

2010*

Year

Imports (millions $)

Canada

China

Mexico

Taiwan

Italy

Other countries

Source: U.S. ITC 2010

The main trading partner for the Non-Wood Office Furniture industry is Canada as well, 

as can be seen in Table 6-34. Imports from Canada have diminished over the past decade, while 

the value of imports from China has risen. 
Market Profile of the Composite Wood Products Industry 98

Table 6-35: International Trade in Showcases, Partitions, Shelving, and Lockers (337215), by top 

Country 2000 2001 2002 2003 2004 2005

Showcase, Partition, Shelving, and Locker Imports

China $406 $502 $700 $1,014 $1,432 $1,787

Canada $764 $659 $674 $660 $776 $809

Mexico $179 $186 $223 $246 $291 $326

Taiwan $198 $158 $192 $179 $195 $201

Vietnam $0 $1 $4 $10 $17 $33

Other 

countries $626 $579 $585 $641 $758 $765

Total $2,174 $2,084 $2,378 $2,751 $3,468 $3,921

Note: Numbers may not add due to rounding, 2010 data is for January through August

Sources: U.S. ITC 2010

Figure 6-17: Imports for Consumption in Showcases, Partitions, Shelving, and Lockers (337215), by 

top 2009 trading partners (millions, current$)

$0

$500

$1,000

$1,500

$2,000

$2,500

2000200120022003200420052006200720082009

2010*

Year

Imports (millions $)

China

Canada

Mexico

Taiwan

Vietnam

Other countries

Source: U.S. ITC 2010

Table 6-35 shows that imports of Showcases, Partitions, Shelving, and Lockers come 

largely from China. Import values from China have been increasing rapidly over the past ten 

years
Market Profile of the Composite Wood Products Industry 99

Table 6-36: International Trade in Signs (339950), by top 2009 trading partners (millions, current$

Country 2000 2001 2002 2003 2004 2005 2006

Sign Imports

China $19 $23 $31 $56 $55 $65 $79

Canada $29 $37 $33 $36 $50 $50 $55

Mexico $5 $7 $14 $13 $12 $12 $13

Germany $2 $2 $3 $4 $7 $7 $8

Korea $2 $2 $2 $2 $3 $3 $3

Other 

countries $27 $28 $30 $32 $40 $41 $39

Total $84 $99 $113 $143 $167 $177 $197

Note: Numbers may not add due to rounding, 2010 data is for January through August

Sources: U.S. ITC 2010

Figure 6-18: Imports for Consumption in Signs (339950), by top 2009 trading partners (millions, 

current$)

$0

$10

$20

$30

$40

$50

$60

$70

$80

$90

$100

2000200120022003200420052006200720082009

2010*

Year

Imports (millions $)

China

Canada

Mexico

Germany

Korea

Other countries

Source: U.S. ITC 2010

International trade in signs has been fairly small relative to most of the other industries, 

as seen in Table 6-36. The largest source of imports has been China, followed by Canada and 

Mexico. Trade data was not available for the Non-Upholstered Wood Household Furniture 

manufacturing industry (337122) and the Custom Architectural Woodwork and Millwork 

manufacturing industry (337212).
Market Profile of the Composite Wood Products Industry 100

6.4 Industry Organization

The following section describes the organization of the industries that use hardwood 

plywood, medium density fiberboard, and particleboard panels as raw materials in their 

manufacturing process. Information is presented on:

• The industry structure

• The characteristics of the manufacturing facilities

• The size distribution of the firms that own the manufacturing facilities

In addition, this section provides detailed information about facilities and firms that are 

key inputs to the economic analysis.

6.4.1 U.S. Census Data on Industry Structure

6.4.1.1 Specialization and Market Concentration

To determine the extent to which Census data on the wood products manufacturing 

industries adequately describe the manufacturers of composite wood products, industry-wide 

specialization and coverage ratios are examined. Products shipped from one establishment to 

another within the same industry are considered “primary”, while all other products shipped by 

the establishment are considered “secondary”. The primary products specialization ratio is the 

ratio of total primary product shipments to total product shipments (primary and secondary) for 

all establishments classified in the industry. The coverage ratio indicates the extent to which the 

primary industry products are manufactured by establishments classified in that industry. The 

coverage ratio is the ratio of primary products shipped by the establishments classified in the 

industry to the total shipments of these products shipped by all establishments classified in all 

industries. Table 6-37 provides specialization and coverage ratios for the four potentially 

affected NAICS industries. 
Market Profile of the Composite Wood Products Industry 101

Table 6-37: Primary Products Specialization and Coverage 

Ratios, by NAICS, 2007

NAICS 

Code Description

Primary 

Products 

Specialization 

Ratio 

(maximum 

value 100)

Coverage 

Ratio 

(maximum 

value 100)

321911

Wood 

Window and 

Door 

Manufacturing

97 96

321918

Other 

Millwork 

(including 

Flooring)

96 93

321991

Manufactured 

Homes 

(Mobile 

Homes) 

Manufacturing

Withheld Withheld

321999

Other 

Miscellaneous 

Wood Product 

Manufacturing

99 95

336213 Motor Homes 95 95

336214

Travel Trailer 

and Camper 

Manufacturing

97 96

337110

Kitchen 

Cabinets and 

Countertops 

Manufacturing

97 98

337121

Upholstered 

House 

Furniture 

Manufacturing

92 95

337122

Nonupholstered 

Wood 

Household 

Furniture 

Manufacturing

90 90

337124

Metal 

Household 

Furniture 

Manufacturing

88 85

337127

Institutional 

Furniture 

Manufacturing

93 92

337129

Wood 

Television, 

Radio, and 

Sewing 

Machine 

Cabinet 

Manufacturing

93 61
Market Profile of the Composite Wood Products Industry 102

337211 Wood Office 

Furniture 91 80

337212

Custom 

Architectural 

Woodwork 

and Millwork 

Manufacturing

92 92

337214

Office 

Furniture 

(except Wood)

91 97

337215

Showcase, 

Partition, 

Shelving, and 

Locker 

Manufacturing

95 92

339950 Sign 

Manufacturing 95 95

Sources: U.S. Census 2009c

As indicated in Table 6-37, half the NAICS codes have specialization and coverage ratios 

above 95. Ratios this high imply that most establishments within these NAICS codes are highly 

specialized, and that product shipments tend to originate in establishments within these NAICS 

codes. Therefore, the Census data on these NAICS industries provide information on the 

primary production of facilities engaged in plywood and wood composite manufacturing.

Table 6-38 presents market concentration ratios and Herfindahl-Hirschman (HH) index 

values for the potentially affected NAICS codes in 2002. M-firm concentration ratios are equal 

to the sum of the market shares for the largest m number of firms in the industry; the higher the 

ratio the more concentrated the industry. HH index values equal to the sum of the squares of 

the market shares for the 50 largest firms in the industry; the higher the HH index, the more 

concentrated the industry. 
Market Profile of the Composite Wood Products Industry 103

Table 6-38: Concentration Ratios by NAICS Code, 2002

NAICS 

Code Description

Number of 

Companies 

in Industry

Percent of value of industry shipments shipped by the largest (in terms of 

shipment value)

Herfin

Hirsch 

Inde 

50 la 

comp

4 

Companies

8 

Companies

20 

Companies

50 

Companies

321911

Wood 

Window and 

Door 

Manufacturing 1,328 34.9% 44.7% 57.4% 70.2%

321918

Other 

Millwork 

(including 

Flooring) 

Manufacturing 2,020 17.7% 24.3% 33.7% 46.8%

321991

Manufactured 

Home (Mobile 

Home) 

Manufacturing 241 44.6% 63.7% 81.1% 92.5%

321999

All Other 

Miscellaneous 

Wood Product 

Manufacturing 2,031 17.6% 22.4% 31.3% 44.5%

336213

Motor Home 

Manufacturing 83 57.7% 77.6% 95.3% 99.6% 1,

336214

Travel Trailer 

and Camper 

Manufacturing 733 38.0% 45.8% 58.4% 72.1%

337110

Wood Kitchen 

Cabinet and 

Countertop 

Manufacturing 9,452 29.2% 35.1% 43.0% 50.0%

337121

Upholstered 

Household 

Furniture 

Manufacturing 1,679 34.7% 42.2% 53.6% 66.9%

337122

Nonupholstered 

Wood 

Household 

Furniture 

Manufacturing 3,975 23.9% 34.5% 49.9% 62%

337124

Metal 

Household 

Furniture 

Manufacturing 353 27.6% 41.6% 64.2% 83.8%

337127

Institutional 

Furniture 693 20.9% 28.7% 43.1% 63.7%

337129

Wood 

Television, 

Radio, and 

Sewing 

Machine 

Cabinet 

Manufacturing 201 64.4% 75.4% 84.6% 93.1% 1,
Market Profile of the Composite Wood Products Industry 104

337211

Wood Office 

Furniture 

Manufacturing 546 34.1% 43.3% 55.8% 71.6%

337212

Custom 

Architectural 

Woodwork 

and Millwork 

Manufacturing 1,552 10.1% 14.9% 23% 35.6%

337214

Office 

Furniture 

(except Wood) 

Manufacturing 261 61.8% 80.0% 88.4% 94.8% 1,

337215

Showcase, 

Partition, 

Shelving, and 

Locker 

Manufacturing 1,800 13.7% 20.5% 31.5% 44.7%

339950

Sign 

Manufacturing 6,125 5.2% 8.9% 16.4% 27.3%

Note: A market is generally considered highly concentrated if the 4-firm concentration ratio is greater than 50 percent. 

The United States Department of Justice use an HH value of 1,000 as a ceiling for market competitiveness; an HH between 1,000 and 1,800 is considered to be moderately concentrated 

anything above 1,800 is considered to be highly concentrated (U.S. DOJ 1997).

Source: U.S. Census 2006

Table 6-38 indicates that the motor home industry, the wood television, radio, and 

sewing machine cabinet industry, and non-wood office furniture manufacturing industry all have 

4-firm ratios above 50 (57.7, 64.4, and 61.8 respectively). This suggests that these industries, of 

the 17 noted above, are considered uncompetitive. The remaining industries have 4-firm ratios 

below 50, and are considered competitive industries.

As shown in Table 6-38, certain industries are much more highly concentrated than 

others. For instance, the sign manufacturing industry has an HH value at just over 19, the lowest 

of the group. Still, industries such as those making motor homes; television, radio, and sewing 

machine cabinets; and office furniture all have HH values over 1,000. This indicates that these 

three industries are “moderately concentrated,” and television, radio, and sewing machine 

cabinet manufacturing approaches the “highly concentrated” marker.

6.4.1.2 Vertical and Horizontal Integration

The high specialization and coverage ratios presented in the preceding section indicate 

that half the fabricator industries are not highly integrated vertically. Vertical integration is 

when companies maintain operations in multiple levels of the supply chain. For example, a 

company that harvested logs, manufactured veneers, adhesives, hardwood plywood panels, and 

hardwood plywood cabinets would be vertically integrated. A vertically integrated industry 

would tend to have lower specialization and coverage ratios since vertical integration implies 

less specialization in a single product type.

Horizontal integration is when a company expands in the same industry and stage of the 

production line. Thus, a horizontally integrated industry is characterized by fewer firms and less 

competition. The HH index values presented in the preceding section indicate that the majority 
Market Profile of the Composite Wood Products Industry 105

of industries using composite wood products as raw materials are not uncompetitive and 

therefore are not highly horizontally integrated.

6.4.1.3 Production Capacity and Utilization

Capacity utilization rates are the ratio of observed output to maximum potential output. 

Table 6-39 provides capacity utilization rates for the general industries using composite wood 

products as inputs between 2000 and 2009.

Table 6-39: Full Production Capacity Utilization Rates by NAICS Codes, 

Fourth Quarters, 2000 – 2009

N

A

I

C

S

Description

Per

ce

nta

ge 

Ch

an

ge

3

2

1

9

Other Wood 

Product 

Manufacturing

(

1

8

%

)

3

3

6

2

Motor Vehicle 

and Motor 

Body 

Manufacturing

(

3

2

%

)

3

3

7

1

Household 

and 

Institutional 

Furniture and 

Kitchen 

Cabinet 

Manufacturing

(

8

%

)

3

3

7

2

Office 

Furniture 

(including 

Fixtures) 

Manufacturing

(

2

0

%

)

3

3

9

9

5

0

Office 

Supplies 

(except Paper) 

and Sign 

Manufacturing

(

7

%

)

Note: A capacity utilization rate under 100 indicates that, for a given existing capital stock, a firm or industry has the potential 

for greater output without incurring major expenditures (FAO 1999).

Note: 2007 values for NAICS Codes 3371 and 3372 were combined, along with 3379, in the census data and are represented 

above in italics

Note: 2007 value for NAICS Code 3362 were combined in the census data with 3361 and 3363

Note: 2007 value for 33950 is simply 3399 and the 2008 and 2009 values are 3394-5

Sources: U.S. Census 2002-2010
Market Profile of the Composite Wood Products Industry 106

As indicated in Table 6-39, capacity utilization rates in the fourth quarter of 2009 ranged 

from 41 to 68 percent. The industries using composite wood product raw materials experienced 

a capacity utilization rate decrease of between 7 and 32 percent between the fourth quarter of 

2000 and the fourth quarter of 2009. The greatest decrease was in the Motor Vehicle and Motor 

Body Manufacturing industry. 

Figure 6-19 presents a graphical representation of quarterly production capacity 

utilization rates between 2007 and 2010 for the related NAICS groups.

Figure 6-19: Full Production Capacity Utilization Rates, Quarterly, 2007-2010

0

10

20

30

40

50

60

70

80

90

2007

Q1

2007

Q2

2007

Q3

2007

Q4

2008

Q1

2008

Q2

2008

Q3

2008

Q4

2009

Q1

2009

Q2

2009

Q3

2009

Q4

2010

Q1

Quarter

Capacity Utilization %

Other wood

product

manufacturing

Motor Vehicle

and Motor Body

Mfg

Household and

instututional

furniture and

kitchen cabinet

mfg

Office Furniture

(including

fixtures) mfg

Office supplies

(except paper)

and sign mfg

Source: U.S. Census 2002-2010

Table 6-40 provides a breakdown of capital expenditures for the related NAICS in 2008. 

The data are broken down into total capital expenditures for permanent additions and major 

alterations to establishments, as well as new and used machinery and equipment for 

replacement or addition to a plant’s capacity, which is divided into 1) automobiles, trucks, etc. 

for highway use; 2) computer and data processing equipment; and, 3) all other machinery and 

equipment. 
Market Profile of the Composite Wood Products Industry 107

mary of Capital Expenditures (New and Used) (thousands, 2008$)

NAICS 

escription

Buildings and Other 

structures

Machinery and Equipment 

Autos, Trucks, etc. for 

Highway Use

Computer and Data 

Processing Equipment

All Other Machine 

Equipment

Value Percent Value Percent Value Percent Value

ood 

ndow and 

or 

nufacturing $67,653 18.94% $16,457 4.61% $42,840 12.00% $230,180 

her 

lwork (incl. 

oring) $19,810 12.03% $10,519 6.39% $8,420 5.11% $125,979 

nufactured 

me (Mobile 

me) Mfg. $55,227 39.67% $12,127 8.71% $6,359 4.57% $65,487 

Other 

scellaneous 

ood Product 

g. $23,596 11.51% $12,979 6.33% $10,388 5.07% $158,083 

otor Home 

g. $4,324 17.21% $1,080 4.30% $4,477 17.82% $15,248 

vel Trailer 

d Camper 

g. $7,328 5.63% $9,316 7.16% $9,507 7.31% $103,974 

ood Kitchen 

binet and 

untertop 

g. $39,028 15.38% $16,216 6.39% $19,576 7.71% $178,935 

holstered 

usehold 

rniture Mfg. $30,100 21.98% $27,375 19.99% $12,891 9.41% $66,583 

nholstered 

ood 

usehold 

rniture Mfg. $11,963 13.91% $5,494 6.39% $9,303 10.82% $59,214 

etal 

usehold 

rniture Mfg. $3,483 16.26% $1,476 6.89% $1,370 6.40% $15,096 

titutional 

rniture Mfg $13,913 15.36% $3,897 4.30% $13,326 14.71% $59,444 

ood 

evision, 

dio, and 

wing 

chine 

binet Mfg. $1,790 22.24% $695 8.63% $773 9.60% $4,794 

ice 

rniture 

cluding 

ures) Mfg. $11,187 19.59% $1,768 3.09% $4,433 7.76% $39,732 

stom 

chitectural 

oodwork 

d Millwork 

g. $21,673 13.78% $13,942 8.86% $16,389 10.42% $105,276 

ice $19,194 13.62% $1,229 0.87% $15,183 10.77% $105,347 
Market Profile of the Composite Wood Products Industry 108

rniture 

cept Wood) 

g.

owcase, 

rtition, 

elving, and 

cker Mfg. $12,187 11.57% $2,054 1.95% $8,097 7.69% $82,958 

n Mfg. $62,868 24.17% $26,509 10.19% $35,255 13.55% $135,492 

ent values that were not represented in the 2008 survey and have been replaced by 2007 figures (in 2008$).

0g,U.S. Census 2009c,U.S. DOC 2010

As indicated in Table 6-40, total capital expenditures in 2008 ranged from about $8

million in the wood television, radio, and sewing machine cabinet manufacturing industry to 

about $350 million dollars in the wood window and door manufacturing industry. Expenditures 

for other machinery and equipment accounted for the largest proportion of these totals, ranging 

from 47 percent in the manufactured home (mobile home) manufacturing industry to 80

percent in the travel trailer and camper manufacturing industry (U.S. Census 2010g, U.S. Census 

2009c).

Employment

Table 6-41 summarizes the employment statistics for the relevant NAICS in 2007. As 

indicated in Table 6-41, in 2007 the universe of potentially affected NAICS groups was composed 

of 33,783 establishments and employed about 821 thousand people (or about 24 employees per 

establishment) and had total payroll amounting to approximately 29 billion dollars. In 2008, the 

wood kitchen cabinet and countertop manufacturing industry had the most establishments 

(9,701) and employed the most people (140,393). Kitchen countertops and cabinetry also had 

the highest payroll (over $4 billion) (U.S. Census 2010j).
Market Profile of the Composite Wood Products Industry 109

Table 6-41: Summary of Employment Statistics, By NAICS (2008)

NAICS NAICS Description Total 

Establishments

Total 

Employees

Average 

Employees 

Per 

Establishment

Total Payroll 

(thousands, 

2008$)

321911 Wood Windows and Door Mfg. 1,493 79,101 52.98 $2,786,366

321918 Other Millwork 2,110 43,423 20.58 $1,436,648

321991 Manufactured Home (Mobile 

Home) Mfg. 379 40,854 107.79 $1,300,118

321992 Prefabricated wood building 

manufacturing 818 24,781 30.29 $861,893

321999 All Other Miscellaneous Wood 

Product Mfg. 1,971 36,582 18.56 $1,105,084

336213 Motor Home Mfg. 79 17,553 222.19 $725,478

336214 Travel Trailer and Camper Mfg. 862 49,445 57.36 $1,824,130

337110 Wood Kitchen Cabinet and 

Countertop Mfg. 9,701 140,393 14.47 $4,479,039

337121 Upholstered Household 

Furniture Mfg. 1,641 77,422 47.18 $2,265,630

337122 Non-upholstered Wood 

Household Furniture Mfg. 3,414 61,005 17.87 $1,769,657

337124 Metal Household Furniture 

Mfg. 329 11,740 35.68 $387,230

337127 Institutional Furniture Mfg. 776 34,295 44.19 $1,313,375

337129 Wood Television, Radio, and 

Sewing Machine Cabinet Mfg. 265 2,764 10.43 $85,719

337211 Wood Office Furniture Mfg. 457 19,059 41.70 $669,959

337212 Custom Architectural 

Woodwork and Millwork Mfg. 2,235 47,467 21.24 $2,001,015

337214 Office Furniture (except Wood) 

Mfg. 290 28,133 97.01 $1,348,739

337215 Showcase, Partition, Shelving, 

and Locker Mfg. 1,375 45,048 32.76 $1,606,858

339950 Sign Mfg. 6,406 86,843 13.56 $3,480,360

Total 34,601 845,908 24 $29,447,298

Source: U.S. Census 2010j.
Market Profile of the Composite Wood Products Industry 110

7 Composite Wood Product Wholesalers and Importers

This section presents information on the value of sales, operating costs and industry 

organization for the wholesale trade establishments that sell products containing composite 

wood. The wholesale trade industry includes both distributers of domestic and imported 

composite wood products. Note that the industry categories as defined by NAICS are likely to 

include some wholesalers that are not subject to any requirements under the proposed TSCA 

Title VI rule. 

NAICS codes for the potentially affected wholesale trade industries were indentified 

through a review of information reported by the United States Census Bureau. 

Section 7.1 presents information on the value of sales by industry and product type. 

Section 7.2 describes industry operating costs. Section 7.3 summarizes the industry 

organization for the composite wood product wholesalers.

7.1 Value of Sales

Table 7-1 shows the sales by NAICS for the products sold in the wholesale industries, 

with specific information for products that may contain composite wood.
Market Profile of the Composite Wood Products Industry 111

Table 7-1: Value of Sales by Industry for Wholesale, 2007$

NAICS 

Code NAICS Description Product Value of Sales

423210 Furniture Merchant 

Wholesalers

Upholstered furniture $3,177,012 

Mattresses and beds $2,271,238 

Lawn and outdoor furniture $1,531,754 

Other furniture $8,010,051 

Sleep sofas $267,527 

New wooden and metal office 

furniture $18,954,544 

New store and restaurant 

furniture $276,684 

New public furniture $1,088,269 

Used office and business furniture $472,750 

Other hard-surface floor coverings 

and accessories $35,504 

Other panel products $4,102 

Wood millwork $6,467 

Products without Composite 

Wood Products $2,469,636 

Industry Total $38,589,359 

423220 Home Furnishing Merchant 

Wholesalers

Upholstered furniture $54,727 

Mattresses and beds $22,173 

Lawn and outdoor furniture $116,110 

Other furniture $114,116 

Sleep sofas $761 

New wooden and metal office 

furniture $45,129 

New store and restaurant 

furniture $19,957 

New public furniture $29,401 

Used office and business furniture $1,933 

Other hard-surface floor coverings 

and accessories $13,879,890 

Boards $10,205 

Other panel products $13,909 

Gypsum, waterboard, and other 

specialty boards $6,187 

Wood millwork $21,818 

Products without Composite 

Wood Products $38,028,815 

Industry Total $52,661,904 

423310 Lumber, Plywood, Wood 

Merchant Wholesalers

Household and lawn furniture $851 

Office and business furniture $5,954 

Flooring and floor coverings $356,613 

Boards $5,843,155 

Softwood plywood and Oriented 

Strand Board (OSB) $7,880,527 

Other panel products $8,165,473 

Gypsum, waterboard, and other 

specialty boards $4,155,239 

Wood millwork $22,942,407 

Products without Composite 

Wood Products $43,933,415 

Industry Total $93,392,394 

423320 Brick, Stone & Construction Flooring and floor coverings $40,327 
Market Profile of the Composite Wood Products Industry 112

Table 7-1: Value of Sales by Industry for Wholesale, 2007$

NAICS 

Code NAICS Description Product Value of Sales

Materials Merchant 

Wholesalers

Boards $1,371 

Softwood plywood and Oriented 

Strand Board (OSB) $6,443 

Other panel products $46,069 

Gypsum, waterboard, and other 

specialty boards $81,566 

Wood millwork $40,346 

Non-lumber forest products $4,793 

Products without Composite 

Wood Products $30,103,037 

Industry Total $30,364,440 

423390

Other Construction 

Materials Merchant 

Wholesalers

Other hard-surface floor coverings 

and accessories $61,111 

Boards $15,931 

Softwood plywood and Oriented 

Strand Board (OSB) $18,647 

Other panel products $16,211 

Gypsum, waterboard, and other 

specialty boards $257,953 

Wood millwork $293,355 

Products without Composite 

Wood Products $19,418,441 

Industry Total $20,163,229 

423450

Medical, Dental, & Hospital 

Equipment & Supply 

Merchant Wholesalers

Household and lawn furniture $2,675 

Office and business furniture $23,185 

Products without Composite 

Wood Products $134,503,782

Industry Total $134,593,534 

423490

Other Professional 

Equipment & Supply 

Merchant Wholesalers

Office and business furniture $37,982 

Products without Composite 

Wood Products $18,162,644 

Industry Total $18,289,961 

423850 Service Establishment 

Merchant Wholesalers

Office and business furniture $179 

Flooring and floor coverings $4,119 

Products without Composite 

Wood Products $19,209,574 

Industry Total $19,295,937 

423330

Roofing, siding, and 

insulation material 

merchant wholesalers

Flooring and floor coverings $33,296 

Untreated lumber $175,167 

Treated lumber $77,576 

Boards $80,692 

Softwood plywood and Oriented 

Strand Board (OSB) $165,553 

Other panel products $65,052 

Gypsum, waterboard, and other 

specialty boards $318,189 

Wood millwork $606,903 

Trusses, wood siding, and wood 

shingles $111,970 

Other construction products and 

materials $1,412,913 

Parts installed in repair work $4,349 
Market Profile of the Composite Wood Products Industry 113

Table 7-1: Value of Sales by Industry for Wholesale, 2007$

NAICS 

Code NAICS Description Product Value of Sales

Products without Composite 

Wood Products $22,657,605 

Industry Total $25,500,802 

423440

Other commercial 

equipment merchant 

wholesalers

Office and business furniture $13,815 

Parts installed in repair work $106,310 

Products without Composite 

Wood Products $20,739,900 

Industry Total $20,860,025 

423510

Metal service centers and 

other metal merchant 

wholesalers

New and used automobiles, 

motorcycles, and trailers $11,730 

Household and lawn furniture $2,233 

Office and business furniture $1,333 

Flooring and floor coverings $4,047 

Untreated lumber $33,240 

Treated lumber $7,612 

Boards $16,083 

Softwood plywood and Oriented 

Strand Board (OSB) $29,880 

Other panel products $13,003 

Gypsum, waterboard, and other 

specialty boards $86,041 

Wood millwork $51,076 

Trusses, wood siding, and wood 

shingles $5,887 

Other construction products and 

materials $424,260 

Other miscellaneous durable 

goods $5,972 

Parts installed in repair work $73,327 

Products without Composite 

Wood Products $204,132,939 

Industry Total $204,898,663 

423610 Elec. equip. and wiring 

merchant wholesalers

Shades and blinds $7,415 

Other construction products and 

materials $3,200 

Other miscellaneous durable 

goods $10,928 

Parts installed in repair work $193,573 

Products without Composite 

Wood Products $119,386,327 

Industry Total $119,601,443 

423620 Electric appliance merchant 

wholesalers

Household and lawn furniture $26,160 

Other panel products $1,813 

Gypsum, waterboard, and other 

specialty boards $10,276 

Wood millwork $41,715 

Parts installed in repair work $33,837 

Products without Composite 

Wood Products $86,929,402 

Industry Total $87,043,203 

423710 Hardware merchant 

wholesalers

Household and lawn furniture $128,620 

Flooring and floor coverings $9,347 

Untreated lumber $837 
Market Profile of the Composite Wood Products Industry 114

Table 7-1: Value of Sales by Industry for Wholesale, 2007$

NAICS 

Code NAICS Description Product Value of Sales

Boards $2,843 

Softwood plywood and Oriented 

Strand Board (OSB) $9,445 

Other panel products $399,607 

Gypsum, waterboard, and other 

specialty boards $292,582 

Wood millwork $756,963 

Trusses, wood siding, and wood 

shingles $1,124 

Other construction products and 

materials $295,637 

Other miscellaneous durable 

goods $5,470 

Parts installed in repair work $31,026 

Products without Composite 

Wood Products $41,967,674 

Industry Total $43,901,175 

423720 Plumbing equip. merchant 

wholesalers

New and used automobiles, 

motorcycles, and trailers $931 

Household and lawn furniture $109,378 

Flooring and floor coverings $16,290 

Softwood plywood and Oriented 

Strand Board (OSB) $2,233 

Other panel products $16,095 

Gypsum, waterboard, and other 

specialty boards $3,573 

Wood millwork $33,675 

Other construction products and 

materials $28,723 

Parts installed in repair work $149,498 

Products without Composite 

Wood Products $49,217,005 

Industry Total $49,577,401 

423730 HVAC equip. merchant 

wholesalers

Household and lawn furniture $1,362 

Flooring and floor coverings $4,087 

Softwood plywood and Oriented 

Strand Board (OSB) $275 

Other panel products $235 

Gypsum, waterboard, and other 

specialty boards $311 

Wood millwork $102,190 

Other construction products and 

materials $55,407 

Parts installed in repair work $86,288 

Products without Composite 

Wood Products $32,445,806 

Industry Total $32,695,961 

423740

Refrigeration equipment 

and supplies merchant 

wholesalers

Parts installed in repair work $51,110 

Products without Composite 

Wood Products $5,745,056 

Industry Total $5,796,166 

423830 Industrial machinery and 

equipment merchant 

New and used automobiles, 

motorcycles, and trailers $36,592 
Market Profile of the Composite Wood Products Industry 115

Table 7-1: Value of Sales by Industry for Wholesale, 2007$

NAICS 

Code NAICS Description Product Value of Sales

wholesalers Office and business furniture $5,632 

Other panel products $8,654 

Wood millwork $6,091 

Other construction products and 

materials $39,816 

Other miscellaneous durable 

goods $1,795 

Parts installed in repair work $2,316,539 

Products without Composite 

Wood Products $167,866,593 

Industry Total $170,281,712 

423910

Sporting and recreational 

goods and supplies 

merchant wholesalers

Household and lawn furniture $52,617 

Other construction products and 

materials $153,094 

Parts installed in repair work $26,834 

Products without Composite 

Wood Products $33,611,700 

Industry Total $33,844,245 

424610

Plastics materials and basic 

forms and shapes merchant 

wholesaler

Flooring and floor coverings $3,069 

Other home furnishings $3,428 

Treated lumber $8,104 

Boards $3,895 

Softwood plywood and Oriented 

Strand Board (OSB) $7,478 

Other panel products $27,504 

Wood millwork $17,244 

Other construction products and 

materials $40,411 

Parts installed in repair work $7,451 

Products without Composite 

Wood Products $46,434,124 

Industry Total $46,552,708 

424950 Paint, varnish, and supplies 

merchant wholesalers

Flooring and floor coverings $187,414 

Other construction products and 

materials $904 

Products without Composite 

Wood Products $13,165,172 

Industry Total $13,353,490 

Value of Sales Total $1,261,257,752 

Source: U.S. Census 2009e

7.2 Wholesale Operating Costs 

The following section summarizes operating costs incurred by the potentially affected 

wholesale trade industries, including the value of annual payroll and operating expenses, and 

the estimated value of sales, inventories, purchases and gross margins. Where possible, data 

are presented at the six-digit NAICS level and provided over a range of years. To prevent 

double-counting, data in this section do not include manufacturers’ sales branches and offices 

maintained by companies for the purpose of marketing their products. 
Market Profile of the Composite Wood Products Industry 116

7.2.1 Payroll and Operating Expenses

Table 7-2 provides the value of annual payroll and operating expenses in 2007 for the 

potentially affected wholesale trade industries. 

Table 7-2: Value of Annual Payroll and Operating Expenses for Wholesalers, 

excluding Manufacturers' Sales Branches and Offices, 2007 (thousands, 2007$)

1

NAICS NAICS Description Annual 

Payroll2

Operating 

Expenses3

423210 Furniture merchant wholesalers $3,159,816 $6,236,936

423220 Home furnishing merchant wholesalers $4,181,919 $8,899,889

423310 Lumber, plywood, millwork, and wood panel 

merchant wholesalers $6,265,545 $10,116,270

423320 Brick, stone, and related construction material 

merchant wholesale $1,512,862 $3,227,211

423330 Roofing, siding, and insulation material merchant 

wholesalers $1,557,069 $3,211,812

423390 Other construction material merchant wholesalers $1,694,939 $3,172,643

423440 Other commercial equipment merchant 

wholesalers $2,250,869 $4,110,201

423450 Medical equipment merchant wholesalers $10,259,277 $18,783,159

423490 Other professional equipment and supplies 

merchant wholesalers D D

423510 Metal service centers and other metal merchant 

wholesalers $7,943,294 $15,659,031

423610 Elec. equip. and wiring merchant wholesalers $9,570,001 $17,201,112

423620 Electric appliance merchant wholesalers $2,561,797 $6,721,857

423710 Hardware merchant wholesalers $3,840,341 $7,488,599

423720 Plumbing equip. merchant wholesalers $4,441,190 $8,115,468

423730 HVAC equip. merchant wholesalers $2,547,025 $4,377,315

423740 Refrigeration equipment and supplies merchant 

wholesalers $531,410 $929,905

423830 Industrial machinery and equipment merchant 

wholesalers $17,151,437 $29,067,870

423850 Service establishment equipment and supplies 

merchant wholesalers D D

423910 Sporting and recreational goods and supplies 

merchant wholesalers $2,487,901 $5,608,736

424610 Plastics materials and basic forms and shapes 

merchant wholesaler $1,718,840 $3,336,281

424950 Paint, varnish, and supplies merchant wholesalers $649,166 $1,153,224

Notes: “1) D” is used to indicate that the data have been withheld to avoid disclosure. 

2) Payroll includes all forms of compensation such as salaries, wages, commissions, dismissal pay, bonuses, vacation allowances, sickleave pay, and employee contributions to qualified pension plans paid during the year to all employees and reported on Internal Revenue 

Service (IRS) Form 941 as taxable Medicare Wages and tips (even if not subject to income or FICA tax).

3) Operating expenses include payroll, employee benefits, interest and rent expenses, payroll taxes, cost of supplies used for operation, 

depreciation expenses, fundraising expenses, contracted or purchased services, and other expenses charged to operations during 2007. 

Expenses exclude cost of goods sold, income taxes, and interest for wholesale establishments; outlays for the purchase of real estate; 

construction and all other capital improvements; funds invested; assessments or dues paid to the parent or other chapters of the same 

organization; and, for fundraising organizations, funds transferred to charities and other organizations.

Source: U.S. Census 2010h

As indicated in Table 7-2, in 2007 the value of the annual payrolls for the potentially 

affected wholesale trade industries ranged from just over $531 million to nearly $17.2 billion, 

while operating expenses ranged from about $929 million to about $29.1 billion (NAICS 423740 
Market Profile of the Composite Wood Products Industry 117

and 423830, respectively). Values for annual payrolls and operating expenses were withheld for 

NAICS 423490 and 423850 to avoid disclosure.

7.2.2 Sales and Inventories

Table 7-3 and Table 7-4 present the estimated annual value of sales and inventories for 

potentially affected wholesale trade industries between 2002 and 2008. The data in these 

tables are from the U.S. Census Bureau’s Annual Wholesale Trade Report, and derive from a 

mandatory annual survey of companies engaged in wholesale trade in the United States.22 Note 

that data are only available at the 4-digit NAICS level.

 22 The survey’s sample includes approximately 2,100 companies and 5,900 parts of companies (defined by Employer 

Identification Numbers, or EINs). Data are collected on annual sales, e-commerce sales, number of establishments, 

value of inventories, inventory by valuation, inventory outside of the United States, total purchases of products, and

total operating expenses (U.S. Census 2010a). 
Market Profile of the Composite Wood Products Industry 118

le 7-3: Estimated Annual Value of Sales for Wholesalers, excluding Manufacturers' Sales Branches and Offices, 2002 -

lions, current $)1

S Description 2002 2003 2004 2005 2006 2007

Furniture and 

Home 

Furnishings

$53,484 $55,396 $59,614 $62,825 $68,981 $69,064

Lumber & 

Other 

Construction 

Materials

$95,091 $105,244 $127,671 $139,412 $142,635 $126,651

Professional 

and 

Commercial 

Equipment 

and Supplies

$272,462 $275,922 $302,984 $316,016 $330,740 $353,781

Metals and 

Minerals, ex. 

Petroleum

$81,746 $81,238 $120,828 $136,091 $158,006 $162,138

Electrical 

Goods $222,957 $232,433 $264,753 $283,614 $319,555 $346,510

Hardware, 

and Plumbing 

and Heating 

Equipment 

and Supplies

$70,431 $74,427 $84,139 $94,844 $108,397 $111,579

Machinery, 

Equipment, 

and Supplies

$227,758 $230,664 $259,836 $288,216 $312,712 $326,416

Miscellaneous 

Durable 

Goods

$145,627 $148,037 $181,114 $184,699 $205,411 $226,798

Chemicals 

and Allied 

Products

$67,721 $70,675 $78,317 $89,829 $92,549 $102,162

Miscellaneous 

Nondurable 

Goods

$161,091 $160,111 $179,031 $187,024 $190,769 $202,044

: 1) All estimates have been adjusted using the preliminary results of the 2007 Economic Census. 

e: U.S. Census 2010b
Market Profile of the Composite Wood Products Industry 119

ble 7-4: Estimated Annual Value of Inventories for Wholesalers, excluding Manufacturers' Sales Branches and Offices 

08, (millions, current$)1

CS Description 2002 2003 2004 2005 2006 2007

2 Furniture and 

Home Furnishings $6,340 $6,760 $7,151 $7,737 $8,306 $8,367

3

Lumber & Other 

Construction 

Materials

$8,855 $10,410 $13,317 $14,280 $14,583 $13,710

4

Professional and 

Commercial 

Equipment and 

Supplies

$24,722 $25,036 $27,291 $27,632 $29,461 $29,988

5

Metals and 

Minerals, ex. 

Petroleum

$12,033 $12,108 $18,938 $19,518 $24,660 $23,049

6 Electrical Goods $25,073 $24,983 $27,849 $30,208 $34,113 $36,434

7

Hardware, and 

Plumbing and 

Heating Equipment 

and Supplies

$11,106 $11,720 $13,515 $15,279 $17,087 $17,891

8

Machinery, 

Equipment, and 

Supplies

$46,557 $44,852 $50,067 $55,963 $60,943 $63,718

9 Miscellaneous 

Durable Goods $17,540 $18,838 $21,046 $23,124 $23,106 $23,808

6 Chemicals and 

Allied Products $6,588 $6,633 $7,297 $8,182 $8,276 $9,753

9 Miscellaneous 

Nondurable Goods $16,108 $16,094 $18,270 $18,929 $18,750 $21,021

es: 1) All estimates have been adjusted using the preliminary results of the 2007 Economic Census. 

rce: U.S. Census 2010b

As indicated in Table 7-3 and Table 7-4, in 2008 the estimated value of sales ranged 

from just over $64.0 billion (NAICS 4232) to nearly $358.5 billion (NAICS 4234), while the 

estimated value of inventories ranged from just over $8.2 billion (NAICS 4232) to nearly $69.7 

billion (NAICS 4238). Between 2002 and 2008, the estimated annual value of sales increased 

from 18 percent (NAICS 4233) to 109 percent (NAICS 4235), while the estimated annual value of 

inventories increased from 24 percent (NAICS 4234) to 120 percent (NAICS 4235). 

Figure 7-1 presents a graphical representation of monthly inventory/sales ratios for the 

potentially affected 4-digit NAICS groups between January 1993 and September 2008.23 To 

smooth out short term fluctuations, the ratios have been calculated as a simple moving average 

of the previous twelve months (i.e. the January 1993 moving average is the average includes 

that month and the previous 11 months). Monthly inventory/sales ratios provide an indication 

of the number of months’ worth of inventory that are on hand in relation to the sales for a 

month. 

 23 The data in Figure 7-1 are from the United States Census Bureau’s Monthly Wholesale Trade report, and derive from 

a voluntary monthly survey of approximately 1,700 companies and 2,700 EINs engaged in wholesale trade in the 

United States.
Market Profile of the Composite Wood Products Industry 120

Figure 7-1: Estimated Monthly Inventory/Sales Ratios, Jan. 1993 - Sept. 2010

0.50

1.00

1.50

2.00

2.50

3.00

1993

1994

1995

1996

199719981999

20002001

200220032004

200520062007

2008

2009

2010

Year

Ratio

4232 Furniture and Home Furnishings

4233 Lumber & Other Construction

Materials

4234 Professional and Commerical

Equipment and Supplies

4235 Metals and Minerals, ex. Petroleum

4236 Electrical Goods

4237 Hardware, and Plumbing and

Heating Equipment and Supplies

4238 Machinery, Equipment, and

Supplies

4239 Miscellaneous Durable Goods

4246 Chemicals and Allied Products

4249 Miscellaneous Nondurable Goods

Source: U.S. Census 2010b

As indicated in Figure 7-1 between January 1993 and September 2010, the simple 12-

month moving average for inventory/sales ratios ranged from 1.13 (NAICS 4246) to 2.33 (NAICS 

4238). 

7.2.3 Purchases 

Table 7-5 presents the estimated value of purchases for potentially affected 4-digit 

NAICS groups between 2002 and 2008 and Figure 7-2 presents this information graphically. 
Market Profile of the Composite Wood Products Industry 121

e 7-5: Estimated Annual Value of Purchases for Wholesalers, excluding Manufacturers' Sales Branches and Offices, 20 

ons, current$)

1

Description 2002 2003 2004 2005 2006 2007

Furniture and 

Home 

Furnishings

$36,919 $38,309 $41,902 $44,676 $48,842 $48,992

Lumber & Other 

Construction 

Materials

$76,077 $84,334 $102,930 $110,930 $112,097 $97,152

Professional and 

Commercial 

Equipment and 

Supplies

$202,784 $205,351 $227,991 $240,599 $255,990 $275,195

Metals and 

Minerals, ex. 

Petroleum

$66,160 $66,563 $99,644 $112,175 $132,768 $136,765

Electrical Goods $174,135 $182,633 $209,839 $223,660 $248,371 $268,631

Hardware, and 

Plumbing and 

Heating 

Equipment and 

Supplies

$49,934 $52,396 $60,979 $68,357 $78,020 $79,512

Machinery, 

Equipment, and 

Supplies

$166,452 $168,109 $191,545 $210,926 $230,785 $236,982

Miscellaneous 

Durable Goods $109,731 $110,502 $136,919 $143,276 $160,317 $177,051

Chemicals and 

Allied Products $50,913 $53,593 $60,794 $70,545 $71,773 $78,663

Miscellaneous 

Nondurable 

Goods

$127,631 $127,582 $145,524 $152,396 $155,234 $161,551

) All estimates have been adjusted using the preliminary results of the 2007 Economic Census. 

U.S. Census 2010c
Market Profile of the Composite Wood Products Industry 122

Figure 7-2: Estimated Value of Purchases, 2002-2008

0

50,000

100,000

150,000

200,000

250,000

300,000

20022003

200420052006

2007

2008

Year

$Millions

4232 Furniture and Home Furnishings

4233 Lumber & Other Construction

Materials

4234 Professional and Commercial

Equipment and Supplies

4235 Metals and Minerals, ex. Petroleum

4236 Electrical Goods

4237 Hardware, and Plumbing and

Heating Equipment and Supplies

4238 Machinery, Equipment, and

Supplies

4239 Miscellaneous Durable Goods

4246 Chemicals and Allied Products

4249 Miscellaneous Nondurable Goods

Source: U.S. Census 2010c

As indicated in Table 7-5 and Figure 7-2, in 2008 the estimated value of purchases in the 

potentially affected wholesale trade NAICS ranged from $45.5 billion (NAICS 4232) to $272.7 

billion (NAICS 4234). Between 2002 and 2008, the estimated value of purchases increased from 

between 11 percent (NAICS 4233) to 75 percent (NAICS 4239). 

7.2.4 Gross Margins 

Gross margins represents total sales less the cost of the good sold. Table 7-6 presents 

the estimated value of gross margins for wholesalers between 2002 and 2008, by 4-digit NAICS, 

and Figure 7-3 presents this information graphically.
Market Profile of the Composite Wood Products Industry 123

ble 7-6: Estimated Value of Gross Margins for Wholesalers, excluding Manufacturers' Sales Branches and Offices, 200 

llions, current$)

1

CS Description 2002 2003 2004 2005 2006 2007

2 Furniture and Home 

Furnishings $16,897 $17,507 $18,103 $18,735 $20,708 $20,133

3

Lumber & Other 

Construction 

Materials

$19,466 $22,465 $27,648 $29,445 $30,841 $28,626

4

Professional and 

Commercial 

Equipment and 

Supplies

$70,165 $70,885 $77,248 $75,758 $76,579 $79,113

5

Metals and 

Minerals, ex. 

Petroleum

$15,694 $14,750 $28,014 $24,496 $30,380 $23,762

6 Electrical Goods $47,547 $49,710 $57,780 $62,313 $75,089 $80,200

7

Hardware, and 

Plumbing and 

Heating Equipment 

and Supplies

$20,596 $22,645 $24,955 $28,251 $32,185 $32,871

8

Machinery, 

Equipment, and 

Supplies

$58,692 $60,850 $73,506 $83,186 $86,907 $92,209

9 Miscellaneous 

Durable Goods $35,521 $38,833 $46,403 $43,501 $45,076 $50,449

6 Chemicals and 

Allied Products $17,254 $17,127 $18,187 $20,169 $20,870 $24,976

9 Miscellaneous 

Nondurable Goods $33,127 $32,515 $35,683 $35,287 $35,356 $42,764

s: 1) All estimates have been adjusted using the preliminary results of the 2007 Economic Census. 

ce: U.S. Census 2010c
Market Profile of the Composite Wood Products Industry 124

Figure 7-3: Estimated Value of Gross Margins, 2002-2008

0

20,000

40,000

60,000

80,000

100,000

120,000

2002200320042005200620072008

Year

$Millions

4232 Furniture and Home Furnishings

4233 Lumber & Other Construction Materials

4234 Professional and Commercial Equipment

and Supplies

4235 Metals and Minerals, ex. Petroleum

4236 Electrical Goods

4237 Hardware, and Plumbing and Heating

Equipment and Supplies

4238 Machinery, Equipment, and Supplies

4239 Miscellaneous Durable Goods

4246 Chemicals and Allied Products

4249 Miscellaneous Nondurable Goods

Source: U.S. Census 2010c

As indicated in Table 7-6 and Figure 7-3 in 2008 the estimated value of gross margins in 

the potentially affected wholesale trade NAICS ranged from $18.3 billion (NAICS 4232) to $101.3 

billion (NAICS 4238). Between 1998 and 2008, the estimated value of purchases increased from 

between 8 percent (NAICS 4232) to 99 percent (NAICS 4235). 

7.3 Industry Organization

The following section describes the organization of the potentially affected wholesale 

trade industries. Information is presented on:

• The industry structure

• The characteristics of the facilities 

In addition, this section provides detailed information about facilities and firms that are 

key inputs to the economic analysis.

7.3.1 U.S. Census Data on Industry Structure

Table 7-7 presents m-firm concentration ratios for the potentially affected wholesale 

trade industries in 2002.24 M-firm concentration ratios are equal to the sum of the market 

shares for the largest m number of firms in the industry; the higher the ratio the more 

concentrated the industry. A market is generally considered highly concentrated if the 4-firm 

concentration ratio is greater than 50 percent. 

 24 As of November 18 2010, data from the 2007 Economic Census had not been released.
Market Profile of the Composite Wood Products Industry 125
Market Profile of the Composite Wood Products Industry 126

Table 7-7: m-firm Concentration Ratios for Wholesalers, excluding Manufacturers' Sales Branches and 

Offices, 2002

NAICS Description

Number of 

Establishments 

in Industry

m-firm Concentration Ratio (Percent)

4 

Firms

8 

Firms

20 

Firms

50 

Firms

423210 Furniture merchant 

wholesalers 5,995 8.2% 12.2% 19.5% 30.2%

423220 Home furnishing merchant 

wholesalers 7,804 6.7% 10.5% 17.0% 27.6%

423310

Lumber, plywood, millwork, 

and wood panel merchant 

wholesalers

8,366 14.4% 21.7% 28.8% 37.9%

423320

Brick, stone, and related 

construction material 

merchant wholesale

3,022 16.0% 21.3% 29.0% 39.6%

423330

Roofing, siding, and 

insulation material 

merchant wholesalers

2,351 26.3% 34.5% 47.6% 62.9%

423390 Other construction material 

merchant wholesalers 2,911 8.6% 13.7% 24.2% 36.1%

423440

Other commercial 

equipment merchant 

wholesalers

4,715 9.8% 17.1% 25.6% 35.9%

423450 Medical equipment 

merchant wholesalers 7,608 30.9% 44.3% 57.7% 65.6%

423490

Other professional 

equipment and supplies 

merchant wholesalers

2,546 D D D D

423510

Metal service centers and 

other metal merchant 

wholesalers

9,741 9.7% 16.2% 26.8% 39.2%

423610 Elec. equip. and wiring 

merchant wholesalers 12,482 18.4% 25.2% 34.1% 42.9%

423620 Electric appliance merchant 

wholesalers 2,989 29.3% 41.5% 59.0% 71.7%

423710 Hardware merchant 

wholesalers 6,659 21.1% 26.3% 34.9% 46.1%

423720 Plumbing equip. merchant 

wholesalers 5,281 20.6% 27.2% 35.5% 45.7%

423730 HVAC equip. merchant 

wholesalers 5,180 15.5% 22.4% 32.4% 44.1%

423740

Refrigeration equipment 

and supplies merchant 

wholesalers

1,332 24.2% 34.9% 49.5% 63.3%

423830

Industrial machinery and 

equipment merchant 

wholesalers

29,843 6.0% 8.3% 12.9% 19.2%

423850

Service establishment 

equipment and supplies 

merchant wholesalers

5,527 D D D D

423910

Sporting and recreational 

goods and supplies 

merchant wholesalers

5,413 10.3% 14.5% 23.4% 36.1%

424610

Plastics materials and basic 

forms and shapes merchant 

wholesaler

3,242 10.5% 16.4% 26.7% 39.1%

424950 Paint, varnish, and supplies 2,041 14.4% 21.6% 34.4% 50.6%
Market Profile of the Composite Wood Products Industry 127

merchant wholesalers

Notes: 1) "D" is used to indicate that the data have been withheld to avoid disclosure.

Source: U.S. Census 2005d

As indicated in Table 7-7, the 4-firm concentration ratios of the potentially affected 

wholesale trade industries ranged from 6.0 percent (NAICS 423830) to 30.9 percent (NAICS 

423450) in 2002. None of the potentially affected wholesale trade industries had 4-firm 

concentration ratios greater than 50 percent; as a result, none can be classified as highly 

concentrated. Data were withheld for NAICS 42340 and 423850 to avoid disclosure.

7.3.1.1 Establishment Employment

Table 7-8 summarizes the employment statistics for the potentially affected employer 

establishments in the wholesale trade industries in 2007. These statistics do not include nonemployer establishments.
Market Profile of the Composite Wood Products Industry 128

Table 7-8: Summary of Employment Statistics for Wholesaler Employer Establishments, excluding 

Manufacturers' Sales Branches and Offices, 2007

NAICS Description Total 

Establishments

Total 

Employees

Average 

Employees 

Per 

Establishment

Total Payroll 

(thousands, 

2007$)

423210 Furniture merchant 

wholesalers 6,640 69,103 10.4 $3,159,816

423220 Home furnishing 

merchant wholesalers 7,540 93,060 12.3 $4,181,919

423310

Lumber, plywood, 

millwork, and wood 

panel merchant 

wholesalers

8,428 138,739 16.5 $6,265,545

423320

Brick, stone, and related 

construction material 

merchant wholesale

3,383 35,005 10.3 $1,512,862

423330

Roofing, siding, and 

insulation material 

merchant wholesalers

2,587 32,662 12.6 $1,557,069

423390

Other construction 

material merchant 

wholesalers

3,383 37,920 11.2 $1,694,939

423410

Photographic equipment 

and supplies merchant 

wholesalers

1,019 D D D

423420 Office equipment 

merchant wholesalers 4,837 105,207 21.8 $5,668,065

423430 Computer and software 

merchant wholesalers 10,668 193,273 18.1 $15,126,360

423440

Other commercial 

equipment merchant 

wholesalers

4,352 48,976 11.3 $2,250,869

423450 Medical equipment 

merchant wholesalers 8,282 141,282 17.1 $10,259,277

423490

Other professional 

equipment and supplies 

merchant wholesalers

2,297 D D D

423510

Metal service centers 

and other metal 

merchant wholesalers

10,148 144,954 14.3 $7,943,294

423610 Elec. equip. and wiring 

merchant wholesalers 13,277 169,355 12.8 $9,570,001

423620 Electric appliance 

merchant wholesalers 3,110 44,819 14.4 $2,561,797

423690

Other electronic parts 

and equipment 

merchant wholesalers

13,223 226,840 17.2 $18,284,664

423710 Hardware merchant 

wholesalers 6,828 83,542 12.2 $3,840,341

423720 Plumbing equip. 

merchant wholesalers 6,939 86,092 12.4 $4,441,190

423730 HVAC equip. merchant 

wholesalers 5,071 50,495 10.0 $2,547,025

423740

Refrigeration equipment 

and supplies merchant 

wholesalers

1,265 11,024 8.7 $531,410
Market Profile of the Composite Wood Products Industry 129

Table 7-8: Summary of Employment Statistics for Wholesaler Employer Establishments, excluding 

Manufacturers' Sales Branches and Offices, 2007

NAICS Description Total 

Establishments

Total 

Employees

Average 

Employees 

Per 

Establishment

Total Payroll 

(thousands, 

2007$)

423810 Construction equipment 

merchant wholesalers 4,694 94,571 20.1 $5,317,183

423820

Farm and garden 

machinery and 

equipment merchant 

wholesalers

8,320 D D D

423830

Industrial machinery and 

equipment merchant 

wholesalers

29,838 319,557 10.7 $17,151,437

423840 Industrial supplies 

merchant wholesalers 8,361 87,012 10.4 $4,420,478

423850

Service establishment 

equipment and supplies 

merchant wholesalers

4,576 D D D

423910

Sporting and 

recreational goods and 

supplies merchant 

wholesalers

6,192 55,842 9.0 $2,487,901

423920

Toy and hobby goods 

and supplies merchant 

wholesalers

2,497 D D D

423930 Recyclable material 

merchant wholesalers 7,377 104,671 14.2 $4,451,467

423940 Jewelry merchant 

wholesalers 7,792 D D D

423990

Other miscellaneous 

durable goods merchant 

wholesalers

10,185 94,341 9.3 $4,047,480

424110

Printing and writing 

paper merchant 

wholesalers

1,174 17,434 14.9 $1,041,390

424120

Stationery and office 

supplies merchant 

wholesalers

5,513 65,234 11.8 $2,899,372

424130

Industrial and personal 

service paper merchant 

wholesalers

4,679 63,049 13.5 $3,283,911

424210

Drugs and druggists' 

sundries merchant 

wholesalers

8,040 159,693 19.9 $9,857,347

424310

Piece goods, notions, 

and other dry goods 

merchant wholesalers

3,445 29,877 8.7 $1,349,274

424320

Men's and boys' clothing 

and furnishings 

merchant wholesalers

4,204 65,295 15.5 $3,046,634

424330

Women's and children's 

clothing merchant 

wholesalers

7,650 101,804 13.3 $5,004,734

424340 Footwear merchant 

wholesalers 1,649 30,387 18.4 $1,916,453
Market Profile of the Composite Wood Products Industry 130

Table 7-8: Summary of Employment Statistics for Wholesaler Employer Establishments, excluding 

Manufacturers' Sales Branches and Offices, 2007

NAICS Description Total 

Establishments

Total 

Employees

Average 

Employees 

Per 

Establishment

Total Payroll 

(thousands, 

2007$)

424410 General line grocery 

merchant wholesalers 2,547 128,987 50.6 $6,184,978

424420 Packaged frozen food 

merchant wholesalers 3,282 80,289 24.5 $3,568,884

424450 Confectionery merchant 

wholesalers 1,938 21,576 11.1 $791,092

424460 Fish and seafood 

merchant wholesalers 2,012 D D D

424480 Fresh fruit and vegetable 

merchant wholesalers 5,074 104,749 20.6 $4,155,569

424490

Other grocery and 

related products 

merchant wholesalers

10,562 D D D

424510 Grain and field bean 

merchant wholesalers 4,851 47,574 9.8 $2,082,359

424610

Plastics materials and 

basic forms and shapes 

merchant wholesaler

3,248 32,552 10.0 $1,718,840

424690

Other chemical and 

allied products merchant 

wholesalers

8,530 83,959 9.8 $5,010,893

424910 Farm supplies merchant 

wholesalers 7,432 73,914 9.9 $3,192,537

424920

Book, periodical, and 

newspaper merchant 

wholesalers

2,644 59,604 22.5 $2,044,015

424930

Flower, nursery stock, & 

florists' supplies 

merchant wholesalers

4,213 D D D

424940

Tobacco and tobacco 

product merchant 

wholesalers

1,305 48,343 37.0 $1,768,529

424950

Paint, varnish, and 

supplies merchant 

wholesalers

1,649 14,631 8.9 $649,166

424990

Other miscellaneous 

nondurable goods 

merchant wholesalers

12,492 D D D

Total 321,242 3,697,293 11.5 $198,838,366

Notes: 1) "D" is used to indicate that the data have been withheld to avoid disclosure.

Source: U.S. Census 2010h

As indicated in Table 7-8, the potentially affected wholesale trade industries were 

composed of 321,242 employer establishments that employed over 3.6 million people (or about 

12 employees per establishment) and had total payroll amounting to over 198 billion dollars.25 

 25 Data were withheld for the following NAICS to avoid disclosure: 423410, 423490, 423820, 423850, 423920, 423940, 

424460, 424490, 424930, 424990.
Market Profile of the Composite Wood Products Industry 131

Note that these figures reflect all employer establishments in these NAICS codes. Not all of 

these establishments will be affected by the rule because not all entities in these industries sell

composite wood products. Of the potentially affected wholesale trade industries, NAICS 423830 

had the most employer establishments (29,838) and employees (319,557; NAICS 423690 had 

the largest payroll (over $18 billion dollars).
Market Profile of the Composite Wood Products Industry 132

8 Composite Wood Product Retailers

This section presents information on the value of sales, payroll and industry 

organization for the retail establishments that sell products containing composite wood. Note 

that the industry categories as defined by NAICS are likely to include some retailers that are not 

subject to any requirements under the proposed TSCA Title VI rule. 

NAICS codes for the potentially affected retail trade industries were indentified through 

a review of information reported by the U.S. Census Bureau. 

Section 8.1 presents information on the value of sales by industry and product type. 

Section 8.2 describes industry payroll costs. Section 8.3 summarizes the industry organization 

for the composite wood product wholesalers.

8.1 Value of Sales

Table 8-1 shows the value of products sold in the potentially affected retail industries by 

product type.
Market Profile of the Composite Wood Products Industry 133

Table 8-1: Value of Sales by Industry for Retail, 2007$

NAICS 

Code

NAICS 

Description Product

Value of 

Sales

44121

Recreational 

Vehicle 

Dealers

New camping trailers, including collapsible $681,131 

New travel trailers, including 5th wheel $5,161,319 

New motor homes $5,511,601 

New travel trailers, including 5th wheel $5,161,319 

Manufactured (mobile) homes, excluding 

modular homes $43,055 

Utility trailers, including horse/livestock trailers $40,366 

Products without Composite Wood Products $3,250,372 

Industry Total $19,220,735 

44221 Floor Covering 

Stores

Furniture, sleep equipment & outdoor/patio 

furniture $71,330 

other hard-surface floor coverings & accessories $3,996,081 

Dimensional lumber & oth bldg/structural 

materials & supplies $201,404 

Products without Composite Wood Products $16,709,338 

Industry Total $20,979,750 

44229

All Other 

Home 

Furnishings 

Stores

Furniture, sleep equipment & outdoor/patio 

furniture $2,078,067 

other hard-surface floor coverings & accessories $25,318 

Dimensional lumber & oth bldg/structural 

materials & supplies $325,948 

Products without Composite Wood Products $26,404,189 

Industry Total $28,834,338 

443112

Radio, TV, and 

Other 

Electronics

Furniture, sleep equipment & outdoor/patio 

furniture $384,993 

Flooring & floor coverings $1,351 

Products without Composite Wood Products $67,212,492 

Industry Total $67,599,235 

44312

Computer and 

Software 

Stores

Furniture, sleep equipment & outdoor/patio 

furniture $2,492 

Dimensional lumber & oth bldg/structural 

materials & supplies $130 

Products without Composite Wood Products $20,055,231 

Industry Total $20,064,021 

44411 Home Centers

Furniture, sleep equipment & outdoor/patio 

furniture $1,420,821 

other hard-surface floor coverings & accessories $4,934,253 

Boards, all grades $1,517,400 

Engineered wood products, incl glue-lam, LVL, 

etc $270,519 

Structural panels, incl softwood plywood, & OSB $1,649,428 

Oth panel products, incl hardwood plywood, 

waferboard, etc $876,187 

Doors & moulding $6,567,706 

Windows, skylights, & patio doors $2,202,930 

Kitchen & bath cabinets & countertops $9,870,715 

Products without Composite Wood Products $100,962,572 

Industry Total $134,547,396 

44413 Hardware 

Stores

Furniture, sleep equipment & outdoor/patio 

furniture $159,539 

other hard-surface floor coverings & accessories $18,302 

RVs, incl camping & travel trailers, campers, 

parts & accessories $1,204 
Market Profile of the Composite Wood Products Industry 134

Table 8-1: Value of Sales by Industry for Retail, 2007$

NAICS 

Code

NAICS 

Description Product

Value of 

Sales

Boards, all grades $37,207 

Gypsum, specialty boards, & treatments $46,916 

Engineered wood products, incl glue-lam, LVL, 

etc $6,482 

Structural panels, incl softwood plywood, & OSB $24,892 

Oth panel products, incl hardwood plywood, 

waferboard, etc $27,066 

Doors & moulding $132,510 

Windows, skylights, & patio doors $27,340 

Kitchen & bath cabinets & countertops $85,680 

Products without Composite Wood Products $19,499,466 

Industry Total $20,067,407 

44419

Other Building 

Material 

Dealers

Furniture, sleep equipment & outdoor/patio 

furniture $102,693 

other hard-surface floor coverings & accessories $3,568,379 

Boards, all grades $2,016,542 

Gypsum, specialty boards, & treatments $3,139,924 

Engineered wood products, incl glue-lam, LVL, 

etc $2,028,242 

Structural panels, incl softwood plywood, & OSB $2,958,413 

oth panel products, incl hardwood plywood, 

waferboard, etc $1,868,350 

Doors & moulding $7,705,336 

Windows, skylights, & patio doors $6,748,045 

Kitchen & bath cabinets & countertops $7,422,340 

Manufactured (mobile) homes, excluding 

modular homes $426 

Products without Composite Wood Products $80,917,307 

Industry Total $118,480,605 

452111

Department 

Stores 

excluding 

Discount

Upholstered furniture $402,408 

Sleep equipment, incl mattresses, springs, cots, 

waterbeds, etc $709,657 

oth living room, dining room, bedroom 

furniture, incl headboards $306,888 

All oth furniture, incl outdoor, office, computerrelated, kitchen $379,922 

Flooring & floor coverings $89,361 

Products without Composite Wood Products $76,351,557 

Industry Total $77,705,181 

452112

Discount 

Department 

Stores

Upholstered furniture $3,377 

Sleep equipment, incl mattresses, springs, cots, 

waterbeds, etc $76,751 

oth living room, dining room, bedroom 

furniture, incl headboards $617,398 

All oth furniture, incl outdoor, office, computerrelated, kitchen $965,868 

other hard-surface floor coverings & accessories $15,440 

Dimensional lumber & oth bldg/structural 

materials & supplies $39,731 

Products without Composite Wood Products $130,718,604 

Industry Total $132,437,186 

45291 Warehouse Upholstered furniture $204,192 
Market Profile of the Composite Wood Products Industry 135

Table 8-1: Value of Sales by Industry for Retail, 2007$

NAICS 

Code

NAICS 

Description Product

Value of 

Sales

Clubs and 

Supercenters

Sleep sofas, daybeds, futons, & other dualpurpose pieces $3,065 

Sleep equipment, incl mattresses, springs, cots, 

waterbeds, etc $624,768 

oth living room, dining room, bedroom 

furniture, incl headboards $469,083 

All oth furniture, incl outdoor, office, computerrelated, kitchen $1,466,589 

other hard-surface floor coverings & accessories $6,577 

Products without Composite Wood Products $322,186,345 

Industry Total $324,962,891 

45299

All Other 

General 

Merchandise 

Stores

Upholstered furniture $523,560 

Sleep sofas, daybeds, futons, & other dualpurpose pieces $5,441 

Sleep equipment, incl mattresses, springs, cots, 

waterbeds, etc $175,784 

oth living room, dining room, bedroom 

furniture, incl headboards $613,927 

All oth furniture, incl outdoor, office, computerrelated,kitchen $307,200 

other hard-surface floor coverings & accessories $82,069 

RVs, incl camping & travel trailers, campers, 

parts & accessories $1,955 

Dimensional lumber & oth bldg/structural 

materials & supplies $63,129 

Products without Composite Wood Products $41,129,109 

Industry Total $42,902,440 

45321

Office Supply 

and Stationary 

Stores

Furniture, sleep equipment & outdoor/patio 

furniture $1,861,178 

Products without Composite Wood Products $20,863,380 

Industry Total $22,725,012 

45393

Manufactured 

(Mobile) Home 

Dealer

Furniture, sleep equipment & outdoor/patio 

furniture $2,182 

RVs, incl camping & travel trailers, campers, 

parts & accessories $21,577 

Dimensional lumber & oth bldg/structural 

materials & supplies $6,465 

New single-section manuf (mobile) homes, less 

than 14 ft wide $60,049 

New single-section manuf (mobile) homes, 14 ft 

wide $221,268 

New single-section manuf (mobile) homes, more 

than 14 ft wide $1,080,641 

New multisection manuf (mobile) homes, two 

sections $4,981,852 

New multisection manuf (mobile) homes, three 

or more sections $601,420 

Other new manufactured (mobile) homes & 

parts & accessories $113,477 

Used single-section manufactured (mobile) 

homes $388,408 

Used multisection manufactured (mobile) 

homes $341,209 

Products without Composite Wood Products $261,354 
Market Profile of the Composite Wood Products Industry 136

Table 8-1: Value of Sales by Industry for Retail, 2007$

NAICS 

Code

NAICS 

Description Product

Value of 

Sales

Industry Total $8,081,437 

4421

Upholstered furniture $15,442,607 

Sleep sofas, daybeds, futons, & other dualpurpose pieces $1,667,339 

Oth living room, dining room, bedroom 

furniture, incl headboards $16,081,470 

Office furniture, including computer-related 

furniture $3,119,384 

Outdoor/patio furniture $1,113,222 

All other furniture, including kitchen, dinette, 

etc. $3,953,474 

Flooring & floor coverings $742,347 

Other hard-surface floor coverings & accessories $69,936 

Kitchenware & home furnishings $1,085,430 

Decorative accessories, incl lamps, lampshades, 

mirrors, etc $1,008,074 

All other kitchenware & home furnishings $77,356 

Products without Composite Wood Products $13,629,811 

Industry Total $57,990,450 

443111

Household 

appliance 

stores

Furniture, sleep equipment & outdoor/patio 

furniture $329,750 

Flooring & floor coverings $79,733 

Kitchenware & home furnishings $261,881 

Products without Composite Wood Products $16,775,724 

Industry Total $17,447,088 

44412

Paint and 

wallpaper 

stores

Furniture, sleep equipment & outdoor/patio 

furniture $2,011 

Flooring & floor coverings $112,420 

Kitchenware & home furnishings $5,631 

Boards, all grades $260 

Engineered wood products, incl glue-lam, LVL, 

etc $792 

Oth panel products, incl hardwood plywood, 

waferboard, etc $226 

Bldg components, incl floor trusses, roof trusses, 

etc $34 

Doors & moulding $3,135 

Windows, skylights, & patio doors $6,135 

Kitchen & bath cabinets & countertops $1,920 

Products without Composite Wood Products $9,922,880 

Industry Total $10,055,444 

44421

Outdoor 

power 

equipment 

stores

Furniture, sleep equipment & outdoor/patio 

furniture $2,597 

Kitchenware & home furnishings $2,770 

RVs, incl camping & travel trailers, campers, 

parts & accessories $78,778 

Products without Composite Wood Products $5,687,087 

Industry Total $5,771,232 

44422

Nursery, 

garden center, 

and farm 

supply stores

Furniture, sleep equipment & outdoor/patio 

furniture $180,733 

Kitchenware & home furnishings $226,263 

RVs, incl camping & travel trailers, campers, 

parts & accessories $13,730 
Market Profile of the Composite Wood Products Industry 137

Table 8-1: Value of Sales by Industry for Retail, 2007$

NAICS 

Code

NAICS 

Description Product

Value of 

Sales

Products without Composite Wood Products $30,722,502 

Industry Total $31,143,228 

44511

Supermarkets 

and other 

grocery 

(except 

convenience) 

stores

Kitchenware & home furnishings $1,319,786 

Products without Composite Wood Products $465,044,903 

Industry Total $466,364,689 

44811 Men's clothing 

stores

Furniture, sleep equipment & outdoor/patio 

furniture $173 

Kitchenware & home furnishings $16,610 

Products without Composite Wood Products $8,634,376 

Industry Total $8,651,159 

44812 Women's 

clothing stores

Furniture, sleep equipment & outdoor/patio 

furniture $27,058 

Kitchenware & home furnishings $234,110 

Products without Composite Wood Products $38,952,883 

Industry Total $39,214,051 

44813

Children's and 

infants' 

clothing stores

Furniture, sleep equipment & outdoor/patio 

furniture $507,303 

Kitchenware & home furnishings $27,781 

Products without Composite Wood Products $8,756,174 

Industry Total $9,291,258 

44814 Family clothing 

stores

Furniture, sleep equipment & outdoor/patio 

furniture $372,295 

Flooring & floor coverings $840 

Kitchenware & home furnishings $1,745,504 

Products without Composite Wood Products $81,919,355 

Industry Total $84,037,994 

44815

Clothing 

accessories 

stores

Furniture, sleep equipment & outdoor/patio 

furniture $282 

Kitchenware & home furnishings $17,732 

Products without Composite Wood Products $5,629,088 

Industry Total $5,647,102 

44819 Other clothing 

stores

Kitchenware & home furnishings $1,340 

Products without Composite Wood Products $10,872,300 

Industry Total $10,873,640 

44831 Jewelry stores

Furniture, sleep equipment & outdoor/patio 

furniture $1,757 

Kitchenware & home furnishings $454,454 

Products without Composite Wood Products $28,826,178 

Industry Total $29,282,389 

45111 Sporting goods 

stores

Furniture, sleep equipment & outdoor/patio 

furniture $33,856 

Kitchenware & home furnishings $68,662 

Products without Composite Wood Products $34,229,605 

Industry Total $34,332,123 

45112

Hobby, toy, 

and game 

stores

Furniture, sleep equipment & outdoor/patio 

furniture $194,416 

Kitchenware & home furnishings $1,729,314 

Products without Composite Wood Products $13,688,176 

Industry Total $15,611,906 
Market Profile of the Composite Wood Products Industry 138

Table 8-1: Value of Sales by Industry for Retail, 2007$

NAICS 

Code

NAICS 

Description Product

Value of 

Sales

45113

Sewing, 

needlework, 

and piece 

goods stores

Furniture, sleep equipment & outdoor/patio 

furniture $50,080 

Kitchenware & home furnishings $77,275 

Products without Composite Wood Products $3,901,592 

Industry Total $4,028,947 

4531 Florists

Furniture, sleep equipment & outdoor/patio 

furniture $12,802 

Kitchenware & home furnishings $221,515 

Products without Composite Wood Products $6,040,999 

Industry Total $6,275,316 

45322

Gift, novelty, 

and souvenir 

stores

Furniture, sleep equipment & outdoor/patio 

furniture $62,718 

Flooring & floor coverings $965 

Kitchenware & home furnishings $1,428,199 

Products without Composite Wood Products $14,652,036 

Industry Total $16,081,200 

45392 Art dealers

Furniture, sleep equipment & outdoor/patio 

furniture $24,802 

Kitchenware & home furnishings $35,093 

Products without Composite Wood Products $8,376,006 

Industry Total $8,435,901 

45399

All other 

miscellaneous 

store retailers

Furniture, sleep equipment & outdoor/patio 

furniture $288,841 

Kitchenware & home furnishings $785,967 

Products without Composite Wood Products $20,127,095 

Industry Total $21,201,903 

454113 Mail-order 

houses

Furniture, sleep equipment & outdoor/patio 

furniture $2,163,377 

Flooring & floor coverings $244,227 

Kitchenware & home furnishings $4,452,548 

Products without Composite Wood Products $124,402,611 

Industry Total $131,262,763 

45439

Other direct 

selling 

establishments

Furniture, sleep equipment & outdoor/patio 

furniture $762,808 

Flooring & floor coverings $1,304,226 

Kitchenware & home furnishings $1,711,807 

Products without Composite Wood Products $22,762,443 

Industry Total $26,541,284 

Source: U.S. Census 2009b

8.2 Retail Payroll and Sales 

Table 8-2 presents the value of annual payroll and sales for the potentially affected 

retail trade industries in 2007. 
Market Profile of the Composite Wood Products Industry 139

Table 8-2: Value of Annual Payroll and Sales for Retailers (thousands, 2007$)

NAICS NAICS Description Annual 

Payroll Sales

441210 Recreational vehicle dealers $1,671,075 $19,057,106

442110 Furniture stores $7,975,034 $58,172,947

442210 Floor covering stores $3,219,963 $21,174,151

442291 Window treatment stores $259,954 $1,546,007

442299 All other home furnishings stores $3,427,682 $27,326,976

443111 Household appliance stores $2,091,185 $17,501,247

443112 Radio, television, and other electronics stores $6,556,328 $67,643,822

443120 Computer and software stores $2,158,114 $19,972,963

444110 Home centers $13,507,517 $134,821,247

444120 Paint and wallpaper stores $1,262,492 $10,052,960

444130 Hardware stores $3,160,537 $20,130,557

444190 Other building material dealers $15,640,862 $116,866,222

444210 Outdoor power equipment stores $739,473 $5,740,482

444220 Nursery, garden center, and farm supply stores $3,399,110 $30,708,803

445110

Supermarkets and other grocery (except 

convenience) stores

$48,088,532 $466,225,948

448110 Men's clothing stores $1,364,692 $8,538,393

448120 Women's clothing stores $5,100,737 $39,463,349

448130 Children's and infants' clothing stores $1,049,016 $9,338,186

448140 Family clothing stores $9,444,412 $84,052,604

448150 Clothing accessories stores $716,830 $5,704,796

448190 Other clothing stores $1,590,895 $10,950,930

448310 Jewelry stores $4,167,145 $29,231,749

451110 Sporting goods stores $3,928,257 $34,490,779

451120 Hobby, toy, and game stores $1,802,386 $15,633,187

451130 Sewing, needlework, and piece goods stores $546,437 $4,017,787

452111

Department stores (except discount department 

stores)

$9,502,596 $76,886,578

452112 Discount department stores $12,710,286 $132,504,850

452910 Warehouse clubs and supercenters $27,855,313 $324,963,224

452990 All other general merchandise stores $4,345,360 $42,743,543

453110 Florists $1,400,307 $6,285,503

453210 Office supplies and stationery stores $2,356,843 $22,833,467

453220 Gift, novelty, and souvenir stores $2,543,692 $16,162,156

453920 Art dealers $984,855 $8,564,335

453930 Manufactured (mobile) home dealers $743,954 $8,121,994

453998

All other miscellaneous store retailers (except 

tobacco stores)

$2,194,660 $14,236,428

454113 Mail-order houses $9,033,008 $137,355,909

454390 Other direct selling establishments $4,115,212 $24,888,550

Notes: 1) Payroll includes all forms of compensation such as salaries, wages, commissions, dismissal pay, bonuses, vacation allowances, sickleave pay, and employee contributions to qualified pension plans paid during the year to all employees and reported on Internal Revenue 

Service (IRS) Form 941 as taxable Medicare Wages and tips (even if not subject to income or FICA tax).

Source: U.S. Census 2010d

As indicated in Table 8-2, in 2007 the value of annual payrolls for the potentially 

affected retail trade industries ranged from just under $260 million dollars to nearly $48.1 

billion, while the value of sales ranged from over $1.5 billion to just over $466.2 billion (NAICS 

442291 and 445110, respectively).
Market Profile of the Composite Wood Products Industry 140

8.3 Industry Organization

The following section describes the organization of the potentially affected retail trade 

industries. Information is presented on:

• The industry structure

• Employment

In addition, this section provides detailed information about facilities and firms that are 

key inputs to the economic analysis.

8.3.1 U.S. Census Data on Industry Structure

Table 8-3 presents m-firm concentration ratios for the potentially affected retail trade 

industries in 2007. M-firm concentration ratios are equal to the sum of the market shares for 

the largest m number of firms in the industry; the higher the ratio the more concentrated the 

industry. A market is generally considered highly concentrated if the 4-firm concentration ratio 

is greater than 50 percent. 
Market Profile of the Composite Wood Products Industry 141

Table 8-3: m-firm Concentration Ratios for Retailers, 2007

NAICS Description

Number of 

Establishments 

in Industry

m-firm Concentration Ratio (Percent)

4 

Firms

8 

Firms

20 

Firms

50 

Firms

441210 Recreational vehicle dealers 3,100 14.6% 19.1% 27.1% 36.2%

442110 Furniture stores 28,834 13.7% 19.0% 28.1% 37.1%

442210 Floor covering stores 14,534 2.9% 4.4% 7.2% 11.3%

442291 Window treatment stores 2,652 16.7% 20.6% 25.3% 33.1%

442299 All other home furnishings 

stores 19,124 48.8% 60.9% 72.5% 76.3%

443111 Household appliance stores 9,336 21.3% 27.6% 32.9% 39.9%

443112 Radio, television, and other 

electronics stores 29,051 70.0% 74.2% 78.6% 81.2%

443120 Computer and software 

stores 10,428 73.1% 77.2% 79.1% 81.4%

444110 Home centers 6,953 92.7% 93.0% 93.7% 94.5%

444120 Paint and wallpaper stores 7,860 59.7% 69.0% 73.7% 77.1%

444130 Hardware stores 16,454 19.5% 22.7% 26.6% 30.3%

444190 Other building material 

dealers 39,551 9.5% 12.6% 17.0% 21.5%

444210 Outdoor power equipment 

stores 4,357 4.7% 7.1% 11.6% 17.9%

444220 Nursery, garden center, and 

farm supply stores 15,895 14.5% 17.5% 21.5% 26.8%

445110

Supermarkets and other 

grocery (except 

convenience) stores

64,881 32.0% 45.6% 58.8% 70.2%

448110 Men's clothing stores 8,321 33.0% 40.5% 49.6% 56.1%

448120 Women's clothing stores 36,220 23.7% 37.8% 59.0% 74.9%

448130 Children's and infants' 

clothing stores 7,102 62.2% 80.7% 85.4% 88.9%

448140 Family clothing stores 28,254 45.4% 58.0% 75.4% 88.4%

448150 Clothing accessories stores 7,494 61.6% 71.9% 76.5% 79.4%

448190 Other clothing stores 12,034 44.1% 48.9% 55.0% 60.2%

448310 Jewelry stores 27,745 24.5% 30.9% 37.5% 43.5%

451110 Sporting goods stores 22,254 29.3% 41.0% 52.1% 56.3%

451120 Hobby, toy, and game 

stores 9,357 71.9% 78.7% 81.7% 83.4%

451130 Sewing, needlework, and 

piece goods stores 5,663 59.4% 61.1% 63.9% 67.1%

452111

Department stores (except 

discount department 

stores)

3,533 81.4% 96.9% D 100.0%

452112 Discount department stores 5,001 96.9% 99.9% 100.0% 100.0%

452910 Warehouse clubs and 

supercenters 4,260 93.9% 99.9% 100.0% 100.0%

452990 All other general 

merchandise stores 33,061 59.2% 68.6% 79.4% 84.3%

453110 Florists 19,822 2.1% 2.9% 4.5% 7.1%

453210 Office supplies and 

stationery stores 9,558 80.3% 81.2% 82.4% 84.0%

453220 Gift, novelty, and souvenir 

stores 31,391 12.4% 19.8% 26.9% 33.3%

453920 Art dealers 6,677 13.4% 18.8% 28.6% 39.8%

453930 Manufactured (mobile) 

home dealers 3,878 26.1% 29.2% 33.1% 39.2%
Market Profile of the Composite Wood Products Industry 142

453998

All other miscellaneous 

store retailers (except 

tobacco stores)

17,270 7.3% 10.1% 14.8% 20.3%

454113 Mail-order houses 7,324 33.9% 46.7% 59.4% 71.7%

454390 Other direct selling 

establishments 22,077 13.3% 20.1% 28.8% 34.6%

Notes: 1) "D" is used to indicate that the data have been withheld to avoid disclosure.

Source: U.S. Census 2005c

As indicated in Table 8-3, the 4-firm concentration ratios of the potentially affected 

retail trade industries ranged from 2.1 percent (NAICS 453110) to 96.9 percent (NAICS 452112). 

In fact, 13 of the 37 industries had 4-firm concentration ratios greater than 50 percent, 

indicating highly concentrated markets.

8.3.2 U.S. Census Data on Employment

Table 8-4 summarizes the employment statistics for the potentially affected employer 

establishments in the retail trade industries in 2007. These statistics do not reflect nonemployer establishments.
Market Profile of the Composite Wood Products Industry 143

Table 8-4: Summary of Employment Statistics for Retailer Employer Establishments, 2007

NAICS Description Total 

Establishments

Total 

Employees

Average 

Employees 

Per 

Establishment

Total 

Payroll 

(thousands, 

2007$)

441110 New car dealers 24,888 1,138,370 45.7 50,148,097

441210 Recreational vehicle dealers 3,100 42,669 13.8 1,671,075

441221 Motorcycle, ATV, and 

personal watercraft dealers 6,137 70,561 11.5 2,362,545

441229 All other motor vehicle 

dealers 2,266 13,414 5.9 457,349

441320 Tire dealers 20,127 173,907 8.6 5,582,498

442110 Furniture stores 28,834 266,374 9.2 7,975,034

442210 Floor covering stores 14,534 89,420 6.2 3,219,963

442291 Window treatment stores 2,652 9,626 3.6 259,954

442299 All other home furnishings 

stores 19,124 192,057 10.0 3,427,682

443111 Household appliance stores 9,336 70,045 7.5 2,091,185

443112 Radio, television, and other 

electronics stores 29,051 309,374 10.6 6,556,328

443120 Computer and software 

stores 10,428 92,777 8.9 2,158,114

443130 Camera and photographic 

supplies stores 1,988 14,287 7.2 414,039

444110 Home centers 6,953 579,442 83.3 13,507,517

444120 Paint and wallpaper stores 7,860 35,491 4.5 1,262,492

444130 Hardware stores 16,454 143,738 8.7 3,160,537

444190 Other building material 

dealers 39,551 405,755 10.3 15,640,862

444210 Outdoor power equipment 

stores 4,357 25,882 5.9 739,473

444220 Nursery, garden center, and 

farm supply stores 15,895 141,014 8.9 3,399,110

445110

Supermarkets and other 

grocery (except convenience) 

stores

64,881 2,432,425 37.5 48,088,532

445120 Convenience stores 25,510 118,787 4.7 1,808,358

445210 Meat markets 6,009 38,703 6.4 723,323

445220 Fish and seafood markets 2,063 10,012 4.9 196,921

445230 Fruit and vegetable markets 2,938 19,444 6.6 374,732

445291 Baked goods stores 4,290 18,250 4.3 275,927

445292 Confectionery and nut stores 3,404 18,030 5.3 233,252

445299 All other specialty food 

stores 5,504 30,256 5.5 362,468

445310 Beer, wine, and liquor stores 31,485 141,255 4.5 2,592,081

446110 Pharmacies and drug stores 42,045 814,836 19.4 22,385,345

446120 Cosmetics, beauty supplies, 

and perfume stores 13,584 86,278 6.4 1,392,792

446130 Optical goods stores 13,149 70,038 5.3 1,841,751

446191 Food (health) supplement 

stores 8,999 40,067 4.5 706,753

446199 All other health and personal 

care stores 10,675 56,967 5.3 2,088,296

447110 Gasoline stations with 

convenience stores 97,508 719,108 7.4 11,292,510

447190 Other gasoline stations 21,248 171,721 8.1 3,378,315
Market Profile of the Composite Wood Products Industry 144

Table 8-4: Summary of Employment Statistics for Retailer Employer Establishments, 2007

NAICS Description Total 

Establishments

Total 

Employees

Average 

Employees 

Per 

Establishment

Total 

Payroll 

(thousands, 

2007$)

448110 Men's clothing stores 8,321 57,340 6.9 1,364,692

448120 Women's clothing stores 36,220 339,798 9.4 5,100,737

448130 Children's and infants' 

clothing stores 7,102 98,729 13.9 1,049,016

448140 Family clothing stores 28,254 642,117 22.7 9,444,412

448150 Clothing accessories stores 7,494 37,575 5.0 716,830

448190 Other clothing stores 12,034 97,581 8.1 1,590,895

448210 Shoe stores 28,076 207,945 7.4 3,233,039

448310 Jewelry stores 27,745 155,492 5.6 4,167,145

448320 Luggage and leather goods 

stores 1,222 7,448 6.1 188,515

451110 Sporting goods stores 22,254 221,439 10.0 3,928,257

451120 Hobby, toy, and game stores 9,357 135,688 14.5 1,802,386

451130 Sewing, needlework, and 

piece goods stores 5,663 49,450 8.7 546,437

451140 Musical instrument and 

supplies stores 4,510 33,996 7.5 796,366

451211 Book stores 9,955 141,185 14.2 1,818,814

451212 News dealers and 

newsstands 1,523 8,301 5.5 138,873

451220 Prerecorded tape, compact 

disc, and record stores 4,153 29,016 7.0 434,786

452111 Department stores (except 

discount department stores) 3,533 534,189 151.2 9,502,596

452112 Discount department stores 5,001 690,265 138.0 12,710,286

452910 Warehouse clubs and 

supercenters 4,260 1,244,237 292.1 27,855,313

452990 All other general 

merchandise stores 33,061 294,783 8.9 4,345,360

453110 Florists 19,822 93,967 4.7 1,400,307

453210 Office supplies and 

stationery stores 9,558 112,734 11.8 2,356,843

453220 Gift, novelty, and souvenir 

stores 31,391 193,317 6.2 2,543,692

453910 Pet and pet supplies stores 8,782 101,538 11.6 1,597,465

453920 Art dealers 6,677 23,126 3.5 984,855

453930 Manufactured (mobile) home 

dealers 3,878 21,068 5.4 743,954

453991 Tobacco stores 6,539 26,158 4.0 416,796

453998

All other miscellaneous store 

retailers (except tobacco 

stores)

17,270 88,296 5.1 2,194,660

454111 Electronic shopping 14,185 0 0.0 0

454113 Mail-order houses 7,324 220,516 30.1 9,033,008

454210 Vending machine operators 5,194 50,811 9.8 1,361,975

454311 Heating oil dealers 4,055 42,663 10.5 1,698,522

454312 Liquefied petroleum gas 

(bottled gas) dealers 5,980 43,525 7.3 1,486,582

454390 Other direct selling 

establishments 22,077 131,013 5.9 4,115,212

Total 1,039,297 14,775,686 14.2 342,443,836
Market Profile of the Composite Wood Products Industry 145

Table 8-4: Summary of Employment Statistics for Retailer Employer Establishments, 2007

NAICS Description Total 

Establishments

Total 

Employees

Average 

Employees 

Per 

Establishment

Total 

Payroll 

(thousands, 

2007$)

Notes: 1) "D" is used to indicate that the data have been withheld to avoid disclosure.

Source: U.S. Census 2010d

As indicated in Table 8-4, in 2007 the potentially affected retail trade industries were 

composed of 1,039,297 employer establishments that employed over 14 million people (or 14

employees per establishment) and had total payroll amounting to over 342 billion dollars. Note 

that these figures reflect all employer establishments in these NAICS codes. Not all of these 

establishments will be affected by the rule because not all entities in these industries sell 

composite wood products. Of the potentially affected retail trade industries, NAICS 447110 had 

the most employer establishments (97,508), NAICS 445110 had the most employees 

(2,432,425), and NAICS 441110 had the largest payroll (over $50 billion dollars).
Market Profile of the Composite Wood Products Industry 146

9 Third Party Certifiers (TPCs)

CARB has approved nine TPCs located in the U.S. (although most of these U.S. TPCs 

provide services internationally). Two of these TPCs are non-profit organizations, and the rest 

are businesses. Table 9-1 lists the domestic TPCs approved by CARB, their NAICS code, the type 

of organization, the sales volume or expenditures and the number of employees for the TPC or 

its parent organization, the U.S. Small Business Administration’s size threshold for the NAICS 

code, and the TPC’s small entity status. 

The economic analysis assumes that 9 U.S. entities will act as TPCs under the TSCA Title 

VI program, and uses existing CARB TPCs as a proxy for their size and characteristics, but that 

does not mean that all of the CARB TPCs will become TPCs under Title VI. In reality, some of the 

CARB TPCs may choose not to participate in the federal program, and/or new entities may apply 

that are not part of the CARB program. 

Size information was available for four of the nine U.S. TPCs, including the two nonprofits. The size of the TPCs ranges from a non-profit with 10 employees and $1.6 million in 

expenditures to a business with 2,500 employees in 125 offices with parent company that 

manages $3.1 billion in assets. 

TPCs come from a diverse set of industries – the six U.S.-based CARB TPCs for which Dun 

& Bradstreet listed an industry classification fall into five different NAICS codes. Thus, the firms 

that are likely to seek TPC accreditation may be very different from each other in terms of size, 

organization, and financial condition. Table 9-2 presents key industry summary statistics for 

these NAICS codes. However, the domestic TPCs approved by CARB represent a very small share 

of the 142,000 firms in these industries. And comparing Table 9-1 and Table 9-2, the CARB TPCs 

appear to be larger than the average firms in these industries. Thus, these Census statistics may 

not be representative of current CARB TPCs or potential new TSCA Title VI TPCs. 
Market Profile of the Composite Wood Products Industry 147

Table 9-1: CARB-Approved Third Party Certifiers Based in the U.S.

Company 

Name

N

A

I

C

S

c

o

d

e

Org

aniz

atio

n 

Typ

e

Annual 

Sales 

Volume 

or 

Expend

itures 1

(million

s $)

Total 

Employe

es

SBA 

Size 

Thres

hold: 

Reve

nues 

($ 

Milli

ons) 

or 

Empl

oyee

s

Sma

ll 

Enti

ty 

Stat

us 

Certificatio

n Services 

Internation

al, LLC

U

n

k

n

o

w

n

Unk

now

n

Unkno

wn

Unknow

n

Unkn

own 

Unk

now

n 

Composite 

Panel 

Association 

North 

America, 

Inc. (CPA)

8

1

3

9

1

0

Non

-

Prof

it

$3.0 14 $7.0 Sma

ll 

Forestwoo

d 

Industries, 

Inc.

U

n

k

n

o

w

n

Unk

now

n

Unkno

wn

Unknow

n

Unkn

own 

Unk

now

n 

Hardwood 

Plywood 

and Veneer 

Association 

(HPVA)

8

1

3

9

1

0

Non

-

Prof

it

$1.6 10 $7.0 Sma

ll 

NTA 

Incorporate

d

5

4

1

3

3

0

Priv

ate 

Co

mp

any

$5.4 80 $4.5 Larg

e 

PFS 

Corporatio

n

5

4

1

6

1

1

Priv

ate 

Co

mp

any

Unkno

wn

Accordin

g to 

company 

website, 

more 

than 100 

employe

es

$7.0

Unk

now

n

Professiona

l Service 

Industries, 

Inc. (PSI), 

U

n

k

n

Priv

ate 

Co

mp

Unkno

wn, but 

Olympu

s 

Unknow

n, but 

PSI 

website 

Unkn

own 

Ass

ume

d to 

be 
Market Profile of the Composite Wood Products Industry 148

owned by 

Olympus 

Partners

o

w

n

any Partner

s 

website 

reports 

they 

manage 

$3.1 

billion 

in 

assets.

reports 

they 

have 

more 

than 

2,500 

employe

es in 125 

offices 

larg

e 

bec

aus

e of 

rep

orte

d 

asse

ts. 

Scientific 

Certificatio

n 

Systems (S

CS)

5

4

1

3

8

0

Priv

ate 

Co

mp

any

Unkno

wn

SCS web 

site lists 

87 

employe

es

$12.0

Unk

now

n 

TIMBERCO 

(dba TECO)

5

6

1

9

9

0

Priv

ate 

Co

mp

any

Unkno

wn 31 $7.0

Unk

now

n 

1 Annual sales volume is reported for businesses, and annual expenditures are reported for non-profits

Sources: California Air Resources Board 2011 (list of TPCs), Dun & Bradstreet 2011 (sales volume and employees for 

businesses and NAICS codes for all entities), Internal Revenue Service 2010 (expenditures and employees for non-profits), 

U.S. Small Business Administration 2010 (size standards), and company web sites for PSI, PFS, and SCS for data on their 

sales volume and employees. 

Table 9-2: Industry Summary Statistics for NAICS Identified for U.S. Third Party Certifiers

NAICS Firms

EstablishmentsRevenues 

($1000)

Number of 

Employees

Average 

Revenues 

per Firm 

($1000)

541330 -

Engineering 

services 47,714 58,391 $187,531,866 977,031 $3,930 

541380 -

Testing 

laboratories 5,288 6,549 $12,386,831 106,618 $2,342 

541611 -

Administrative 

management 

consulting 

services 59,612 61,583 $67,994,053 351,829 $1,141 

561990 - All 

other support 

services 12,888 14,539 $20,897,346 195,544 $1,621 

813910 -

Business 

associations 16,418 17,028 $22,482,137 116,055 $1,369 

Total 141,920 158,090 311,292,233 1,747,077 $2,193 

Note that TPCs could potentially be classified in additional NAICS as well; as a result, this list may not be comprehensive.

Sources: U.S. Census Bureau 2010a; U.S. Census Bureau 2010b; U.S. Census Bureau 2010c; U.S. Census Bureau 2010d
Market Profile of the Composite Wood Products Industry 149

As shown in Table 9-3, there are a total of 27 CARB approved TPCs outside of the U.S., 

bringing the total number of CARB approved TPCs to 36. 

Table 9-3: CARB-Approved Third Party Certifiers by 

Country

Country Where TPC is Located Number of TPCs

Australia 1

Austria 1

Belgium 1

China 5

Czech Republic 1

Denmark 1

France 1

Germany 4

Hong Kong 3

Indonesia 1

Italy 3

New Zealand 1

Poland 1

Spain 1

Sweden 1

Taiwan 1

 Sub-total for TPCs outside the 

U.S. 27

United States 9

 Total 36

Source: California Air Resources Board 2011
Market Profile of the Composite Wood Products Industry 150

10 Composite Wood Products Market Outlook

This chapter presents a summary of the market outlook for composite wood products. 

Section 10.1 presents a summary of the historical and forecast North American consumption of 

MDF and particleboard. Section 10.2 presents the housing market outlook and section 10.3

presents the renovation market outlook.

10.1 Outlook for MDF and Particleboard Consumption

Figure 10-1 presents historical and forecast North American MDF and particleboard 

consumption. (Similar information was not identified for hardwood plywood.) Particleboard 

has experienced steep declines in demand since it peaked in 2000 and is expected to improve, 

but remain well below peak levels over the next ten years. MDF experienced similar, but slightly 

more modest declines in demand over the past few years compared to particleboard and is 

expected to rebound to levels near its 2002 peak by 2023 (Kennedy 2009). 
Market Profile of the Composite Wood Products Industry 151

Figure 10-1: Historical and Forecast Particleboard and MDF 

Consumption 

Particleboard

MDF

Source: Kennedy 2009
Market Profile of the Composite Wood Products Industry 152

10.2 Housing Market Summary

10.2.1.1 Mortgage Market

The financial recession in the second half of this decade has resulted in a high level of 

turbulence within the housing and mortgage markets. The housing bubble, signaled by inflated 

prices and excess housing supply, burst in the first half of the decade, leaving the home building 

industry with a severe slowdown in both sales and production. A surplus inventory of vacant 

homes is now the largest obstacle to returning to balance in the marketplace, or to a situation 

where levels of production are more in line with long-term trends in demand.

Housing prices have declined from peak levels at the height of the housing boom 

according to a range of measures. Prices are approaching trend levels from the 1990’s, adjusted 

for changes in mortgage interest rates and income growth. Stabilization of prices, along with a 

reduction of foreclosures, will be a key component in reduction of the number of unsold homes 

(NAHB 2008).

The National Association of Realtors releases national and regional existing-home sales 

price and volume statistics monthly. They also provide a monthly summary forecast of actual 

and predicted movement in home sales, home prices, housing starts, and mortgage rates. 

Although home sales were extremely low in 2009 and 2010, the National Association of Realtors 

expects that existing home sales, new sales, and residential construction will begin a steady 

recovery to regular growth trends within the next three years. These home sale statistics and 

predicted trends are illustrated along with predicted trends in relevant mortgage rates in Table 

10-1 below.

Table 10-1: Economic Outlook for Housing Statistics and Mortgage Rates

2009 2010 2011 2012

Housing Sales and Starts (thousands of housing units)

Existing Home Sales 5,156 4,824 5,166 5,388

New Single-Family 

Sales 376 325 420 537

Total Housing Starts 554 617 769 1,013

Construction Expenditures (billions, current$)

Residential 

Construction (Billion 

Dollars)

$359 $341 $374 $441

Mortgage Rates 

30-Year Fixed Rate 5.1% 4.7% 5.0% 5.9%

1-Year Adjustable 4.7% 3.9% 4.1% 5.0%

Source: NAR 2010

10.2.1.2 Housing Demand

There has been a recent dramatic slowdown in household growth – the net addition of 

homeowner households. An examination of what has been driving the slowdown reveals that it 

is attributed largely to a falloff in immigration, and not from a reduction in headship rates. 

Demand for new residential units is the sum of three components: 1) demand for 

additional units to accommodate household growth; 2) demand for additional second homes 
Market Profile of the Composite Wood Products Industry 153

and vacant units for rent or sale to accommodate the normal turnover of a larger housing stock; 

and 3) demand for additional units to replace existing units lost on net from the stock. To turn 

projected new home demand into an estimate of the amount of construction needed to meet 

demand 2010-2019 existing market imbalances must also be accounted for. 

Together the projected components of new home demand 2010-2020 under the low 

immigration household growth series is 16.4 million units and under the high immigration 

household growth series is 18.7 million. The individual components are summarized in Table 

10-2 below. 

Table 10-2: Projected Components of New Home Demand, 2010-2020

(thousands)

Low Immigration 

Projection

High Immigration 

Projection

Projected Household 

Growth 11,802 13,828

Projected Total Vacant Unit 

Demand 1,361 1,595

Projected Total Estimated 

Net Removals 3,279 3,279

Projected Total Demand 

for New Units 16,442 18,702

Annual Average 1,644 1,870

Source: Masnick et al. 2010

The new housing demand projections presented above do not take into account cyclical 

factors or short-term market imbalances during the projection period. The period from 2001-

2010 was near the lowest point for housing construction over the last 27 ten-year periods. This 

implies an inventory correction that may have already run its course during the past few years, 

with markets now at or near long-term balance. However, it is not completely evident yet 

whether or not market balance has been reached because of depressed household formation 

and replacement demand that could potentially be made up in coming years (Masnick et al. 

2010).

10.3 Market for Housing Renovation Activities

The current remodeling downturn is more severe than others seen in recent decades, 

largely because of the growing share of expenditures on upper-end discretionary projects. The 

decrease in homeowner spending should, however, be less drastic than that in new residential 

construction spending. One reason is that spending in large segments of the home 

improvement market – exterior replacements, system upgrades, and disaster repairs – has very 

limited variation from year to year (Joint Center for Housing Studies 2009). 

As the housing market stabilizes and the overall U.S. economy begins to recover, 

remodeling activity is expected to return to a steadier pace of growth. Also, as credit conditions 

improve, owners will find it easier to finance their remodeling and maintenance projects. There 

will both be a greater number of households to make home improvements, as well as an 

expected growth in per-household spending (Joint Center for Housing Studies 2009). 
Market Profile of the Composite Wood Products Industry 154

Remodeling expenditures are expected to increase on an annual basis by the end of the 

year, and the Joint Center for Housing Studies’ Leading Indicator of Remodeling Activity (LIRA) 

indicates growth accelerating to 12.4 percent in the first quarter of 2011. The Leading Indicator 

of Remodeling Activity is designed to estimate national homeowner spending on improvements, 

measured as an annual rate-of-change of its components. Consumer optimism is allowing for a 

recovery in home improvement investment. Figure 10-2 below illustrates the recent trends and 

future projections for home improvement spending, as well as the annual rate of change 

through quarter 1 of 2011.

Figure 10-2: Recent and Projected Indicator of Remodeling Activity

Note: Historical data and LIRA weights are revised annually in July.

Source: Joint Center for Housing Studies 2010

10.4 Market for Furniture Manufacturing

Before the economic crash of 2008, the office furniture market experienced regular 

growth, with production rising from $10.07 billion in 2005 to $11.42 billion in 2007 and 

consumption increasing from $11.91 billion to $13.42 billion in the same period. Between 2008 

and 2009, the furniture industry was heavily affected by the economic downfall with a nearly 30 

percent drop in both production and consumption (See Table 10-3). In the second quarter of 

2010, both orders and shipments came in higher than expected despite a weak labor market, 

slower than anticipated growth in consumer spending, and an overall deceleration of the 

recovery (BIFMA 2010b). 

In the tabled historical data below, production represents the total shipments value, or 

sales of office furniture manufacturers located in the U.S. to all locations in the world. 

Consumption represents the value of all office furniture sold in the U.S. from all sources in the 

world including those in the U.S. BIFMA’s data on projected industry production and 
Market Profile of the Composite Wood Products Industry 155

consumption, adjusted from the IHS Global Insight industry forecast model, is also included in 

the table below. 

Table 10-3: Economic Trends and Projections for U.S. Office Furniture 

Market 

Year

Production 

(Billions, 

current$)

Percent 

Change

Consumption 

(Billions, 

current$)

Percent 

Change

Historical Data

2005 $10.07 12.7% $11.91 12.3%

2006 $10.82 7.4% $12.86 7.9%

2007 $11.42 5.5% $13.42 4.4%

2008 $11.16 (2.3)% $12.99 (3.2)%

2009 $7.84 (29.7)% $9.23 (29.0)%

Projected Data

2010 $ 8.20 + 4.4 % $ 9.80 + 6.3 %

2011 $ 8.90 + 8.3 % $ 10.80 + 10.0 %

Source: BIFMA 2010b, BIFMA 2010c

The industry forecast in the 2010 Business and Institutional Furniture Manufacturers 

Association (BIFMA) International newsletter predicted that product shipments and orders in 

2010 will remain fairly steady; however, financial indicators of the furniture market will 

experience accelerated growth in 2011 (BIFMA 2010a). In particular, as can be seen from the 

data above, industry production is projected to rise 6.7 percent from 2010 to 2011, and 

consumption is projected to rise 8.7 percent that same year.
Market Profile of the Composite Wood Products Industry 156

11 Number of Affected Entities by Small Business Status

This chapter presents the estimated total number of affected entities and the number of 

small entities potentially affected by the proposed TSCA Title VI rule.

The proposed rule will affect small businesses, but small non-profit organizations or 

small governments are not expected to be affected by the proposed rule because they are not 

expected to be panel producers, fabricators, wholesalers, or importers. Under the Regulatory 

Flexibility Act (RFA), a “small business” is determined by the U.S. Small Business Administration’s 

regulations at 13 CFR 121.201 (which create small business size standards using either a sales or 

employment threshold, depending on the nature of the industry), unless an agency establishes 

an alternate definition. 

The small business impacts are presented separately according to the types of 

requirements they are subject to. The number of small firms in the affected NAICS codes was

estimated using Census data and SBA’s small business size standards. Table 11-1 presents a 

summary of the number of small firms affected by the rule. 
Market Profile of the Composite Wood Products Industry 157

Table 11-1: Summary of Affected Number of Firms

Employer 

Status Firm Type

Number of 

Affected 

Firms

Number of 

Affected Small 

Firms

Employers

Stock Panel Producer 54 31

Wood Veneer Laminated 

Product

5,26

0 5,260

Fabricator 28,0

14 27,879

Wholesale 34,9

48 34,324

Retail 247,

689 202,630

All Firms 315,

965 270,123

Nonemployers

Stock Panel Producer - -

Wood Veneer Laminated 

Product

2,22

6 2,226

Fabricator 44,4

78 44,478

Wholesale 50,6

12 50,612

Retail 511,

359 511,359

All Firms 608,

675 608,675

All Firms

Stock Panel Producer 

54 31

Wood Veneer Laminated 

Product

 

7,48

6 

 7,486 

Fabricator

 

72,4

92 

 72,356 

Wholesale

 

85,5

60 

 84,936 

Retail

 

759,

048 

 713,988 

All Firms 924,

640 878,798
Market Profile of the Composite Wood Products Industry 158

12 Baseline Formaldehyde Emissions Levels

This section estimates baseline emissions levels for domestic and imported composite 

wood products. The TSCA Title VI emissions standards take effect on January 1, 2013. 

Therefore, baseline emissions are the levels that would occur at that time if TSCA Title VI were 

not in effect.

12.1 Baseline Emissions for Domestically Produced Products

EPA administered a survey between June and October 2010 to domestic manufacturers 

of composite wood panels. The survey achieved a response rate of 85% of the 39 hardwood 

plywood mills that received the survey, 100% of the 20 MDF mills, and 97% of the 31 

particleboard mills, respectively.26 The survey asked about current emissions levels and about 

planned levels. Since many composite wood product mills were in the midst of modifying their 

production technology and raw materials to achieve compliance with Phase 2 of the CARB ATCM

when they completed the survey, the “current emission levels” reported in the 2010 survey 

would not accurately reflect emissions levels in the 2013 baseline. Instead, baseline emission 

levels are estimated using responses to a question in the survey about the emissions levels mills 

planned to achieve within the next three years (from the time of the 2010 survey). These 

emissions levels were weighted by the production levels the mills reported in the survey, in 

order to estimate the average emission levels by certification standard. The survey data were 

also used to estimate the share of total production volume represented by products meeting 

each of the emissions standards. The results are reported in Table 12-1. For comparison 

purposes, the CARB emission limits (which are identical to the TSCA Title VI limits) are shown in 

Table 12-2.

 26 The number of mills for each product type is limited to those that are subject to FCWPA, and does not include mills 

that only produce products that are exempted or not otherwise covered by TSCA Title VI (such as curved plywood, 

wood packaging, and molded products that do not qualify as panels). The response rate includes mills that only 

responded to a brief phone questionnaire, which collected information about the compliance standards being 

achieved, but not specific emissions levels.
Market Profile of the Composite Wood Products Industry 159

Table 12-1: Baseline Emissions Levels (2013) For Domestically Produced 

Composite Wood Products, by Product Type and Certification Standard

Certification 

Standard

Hardwood 

Plywood MDF Particleboard

Weighted Average Emissions (ppm) a

None 0.058 - 0.058

CARB 1b - - 0.090

CARB 2 0.032 0.082 0.057

CARB ULEF c 0.024 0.042

CARB NAF 0.013 0.035 0.013

Share of Production

None 0.4% - 0.2%

CARB 1b - - 1.8%

CARB 2 60.2% 86.1% 88.5%

CARB ULEF 4.6% 2.8%

CARB NAF 39.4% 9.3% 6.7%

Total 100% 100% 100%

a Emissions are weighted based on the production volume reported by reported by respondents.

b Some hardwood plywood mills producing product currently certified under CARB Phase 1 reported that 

they would continue this product line after the CARB Phase 2 effective date.

c

Hardwood plywood mills meeting CARB 2 and CARB ULEF were grouped together in the CARB 2 category. 

Several hardwood plywood mills appeared to be meeting CARB ULEF standards but did not report this in 

their response. For example, they listed certification standard as “CARB 2” but resin type as “ULEF” and/or 

reported maximum emissions that satisfy ULEF requirements. Due to difficulties in distinguishing between 

CARB 2 and CARB ULEF product lines and the fact that emissions levels appeared similar among mills 

reporting either CARB 2 or CARB ULEF certification standards, these mills were grouped together.
Market Profile of the Composite Wood Products Industry 160

Table 12-2: Formaldehyde Certification Standards in the California Air 

Resources Board’s Air Toxic Control Measure for Formaldehyde 

Emissions from Composite Wood Productsa (ppm)

Certification 

Standard

Hardwood 

Plywood MDF Particleboard

CARB 1 0.08 0.21 0.18

CARB 2 0.05 0.11b 0.09

CARB ULEF –

less frequent 

testing

0.05

90% of samples <

0.06

All samples < 0.09c

90% of samples 

< 0.05

All samples <

0.08 

CARB ULEF –

exemption 

from third 

party 

certification

90% of samples <

0.04

All samples < 0.05

90% of samples <

0.04

All samples < 0.06

90% of samples 

< 0.04

All samples <

0.06 

CARB NAF

90% of samples <

0.04

All samples < 0.05

90% of samples <

0.04

All samples < 0.06

90% of samples 

< 0.04

All samples <

0.06 a The TSCA Title VI emissions limits are the same as the CARB ATCM limits.

b The CARB 2 emissions limit for thin MDF is 0.13 ppm.

c The ULEF limits for thin MDF are 90% of samples < 0.08 ppm, and all samples < 0.11 ppm.

12.1.1 Baseline Emissions Levels for Imported Products

Baseline emissions are estimated separately for imported products from Canada and 

those from the rest of the world. The known composite wood manufacturers in Canada were 

compared to the California Air Resources Board list of certified mills, and most Canadian mills 

were found to be CARB certified. As a result, Canadian mills are assumed to achieve the same 

baseline emissions as U.S. firms (whose emissions were shown in Table 12-1).

The baseline emissions for non-Canadian imported composite wood products were 

estimated using data from a 2009 presentation by Professional Service Industries (PSI), a CARB 

Third Party Certifier (PSI 2009). While PSI is located in the U.S., the mills it certifies are mainly 

located in Asia.27 The mills that PSI certifies are located in countries that are major sources of 

pressed wood products imported into the U.S. So the data from the PSI presentation is assumed 

to represent emission levels from all non-Canadian composite wood products imported into the 

U.S. 

The PSI presentation included histograms of observed formaldehyde emission levels for 

hardwood plywood, MDF, and particleboard. The data included emissions levels for 387, 198, 

and 193 samples of hardwood plywood, MDF, and particleboard, respectively, and for all three 

product types combined. After imputing the data underlying these graphs, the average 

 27 According to CARB’s list of certified mills, as of November 12, 2010, PSI was the TPC for 95 mills in 9 countries. The 

countries, and the number of mills certified by PSI in each country, were as follows: Argentina (1), Chile (1), China 

(55), Ecuador (2), Indonesia (2), Malaysia (26), Philippines (1), Taiwan (1), and Thailand (6).
Market Profile of the Composite Wood Products Industry 161

emissions values reported in the presentation were successfully replicated.28 This information 

was used to estimate the number of samples at different emissions levels.

The emission levels reported in the PSI presentation ranged from near zero to levels 

that exceed the CARB 2 emission standards by a substantial margin. The emission levels 

observed in these data were from a period after CARB 1 took effect but before CARB 2 did. 

Since many mills that met the CARB 1 standards at the time these samples were taken may 

subsequently achieve CARB 2 levels, baseline emissions were predicted by assuming that 

products with emission levels between the CARB 1 and CARB 2 levels in the PSI data would 

achieve CARB 2 levels by 2013. Emission levels of 0.06 and 0.05 ppm were used for CARB 2 

baseline emissions for MDF and particleboard, respectively, because these levels represent the 

midpoints of the highest emissions intervals in the PSI data that meet the CARB 2 limits. None of 

the intervals in the PSI data for hardwood plywood reflected the CARB 1 emission limits. (The 

CARB 1 limit of 0.08 ppm is spanned by the interval of 0.075 to 0.125 ppm in the PSI data, and 

the CARB 2 limit of 0.05 ppm is spanned by the interval of 0.0375 to 0.075 ppm.) Therefore no 

adjustments were made to hardwood plywood for the shift from CARB 1 to CARB 2. After this

adjustment the average emissions by product type were calculated (see Table 12-3).

Although a number of samples in the PSI data had emissions levels close to zero, it was 

not possible to determine whether the products qualify for certification as ULEF or NAF. The PSI 

presentation did not identify the resin type used for each sample. Also, as shown in Table 12-2, 

NAF and ULEF have emissions requirements for 90% of the samples from a mill as well a ceiling 

for all samples, and this distribution of emissions could not be determined from the PSI 

presentation. Thus, baseline emissions levels are not estimated separately for non-Canadian 

imports of ULEF and NAF products. Such products are included in the baseline emissions 

estimates for the CARB-2 category.

Table 12-3 also includes the share of imports for each product type and emissions 

standard. This was estimated by assuming that the fraction of samples for each category in the 

PSI presentation is equivalent to the share of imports for that category across all non-Canadian 

composite wood products imported into the U.S.

 28 The emissions levels in the graphs seemed to be labeled according to the interval midpoints (e.g., a reported value of 

0.05 ppm represented an interval of 0.0375 ppm to 0.075 ppm). The maximum values reported in the presentation for 

MDF and particleboard were used for the maximum intervals. The median value was used for the median interval for 

MDF. The data in the hardwood plywood graphic is consistent with an average value of 0.07 ppm rather than the 0.05 

ppm value that could be calculated from the summary statistics shown in the presentation for all three product types 

combined. For hardwood plywood, the three highest emission levels (all of which exceeded 1.0 ppm) seemed to be 

driving this discrepancy so they were dropped from the analysis. After dropping these outliers the imputed average 

emissions matched the 0.05 ppm value that could be calculated from the other summary statistics shown in the 

presentation.
Market Profile of the Composite Wood Products Industry 162

Table 12-3: Baseline Emissions Levels For Non-Canadian Imported 

Composite Wood Products, by Product Type and Certification Standard

Certification 

Standard

Hardwood 

Plywood MDF Particleboard

Average Emissions (ppm)

None 0.163 0.502 0.384

CARB 2 0.015 0.047 0.036

Share of Imports

None 26% 11% 38%

CARB 2 74% 89% 62%

The estimates presented in Table 12-3 rely on several critical assumptions that are a 

source of uncertainty in this analysis, the most important being:

• The sample is representative of imported non-Canadian composite wood products.

o It is not known whether the sample is representative of products destined for the United 

States. The destination of these products could be other countries or their country of 

origin. On the one hand, U.S. end users may be more likely to insist on lower emitting 

products. On the other hand, U.S. end users not shipping to California face less stringent 

formaldehyde emissions standards than many other potential destinations. (Although 

many end users prefer to handle a single type of product, rather than one product that 

meets the California requirements and another type for the other 49 states). The fact 

that the samples were being tested for formaldehyde emissions by a CARB TPC suggests 

that many of them were produced by mills whose products ultimately end up in the U.S. 

• The distribution of emission levels will not change for mills that were producing products with 

emission levels exceeding CARB 1 standards.

o If some of these mills decide to obtain CARB 2 certification, it is not known whether 

these will be the higher or lower emitting mills on average. Some additional mills (aside 

from those below the CARB 1 limits but above the CARB 2 limits) may subsequently 

decide to lower their emissions levels. 

o Conversely, the PSI data may under-represent imported products with very high 

emissions levels. Mills making products likely to exceed the CARB levels may not have 

had their products tested because they intended to sell them in the other 49 states.

• The percentage of samples with current emissions below CARB 1 levels is a reasonable estimate 

of the percentage of mills that will be achieving CARB 2 levels in the baseline scenario.

o The PSI presentation was given after CARB 1 was in effect but before CARB 2 was. It is 

not known whether more overseas producers will ultimately meet the Phase 2 emission 

limits than initially met the Phase 1 limits. 

12.2 Composite Wood Product Consumption by Product Type and Trade Status

Table 12-4 presents the domestic production, international trade, and domestic 

consumption for composite wood products. Data from 2005 were used in Table 12-4 since that 

was the most recent data available for all categories shown when the table was prepared, and 

because 2005 may be more representative of consumption after the current economic 
Market Profile of the Composite Wood Products Industry 163

downturn ends. According to PanelWorld Magazine (PanelWorld 2010a), citing a 2010 

Composite Panel Association report, U.S. particleboard and MDF shipments have experienced 

substantial declines since 2009, and were about 2.5 and 3.9 million cubic meters for MDF and 

particleboard in 2009, respectively. Domestic hardwood plywood production has likely 

experienced similar declines, but published data were not identified. While imports of 

hardwood plywood and particleboard have also declined substantially, MDF imports have 

increased over 40 percent since 2005. 

Table 12-4: 2005 U.S. Production, Trade, and Consumption of Composite Wood 

Product Panels 

(Cubic Meters)

Product 

Type

Do

mes

tic 

Pro

duct

ion

Ex

po

rts

Domestic Consumption

Percent 

of 

Consump

tion from 

NonCanadian 

Imports

Non

-

Can

adia

n 

Imp

orts

Ca

na

di

an 

Im

po

rts

Dome

stic

Tot

al

Hardwoo

d 

Plywood 

Panels

1,84

4,00

0

24

3,7

63

3,59

8,80

5

42

1,

52

6

1,600

,237

5,62

0,56

8 64%

Medium 

Density 

Fiberboa

rd Panels

3,25

7,29

7

16

3,8

89

309,

188

65

7,

77

9

3,093

,408

4,06

0,37

5 8%

Particleb

oard 

Panels 7,27

6,26

3

25

8,8

27

289,

369

1,

05

7,

53

4

7,017

,436

8,36

4,33

9 3%

Notes: MDF and particleboard production are 2005 data from CPA 2006. Hardwood plywood production is 2005 data from Table 

2.2 in U.S. ITC 2008. Imports and Exports data are from U.S. ITC and include the following HTS codes: (1) Hardwood plywood: 

4412.13, 4412.14, 4412.22, 4412.23, 4412.29; (2) MDF: 4411.21, (3) Particleboard: 4410.31, 4410.32, 4410.33, 4410.39.

12.3 Summary of Baseline Emission Levels

Note that baseline emissions data are not available for hardwood plywood defined as 

laminated products. The CARB 1 standard for hardwood plywood is used to represent the 

average baseline emissions level for laminated products made in the U.S. and Canada. The 

CARB 1 level represented the average emissions level that CARB found prior to promulgating the 

ATCM. It reflects a mix of products using different resin types, including both UF and NAF resins. 

This is a reasonable proxy for domestically produced laminated products. These products are 

thought to generally be made with UF or PVA resin, so their emissions may be similar to those 

from stock hardwood panel products before the ATCM went into effect. 

For laminated products made outside the U.S. and Canada, average baseline emissions 

are assumed to be the same as the levels for imported hardwood plywood that does not meet 

an emissions standard (estimated from the PSI presentation). Emissions data prior to the CARB 

ATCM are not available for non-Canadian imported hardwood plywood. Since the PSI 
Market Profile of the Composite Wood Products Industry 164

presentation was given after CARB 1 was in effect, it presumably reflects a reduction in 

emissions compared to pre-ATCM levels. Therefore, if baseline laminated product emissions are 

similar to pre-ATCM emissions, using the average of all non-Canadian imported hardwood 

plywood would underestimate emissions levels for laminated products. Using the estimated 

average emissions from hardwood plywood that does not meet an emissions standard reflects 

the possibility that many of these imported laminated products are made with UF resins.
Market Profile of the Composite Wood Products Industry 165

Table 12-5: Baseline Emissions Levels For Composite Wood Products by 

Product Type, Country of Origin, and Certification Standard

Certific

ation 

Standa

rd

Hardwood 

Plywood MDF Particleboard Laminated Products

U

.S

./

C

a

n.

N

o

nU.

S.

/

C

a

n.

U.

S.

/

C

a

n.

N

o

nU.

S.

/

C

a

n.

U.

S.

/

C

a

n.

N

o

nU.

S.

/

C

a

n.

U.

S.

/

C

a

n.

N

o

nU.

S.

/

C

a

n.

Average Emissions (ppm)

None

0.

0

5

8

0.

1

6

3

-

0.

5

0

2

0.

0

5

8

0.

3

8

4

0.

0

8

0

0.

1

6

3

CARB 1 - - - -

0.

0

9

0

- - -

CARB 2

0.

0

3

2

0.

0

1

5

0.

0

8

2

0.

0

4

7

0.

0

5

7

0.

0

3

6

- -

CARB 

ULEF

0.

0

2

4

0.

0

4

2

CARB 

NAF

0.

0

1

3

0.

0

3

5

0.

0

1

3

Share of U.S. Consumption

None

0.

1

%

1

6.

6

%

-

0.

8

%

0.

2

%

1.

1

%

3

6.

0

%

6

4.

0

%

CARB 1 - - - -

1.

7

%

- - -

CARB 2

1

9.

7

%

4

7.

4

%

7

9.

2

%

7.

2

%

8

5.

0

%

1.

9

%

- -

CARB 

ULEF

4.

2

%

3.

0

%

CARB 

NAF

1

6.

2

%

8.

6

%

7.

1

%

Total 100% 100% 100% 100%
Market Profile of the Composite Wood Products Industry 166
Market Profile of the Composite Wood Products Industry 167

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Market Profile of the Composite Wood Products Industry 171

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sortkey1=&-defOrder=Y&-ds_name=NS0800A1&-sortkey0=&-NAICS2007=31-

33|311|3111|31111|3112|3113|3114|3115|3116|31161|3117|31171|3118|3119|31

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1|3273|3274|3279|331|332|333|334|335|336|337|339|3391|33911|3399|42|423|

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39&-geo_id=01000US&-geo_id=04000US06&-_lang=en.

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