**'MALAV.SIA~ TIMBE~**  COUNc;IL Re(.TibO/EPA/0001/L/14 ' ' ·' 

# '

., 16Ja.nu.ary 2014

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## ...,·'".:,{{t:JO!**Docu,IJ1~(:1~** Control Office!(740?M) 

# \-.**.,~ :~;J**  Environmental Protection·Agency ·;.,;;.'·· 1200Pennsylvania Ave., NW · Washington, DC 20460-0001 Emission Assessment Branch Californfa

### Ai~·Resources Boafd 10011 Street P.O. Box 2815 ,• I Sacramento, CA,95812 II''

### 6earSir/Mad~m,**'** • ' • I "**~** :..1 l'. 

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CBJC Control_ Number 

# 358925

RE: Comments on EPA's Proposed Regulation on Formaldehyde Emissions Standards for CompositeWood Products ' I am writing on behalf ofthe Malaysian Timber Council (MTC), which represents the interest of Malaysian timber industry, to provide comments to the Environmental Protection Agency's (EPA) Proposed Regulation on Formaldehyde Emissions Standards for Composite Wood Products. Malaysia exports to the United States various timber products including plywood, MDF, particleboard and other products such as furniture, flooring and doors that incorporatecomposite wood productstothe United States. The export ofthese products was valued .at USD 737.7 million in 2012, as shown in the table below. In many**ca~es,** these products· contain American sourced hardwoods that are being exported into the United**~tates** (US.) in theform offinished goods.
i'. ·, :**~·** MALAYSIA: EXPORT OF TIMBERANDTIMBER PRODUCTSTOTHE UNITED STATES OF AMERICA 2008 2009 2010 2011 2012 Jan- Aug PRODUCTS 2013
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..Val. VQI, Val• VQI, Val. VQI. Val. VQI. Val. VQI, Val. :PLYWOOD· "·**~;·I** 1'153.3 67.3 117.9 56.2 133.1 70.3 92.5 54.2 110.0 64.6 83.5 47.9 _CHIPBOARD/ ': ..

## ·a.os n.a. 0.0 0.0 0.4 0.2 5.5 1.4 3.0 0.7 0.9 0.3**PARTICLEBO~RD** ,**~** ' ' .., .. i ·, ' . '

,FIBREBQA,RD ·, ,;. 21.4! ' 12/2 

### ,,zpA 11.8 23.9 13.0 18.6 10.7 17.3 10.1 12.9 6.4**v'Y!OULDI~~S** :. •. ':;16.5' ; 19<l' ·1•20>5; 15.5 20.7 16.9 24.4 19.8 24.0 21.8 12.9 11.6 BUILDERS' JOIN_ERY&, n.a. 37.1 n.a. 23.0 n.a. 22.2 n.a. 22.9 n.a. 21.2 n.a. 11.4 CARPENTRY WOODEN 'J·. FURNITURE n.a.. 583.3 · n.a. 565.4 n.a. · 645.0 ·n.a. 561.5 n.a. 619.2 n.a. 344.4 TOTAL 

### ."•-it'.:_·· 719.1 671.9 767.6 670.6 737.7 421.9 

### ' " 

### .. Source: MolayswrfTimberIndustryBoard{MTIB}

. . .'.**·~·** ' {Vol. ('000 m3 }, Val. (USD Mtllion)]

18th Floor, Menara PGRM. 8, Jolon Pudu Ulu. Cheras, 56100 Kuala Lumpur. Tel: 03-9281 1999 Fax: 03-9282 8999 (229752-X)o'f \

MALAYSIAN TIMBER COUNCIL We understand that the U.S. EPA has proposed new rules to regulate formaldehyde emissions from composite wood products and thatthe California Air Resources Board (CARB) is also seekingto amend its regulations ofthese products. We understandthat neitherthe US EPA nor CARB are seeking to change the current CARB emission levels, but are changing the scope of products affected. We appreciate that the U.S. is concerned about ensuring there are safe levels of formaldehyde in the composite wood products sold in the country. We want our exporters to meet all the required emission levels in the global marketplace and meetingcustomers' expectations. In ordertofacilitatetrade between thetwo countries, we proposethefollowing:

• The U.S. EPA and CARB work closely to create complementary regulations so that it is possible to meet both agencies' requirements with minimal cost and recordkeeping burden. When our products are exported to the U.S. we do not in many cases know where these products will ultimately reach the retail consumers. For that reason, we would expect that most products exported to the U.S. would have to be manufacturedto meet both CARB and US EPA regulations.

• CARB and EPA should provide reciprocity to CARS-recognized Third Party Certifiers (TPCs) so that a TPC already approved by CARB would not have to obtain separate accreditation from EPA-recognized accreditation bodies. This will greatly simplify and lowerthe cost ofcomplying with the rule for both theTPCs and theirclients.

• TPCs will be critical to informing manufacturers ofthe new requirements. We ask that US EPA and CARB phase in the new rules first for TPCs and conduct workshops early with foreign TPCs so that they will be ready to assist their manufacturer clients. Because of shipping times, importers will be required to comply with the new rules ahead ofthe U.S. industry and thus they will need additional lead time and earlier outreach. We understand that the International Wood Products Association (IWPA) has offered to coordinate and provide a location for US EPA and CARB to conduct such workshops. We urge EPA and CARB to workwith IWPA and others on workshops and outreach.

• We are especially concerned about the US EPA proposal to require third-party certification offabricators of laminated products. While panel manufacturers are in manycases very knowledgeable about the CARB rules and already have a relationship with aTPC, that is not the case for fabricators of laminated products. Most ofthese businesses are very small furniture and housewares producers and have not had to followthe CARB processes otherthan purchasing compliant core panels. These small businesses would find it challenging to comply with the proposed scheme. In particular, thetesting and reporting requirements proposed by US EPA for laminators would be verycostly and difficultto implement.

18th Floor. Menoro PGRM. 8. Jolon Pudu Ulu. Cheras. 56100 Kuala Lumpur. Tel: 03-9281 1999 Fax: 03-9282 8999 (229752-X)'•· i.



### MALAYSIAN TIMBER COUNCIL

• The labeling requirements proposed by US EPA should be simplified to only require a statement that they are US EPA and CARB compliant. In addition, we would like to propose that the CARB proposal to label each component part and individual unit, including individual panels be reviewed as it would be difficult and in some cases simply impossible to comply withthis requirement. Thank you for considering ourviews as you finalize your new rules. 

### Yours sincerely, MALAYSIAN TIMBER COUNCIL

18th Floor. Menara PGRM. 8, Jolon Pudu Ulu, Cheras, 56100 Kuala Lumpur. Tel: 03-9281 1999 Fax: 03-9282 8999 (229752-X)