'MALAV.SIA~ TIMBE~ COUNc;IL 

Re(.TibO/EPA/0001/L/14 

' ' ·' ' ., 16 Ja.nu.ary 2014 

• ' ~ ' ' ~ I 

National Prpgram.Ch,emic<tiSi Divisjon 1 ; , 

Offk~ of Pollution Preventior:anq Taxies 

... , ·'".:,{{t:JO! Docu,IJ1~(:1~ Control Office !(7 40?M) \-. .,~ :~;J Environmental Protection· Agency 

·;.,;;.'·· 1200 Pennsylvania 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'. 

·'' 

CBJC Control_ Number 

358925 

RE: Comments on EPA's Proposed Regulation on Formaldehyde Emissions Standards for 

Composite Wood Products ' 

I am writing on behalf of the 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 

incorporate composite wood products to the United States. The export of these 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 the form of finished goods. 

i'. ·, : ~· 

MALAYSIA: EXPORT OF TIMBER AND TIMBER PRODUCTS TO THE UNITED STATES OF AMERICA 

2008 2009 2010 2011 2012 Jan- Aug 

PRODUCTS 2013 

\' 

·. VQt.· .. 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/ ': .. 

n.a. ·a.os 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: MolayswrfTimber Industry Board {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 

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MALAYSIAN TIMBER COUNCIL 

We understand that the U.S. EPA has proposed new rules to regulate formaldehyde 

emissions from composite wood products and that the California Air Resources Board (CARB) 

is also seeking to amend its regulations of these products. We understand that neither the 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 

meeting customers' expectations. 

In order to facilitate trade between the two countries, we propose the following: 

• 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 

manufactured to 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 

lower the cost of complying with the rule for both the TPCs and their clients. 

• TPCs will be critical to informing manufacturers of the 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 of the 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 work with IWPA and others on workshops 

and outreach. 

• We are especially concerned about the US EPA proposal to require third-party 

certification of fabricators of laminated products. While panel manufacturers are in 

many cases very knowledgeable about the CARB rules and already have a relationship 

with a TPC, that is not the case for fabricators of laminated products. Most of these 

businesses are very small furniture and housewares producers and have not had to 

follow the CARB processes other than purchasing compliant core panels. These small 

businesses would find it challenging to comply with the proposed scheme. In 

particular, the testing and reporting requirements proposed by US EPA for laminators 

would be very costly and difficult to 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 with this requirement. 

Thank you for considering our views 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)