Concerns Rising on CARB Labeling, Documentation Requirements
The world's strictest formaldehyde emission standards for composite wood products take effect in California starting Jan. 1, 2009. That means particleboard, medium density fiberboard (MDF) and hardwood plywood manufactured for sale or use in California must comply with the new California Air Resources Board (CARB) regulations. Even if you are not located or currently doing business in California, several other states, and the Federal EPA, are looking at the CARB rule for possible consideration.

Countdown to CARB, brought to you by panel producers Timber Products Company and SierraPine, will provide you with the information you need to know to get ready for the new CARB regulations. Each issue will focus on news and updates relevant to your segment of the wood products pipeline, and show you what companies are doing to get themselves positioned for compliance. This second issue looks at the labeling and documentation requirements that are causing some confusion and concern in the market.

Look for future editions of Countdown to CARB throughout the rest of 2008. For more information or for specific CARB-certified material questions, contact info@timberproducts.com or info@sierrapine.com.

Retailers Juggling Inventory
Retailers are starting to focus more on the new CARB rules, according to reports from the field. For example, Deonn Deford, a buyer at Ganahl Lumber in Orange County, Calif., thinks that retailers didn't know much about CARB until recently and are starting to consider their options when it comes to purchasing.

"Right now, 95 percent of our inventory is not certified, but we won't have any problem moving that in the next few months, well within the sell-through period," said Deford, referring to the 12 months that retailers have after Jan. 1, 2009, to move existing unfinished product and 18 months for finished goods. "As it gets closer to the deadline, I'll be looking to make some deals to clear inventory. The concern then will be replacing that inventory volume with CARB certified products."

Deford also sees a lack of understanding among his customers on what the CARB requirements will be.

"We mainly sell to small cabinet shops and contractors who do remodels," said Deford.

"Most of them are not aware at all of CARB. It's not a huge concern for them. I'm guessing that they will just rely on us to make sure the products are certified."

However, that might not be enough to meet the requirements. With CARB requiring labeling of products, just keeping invoices for two years is insufficient. The responsibility for product labeling will ultimately lie with the fabricator.

"The most important thing to know right now is how to interpret the rules," said Deford. "Also, what's CARB asking you to do? Mark each product? Or unit? We need clarification on these types of items."

Both Timber Products and SierraPine are taking proactive approaches to labeling their panel products to help retailers, distributors and fabricators in the tracking process. Each company includes CARB certification identification on unit tags and invoices, while SierraPine adds the information to bills of lading and Timber Products applies labeling information on the edge of every panel.

Distributors Leery of Labeling Rules
With the CARB deadline looming, distributors are still learning what new regulations they will need to follow. So far, what they see is not pretty.

"Right now, distributors need to understand the paperwork requirements that are involved. It goes way beyond just keeping purchase orders and invoices," said Dana Linz, owner of Royal Plywood in the Los Angeles area. "The issue we see with CARB is that it wants distributors to include a copy of the purchase tag from each unit of material with each sale to a fabricator. So that means if we split up units, we have to photocopy the original tag and include it with each sale. That's going to be very challenging."

Linz has concerns for his customers, also, who will have to keep track of product tags along the way and connect each product to each unit of wood.

"We have major customers who don't know anything about this," he said. "The word has not spread to them about their responsibilities. They are just now seeing the amount of documentation work this is going to present. Understanding the paperwork is going to be a challenge because they need to be able to trace each product back to the material it was made from.  This will greatly change the parts bin of extra material. Nothing ever comes out that neatly."

For now, Linz is focused on supplying certified material while balancing the troubling economic times his customers are experiencing.

"We're trying to order all CARB-certified material now but it's difficult to get," he said. "Some of our customers are asking for only certified materials. For example, RV manufacturers, with the current economy, are making vehicles that may sit well beyond the sell-through provisions. They don't want non-compliant materials because they will be in violation next year."

End of the Scrap Bin?
Kitchen Cabinet Manufacturers Association Executive Vice President Dick Titus has seen industry-changing regulation before.

"The MACT finishing requirements in 1995 had a similar impact on the industry to what CARB is having now," said Titus."We learned from that in how we approach sharing CARB information today. The cabinet industry has not been heavily regulated but this ruling is huge and it comes at a bad time for the business. We're advising our members that even if they are not in California, they need to know what's going on because it could be coming their way someday soon."

Titus recommends that fabricators start the process of understanding how they are going to get compliant boards. Then, they need to understand the labeling and documentation requirements they have to pass along to their customers.

"Labeling requirements need to go either on the box or the product. CARB recommends the product and not to trust the box to hold up," said Titus.

Fabricators also need to be able to determine which batch of plywood came from each supplier, and how that was used to make products.

"The paper trail requirements are really new for this industry," said Titus. "California has more small cabinet shops that any other state. There are literally thousands. I think a lot of these small shops are not paying attention to what they need to do. It could be the end for the scrap bin because they need to keep track of all that wood."

A summary of the California Air Resources Board (CARB) regulation of formaldehyde in composite wood is available at www.kcma.org/CARB_Compliance_Document_FINAL1.doc to assist you as the effective date draws nearer.

Timber Products, SierraPine CARB Certification Update
On Sept. 24, Timber Products Company announced that its hardwood plywood and particleboard mills in Medford, Ore., have been certified to meet the California Air Resources Board (CARB) requirements.

With this designation, Timber Products becomes one of the first U.S. hardwood plywood manufacturers to have its entire product line CARB certified.

The audit process was conducted by the Composite Panel Association, a U.S. agency authorized by CARB as an official third-party certification body.

The company's mills in Grants Pass, Ore., and Corinth, Miss., are expected to be CARB- certified in the next 30 days, according to Timber Products Vice President Roger Rutan.

Read the press release on this full announcement at www.timberproducts.com/newsroom.

SierraPine, a leading manufacturer of composite panels with six manufacturing facilities in California, Oregon, and Georgia, has all of its products certified to the CARB Phase I or Phase II emission limits. In addition, SierraPine will be one of the first manufacturers to receive the NAF Exemption on its line of Sustainable Design Fiberboard MDF products.

For a complete list of SierraPine's CARB certified panels, click here.

Next issue of Countdown to CARB coming Nov. 15, 2008