Did I get your attention? I hope so! Because I want to make sure you’re aware of an important issue that will impact our industry if the changes that we and other organizations are pushing for, are not met.
I’m talking about the refreshed formaldehyde regulations (CANFER). This is not something our industry has had to be concerned about before, but the new regulations have a list of requirements that will leave you wondering how you’re going to manage compliance on top of everything else you deal with in a day.
Before we dive in, I think it’s important to say that membership in your industry association is so valuable because without your support we wouldn’t be here to represent you. Your membership helps fund this work and while we know many are not comfortable being in the political arena,
we are comfortable speaking
up for you, so let us do that
for you. Support us, so we
can support you.
CKCA is part of a coalition of wood organizations that have been working to get the new formaldehyde regulations modified. The coalition was spearheaded by the International Wood Products Association and the National Wood Flooring Association. While we agree with the intent of these refreshed regulations which is to reduce and manage levels of formaldehydes in wood manufactured products, we believe it needs to be balanced with the industry’s ability
to not only comply, but to remain competitive by not
being bogged down in
tracking processes that
will take significant amounts of time away from getting business done.
Let’s run a scenario to show you how these regulations could play out. To comply there is a chain of custody requirement that runs the length of the supply chain from panel manufacturer to retailer. How it impacts you
You make cabinets that utilize both plywood and MDF. You buy plywood and MDF from up to six domestic sources that might sell you domestic or imported panels. You assume their sources will vary as well because you don’t always get the exact same material. You also buy custom drawer sides made of plywood from another local manufacturer who is buying plywood from other sources. You don’t know their sources and they would not tell you. You sell boxes sometimes and do not want to have to track from your supplier back to their supplier to know where things are coming from. The new regulations would require you to track all of it, AND your custom drawer supplier would be required to disclose their sources in order for you to keep the tracking records needed for compliance. Keep in mind that this tracking and disclosure of sources is applicable whether you are a cabinet manufacturer or dealer.Is it law?
Yes! Under the law, you are supposed to register with the government, utilize bilingual labelling and be tracking production already. The reality is we know many companies are not in compliance, not
just in the kitchen cabinet industry, but in other wood industries too who fall
under these regulations.
And when the regulations
are finalized this year (hopefully with the changes we have asked for), we will support stakeholder education on final responsibilities.
Right now, the reality is we cannot guarantee the changes we are advocating for will be made. However, rest assured we continue to voice our concerns and proposed solutions and remain optimistic that these revisions will be accepted. Members and partners speak up
We spoke with a number of members to get their take on the impact these regulations have and we’re grateful for the letter writing they did to speak up on this issue with government. We have also brought our partners CFIB into this and leveraged their help. We do believe that we are finally being heard as an industry. If we need more letter writing done, rest assured we’ll be reaching out to you for help. The more we speak up, the better our chances of getting these regulations revised.
As one member said: “To keep track of all the different composite panels, their original source and the quantities used for each order would be extremely difficult if not impossible. This legislation would put us at a competitive disadvantage when competing for work on foreign projects and against foreign companies importing into our local market.”
We presented to our members the information on what was happening with these regulations at our National Forum last October. Here’s the “Cole’s Notes” of the information shared as a handy summary. We will keep you posted on how this all progresses. It is frustrating that the industry has had to spend significant funds to advocate on this issue. We are determined to get these regulations revised, because the alternative is unrealistic and anyone working in the wood industry whether it’s kitchens, flooring or other – will feel the impact once they are actively applied.Summary:
Canadian government created regulation regarding Formaldehyde Emissions from Composite Wood Products known as CANFER - final version of existing regulation first published in July 2021 and became effective Jan. 7, 2023.
Regulation impacts ANY company that manufactures, distributes, imports, retails, processes or otherwise utilizes composite wood products (plywood, MDF, particleboard and finished goods containing those materials.)
While industry generally supports regulation, we want government to address inconsistencies between U.S. and Canadian regulations to ensure any requirements do not add undue costs or administrative burdens to Canadian businesses.
We want to reduce the risk that current ambiguities and conflicting requirements might lead to unintended violations.
To address industry concerns with regulation, International Wood Products Association and National Wood Flooring Association spearheaded created coalition called “The Right Reg coalition,” which encompasses wide membership of suppliers, retailers, manufacturers, and other organizations involved in the overall supply chain, CKCA is member.
Coalition has invested well over $50,000 U.S. in this effort to get these regulations changed. Most of work is done by volunteers, funds coalition collects pays for a professional lobbyist who met Government numerous times to discuss implications of regulatory changes and guiding our political action.
Regulation REQUIRES businesses that use or sell composite wood products keep overly onerous, comprehensive record tracking materials under CANFER at every stage of manufacturing, importing, distribution, and retail processes.
Regulation currently requires industry to house physical copies of documents “Declarations of Certification” from panel manufacturers or “Attestations” from downstream companies that outline entirety of complex supply chain that feeds industry’s manufacturing facilities and supplies or retail stores.
Records contain confidential business information and impose significant administrative and cost burden on small businesses and retailers, who have to track and keep up-to-date records on composite wood panels used to make our cabinets, as well as products like flooring, furniture, moldings, etc.
Right Reg Coalition strongly believes that this goal would be better accomplished if original panel manufacturer in Canada or importer to Canada were required to maintain records and not pass them down further in the supply and retail chain. CKCA wholly supports this proposed administrative amendment.
Good news is government has agreed to consult industry on amending CANFER in 2023.
CFIB also sent letter of support and commented that this isn’t the first time in 2023 they’ve had to help members deal with regulatory changes that create a heavy burden on small business. Some of you may know that CFIB is quite vocal on their Red Tape Campaign – we hope to get situation resolved so it doesn’t become one of those!
Government is supposed to respond late spring or early summer of this year, but we must keep the pressure on them to do the right thing.
If you want to sign up with the Coalition directly, please go to https://www.therightreg.ca/supportl. You will also find details of regulations in “comments” part of site. If you can, please donate to coalition so it can continue to do the great work it has been doing on your behalf. They are not asking for much and it all helps.