While it is understood the Lacey Act regulates imports and exports of endangered hardwoods and softwoods, aspects of the law govern engineered panel as well, explains the USDA at its Lacey Act website. Here are three FAQs.
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How do I declare the species of highly processed products such as Particleboard or MDF?
The filer must exercise due care in identifying the different species contained in their products. If after the exercise of you are still unable to determine the species of the plant material in a Composite Product, you may make use of the Special Use Designation (SUD) “Special Composite”. APHIS has created these SUDs in order to streamline the declaration of certain products for which identification of the scientific name is difficult. Please see the Guidance on Special Use Designations.
What types of products are considered Composite Products with respect to the Lacey Act Declaration?
For purposes of the Lacey Act Declaration, APHIS considers composite products to be: Products or materials that are made of more than one kind of plant that are mechanically processed into small fibers and bonded together chemically. This includes: Medium Density Fiberboard (MDF), High Density Fiberboard (HDF), Oriented Strand Board (OSB), Particle Board, Paper, Paperboard, and Cardboard.
Does plywood count as a “Composite Product” for the purposes of the Lacey Act Declaration?
Plywood and products made from plies of wood do not count as a composite product for use of the Special Use Designation “Special Composite” and must be declared normally. The “Special
Composite” Designation is only for products where the small fibers of more than one kind of plant have been mechanically processed, mixed and chemically bonded together (e.g. Medium Density
Fiberboard (MDF), High Density Fiberboard (HDF), Oriented Strand Board (OSB), Particle Board, Paper, Paperboard, and Cardboard.). Thin plies or layers of solid wood do not meet this requirement.
However, if a piece of plywood has a Particleboard core, that core is considered a composite material and the filer may use the Guidance on Special Use Designations. The other plies in this example
must be declared normally.
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