Importing plywood to the U.S. is different from importing most timber products and it’s one of the fastest-growing import markets. Successful importers become part of an industry that is worth over $55 billion dollars worldwide and projected to keep growing. Continued success will depend on keeping up with changes and adapting your business model to meet them.
The Environmental Protection Agency (EPA) determines import regulations for plywood. The United States Department of Agriculture (USDA) tracks imports, but it only requires a permit if the wood is sourced from CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora) protected plants and trees.
Learn to navigate the regulations involved in importing plywood to the United States as a composite wood product or wood packing material.
One of the first things you should understand about importing plywood is that despite its name, it is not considered a timber or timber product regulated by the USDA. Plywood is considered a composite wood or engineered wood product along with medium-density fiberboard (MDF), oriented strand board (OSB), and particleboard.
The process by which the panels are created uses resins and glues that are regulated by the EPA. The majority of plywood panels can be imported to the U.S. without a permit. Exceptions exist depending on what type of timber gets used to create the panels in the first place.
Plywood is also commonly used as a wood packing material for transporting other timber that is subject to USDA regulation. It is used in the creation of packing crates and even for some wood pallets and skids.
Rising demands for construction materials in the U.S. have driven import quantities and raised values. Between 2019 and 2021, it went from being the 172nd most imported product to the 130th. From 2020 to 2021 the values of plywood imports went up by over 70% from $252 million to $430 million. With the housing boom still going, value and demand continue to remain high.
If you are looking to import other kinds of timber, check out our article, “Importing Wood to USA”.
The U.S. imports plywood from several different nations. Depending on whether the plyboard is hardwood or softwood, the top five list changes slightly.
Trends in construction, EPA regulations, and changing duty laws impact our ability to import from certain nations. Keeping track of changing circumstances can help you import quality products at reasonable rates.
As the world’s leader in plywood imports, the U.S. market demand increase has created opportunities for other nations to become major players in the trade. By the end of 2021, the U.S. was actively importing plywood from over 50 countries.
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Vietnam and Cambodia have especially grown as suppliers. In 2016, each of those nations accounted for less than $30 million and they are now among the top five exporting nations to the U.S.
For softwood plywood, the list looks different, but there are some common players.
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Regardless of where the imported plywood is shipped from, you should take care to look into local laws as well as U.S. import regulations. Choosing wood products from responsibly managed forests and factories can play a role in the import duties you may be required to pay.
The best place to import plywood from will depend on different factors. Ask yourself what type of plywood potential clients may want to purchase. Will they be used in a manufacturing capacity, like making furniture? Will they be repurposed into wood packaging material for transport?
How you answer these questions will play a role in choosing a nation of origin for your plywood imports.
Likewise, changing political climates can have both positive and negative effects on imports. Trade agreements and tariff changes are often affected during such circumstances.
Tensions between the U.S. and China led to Customs and Border Protection (CBP) doubling down on making sure that plywood tariffs were being paid correctly. As a result, antidumping and countervailing duties on hardwood plywood have made Chinese imports extremely expensive despite the volume they produce. This has driven down the value for what does get imported.
It’s possible that Russia’s current political conflict with Ukraine could lead to production interruptions and trade shutdowns. Considering they are the main source of Russian birch plywood, valued for its strength and appearance versus domestic plywood, such a shutdown could be damaging to importers.
On the flip side, nations such as Vietnam, Chile, and Canada, members of the CPTPP (Comprehensive and Progressive Agreement for Trans-Pacific Partnership), have experienced tremendous growth in their manufacturing and export capabilities since signing in 2018. While no longer a member of the CPTPP, the United States import industry has managed to benefit from their improvements.
The process for producing hardwood and softwood plywood is the same. Therefore, the regulations to import hardwood and softwood plywood are the same.
The type of wood used for the majority of each panel that makes up a board determines whether it's hardwood or softwood. While hardwood plywood is considered by most to be stronger, it is also more expensive and prone to splitting when used for industries such as furniture production.
Softwood plywood is less expensive and is used commonly in furniture or other applications where pliable wood is preferred. The trees that softwood plywood comes from also tend to grow faster, which also makes it the more sustainable option.
Many nations will only export one type of plywood, based on what commonly grows in the region. If you are looking to expand your current import business to include other products from the same area, this may be a factor in which type you choose.
Importers who do want to bring in both types of plywood should consider nations such as Canada, which manufactures hard and softwood plywood.
Unlike other timber and timber products, plywood does not require an Animal and Plant Health Inspection Service (APHIS) import permit from the USDA. This permit, PPQ form 585, only applies to timber and timber products that may be subject to Plant Protection and Quarantine (PPQ) procedures.
PPQ procedures are determined by the International Standards for Phytosanitary Measures (ISPM). Plywood is exempt from the ISPM’s phytosanitary certificate requirement because of the manufacturing process used to create it.
If the lumber used to create the plywood comes from protected timber sources, you may need to file for a CITES permit. As an organization, CITES works to regulate the trade of protected species through an animal, timber, and timber product import permit. CITES is an international organization and member nations follow regulations voluntarily.
Many nations use CITES regulations to frame their own national conservation laws. Participating nations manage their own enforcement of regulations, permits, and certificates.
CITES classifies tree species into three different appendices based on degree of endangerment and extent of regulation.
Trees listed in Appendix I are in danger of extinction and cannot be traded internationally. Heavy fines may be imposed by both the country of origin and the U.S. if you are found trading in plywood made from these trees.
Trees in Appendix II are not endangered but are closely monitored because they may resemble Appendix I trees and could become threatened if commercial use is not regulated. Products made from these trees can be traded with the proper permits.
See our article on rosewood imports for more information on importing CITES regulated timbers.
Appendix III is voluntary. A nation may submit a species to CITES to help with international regulation if they feel it is coming under threat.
When importing plywood, your export partner needs to provide the scientific name of the tree species used. You must then check that name against the database of endangered trees maintained by CITES.
The species name must be provided on at least one of these documents:
Should the species of timber used in the plywood fall into any of the appendices, further documents are needed. Each appendix will have different documentation requirements for importing the wood successfully. In general, importers would be required to apply for a Protected Plant Permit (PPP).
At times, it’s the exporting service that needs to apply for export permits. CITES issues export permits and re-export certificates to make them eligible as suppliers.
The CITES timber manual is a complex document covering the import of wood products as well as raw wood. A CITES representative may be the best resource for document follow-up if the plywood you import gets made with CITES regulated timbers.
While the U.S. uses CITES regulations and enforces the recommended permit system, we also have domestic protection laws. These are most commonly applied to protecting native North American flora and fauna. They also aim to stop the spread of invasive species that might tag along on certain imports, such as wood products.
Administered in part by APHIS, the Lacey Act is focused on fighting and preventing the illegal traffic of wildlife, fish, and plants. Importers working with goods related to any of those categories must submit a Lacey Act Declaration.
Plywood classified under HTS code 4412 requires importers to file a Lacey Act Declaration.
A Lacey Act Declaration must include information on:
While there are some exemptions, these should be discussed with an experienced and licensed customs broker familiar with wood and wood product imports.
We have established that the USDA does not heavily regulate plywood. From an agricultural standpoint, imported plywood does not present a biological threat.
Plywood regulations are instead based on the chemicals and emissions involved in their manufacture. The EPA has set standards in place for plywood as a composite wood product created using formaldehyde. These standards were created with the Formaldehyde Emission Standards for Composite Wood Products Act. Commonly known as Title VI of the Toxic Substances Control Act (TSCA), it began enforcing new regulations in March of 2019.
These regulations are specifically enforced on:
Anyone importing, distributing, or selling these products must comply with TSCA regulations. Importers must take care to source products from manufacturers meeting emission requirements. The EPA has provided a compliance checklist for importers to complete before starting the process of importing plywood to the U.S.
Once everything on the checklist is confirmed, importers certify that it meets standards by signing a TSCA section 13 certificate. For small businesses or new importers who may need help, the EPA provides some compliance assistance.
For new importers looking to fully dive into the plywood industry, it's recommended you contract or at least consult with an experienced customs broker. If shipments come into port and are found to be out of compliance, the EPA can file penalties of up to $37,000 per day.
A conversation with a customs broker that may cost you a few hundred is a worthwhile investment in that scenario.
In an effort to prevent pests and invasive species from entering the country, chemical treatments to fumigate shipments are often done. For timber products, heat treatments in kilns are also used. The manufacturing process to produce plywood submits it to both high heat and pressure which makes fumigation unnecessary.
The sheets that makeup plywood are glued and pressed together under hydraulic presses using immense pressure - as much as 200 psi’s worth. At the same time, the sheets are heated to about 300°F. This far exceeds the USDA’s requirement for heat treatment, which only requires temperatures of 133°F.
Manufacturing plywood removes any pests or other invasive lifeforms in the wood that would otherwise be removed by chemical or heat processes. It is because of this process that plywood is not as heavily regulated as other types of timber and timber products that enter the U.S.
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