CPA Comments on Proposed Lacey Act Requirements for Composite Plant Materials

CPA submitted comments today to the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) regarding the definition of “composite plant materials” under the Lacey Act and potential reporting requirements for products containing composite plant materials.  The Lacey Act is a law intended to combat trafficking in “illegal” plants, in part by requiring an import declaration to import certain plants and plant products.  Currently, “composite plant materials” is defined under the Lacey Act to include MDF and particleboard, but CPA in its comments called for an expansion of the definition to include hardboard. 

CPA also commented in support of a proposed approach to a de minimis exemption from the Lacey Act declaration requirement for composite plant materials based on documenting the average percent composite plant content, measured on the basis of either weight or volume.  This approach would acknowledge the significant challenge associated with determining with certainty the species mix of wood chips, shavings, sawdust and post-consumer recycled wood fiber that is contained in each particleboard, MDF and hardboard panel.  See CPA Comments.  More Info: Jackson Morrill


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