Request for Extension of QCO—AIPMA

January 11, 2024
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Ref No. AIPMA/2023-24/75 Date – 28/12/2023

The Hon’ble Shri. Piyush Goyal

Union Minister of Consumer Affairs

New Delhi

Subject :- Request for Extension of Wood Based Boards (Quality Control) Order 2023, & Plywood and WoodenFlush Door shutters (Quality Control) Order 2023 implementations for MSMEs – Reg.

Respected Sir,

The Quality Control Orders (QCOs) notified by DPIIT during the end of August 2023 for wood-based industries sector – as in the subject above, respectively, is a major step towards standardizing quality of products manufactured in Bharat, as well as to effectively stop cheap product imports being dumped into our country in huge bulk.

The entire industry sector is set to benefit from the same, and we wish to fully support the introduction of QCO norms for the plywood, panels, and wood-based boards industry sector.

However, as the Chairman – All India Plywood Manufacturers Association (AIPMA), and as a representative of plywood & panel industry sector, I humbly wish to put forward the following aspects to be kindly considered with utmost significance and we sincerely hope for your kind consideration the following very important points specifically with regard to small and medium manufacturers in this sector, please:

1) Implementation of QCO for plywood & panel industries in such a short span has already created a lot of fear, panic and confusion within our industry. Majority of our sector consists of micro & small enterprises which run into 1000s of units.

Shri Naresh Tewari Submitting the Memorandum to union minister Shri Arjun Ram Meghwal, along with Mr Manoranjan kalia ex Minister Punjab, Mr KD Bhandari ex CPS n MLA Punjab, Mr Sarvjit Singh Makkar ex MLa n Mr TUSHAR Jain President industries association.

2) 99% of the factories have to use juvenile timber for peeling into core veneers for plywood manufacturing. This has created a situation of being forced to utilize smaller size core veneers, and pieces of veneers having multiple joints within plywood layers. In this situation, it is extremely difficult in such manually manufactured natural-based products to maintain the extremely strict mechanical property values enlisted in the BIS Standards. Increasing synthetic binder (resins used in manufacturing) usage will only further increase chemical imports, and also increase the costs of raw materials and end product.

3) The Indian Plywood sector is already facing lot of factory closures due to break-neck competition from alternative panel products like MDF, OSB, Agri-boards, PVC Foam Boards, WPC (wood plastic composite) Boards etc., in addition to large amounts of imported goods at cheaper prices.

4) We must be able to appreciate and support the fact that our plywood sector is one of the major employers of unskilled, semi-skilled and even illiterate people from all walks of life – irrespective of language & cultural barriers. The plywood sector in Bharat is a proud contributor to our economy in terms of providing employment – directly & indirectly – to millions of such labor & workforce across our country. All these labour forces face a bleak future, if the QCO norms are going to be strictly implemented in such a short span of time and space. The entire sector is in panic and fear.

5) 99% of factories in our sector depend entirely on external consultants and middlemen for enabling BIS Licensing and Quality Control maintenance and liaison. This puts the entire factories at the hands of these consultants and middlemen who are sure to make merry with the QCO implementation and harass our sector factories and managements. Also, the sector is also in fear & panic about the unlimited power of BIS representatives to enforce stop-marking, suspension of sales etc., which in turn will force the factories to stop functioning and stop the industry itself. We are in great fear about being forced to be at the mercy and will of BIS representatives and officials. The industry fears the beginning of extreme levels of corruption and even to the extent of extortion practices in the name of BIS Standards. We fear the stoppage of 100s of factories, loss of economy, business, and lakhs of jobs in the sector.

6) Lack of skilled/trained technical manpower – Our sector is entirely dependent on skilling of technical staff through IWST (ICFRE, erstwhile IPIRTI), at present. Only 30 to 35 students pass out of IWST every year, after completion of the 2-year training course in plywood manufacturing technology. Whereas, our sector is currently short of more than 6,000 technical/QC staff at the least, for immediate placement across the country. Training and skilling such a number of people and placing them timely, for maintenance of quality control will take at least a span of 2 years to be completed.

7) Out of an estimated three and half thousand factories across our country, there are only around 800+ factories having BIS License, as on today. Enabling licensing of other factories would need tremendous amounts of laboratory equipment, glassware, apparatus, and skilled manpower for maintaining quality control practices. Sourcing of reliable equipment needs more time as it cannot be hurried in such a short period of time. Industry is in fear of getting sub-standard equipment at high/premium prices, and techno-commercial consequences related to the same.

8) We also request your good self to initiate support to micro-, small- enterprises across the country to benefit from Common Facility Centre (CFC) schemes as well as CBTL (Cluster Based Testing Lab) Facility schemes offered under the provision of BIS and GoI. This will help small factories to keep up with the testing requirements by having 1 cluster for around 8 to 10 factories. It would also help them to reduce the cost of maintaining lab, technical staff and test requirements. This will also take around 2 to 3 years’ time to cover all the factories.

9) Fear and anxiety of Stop-Marking: At present, once goods are notified for Stop-Marking, under the mandatory QCO, affected factories cannot make boards and sell anymore, which would immediately render the factory dysfunctional and affect its very existence. Plywood manufacturing, being entirely manual & natural material-based product, with 100% juvenile farm-grown wood, is bound to have a lot of inherent as well as involuntary defects due to unavailability of full size rotary peeled core veneers.

Though we wish to undertake maximum care regarding strict quality standards for our consumers, there are still bound to be lower grade lots generated out of such manual, juvenile wood related processes. In this regard, we wish to request support of your kind self to initiate a process of marking Non-Conforming (NC) Boards separately for domestic manufacturers, and place them upon mutual consent with purchaser(s) as NC (Non-Conforming) Grade boards of slightly lower grade than the original standards conformance. This would go a long way in helping small factories to get some breathing period and work on improvements regarding the same. Introduction of NC Grade suggestions and amendments to current standards also would likely take some more time in this regard.

10) The situation is leading to a state where the entire plywood industry sector of Bharat will be at the mercy & will of a single government institution, where lakhs of jobs are at stake, lots of investments are at stake, lots of hopes & dreams are at stake, and lots of factories may face closure and irreparable losses & damage through their entire supply-chain and the economy.

Considering these dire situations our plywood sector is facing at present, I humbly wish to represent our domestic MSME plywood, wooden flush doors & panel manufacturing sector in order to seek your kind consideration and generosity in extending the QCO implementations by 3 years for our domestic manufacturers, so that our industry can ready itself to fully implement the same as appropriate. We fully support the steps towards QCO implementation, and are sure that our government would consider with heart and soul our industry’s current situations, and that we would be able to work together towards ensuring the vision of our Hon PM Shri Narendra Modi’s vision of providing 2 crore jobs a year and not a single hungry family, and making Bharat’s economy the greatest in the world.

Once again humbly requesting your kind self to consider extension period for the QCOs for our domestic manufacturers , and awaiting your considerate decision and support regarding the same.

Sincerely,

For All India Plywood Manufacture’s Association

Chairman

Mr.Naresh Tewari- (M)-98780-45566

Email Id: – nareshtewari2011@gmail.com

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