QCO on Synthetic Resin Adhesives

To

Sh. Sanjeev, Joint Secretary

Department for Promotion of Industry and Internal Trade (DPIIT)

Ministry of Commerce & Industry, Government of India, New Delhi

Subject: Comments on Draft Synthetic Resin Adhesives Synthetic for plywood (Phenolic and Aminoplastic) – Specification (Quality Control) Order, 2025 Request for Exemption for Captive Use in Plywood manufacturing units having BIS license mandatorily

 Reference: Meeting Notice dated 14.05.2025 – Stakeholder Consultation on 21st May 2025.

With reference to the above-mentioned stakeholder consultation meeting on the Draft Synthetic Resin Adhesives (Quality Control) Order, 2025, it was discussed that the Quality Control Order shall be applicable to synthetic resin adhesives as well as to plywood and other panel products.

This implementation, however, may impose an undue burden on plywood industries as a significant portion of synthetic resin adhesives, particularly those conforming to IS 848:2006, are manufactured and used captively by plywood industries for their day-to-day production. These adhesives are not intended for sale in the open market but are consumed internally during the manufacturing of wood-based panels. In contrast, there are other units that solely manufacture and market resin/adhesives to the panel industry.

We would like to bring to your kind notice that Synthetic Resin Adhesives (Quality Control) Order, 2025 implies that the adhesives should comply with cyclic boil dry test requirements corresponding to the grade of plywood. Additionally, tests such as shelf life, pot life, and pH are included to assess the quality of resin stored for long periods.

The shelf life and pot life of adhesives are important when they are stored for extended periods, as this may affect bond integrity.

However, the critical parameter to assess bond quality is the cyclic boil water resistance test. Plywood made using specified resin formulations and manufacturing parameters is subjected to this test, as required under IS 303, IS 4990 and IS 710 for the final product, all of which are covered under QCO 2024 for Plywood.

Importantly, the key parameter for bond quality or integrity of the final product is the water resistance test as specified in IS 303 for each grade of plywood (MR, BWR, BWP) under clause 11.3.1. Since water resistance test in the final plywood is mandatory and subjected to quality tests which are already covered under applicable QCOs, imposing mandatory BIS certification for adhesives used solely within such integrated production units may result in unnecessary duplication of regulatory compliance, increased cost and operational burden on the manufacturers, without any benefit in product quality assurance.

In view of the above, it is sincerely requested that a suitable exemption may be considered in the final Quality Control Order for synthetic resin adhesives, specifically exempting  adhesives manufactured and used captively within integrated production units, where the end-products (e.g., plywood) are already mandatorily standard certified under the applicable Quality Control Orders.

Please consider the following proposed exemption clause to be included in the Quality Control Order for IS 848:

However, adhesives manufactured and solely used captively within integrated plywood production units mandatorily having BIS licensing (as applicable under Quality Control Order 2024) shall be exempted from the additional requirements of this Quality Control Order”

We believe that the above inputs and proposed clause for exemption will be duly considered during finalization of the Quality Control Orders.

 👇 Please Note 👇

Thank you for reading our article!

If you don’t received industries updates, News & our daily articles

please Whatsapp your Wapp No. or V Card on 8278298590, your number will be added in our broadcasting list.