New vs. Recycled Wood

Hi Kevin - Good Question. One clue to consider, is the manufacturer claiming it to be pre-consumer? (Consider that manufacturers don't always know how to authentically define pre-consumer and I've seen pre-consumer claims made that didn't really qualify). This one is clearly all about the definition of 'pre-consumer recycled content' and it may require some investigating on your part to find out the early life of those short-pieces. It is very likely they are 'new wood' unless they are starting off at the factory as post-consumer...particularly if the short pieces are recovered as off-fall from other moulding production (or similar operations) at the moulding factory in question OR if the shorts are readily marketable / valuable and clearly not headed for the landfill or as fuel for a biomass burner. The FTC has this to say about pre-consumer recycled content and this document is referenced in LEED 2009 MR 4: ---------------------------------------------------------------------------------- PART 260—GUIDES FOR THE USE OF ENVIRONMENTAL MARKETING CLAIMS § 260.13 Recycled content claims "If the source of recycled content includes pre-consumer material, the advertiser should have substantiation that the pre-consumer material would otherwise have entered the waste stream." (Excerpt from the Electronic Code of Federal Regulations - May 29th, 2013 located here): http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=1878c6359e4c8ee6abba22eb6671d114&rgn=div8&view=text&node=16:1.0.1.2.24.0.5.13&idno=16 ------------------------------------------------------------------------ I did some digging on this years ago to try and figure out what constituted 'substantiation' of a pre-consumer claim and at that time found a reputable / credible source (which I cannot recall at the moment, however I believe it was an FTC document) that required a commercial transaction to occur between (2) entities in which one transferred ownership of a waste product to another entity for their use as feedstock. Doug