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Prero, Judah [jprero@sidley.com] 4/24/2018 4:28:30 PM Beck, Nancy [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=168ecb5184ac44de95a913297f353745-Beck, Nancy] Quick Formaldehyde question
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Nancy - hope all is well.
I have a quick question on the Formaldehyde Emission Standards for Wood Composite Products. Sorry to bother you personally about this, and I am sure you can direct this inquiry appropriately.
Under the regs, a distributor is any person or entity to whom a composite wood product, component part, or finished good is sold or supplied for the purposes of resale or distribution in commerce.
My question: if a warehouse receives a shipment of product, but never takes title to the product, and merely serves as a distribution facilitator, would that warehouse operator be considered a distributor?
Please feel free to pass on to the appropriate party - and thanks in advance for the help.
Judah
JUDAH PRERO Counsel
SIDLEY AUSTIN LLP 1501 K Street, N.W. Washington, DC 20005
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prero@sTdiey.com www.sidley.com
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Sierra Club v. EPA 18cv3472 NDCA
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