Disclosing moisture content in firewood sales: is it worth it?

For more than a century, Weights and Measures agencies have regulated the sale of firewood, stipulating that firewood be advertised and sold by the cord, and also requiring sellers to provide a written receipt with their name, address, price, amount and other details. 

Consumers still often struggle to get a full cord (and sellers still often struggle to make a living wage), but an equally important issue has never been addressed by the Weights and Measures bureaucracy: moisture content. Firewood advertised as “seasoned” or “dry” is often well above 20% moisture content and many buyers either don’t notice, don’t care or just assume they need to do the seasoning. But many buyers do notice, and do care and sometimes the neighbors of the buyer care. 

The issue is widely known but to date, very little has been done to address the problem beyond ongoing educational campaigns. The EPA, states, air quality agencies, companies, non-profits and the media for decades have recommended burning only “dry, seasoned wood,” and checking the moisture content of wood with a moisture meter to ensure it is less than 20% moisture content. However, the problem remains rampant and it is unclear if its getting better or worse. Congress could pass a law regulating firewood or the EPA could develop regulations which could require firewood retailers to disclose moisture content. 

They could go further, as the United Kingdom has, and require that only seasoned wood be sold. But simply changing Weights and Measures regulations may provide a lot of benefit. Weights and measures are developed by the National Institute of Standards and Technology (NIST) and the standards are then adopted – and enforced to varying degrees– by states. Many states do provide some level of enforcement and all of them engage in education, which changes the expectation and behavior of many consumers shopping for and purchasing firewood. 

If NIST agreed to the change, firewood sellers would have to buy and use moisture meters according to a specified procedure and provide the buyer with that information. It would not prevent unseasoned wood from being sold and it would not necessarily change if firewood is advertised as unseasoned or seasoned. It would only require the disclosure of the average moisture content. 

Logo from Alaska's program

Changes are made by NIST through a transparent process where stakeholders propose changes via Form 15, attend in-person Regional Association Meetings, and other relevant meetings. One or more regional association needs to support the amendment. One of the key regional meetings is the Northeast Weights and Measurements Association meet that occurs April 25 – 28. After that, a series of other meetings occurs through the summer and into the fall of 2022. If the item is deemed by a region to have merit, that region will forward the item for national consideration. A final rule could be voted on in July 2023, and it could come into effect on Jan. 1, 2024.

The success of this effort will be more likely if states and agencies support it. Formal support from one or more states will make the process easier since NIST is a state-based entity. Article 1, Section 8 of the U.S. Constitution grants Congress the right to “fix the Standard of Weights and Measures.” This law led to the creation of the Weights and Measures Division within the National Institute of Standards and Technology, which regulates products sold to consumers such as food, drink and fuel. These regulations set the units of measurement which must be used in the sale of such items and require certain information to be present. 

The NIST firewood brochure

The NIST Handbook, a document that is re-formulated every year at the National Conference on Weights and Measures (NCWM), lays out the guidelines for each kind of product. The document, Handbook 130, “Uniform Laws and Regulations in the areas of legal metrology and fuel quality,” as adopted by the 106th National Conference on Weights and Measures in 2021, says the following about the sale of firewood. First, it defines fireplace and stove wood as “all wood, natural and processed, for use as fuel or flavoring.” It requires that firewood be sold by the cord and prohibits selling it by the “truckload,” “pile,” or similar terms. Exceptions to this are of course pellets, which can be sold by weight, in addition to artificial compressed/processed logs, flavoring chips, and packaged natural wood. 

A US EPA flyer

Finally, it requires that non-packaged firewood be sold with a delivery ticket, which is required to have the following information: “2.4.5. Delivery Ticket or Sales Invoice. – A delivery ticket or sales invoice shall be presented by the seller to the purchaser whenever any non-packaged fireplace or stove wood is sold. The delivery ticket or sales invoice shall contain at least the following information: 

(a) the name and address of the vendor; 

(b) the name and address of the purchaser; 

(c) the date delivered; 

(d) the quantity delivered and the quantity upon which the price is based, if this differs from the delivered quantity; 

(e) the price of the amount delivered; and 

(f) the identity, in the most descriptive terms commercially practicable, including any quality representation made in connection with the sale. (Added 1975)” 

Amendments to the Handbook are always more complex than they seem and the exact language would have to be carefully crafted. It is nearly impossible to get an accurate average moisture content of a cord of wood, but possible to get a general idea based on a random selection of pieces. 

Flyer from the UK program

A 20% moisture requirement to sell firewood is not unheard of. The United Kingdom passed legislation in 2018, stating that “You can only supply or sell wood fuel in volumes of less than 2 cubic metres if it is certified as ‘Ready to Burn’. This confirms it has a moisture content of 20% or less.” To determine moisture content, sellers have to take 6 measurements of split logs, add them up and get an average efficiency.  The UK has developed an elaborate, consumer facing labelling program, Ready to Burn, to help consumers identify seasoned wood. 

The State of Alaska is the only state that we know of that has a statewide voluntary moisture content disclosure process and the City of Fairbanks has a mandatory process. In Fairbanks, “Beginning October 1, 2021, as defined in 18 AAC 50.076(k), only dry wood (wood with a measured moisture content of 20% or less) may be advertised, marketed or sold within the Fairbanks PM2.5 nonattainment area.” To determine moisture content, the regulations simply says “Cut open and measure three pieces of wood per cord. All Measurements Must be Taken Prior to Freezing.” There is also a requirement to write the moisture levels on a Carbon Copy Form (PDF), give one to the customer, send one to the Department of Environmental Conservation (DEC) and the seller keeps one copy for 2 years. 

A Canadian flyer

In Canada, they have specifications for firewood that includes moisture content, along with species, source and dimensions, but there are no requirements for sellers to disclose moisture content to our knowledge. These specifications are based on CSA ISO 17225-5:15 (R2020). 

Australia has a strong trade group, the Firewood Association of Australia, that maintains a voluntary code of conduct but they have not included the disclosure of moisture content. All they say is ”Where practicable, seasoned firewood (i.e. that with an internal moisture content of less than 25% (dry weight)) will be sold. Where unseasoned wood is sold it will be accompanied by advice on the time at which the wood will be sufficiently dry to burn.” 

As part of its due diligence to investigate this idea, the Alliance for Green Heat has had a lively debate among our Board of Directors and Board of Advisors who have put forth long lists of pros and cons. Once this process is finished, we will share the pros and cons here. 

If your organization, agency or company is interested in this issue, and think it is or is not worth pursuing, please contact John Ackerly at jackerly@forgreenheat.org.

The U.S. and Australia have Similar, but Distinct, Stove Regulation Strategies.

Australia is in the process of developing stricter emission standards for wood heaters and their approach is a fascinating glimpse into another regulatory culture. The strategies and cost – benefit analysis in Australia should be a valuable comparison for the EPA as it finalizes its New Source Performance Standards (NSPS) for US wood heaters. This post is an overview of an Australian report showing the financial gains created by stricter regulations on wood heaters.

In 2011 the Council of Australian Governments (COAG) identified air quality as a Priority Issue of National Significance and agreed that the COAG Standing Council on Environment and Water (SCEW) would develop a National Plan for Clean Air to improve air quality, and community health and well being, to be delivered to COAG by the end of 2014. The first stage of the National Plan for Clean Air will focus on particle emission reductions and a consultation Regulation Impact Statement which assesses alternative policy options that could be employed to reduce emissions from wood heaters in Australia, and establishes their relative costs and benefits.

The current Australian Standards that cover wood heater emissions and efficiency set a criterion of 4 grams of particulate matter (PM₁₀) per kilogram of fuel brunt (4g/kg). There is currently no efficiency criterion, but efficiency results must be reported on a label permanently attached to the appliance.

The report showed a large range of potential policy measures that could be implemented to reduce emissions from wood heaters. The potential measures fall into three major categories:

• wood heater design or performance standards;
• measures to promote compliance of retail models against these standards; and
• measures influencing the in-service operational performance of wood heaters.

These measures could be delivered through a range of policy 'vehicles'. The policy delivery approaches examined are a voluntary national program, a collaborative approach or a national regulatory approach.

Under the business-as-usual or 'base case' scenario, particulate emissions from wood heaters in Australia are expected to fall by around 5000 tons (or 12%) over the next twenty years, as old heaters are progressively replaced with new, lower particulate emitting heaters. The reduction in annual particulate emissions from wood heaters under the policy options examined, over and above the business-as-usual reductions, range from 3% to 18%.

The estimated costs to government of implementing the different policy options range from $15 million over the next twenty years to around $39 million. The estimated costs to manufacturers range from $240,000 to $17 million, the strictest boasting an efficiency standard of 60% as well as an emission limit of 1.5 g/kg. The health benefits of the options are estimated to range from $760 million to around $1,850 million over the twenty year assessment period. Although the greatest emission reductions are estimated for the most expensive option, the highest health benefits are estimated for another which has a shorter phase-in period for the new standards. The estimated benefits far outweigh the estimated costs of all options included in the analysis. The present value of the net benefits range from around $750 million to $1,800 million.

The report concludes the greatest net benefits are likely to be achieved via a national regulatory approach for managing wood heater emissions, rather than through a voluntary or collaborative approach. This could be achieved either through a Commonwealth regulation, a National Environment Protection Measure (NEPM) or through mirror legislation.

View the full report here.

Firewood Seller in Australia Selling Green Wood

We often run material from the Firewood Association of Australia because it's a great example of what a national firewood association can do to ensure dry wood is being delivered. This story is about overall firewood supply - and reports that one dealer is mixing in green wood.



"Reports from around the country are that this is shaping up to be a much better average firewood season. The ACT is on track for a record year, which is not surprising given below temperatures they have been experiencing. Supplies of good quality red gum into Melbourne and Adelaide are still readily available at this stage, which is an improvement from last year! Supply into Sydney seems to be just keeping pace with demand, which is well up on the same time last year. Only a couple of negative are the wet weather in Queensland which has restricted access to the main western ironbark resources for the Brisbane marker and the shift to green log supply by the FPC in Western Australia that is still causing some concerns. We also hear that one red gum supplier (not a FAA member) has started mixing green wood into semi-loads to extend his supply. This is really regrettable as it undoes a lot of the good work put in by our members to build on the reputation of red gum as a top quality seasoned firewood."