E tū Northland representative Annie Tothill said since the CHH did not respond to her letter, union lawyers would file papers for mediation.
She said CHH debited leave entitlements of about two weeks for each union member without prior consultation or agreement, which was a breach of the Holidays Act.
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Despite ample opportunity, she said CHH made no effort to consult with E tū on any Covid-19 related matters leading into the lockdown when concerns were raised in late March and again a week later.
She said no response was given until April 14 by which time the harvesting of leave had started.
"Members have expressed feelings of bring ripped off, undermined, deceived, robbed, cheated, devalued, stripped of their rights, ignored and unappreciated by CHH LVL," she said in her letter to senior human resources advisor Katie Hirst.
Tothill said other employers faced with the same urgency of the pandemic acknowledged their employees' right to be consulted about if and how leave may be accessed.
E tū is seeking the reinstatement of all annual leave, including alternate and lieu days, and long service leave and their cost to be met by the company.
For those who will lose their jobs, the union wants CHH to be the same value of the leave debited as compensation under the Employment Relations Act.
Additional compensation is sought for humiliation, loss of dignity, and injury to feelings.
CHH did not wish to comment.
It plans to complete its restructure by the end of August.
The plant presently runs 24 hours, seven days a week using renewable plantation pine to make laminated veneer lumber (LVL) which is an engineered wood product typically used as structural members for lintels, beams, mid-floors and roofs across residential and commercial building projects.