New Wood Packaging Material Rules

The United States and Canada have been researching and discussing the possible termination of their mutual International Standards for Phytosanitary Measures 15 (ISPM 15) exemptions for solid wood packaging materials (SWPM) for about two and a half years. The United States Department of Agriculture (USDA) and the Canadian Food Inspection Agency (CFIA) have recently announced that both countries will move forward with a phased-in approach to removing the exemptions between our two countries. While final dates for the rules have not yet been published, it is expected that full enforcement will likely take effect by January of 2013.

The primary purpose of the ISPM 15 is to prevent the international transport and spread of disease and insects that could negatively affect plants or ecosystems, and has been mandated in many countries over the past decade. Untreated wood poses a significant risk of introducing non-native plant pests. Because wood packaging materials (WPM) are frequently reused, the origin of a particular piece of wood can be difficult to determine.

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The USDA Animal and Plant Health Inspection Service (APHIS) defines WPM as wood or wood products used in supporting, protecting, or carrying a commodity, and includes dunnage, crating, pallets, packing blocks, drums, cases and skids or pallets. The regulation does not affect manufactured wood material, loose wood packing materials, or wood less than 6mm thick - this would include alternatives such as paper, oriented strand board (OSB) or hardboard.Firms who currently import or export merchandise from or into the United States or Canada are already quite familiar with the requirement for all packaging material to be:

  1. Debarked
  2. Either fumigated with methyl bromide or heat treated
  3. Stamped or branded with an approved mark from an accredited inspection agency

While both the U.S. and Canada ceded to the ISPM 15 in 2005, agreed exemptions were made for WPM derived from trees harvested in either of the two countries, never having been moved outside of the two countries, and are still subject to inspection & other requirements of each country.

It is expected that while final enforcement may not come into effect until 2013, an “informed compliance” period will provide shippers and exporters ample time to fully understand and make necessary preparations to comply with the requirements. Once the informed compliance phase is in place, it is expected that verbal or written notifications will be provided to either the broker, forwarder or importer. Once that phase has expired, enforced compliance will follow, which will dis-allow shipments with non-compliant material entrance to the country of destination.Importers, exporters, wood packaging manufacturers and carriers will all be affected by these regulations. We will continue to keep you abreast of the changes as they are published, and we welcome your comments and questions.

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About Author
April Collier
LCB, CCS

April Collier is a Sr. Trade Advisor with Pacific Customs Brokers USA with over 35 years of experience in international trade. April has been a valued member of the Pacific Customs Brokers team for 14 years, having taking the lead in implementing the Compliance department for U.S. imports. Her current responsibilities include advising and coaching clients on a variety of regulatory compliance matters, and include expertise in Antidumping & Countervailing matters. April develops, maintains and conducts various training workshops and seminars for staff and importers related to regulatory compliance, including Free Trade Agreements, Valuation and HTS classification. In addition to her regular duties, April is also the CTPAT coordinator for Pacific Customs Brokers.

While we strive for accuracy in all our communications, as the Importer of Record it is incumbent upon your company to ensure that you are aware of the requirements under the new regulations so that you maintain compliance as always.