Solid Sawn Wood Packaging Regulations
Updated October 1, 2010
ISPM 15 Update
The new draft of ISPM 15 has been approved by the IPPC member countries, and is now in effect. There are two major changes that affect U.S. makers of export wood packaging. They are…
Bark Restriction. All wood packaging material should be free of bark, with exceptions for presence of any number of pieces of bark as follows: (1) bark will be permitted if it is less than 3 Centimeters (1-3/16 inch) in width, regardless in length. Or (2) if the bark is greater than 3 centimeters in width, the total surface area of a piece of bark must be less than 50 square centimeters. About the size of a credit card.
These peramiters have been in place by the EU since January of 2009, with full enforcement set for July 1st. PLEASE NOTE that beginning June 1, 2009, all US inspection agencies (including ours), will require that all wood packaging material meet or exceed these bark restrictions regardless of export destination, and will incorporate these requirements in their regular inspection visit. Items not meeting this requirement will be subject to hold and correction if the limitations are exceeded.
If you have any questions, please call.
Federal Quarantine
As of October 1, 2008, The Federal Government has added the states of Missouri, Pennsylvania, Virginia, West Virginia, and Wisconsin to its quarantine list along with the entire states of Illinois, Indiana, Ohio, Michigan, and Maryland for the Emerald Ash Borer. If your Company works in any way with Hardwood Packaging, Ash logs, Ash lumber, hardwood pallet, or hardwood firewood from any of these states you need to contact the closest USDA office in Illinois for information about what regulations and conditions you may need to follow.
Additional information about the Emerald Ash Borer regulations can be found at www.emeraldashborer.info/
Information about the Emerald Ash Borer regulations, quarantines and compliant businesses within the State of Illinois go to www.agr.state.il.us/eab/
USDA Plant Protection and quarantine Offices in Illinois
Des Plaines – 847-299-6939
Peoria – 309-681-6572
Champaign – 217-398-1698
Dunnage Stamp
The ALSC has issued a new mark for dunnage. At this time, Australia , New Zealand , and South Africa require material used specifically as dunnage must be stamped with this mark. Dunnage refers to wood packaging material used to secure or support a commodity, but which does not remain associated with the commodity. The mark may be used on dunnage for other countries other than the ones listed above. Carr Lumber is certified for dunnage, and can assist with any requirements you have.
The World Trade Organization (WTO) Solid Sawn Wood Packaging Standard or International Standards for Phytosanitary Measure 15 (ISPM 15) has been approved for implementation by participating WTO countries. The ISPM 15 standard requires all species of wood packaging to be heat treated or fumigated with Methyl Bromide to kill insects or fungus prior to export.
All shipments using any species of solid sawn wood packaging must be heat treated, or fumigated with Methyl Bromide (if allowed. Some countries such as China and South Africa do not allow fumigation at all), by the final assembler and marked with the approved ALSC stamp before being allowed entry to, or crossing through a participating country. Shipments going to any WTO country after their implementation date can be stopped at the border if they do not have the proper mark on the unit. The mark shows customs that all solid wood packaging material has been treated to meet the new global ISPM 15 requirements.
Non compliance can be a serious problem. Foreign as well as US customs have said they could turn back, repackage, destroy or quarantine items that do not meet the new standards. Delays and costs will be the responsibility of the shipper of record. One example is the United States standard that requires immediate re-export of non compliant products with no exceptions.
Country Information
Argentina
Enforcement date: January 1, 2006.
Australia
Australia now requires any solid wood material being used as dunnage to be marked with an IPPC mark rather than the HT mark. APHIS and the ALSC have issued a new mark with all IPPC criteria, but with the word “Dunnage” added to reflect its use for export shipments.
Also, Australia is requiring that all plywood or other veneer products be treated as solid wood packaging. This means that all plywood and other veneer products must be heat treated or fumigated with Methyl Bromide. The old plywood declaration is no longer allowed.
This new requirement will take effect on August 1, 2009.
Australia implemented the ISPM 15 standard on September 1, 2004. The current standard is still in force, and will not be replaced by ISPM 15, but will run in addition to the new standard. Australia has the additional requirement that all wood be free of bark. Also required is a Packaging Declaration. This must be filled out by the exporter, and be on their letterhead. Australia , as of January 1, 2006 will require wood packaging, break bulk, and air cargo be compliant with ISPM-15.
The 21 day requirement is no longer in effect.
If you have any questions, please call us for assistance.
http://www.affa.gov.au/corporate_docs/publications/word/quarantine/border/2004/notice_industry_19_03_04_update.doc
Bolivia
Enforcement date July 2005
Brazil
Enforcement date June 2006
Bulgaria
Enforcement date June 2006
Chile
Enforcement date June 2005
China
Enforcement date January 2006
Special Restrictions for China and North Korea : Heat treating is the only allowed treatment from countries where the pinewood nematode originates. Current countries on this restricted list are: USA , Canada , Mexico , South Korea , Japan , Portugal , Taiwan and Hong-Kong.
Columbia
Enforcement date September 2005
Costa Rica
Enforcement date March 2006
Cuba
Enforcement date October 2008
Dominican Republic
Enforcement Date July 2006
Ecuador
Enforcement date July 2006
Egypt
Enforcement date is October 1, 2005
European Union:
Enforcement date March 1, 2005. Please note that the bark free requirement for wood packaging is now moved to July 1, 2009.
E.U.: http://www.forestry.gov.uk/planthealth
Fiji
Fiji has implemented ISPM 15 as of January 2004. No enforcement date has been set.
Guatamala
Enforcement date September 16, 2005
Honduras
Honduras has implemented ISPM 15 as of February, 2006
India
Enforcement Date November, 2004
Phytosanitary Certificate required only for WPM not ISPM-15 compliant.
Indonesia
Enforcement date September 2009
Israel
Enforcement date October 2009
Jamaica
Enforcement date October 2007
Japan
Enforcement Date April, 2007
Jordan
Enforcement Date November, 2005
Lebanon
Enforcement Date March, 2006
Malaysia
Enforcement date January 2010
Mexico
Enforcement Date July, 2006
New Caledonia
Enforcement Date June, 2006
New Zealand
In June, 2006, New Zealand added the ISPM 15 standard as an option to their existing requirements. Either system may be used for wood packaging material. Starting November 2009, New Zealand requires debarked WPM.
Nicaragua
No official date of implementation.
Nigeria
Enforcement Date September, 2004
Norway
Enforcement Date January, 2008
Oman
Enforcement Date December, 2006
Paraguay
Enforcement Date June, 2005
Peru
Enforcement Date January, 2006
Philippines
Enforcement Date June, 2005
Puerto Rico
Puerto Rico will follow the U.S. in implementation and enforcement.
Romania
Enforcement Date January, 2007
Samoa
Samoa now requires that all Wood Packaging be ISPM 15 compliant.
Senegal
Senegal plans to implement ISPM-15 by August 15, 2010.
Seychelles
Enforcement Date March, 2006
South Africa
South Africa implemented ISPM-15 on January 1, 2005. South Africa also states that fumigation with Methyl Bromide is no longer acceptable as an approved measure for coniferous wood packaging for export.
South Korea
Enforcement Date June 2005
Switzerland
Enforcement Date March 2005
Sir Lanka
Enforcement date March 2010
Syria
Enforcement date April 2006
Taiwan , Penghu , Kinmen and Matsu
Enforcement date January 2009
Trinidad & Tabago
Implementation Date September 2005. No enforcement date has been announced.
Turkey
Enforcement Date January 2006. In addition, all wood packaging material from all countries entering Turkey must be debarked.
Ukraine
Enforcement Date October 2005
Venezuela
Enforcement Date May 2005
Vietam
Enforcement Date June 2006
United States Official Program Summary:
The WTO has turned over the compliance portion of the ISPM 15 standard to the USDA Animal Plant Health Inspection Service (APHIS). APHIS in cooperation with the American Lumber Standards Committee (ALSC) developed the US standard that meets or exceeds what ISPM 15 requires. The ALSC currently monitors and oversees the lumber grading agencies which currently control and certify the lumber mills grade stamping program. They now certify both the heat treating facilities and Solid Wood Packaging Manufacturers (SWPM).
Each SWPM must enroll with an ALSC agency if they are building or heat treating for export. Each SWPM will have a unique number assigned to its facility on their stamp. The ALSC program requires site inspections every 30 days at each manufacturing or heat treating facility by their agency to allow the use of their stamp. For a listing of ALSC agencies go to www.alsc.org
USDA Packaging Options:
Four options below are currently available for exporters under ISMP 15. Heat Treatment along with fumigation with Methyl Bromide are the only universal standards for solid wood listed in the ISPM 15 regulations.
1) Heat Treatment (HT): all solid wood used in the packaging must be heat treated to a core temperature of 56 Celsius for 30 minutes. In accordance with Annex I of ISPM 15
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2) Fumigate with Methyl Bromide (MB): fumigation with Methyl Bromide in accordance with Annex I of ISPM 15. In the US the EPA is currently phasing out Methyl Bromide as a chemical fumigant. See www.epa.gov/spdpublc/mbr
3) Manufactured Wood Packaging: Exclusive use of plywood, OSB, glue lams, etc only – no solid wood. Manufactured wood has been manufactured with heat, glue and or pressure does not need any certification under the standards since the heat used in the manufacturing process exceeds the ISMP 15. Countries such as China and Australia may have different requirements. However, please note that some countries, Australia for one, are taking a closer look at some types of manufactured wood. Check our web site for any updated information on this subject.
4) Plastic or Cardboard: Exclusive use of materials other than wood based.
USDA- APHIS- ALSC Heat Treated Solid Wood Packaging Program:
Solid Sawn Hardwood or Softwood Packaging: The program requires packaging assemblers or heat treating facilities to enroll with any one of the currently approved ALSC agencies. www.alsc.org
Packaging Assemblers: In order to use the ALSC mark the final packaging assembler must use either heat treated softwood, heat treated hardwoods or man made products such as plywood and OSB. The assembler is required to keep records and submit to on site monthly inspections by the grading agency they subscribe to. The mark is required on a minimum of two opposing faces of the completed packaging product.
Heat Treating Facilities: In order for a heat treating facility to use an ALSC mark they must provide time and temp charts on every oven charge, document material in each charge by species and sizes, submit to monthly inspections and provide the proper documentation on each order..
Frequently asked Questions
Q: What treatments are allowed?
A: Currently, there are two approved measures. Heat Treatment and fumigation with Methyl Bromide. Both treatments must be in accordance with Annex I of ISPM 15.
Q: Do repaired, remanufactured or recycled WPM need to be retreated?
A: Yes. In order to establish chain of custody, and maintain accountability, repaired, remanufactured and recycled wood packaging must be retreated and remarked. All previous ISPM 15 marks must also be obliterated.
Q: Are Phytosanitary Certificates available for wood packaging?
A: No. With the implementation of ISPM 15, APHIS will no longer issue Phytosanitary Certificates for wood packaging Material.
Q: What happens to existing packaging?
A: It must be treated with one of approved measures or stay out of the countries that have implemented ISPM 15.
Q: Does “ dunnage ” have to comply with the standard?
A: Ideally, dunnage should be marked in accordance with Annex II of ISPM 15 as having been treated with an approved measure (heat treat or fumigation with Methyl Bromide). If not, as a minimum, be made from bark free wood that is free from pests and signs of live pests. Currently, Australia, New Zealand and South Africa require the dunnage mark.
Q: If I buy and manufacture packaging using HT lumber do I automatically comply?
A: No. You must be certified to use the approved ALSC stamp for assembled packaging, or have the packaging treated.
Q: What happens if we do not comply?
A: Participating countries have indicated they will refuse entry, re-export, destroy or treat themselves prior to entry. The United States standard has non compliant shipments being immediately re-exported without exception.
Q: Other than the IPPC mark, is there other documentation needed?
A: No, the ISPM 15 standard requires the product to be stamped to show who treated the wood and where.
Q: What is the effective date?
A: Normally, each country will implement a start date within 6 months after they choose to accept the standard.
Q: Is this is the same standard as China is using?
A: Yes. China adopted ISPM 15 in 2006.
Q: Is this the same standard as Australia ?
A: As of September 1, 2004, Australia has added the ISPM 15 standard to their acceptable treatment program. ISPM 15 will run parallel with their current program, but not replace it.
Q: Who can meet the HT standard now?
A: Only those assemblers or heat treating facilities that subscribe to an ALSC agency and have been certified to use the ALSC stamp.
Q: Can I use pressure treated wood for now?
A: The ISPM 15 does not include pressure treated as an option. Some countries (The Netherlands is a current example) have prohibited CCA treatments due to the use of copper. The EPA is phasing out the use of CCA in wood as a whole. For other information contact the American Wood Preservers Association at www.awpa.com
Carr Lumber and Manufacturing has 2 ovens which total 14,000 cubic feet of available heating space under the ULSC/APHIS program. We are certified through NELMA for use of the "Final Assemblers" stamp for all types of wood products and the HT stamp for heat treated raw lumber. We have been heat treating products for export since the EU measure in 2001.
These ovens allow us to produce heat treated products through our shop, heat treat other manufacturers products, heat treat existing products that are already in transit as well as raw lumber stock for other manufacturers.
We welcome your questions and look forward to taking care of your compliance requirements in this or any other shipping issues We welcome your questions and look forward to taking care of your compliance requirements in this or any other shipping issues
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