On September 16, 2005, U.S. Customs and Border Protection will begin enforcement of the U.S. Department of Agriculture’s "Guidelines for Regulating Wood Packaging Material in International Trade," also known as ISPM 151. ISPM 15 governs imports using wood packaging material ("WPM") and is being implemented to address the environmental problems arising from the import and export of wood-boring parasites between countries and continents. Insects such as the Asian Longhorned Beetle, Asian Cerambycid Beetle, Pine Wood Nematode, Pine Wilt Nematode, Anoplophora Glabripennis and others have appeared in the U.S. after being shipped across the Pacific from Asia within wooden pallets. The spread of these species have to date caused extensive damage to indigenous plant species and habitats in China, Japan, Brazil, USA, among others.
"The regulations on wood packaging material are necessary to ensure we avoid potentially severe damage to U.S. economic and agricultural interests," said CBP Director Michael C. Mullen, Office of Trade Relations. "I am asking the trade community to provide its full attention to this issue to ensure your company’s compliance with this rule. Do not risk the exportation of your cargo because of noncompliant wood packaging materials."
ISPM 15 rule requires WPM used to package imports such as pallets, crates, boxes and dunnage/packing used to secure ocean cargo loads to be treated and marked. Two treatments are approved for wood packaging material:
- Wood packaging material should be heated in a schedule that achieves a minimum wood core temperature of 56ºC for a minimum of 30 minutes. Kiln-drying, chemical pressure impregnation, or other treatments may be considered heat treatments to the extent that these meet the heat treatment specifications. The American Lumber Standards Committee administers the U.S. certification program for heat treatment.
- The wood packaging material should be fumigated with methyl bromide. The minimum temperature should not be less than 10ºC and the minimum exposure time should be 16 hours. National Wood Pallet & Container Association ("NWPCA") has been tasked by the APHIS to administer the fumigation program.
To certify treatment, the WPM must be marked with the International Plant Protection Convention ("IPPC") logo. The marking must also include the unique number assigned by the national plant protection organization to the company responsible for ensuring the WPM was properly treated, and either the abbreviation HT (heat treatment) or MB (methyl bromide). The use of red or orange should be avoided since these colors are used in the labeling of dangerous goods. Paper certificates of treatment will no longer be required or accepted. Recycled, remanufactured or repaired WPM should be re-certified and re-marked. All components of such material should have been treated.
In cases of noncompliance, the mispackaged cargo will be subject to immediate re-exportation, and treatment or destruction of the imports will not be permitted. Unmarked WPM may be separated from the commodity being imported if the inspector determines separation can be done without pest escape. However, a user fee will be assessed for supervising the separation of the WPM from the cargo.
Some types of WPM are exempt from these new requirements. WPM made entirely of manufactured wood material (e.g. particle board, plywood, oriented strand board) and wine and whiskey barrels, or WPM made entirely of thin pieces of wood (6mm thickness or less) is exempted from the treatment/marking requirements. Since determining wood origin will be very difficult and Canada is implementing ISPM 15 requirements, WPM arriving from Canada will be allowed to enter the U.S. without the IPPC mark. However, WPM from Canada will be inspected for pests.
Some member countries of the United Nations Food & Agriculture Organization, including Australia, Canada, EU and South Africa, have already implemented ISPM 15.
APHIS’s alert can be accessed on the agency’s website at: http://www.aphis.usda.gov/ppq/wpm/import.html.
Footnotes
1. Published in the alert by Animal and Plant Health Inspection Service ("APHIS") in September of 2004.
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