Requirements for Wood Packing Material Products (SWPM) Import/Export: USA, Canada, Mexico and Exportation
APHIS: Animal Plant Health Inspection Service
IPPC: International Plant Protection Convention
NAPPO: National Plant Protection Organization
I) Effective date is January 2, 2004
Important note 1: U.S.A.
Final Rule published in the Federal Register of September 16, 2004 indicates the law has been ratified with an effective date of September 16, 2005.
Important note 2:
Although the implementation for mandatory compliance has been delayed in the U.S., APHIS is urging all importers to begin implementing proper treatment of the wood products January 2004.
SCOPE: The Rule provides requirements for the entry of SWPM wood packing material other than loose wood packing materials, used or for use with cargo to prevent damage, including, but not limited to, dunnage, crating, pallets, packing blocks, drums, cases and skids".
Exempt commodities: All wood packing materials constructed from manufactured wood.
II) Approved Methods of Treatment as per IPPC:
1) Heat Treatment – to a minimum internal wood core temperature of 56 degrees Celsius for 30 minutes. Kiln drying, a chemical pressure impregnation, or other treatments may be used as a means of achieving heat treatments provided the above temperature and time requirements are met.
2) Fumigation - methyl bromide at normal atmospheric pressure at the following rates:
Minimum concentration g/m3 after:
Dosage --------------------------------------- (g/m3) 0.5 hrs 2 hrs 4 hrs 12 hrs 24 hrs 21/70 or above 48 36 36 31 28 24 16/61 or above 56 42 42 36 32 28 10/50 or above 64 48 48 42 36 32
The minimum temperature should not be less than 10 [deg]C/50 [deg]F and the minimum exposure time should be 24 hours.
3) Other Treatment Methods:
Each local government might approve other treatments, if it can be proven that such measures are effective in minimizing the risk of quarantine pests associated with untreated wood packaging materials. All costs associated with the verification that an alternative treatment method is effective in precluding pest movement must be borne by the importer.
III) Acceptable Marking of Treated Wood Packing Materials:
Officially endorsed by the NPPO of the country from which the wood packaging materials originates will be permitted entry if:
a) The IPPC symbol as per the Annex II of the International Standard for Phytosanitary Measures #15 [March 2002] in lieu of paperwork or certificates
b) Any other marking system provided by the NPPO of the country in which the wood packaging materials is produced.
The SWPM must be marked in a visible location on each article, preferably on the least two opposite side of the article, with a legible and permanent mark including a unique graphic symbol, the ISO two-letter country code for the country that produced the SWPM, a unique number assigned by the national plant protection agency of the country to the producer of the SWPM, and an abbreviation disclosing the type of treatment (e.g, HT for heat treatment or MB for methyl bromide)
Important note 3:
Until June 1, 2004- Canada, Mexico and USA may permit the entry of wood packaging materials from countries that do not have a certification system in place. The wood packaging materials must have been treated in accordance with the specifications and must be accompanied by a document officially endorsed by the NPPO of the country producing the wood packaging materials.
The document must identify the treatment that has been applied to the wood packaging materials, the date treatment was applied, the signature and date of the certifying official of the NPPO and the nature of the product accompanying the wood packaging materials.
Arrangements regarding the types of certificates to be used and the type of endorsement to be applied must be made available to the respective US, Canada or Mexico agencies prior to any wood packaging materials certified in this manner entering directly by the importer.
IV) Non- Compliance:
However, during a transition period, which ends June 1, 2004, an inspector may permit non-compliant wood packaging materials to be moved to a facility that safely disposes or process the wood packaging materials in accordance with the conditions specified as
- Incineration or
- Deep burial to a depth of no less than 3 meters that will not be disturbed, (non-compliant wood packaging materials must be immediately covered with soil/dirt) or,
- Treatment by heat treatment, kiln drying or fumigation as specified or;
Processing to produce wood by-products such as wood dust, wood mulch, wood fuel, paper finish mulch, recycled fiber wood and oriented strand board.
The inspectors must determine that this movement of non-compliant wood packaging materials is both practically feasible and does not constitute a biological risk to introducing a pest. Any costs incurred in the disposition of non-compliant wood packaging materials are the responsibility of the person or entity in care and control of the non-compliant wood packaging materials at the time of entry (including port or berthing facilities receiving untreated dunnage). Naturally, those costs would be re-billed to the cargo owner /customer.
Any costs incurred by the Carrier, including the cost of any inspection, detention, unloading, re-stuffing, re-exportation, or other action taken by the Carrier, as a result of a shipper's failure to comply with APHIS, CFIA or SAGAR regulations or orders regarding the importation of logs, lumber, other unmanufactured wooden articles, and solid wood packing material or regulated wood packing material (whether in actual use as packing for regulated or non-regulated articles or imported as cargo) into the United States, Canada and Mexico, shall be the responsibility, jointly and severally, of any person within the definition of "Merchant" in the "K" Line long form of Bill of Lading and shall be paid to the Carrier prior to release of the cargo to the consignee. "
V) Parties responsible for compliance and monitoring:
Important note 4:
The rules do not confer any reporting or verification requirements on ocean carriers to ensure compliance with the treatment requirements. The arrangement for the required treatment, the accompanying costs, and overall compliance with the rules (e.g. certificates of treatment) are issues to be dealt with by the shipper/exporter/consignor on the one hand and the importer/consignee.
VI) Declaration verbiage of Bill of Lading:
Shippers must ensure proper clauses are used on their Bills of Lading. This program will be paperless and no longer utilize paper Phytosanitary Certifications – therefore”
"SHIPPER ADVISES APHIS/CFIA Certification obtained" will be obsolete
Although, no required verbiage is required one might suggest something along the lines of:
"Shipper Advises APHIS/CFIA shipment is treated in accordance with ISPM 15"
VII) Clarification on Wood Packaging in bilateral trade USA-Canada as of September 16, 2005
The United States and Canada (excluding Mexico) have agreed not to regulate wood packaging between the two countries and recognize that the existing pest specific regulatory controls are sufficient. Additional details on the new requirements may be found on the following web sites:
- www.inspection.gc.ca/english/plaveg/for/cwpc/wdpkgqae.shtml choose Question 10 for the answer.
Canada Import Policy - Wood Packaging Materials
Canadian NAFTA Committee informs that the US Customs and Border Protection require that all shipments entering the USA from Canada must specify MADE IN CANADA . These pallets, wood packaging etc. do not necessarily have to be marked or stamped and the customers' customs documents or invoice and Bill of Lading can simply state, “that all wooden pallets or other WPM associated with this shipment where made in Canada.”
- CFIA Wood Packaging - Questions and Answers
- Entry Requirments for Wood Packaging Materianls Produced in All Areas other than the Continental United States
VIII) Other reference materials
Canadian Food Inspection Agency: