intnl standards wood packaging ispm15

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issues reference guide • industry backgrounder • september 2009

International Standards for Wood Packaging Material (WPM)

ISPM 15

One-hundred and thirty-four countries have signed onto an International Plant Protection

Convention (IPPC) agreement that creates a uniform system to control pests in wood packaging

material (WPM) – both hardwood and softwood – used in international trade.1

Under ISPM 15, all WPM (such as pallets, crates, boxes, and dunnage used to transport cargo)

must be either:

The standard is

called International Standard for Phytosanitary Measure 15 or more commonly “ISPM 15.” Each

country that signs onto the agreement must pass its own legislation implementing ISPM 15.

Because each country is legislating on its own schedule, U.S. exporters should be aware of

different implementation dates and national regulatory regimes.

• heat treated to a minimum wood core temperature of 56ºC for a minimum of 30 minutes; or,• fumigated with methyl bromide according to the following schedule:

TemperatureDosage Rate Hours of Exposure

Minimum Gas

Concentration

(g/m3)

2hr 4hr 12hr 24hr

21 C or greater 48 24 36 31 28 24

16 - 20.9 C 56 24 42 36 32 28

11 - 15.9 C 64 24 48 42 36 32

This fumigation schedule was revised by the IPPC in April 2006. Countries that require ISPM

15 are in the process of revising their regulations to include this new treatment schedule. For

1Much of the information in this paper is taken from: www.nwpca.com/PalletUser/ISPM15Background.pdf and from the NationalResources Canada site, www.forestry-quarantine.org/ISPM15_e.html.

http://www.nwpca.com/PalletUser/ISPM15Background.pdf



http://www.forestry-quarantine.org/ISPM15_e.html







The Almond Board of California welcomes the participation of all industry members and does not discriminate on the

basis of race, color, national origin, sexual orientation, gender, marital status, religion, age, disability or political beliefs.

example, the U.S. regulation still only requires 16 hour fumigations, but a new rule requiring the

24 hour fumigation is moving through the U.S. rule-making process.

WPM that was fumigated under the previous fumigation schedule does not need to be retreated

with the 24 hour fumigation. This new fumigation treatment only applies to new wood packing

materials.

Treated materials must display a trademark developed by the International Standards

Committee. This mark certifies the materials have been treated. There is no standard size or

required placement for the mark, but it must be permanent, and it is recommended that it be

displayed on two sides of the WPM.2

Samples are shown on the following page:

For more specific information on how to comply with wood packing material requirements,please contact either the American Lumber Standards Committee (ALSC),3 or the National

Wooden Pallet & Container Association (NWPCA).4

www.aphis.gov/ppq/wpm/export/requirements.html

The ALSC oversees the U.S. WPM heat

treatment program, while the NWPCA is charged with implementing the fumigation program.

International regulations are also available on the USDA/APHIS website at:

.

2Additional information on the mark may be obtained at: www.forestry-quarantine.org/ISPM15_e.html, a site sponsored by National

Resources Canada – Canadian Forest Service.

3 The ALSC website is: www.alsc.org/WPM_summary_mod.htm

4 The NWPCA website is: www.palletcentral.com/ExportTreatment/ExportTreatmentProg.asp

http://www.aphis.gov/ppq/wpm/export/requirements.html





http://www.alsc.org/WPM_summary_mod.htm



http://www.palletcentral.com/ExportTreatment/ExportTreatmentProg.asp











The following are answers to Frequently Asked Questions: 5

Is there is any required writ ten certification that the WPM has been properly treated and

stamped?

No. The international standard (ISPM 15) does not require written certification. The standard

and mark were developed in part to eliminate the need for paper certification.

Must the mark be applied to every p iece of wood in the treated article?

No. According to the International Forestry Quarantine Research Group (IFQRG), the mark only

needs to be applied to the packing unit, for example the pallet. Preferably it will be applied twiceon opposing vertical faces. It needs to be easily seen: “On pallets, this could be on the inner

faces of blocks because these are more visible to an inspector when looking inside a container

or anywhere else where pallets are stacked.”6

Is any marking required for manufactured wood packaging such as plywood, particle

board or veneer peeler cores?

There is no marking requirement for exempted WPM comprised entirely of wood based

products such as plywood, particle board, oriented strand board, veneer or material such asveneer peeler cores, as well as barrels containing spirits. However, if veneer peeler cores are

altered such as by sawing or shaping so that they lose their visual identity, they will need to be

regarded in the same way as non-manufactured wood and marked to show that they have been

subject to an approved measure in accordance with ISPM 15.

European Commission law requires treatment for “wood packaging material, in the form of

packing cases, boxes, crates, drums and similar packings, pallets, box pallets and other load

boards, pallet collars, actually in use in the transport of objects of all kinds, except raw wood of

6 mm thickness or less, and processed wood produced by glue, heat and pressure, or a

combination thereof , coming from third countries, except Switzerland.”

5 These questions and answers were initially based on information prepared by the AgOTC. They have been since modified usinginformation from the following websites and from input provided by APHIS:

www.aphis.usda.gov/ppq/wpm/export/faq-wpm.html www.forestry-quarantine.org/ISPM15_e.html

6www.forestry-quarantine.org/ISPM15_e.html

http://www.aphis.usda.gov/ppq/wpm/export/faq-wpm.html














Can individual companies certify their own pallets?

According to APHIS and the NWPCA, self certification is not an option. Certification must be

controlled by a national quarantine authority. In the U.S., USDA/APHIS has authorized theNWPCA to administer the wood packing material fumigation certification program. Four

agencies have been accredited to certify individual companies to conduct the fumigation

treatment.7

Once certified, companies may themselves apply the trademark to their packing

materials. Their activities and records are subject to audit by the accredited agency. Similarly,

the American Lumber Standards Committee has accredited 17 agencies to certify companies

conducting heat treatment.

Is kiln-drying the same as heat treatment?

The question and answer section of the IFQRG’s website makes it clear that kiln drying and

heat treatment are separate processes. Kiln-drying is not a quarantine measure and is

“designed primarily to reduce the moisture content of the wood to below, typically, 20%. It uses

artificial heat, but there is no minimum requirement for temperature and some kiln temperatures

are too low to ensure that all pests present are killed. Heat treatment means wood has been

heated to a core temperature of 56 degrees Celsius (133ºF) for a minimum of 30 minutes.”8

Does the fumigation or heat treatment need to be repeated?

Currently no. Under ISPM standards, once treated the WPM is considered free of pests.However, some governments have questioned the lasting effects of the treatments. This is one

part of the standard that the IPPC is studying, and that could be subject to future change.

Does WPM need to be re-treated and re-marked before being re-used?

As long as no alterations were made to the wood packing, and as long as it simply is being

reused and has not been modified or repaired, it does not need to be retreated and remarked.

Is this an issue for recycled WPM?

7www.nwpca.com/ExportTreatment/ProgramOverview.htm#accredited 8www.forestry-quarantine.org/ISPM15_e.html

http://www.nwpca.com/ExportTreatment/ProgramOverview.htm#accredited












If the WPM is repaired, remanufactured, or recycled, the IPPC mark must be removed and then

the WPM must be re-treated and re-certified.9

Are all new pallets being de-barked?

According to USDA/APHIS all new pallets are not necessarily debarked. ISPM 15 does not

require the wood packing material to be debarked unless there is a technical justification for this.

However, Bolivia, Chile, Indonesia, Peru, Samoa, and Turkey have debarking requirements.

Meanwhile, both Australia and New Zealand require “bark freedom.” Mandatory treatment or re-

exportation will be required for any WPM found to posses bark in these two countries. This

requirement is the subject of negotiation between the United States, New Zealand and

Australia. The European Union debarking mandatory compliance begins on J uly 1, 2009. The

U.S. and Canada also have studies underway related to debarking.

For imports into the U.S., how will Customs know if the WPM inside the container has

been properly t reated if there's no certification or statement on the Bill of Lading?

According to APHIS, customs officials rely on visual inspections.

Are exports of WPM from the U.S. to Hawaii , Puerto Rico, and other U.S. Trust Territories

required to be treated and marked according to ISPM 15?

No, provided that the WPM originates in the U.S. or Canada.

Some countries are asking for phytosanitary (plant health) certificates to be issued for

WPM. Does the U.S. issue a phytosanitary certif icate for WPM?

No, it is against APHIS policy to issue a phytosanitary certificate for WPM used in the transport

of commodities. If WPM is the actual shipment, then a phytosanitary certificate could be

required and APHIS would provide it. India, Lebanon, Nigeria, and Samoa are four countries in

which this issue has arisen. If any of these countries request a phytosanitary certificate forWPM used to transport other goods, the exporter is encouraged to contact APHIS.

9www.forestry-quarantine.org/ISPM15_e.html and www.aphis.usda.gov/ppq/wpm/export/faq-wpm.html













IMPLEMENTATION DATES OF THE WOOD PACKING STANDARD ISPM 15November 11, 2009

CountryImplementation Date and Additional Country Specifi c

Requirements

Argentina Argentina implemented ISPM 15 on J anuary 1, 2006.

Australia

Australia implemented ISPM 15 on September 1, 2004 requiring that

WPM be bark free and include a packaging declaration. Since

J anuary 1, 2006, Australia has also required that all non-ISPM 15

compliant WPM in break bulk and air cargo be treated as per

Australian ISPM 15 requirements. WPM in containerized sea cargomust also be treated, yet any WPM containing live insects, bark, or

other quarantine risk material can receive onshore treatment upon

arrival.

Packaging declarations must include the following information:

• Letterhead or company stamp• Date or vessel/voyage reference• Consignment identifier or numerical ink

• Straw declaration• Timber declaration and bark declaration where required• Signature

Bolivia

Bolivia implemented ISPM 15 on May 24, 2005 requiring that all WPM

be debarked. However, there is no provision that the wood be marked

with “DB”.

Brazil † Brazil implemented ISPM 15 on J uly 1, 2005.

Canada

Canada implemented ISPM 15 on September 16, 2005. Shipments

from the U.S. comprised of U.S.-origin WPM are exempt, but the

phrase “Wood Packaging Material of Continental U.S. Origin” must beincluded on all documents.





Chile

Chile implemented ISPM 15 on J une 1, 2005. All WPM must be

debarked.

Note: Chile will accept a phytosanitary certificate in lieu of the official

mark under ISPM 15. However, it is against APHIS policy to issue a

phytosanitary certificate for WPM used in the transport of

commodities.

China

Effective J anuary 1, 2006, China requires WPM to be treated and

marked in accordance with ISPM 15 with the following exceptions:

• Softwood packing material from the U.S. (and other countries withpinewood nematode).

• If fumigated, WPM must be fumigated for a minimum of 24 hours(note: this 24 hour requirement for fumigation exceeds the ISPM15 standard).

Note: These WPM requirements are also required for goods coming

from Hong Kong SAR, Macau, and Taiwan. Hong Kong SAR (see

requirements below) does not apply the standard, yet all goods

destined for China must be compliant to Chinese ISPM 15

requirements.

Note: In late August 2007, China complained it had discovered pests

in U.S. pallets marked with the ISPM-15 symbol.

Colombia Colombia implemented ISPM 15 on September 15, 2005.

Costa RicaCosta Rica implemented ISPM 15 on March 19, 2006.

Croatia †† Croatia implemented ISPM 15 on J anuary 1, 2007.

†Not referenced on the USDA/APHIS website, but cited in “ISPM 15 Solid Wood Packaging Update – March 3, 2008” from NationalWooden Pallet And Container Association.††Not referenced on the USDA/APHIS website, but cited in “Countries Requiring ISPM 15: Update: July 31, 2008” from Italian

Federation of Shipment Companies (Federazione Nazionale Delle Imprese Di Spedizioni Internazionali – FEDESPEDI) or obtained

from the UK Forestry Commission (www.forestry.gov.uk/forestry/INFD-6ABLSN).

http://www.forestry.gov.uk/forestry/INFD-6ABLSN








Cuba

Cuba notified the World Trade Organization (WTO; Notification

G/SPS/N/CUB/16) on J une 25, 2008 of the proposed implementation

of ISPM 15 requirements under the passing of Resolution No.

50/2008. ISPM 15 compliance will enter into force on October 1,

2008.

Dominican

RepublicDominican Republic implemented ISPM 15 on August 1, 2006.

Ecuador Ecuador implemented ISPM 15 on September 30, 2005.

EgyptEgypt implemented ISPM 15 on October 1, 2005.

European Union

EU implemented ISPM 15 on March 1, 2005 for WPM entering from

third countries (Switzerland excluded).

All WPM must be debarked and marked DB, with mandatory

compliance will begin on J uly 1, 2009.

Fiji †† Has indicated intention to adopt ISPM 15, but no implementation date

has been announced.

Guatemala Guatemala implemented ISPM 15 on J anuary, 2006.

Guyana †† Guyanese authorities have commented that they have implementedISPM 15. Unfortunately, there has been no official document found

concerning their implementation or compliance procedures.

Honduras Honduras implemented ISPM 15 on February 25, 2006.

Hong Kong

Hong Kong SAR does not enforce ISPM 15 standards, yet all goods

destined for transshipment must adhere to the ISPM 15 requirements

of their final destination. Goods transshipped through Hong Kong

SAR to China must be compliant with Chinese ISPM 15 requirements

(see above).

†Not referenced on the USDA/APHIS website, but cited in “ISPM 15 Solid Wood Packaging Update – March 3, 2008” from NationalWooden Pallet and Container Association.††Not referenced on the USDA/APHIS website, but cited in “Countries Requiring ISPM 15: Update: July 31, 2008” from Italian











India

India implemented ISPM 15 on November 1, 2004. Non-complaint

packaging material must be accompanied by a phytosanitary

certificate.

Indonesia †

Indonesia has issued a draft decree mandating that all WPM meet

ISPM 15 requirements and be bark and soil-free. All WPM must also

be accompanied by a packing declaration:

http://agotc.org/WoodPackingMaterials.doc

An enforcement date has yet to be announced, but it is expected

before the end of 2008.

J amaica J amaica has an export certification system in place, but will acceptISPM 15 compliant WPM.

J apan

J apan implemented ISPM 15 on April 1, 2007. The full text is

available at:

http://www.pps.go.jp/english/woodpack/import/Implementation_of_ISP

M_No15_E.pdf

J ordan J ordan implemented ISPM 15 on November 17, 2005.

Kenya †† Kenya implemented ISPM 15 on J anuary 1, 2006.

Lebanon Lebanon implemented ISPM 15 on March 26, 2006.

Mexico

Mexico implemented ISPM 15 on September 16, 2005. Full

enforcement began February 1, 2006.

Important Notice: The Mexican Ministry of the Environment and

Natural Resources recently notified the WTO (Notification

G/SPS/N/MEX/211) of new requirements for wood products including

WPM imported into Mexico to protect against Coptotermes gestroi

(Asian subterranean termite). New measures include application of

termicide if an infestation is discovered. The full text of the regulation

is available in Spanish at:

http://www.dof.gob.mx/nota_detalle.php?codigo=4986893.



http://www.pps.go.jp/english/woodpack/import/Implementation_of_ISPM_No15_E.pdf



http://www.dof.gob.mx/nota_detalle.php?codigo=4986893










Morocco †Export certification system in place, but will accept ISPM 15 compliant

WPM.

New

CaledoniaNew Caledonia implemented ISPM 15 on J une 1st, 2006.

New Zealand

New Zealand began enforcing WPM treatment requirements on J une

1, 2003. Such requirements vary from ISPM 15 requirements, but the

country accepts ISPM 15 certification.

Effective May 1, 2006, all WPM must be bark-free.

WPM must also be free from pests, not contain extraneous materials

(leaves, soil), and must be bark-free. Treatments are not mandatory,

but shipments arriving without treatment are subject to inspection.

For specific New Zealand documentation and treatment requirements,

please see: www.aphis.usda.gov/ppq/wpm/export/newzealand.html

Nicaragua †† Nicaragua implemented ISPM 15 on September 6, 2007.

NigeriaNigeria implemented ISPM 15 requirements on September 30, 2004.

Norway

Norway notified the WTO on J uly 24, 2007 (Notification

G/SPS/N/NOR/23) of its intention to implement ISPM 15 requirements

on imported WPM. Enforcement will begin on J anuary 1, 2009.

Norway does not require the debarking requirement.

Oman Oman implemented ISPM 15 requirements on December 1, 2006.

Panama †

Panama notified the WTO on April 15, 2005 (Notification

G/SPS/N/PAN/44) of its intention to implement ISPM 15 standard

requirements on imported WPM. Despite an initial implementation

date of February 17, 2005, a final date of implementation has yet to

be announced.

Paraguay † Paraguay implemented ISPM 15 requirements on J une 28, 2005.

http://www.aphis.usda.gov/ppq/wpm/export/newzealand.html

http://www.aphis.usda.gov/ppq/wpm/export/newzealand.html





Peru †Peru implemented ISPM 15 requirements on September 1, 2005. All

WPM must be debarked.

Philippines The Philippines implemented ISPM 15 requirements on J une 1, 2005.

Samoa †A phytosanitary certificate is required unless the WPM is ISPM 15

compliant. All WPM must be bark-free upon arrival.

Seychelles †† Seychelles implemented ISPM 15 requirements on March 1, 2006.

SingaporeSingapore does not maintain ISPM 15 requirements, yet it is

recommended for re-exportation.

South AfricaSouth Africa implemented ISPM 15 on J anuary 1, 2005. Softwood

packaging material must be fumigated for a minimum of 24 hours.

South Korea

South Korea Implemented ISPM 15 on J une 1, 2005.

Containers will be randomly selected for inspection to confirm WPM

complies with ISPM 15. Failure to comply with ISPM 15 will result in

the WPM being directed for treatment.

Note: Coniferous WPM from the U.S. and other countries with

pinewood nematode must be heat treated or fumigated for a minimum

of 24 hours.

Sri Lanka †† Sri Lanka has adopted ISPM 15 requirements, but has not

established a date of mandatory implementation.

Switzerland †

Switzerland implemented ISPM 15 requirements on March 1, 2005

along with the EU. WPM from EU member states do not require

ISPM 15 certification or treatment.

Syria Syria Implemented ISPM 15 requirements on April 1, 2006.

†Not referenced on the USDA/APHIS website, but cited in “ISPM 15 Solid Wood Packaging Update – March 3, 2008” from NationalWooden Pallet and Container Association.††Not referenced on the USDA/APHIS website, but cited in “Countries Requiring ISPM 15: Update: July 31, 2008” from Italian











Taiwan Taiwan implemented ISPM 15 requirements on November 1, 2005

and is expected to begin mandatory compliance on J anuary 1, 2009.

Tanzania †† Tanzania indicated intention to adopt ISPM 15, but no implementationdate has been announced.

Trinidad &

Tobago

Trinidad & Tobago implemented ISPM 15 requirements on

September 15, 2005.

Turkey Turkey implemented ISPM 15 requirements on January 1, 2006. All

WPM must be debarked.

Ukraine † Ukraine implemented ISPM 15 requirements on October 1, 2005.

Uruguay †† Uruguay implemented ISPM 15 requirements on May 31, 2006.





USA (including:

Guam and U.S.

protectorates)

The U.S. and its protectorates implemented ISPM 15 requirements on

September 1, 2005. Since February 1, 2006, non-compliant WPM

has been rejected -- non-compliant pallets and crates to be repacked

or re-exported at the cost of the importer.

On February 7, 2008, the U.S. also incorporated the 24-hr methyl

bromide fumigation schedule in their requirements.

Important Notice: Canadian WPM was exempt from ISPM 15

certification, yet the growing number of invasive species in the two

countries mandates the removal of the ISPM 15 exemption forCanadian WPM to further protect the safety of groves, orchards,

forests, and nurseries. The USDA and CFIA have developed an

action plan which involves a two-year ISPM 15 compliance phase-in

period for Canadian WPM entering the U.S., yet a start date has not

been announced. Implementation of the phase-in period will take

place after a one-year grace period to allow Canadian industry to

implement ISPM 15 compliance measures. The phase-in process will

proceed as follows:

• Phase One: Six months of informed compliance. Notices will beposted in connection with cargo that contains noncompliant WPM.

• Phase Two: Six months of rejection of violative noncompliantwood crates and wood pallets through re-exportation. Informedcompliance and notices posted in cargo with other types of noncompliant WPM (dunnage, blocking and bracing).

• Phase Three: Full Enforcement on all ISPM 15 articles of regulated WPM entering the U.S. Shipments containingnoncompliant regulated WPM will not be allowed to enter.

Venezuela Venezuela implemented ISPM 15 requirements on J une 1, 2005.

Vietnam Vietnam implemented ISPM 15 requirements on J une 5, 2005.





ISPM 15 VIOLATIONS

According to APHIS Officials, there were 336 notifications of ISPM 15 violations among U.S. exports from

August 2007- August 2008. Below is a list of the countries reporting violations as well as their frequencyover the last year:

Country Number of ViolationsArgentina 4

Brazil 138Canada 15Chile 2

Croatia 1

EuropeanUnion

Austria 3

EU Total: 143

Bulgaria 1Czech Republic 2

Denmark 1

Estonia 1Finland 1France 1

Germany 54Latvia 14

Lithuania 2Netherlands 2

Poland 6United Kingdom 55

Israel 2South Korea 31

Total 336

Result of ISPM 15 Violations

Below is a breakdown of the results of the ISPM 15 violations during the August 2007- August 2008period:

Result of the ISPM 15 Violations Number of ViolationsHeld 7

Treated and Released 132Destroyed 166

Entry Refusal 6Under Investigation 1Action Not Specified 24

intnl standards wood packaging ispm15

Documents

new fumigation treatment

international regulations

new treatment schedule

previous fumigation

fumigation program

international trade

following schedule

new wood packing materials