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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.
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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
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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
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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
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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
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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.
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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).
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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
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).
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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. Page 9
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.
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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.
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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
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).
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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.
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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.
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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