U.S. Exporters Cautioned by USDA Regarding Certified Wood Packaging Materials

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Buyers of used wood pallets for export should be cautioned to only purchase ISPM-15 certified pallets from approved vendors, and to understand basic compliance requirements so as to avoid leaving themselves exposed to quarantined loads or monetary penalties. The U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) recently issued a cautionary note in this regard, reminding U.S. exporters not to alter certified wood packaging material in any way or mix it with other, noncertified materials. (It is similar in tone to an announcement this month from Brepal directed at the UK pallet repair sector.) The remainder of the notice is as follows:

Individuals or companies who alter certified wood packaging material and distribute the altered product are not in compliance with APHIS regulations and the “International Standards for Phytosanitary Measures No 15, Guidelines for Regulating Wood Packaging Material in International Trade” (ISPM 15).

United States exporters who use noncompliant materials may be subject to international fees, fines, and possible bans by our trading partners. Repair and re-manufacture companies producing and distributing noncompliant wood packaging material could be held liable by the exporter and/or prosecuted by the U.S. Department of Justice.

APHIS’ wood packaging material regulations took effect in July 2006 and require wood packaging material moving internationally to have an ISPM 15 mark which is legible and easily visible on each piece of packaging; preferably on two opposite sides of the material. To find approved wood packaging material production companies in your area, or to learn how to become an approved company, please contact one of the 19 agencies authorized to perform wood packaging material inspections on behalf of APHIS.

Consult the listing of agencies and their contact information at the Web site of the ACCREDITED AGENCIES FOR SUPERVISORY AND LOT INSPECTION OF WOOD PACKAGING MATERIAL, April 2015. (Please note the locations of these agencies are the company headquarters and may not indicate their areas of service.)

APHIS’ wood packaging material regulations are based on the ISPM 15. ISPM 15 provides effective, equitable, and uniform standards (prescribed treatments, certification procedures, and standardized markings) that all nations could use to mitigate the risk from wood packing material. APHIS incorporated the ISPM 15 requirements into its import and export regulations (7 CFR 319.40-3(b) and 7 CFR 353.7 (d), respectively).

In accordance with these regulations, U.S. Customs and Border Protection inspects imported wood packaging material. American Lumber Standard Committee, through a Memorandum of Understanding with APHIS, inspects U.S.-produced or -reconstituted wood packaging material, using accredited third-party inspection agencies. These inspections keep noncompliant material out of the United States. APHIS is authorized through the Plant Protection Act to take the same legal action against fraudulent stamps as it would against counterfeit phytosanitary certificates. Violations of ISPM 15 requirements under the Plant Protection Act have resulted in a variety of enforcement actions, including an administrative decision and order, civil penalties of as much as $100,000, and felony convictions.