With the arrival of Brexit, solid wood pallets and packaging moving back and forth between the EU and the UK will be required to be ISPM 15 compliant, effective January 2021. Wood packaging associations, including the European Federation of Wooden Pallet and Packaging Manufacturers (FEFPEB) and TIMCON, are working diligently toward a smooth transition.
Wooden Packaging Material (WPM), including pallets and lightweight and industrial wooden packaging, is critical to the smooth trade of goods between countries, FEFPEB notes in a recent announcement. This fact, it says, was evidenced during the recent COVID 19 lockdown periods earlier this year, when the governments of several countries in Europe designated the manufacture and repair of pallets and packaging as ‘essential’ sectors, which should continue operating throughout the pandemic restrictions to ensure supplies of items including food, drink and pharmaceutical goods.
If the production, repair, or movement of WPM becomes disrupted, vital international supply chains are also disrupted. With the introduction of ISPM 15 requirements, a major change is coming. Whether it becomes a disruption will depend on the collaborative efforts of industry and enforcement agencies. When the UK fully leaves the EU on January 1st, 2021, ISPM-15 will take effect pallet movements between the two markets.
The current enforcement regime for ISPM 15 between EU countries is based on the fact that the plant health risk of WPM movements in these areas of the world is negligible. When the Brexit transition period ends at the end of 2020, this risk to plant health will not change. The wooden packaging industry is therefore clear in its assertion that there is no scientific or fact-based justification for a change in the rules or enforcement regimes applied at EU and UK borders from January 1st, 2021.
FEFPEB has been liaising with industry representatives in the UK and Europe. Together, the groups wish to ensure an aligned approach to this important issue.
• Continuing to work together to ensure that there are sufficient stocks of ISPM15-compliant WPM available for January 1st, 2021
• Asking plant health authorities in each EU country for confirmation that they will continue to employ a risk-based approach to ISPM 15 enforcement after Brexit. This would be fully consistent with EU legislation relating to ISPM 15 and would allow member states to continue to do this after January 1, 2021
In the UK, TIMCON has engaged the government’s Department for Environment, Food & Rural Affairs (DEFRA). They have issued a joint position statement in which TIMCON states that its members are working hard to increase production and treatment capacity to ensure adequate stocks of ISPM15-compliant pallets and packaging, and Defra clarifies that it advocates the continuation of a risk-based approach to enforcement to WPM movements entering the UK after Brexit.
“Ultimately, we feel that there is a real risk that there will be supply shortages in the latter part of this year and most definitely Q1 2021, which will be to nobody’s benefit,” Timcon president John Dye wrote to Irish minister, Pippa Hackett, adding that the organization was “fully supportive” of draft emergency legislation to try and solve the issue.
It is important, and in everybody’s interest, that we seek similar clarifications from the national wooden pallet and packaging associations and plant health authorities across Europe, FEFPEB states. As such, the group is calling on all its national association members to communicate the following points to their own membership:
• Continue to expand treatment and production capacity to provide an increase in stocks of ISPM15-compliant pallets and packaging to cover the demand for ISPM 15 compliant wood packaging material
• Encourage national government departments/national plant protection organizations (NPPOs) for clarity on the ISPM 15 enforcement regime after Brexit
FEFPEB is engaging other EU organizations to further communicate the importance that ISPM 15 inspections in all EU member states should continue to be carried out on the current low-risk basis. It is in the interest of businesses, and ultimately consumers, in both the UK and the EU, FEFPEB concludes, that stakeholders take an aligned approach and speak with a joint voice across the UK and EU markets.