ISPM No. 15 Exemption to End, but When?

While we like to stress there is more to consider than ISPM No. 15 when buying export pallets, it will be important for many to keep an eye on the Canada/United States exemption.

The ISPM No. 15 exemption for wood pallets and packaging  moving in either direction between United States and Canada will soon be discontinued, but the question is when? Canada is still waiting for the United States to make an announcement, according to one Canadian Food Inspection Agency official.

To take a step back, wood packaging material (WPM) moving in international trade (wooden pallets, crates, dunnage, etc. used in the transportation of goods) is regulated by many countries – to prevent the spread of pests – in accordance with the specifications described in the International Standard for Phytosanitary Measures (ISPM) No. 15 (2009) Regulation of wood packaging material in international trade.

In 2005, Canada and the United States implemented import requirements for wood packaging material consistent with ISPM No. 15, but agreed to forego implementation of these requirements on Canadian or United States origin wood packaging material moving between Canada and United States. Since then, both countries have completed a review of the pest-risk associated with wood packaging material and have concluded that several pest risks and logistical issues can be addressed by requiring wood packaging moving between Canada and the United States be compliant with ISPM No. 15 (2009). These include improved protection from the movement of pests present in one country; improved regulatory control of non-compliant wood packaging material which originated in a third country and improved ongoing usage of wood packaging material regardless of end destination.

Recognizing that the regulation of wood packaging material moving between Canada and the United States brings with it added costs and that time to required to utilize existing wood packaging material inventories as well as to establish new wood packaging material production practices, Canadian and United States regulators have agreed to establish a harmonized implementation process to phase in the ISPM No. 15 requirements.

On December 2, 2010, the United States published a proposed rule notifying their intention to regulate the import of wood packaging material from Canada in the same manner as wood packaging material entering from other countries.

The CFIA is also revising Canada’s regulatory policies for wood packaging material entering or leaving Canada:

  • D-98-08: Entry Requirements for Wood Packaging Materials Produced in All Areas Other Than the Continental United States will be revised to include wood packaging material from all United States.
  • D-01-05: Canadian wood packaging certification program (CWPCP) for export will be revised to include exports of wood packaging material to the United States.

After the implementation schedule has been announced, both countries will commence a three phase implementation.  During the  “informed compliance” phase, wood packaging material found non-compliant will be permitted to proceed to destination provided no pests are present. However, the carrier will be notified that shipments will be required to comply with ISPM No. 15 once full implementation occurs. If pests are detected, the countries will enforce actions such as requiring treatment of the shipment, or refusing the shipment to enter the country.

After full compliance, shipments with wood packaging material found to be non-compliant will not be permitted to enter the country of destination. Should pests be detected, the importer may also be required to treat the shipment to prevent escape of pests, prior to having it returned to the country of origin. The importer, or person in care and control of the regulated articles, is responsible for all costs incurred.

Check for updates on the CFIA website.


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