Solid Wood Packaging Exemption to End in 2012

The ISPM 15 exemption for wood packaging material, including wood pallets, moving in either direction between United States and Canada is now slated to end completely in 2012.

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 time to utilize existing wood packaging material inventories, and 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.

Although the full implementation timelines have not been finalized, it is expected that the Canadian policies and the United States final rule will be published in the spring of 2011, at which time both countries will commence a period of “informed compliance”, during which 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.

Canada and the United States are aiming for full implementation of ISPM No. 15 for wood packaging material as early as the summer of 2012. At that time, 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.

Discussions between the CFIA, the United States Department of Agriculture (USDA), and border authorities in both countries, are currently underway, to establish fair harmonized approaches to wood packaging material inspection and enforcement. The CFIA will continue to provide notices regarding implementation through national industry associations, and publication on the CFIA website.

Should you have comments or questions regarding the implementation of ISPM No. 15 for goods moving between Canada and the United States, or wish to obtain information on becoming a certified producer of wood packaging for export, you may contact your local Area Forestry Specialist (as listed below) or send a question or comment through the Canadian Food Inspection Agency (CFIA) website.

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