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More Changes on Deck for Solid Wood Packaging and Pallet Export Compliance

Posted by IFCO Systems
November 18, 2015

Shippers should take note that changes are once again in motion with respect to solid wood packaging and pallet compliance for international freight movements. Trade experts report that Customs officials are taking a closer look at compliance for certified used pallets, as well as less “top of mind” uses of wood packaging such as bracing and dunnage. Additionally, the rules for wood packaging and pallet movements between Canada and the U.S. are also expected to be falling under ISPM 15 requirements in the near future. Now is the time for shippers to be preparing for that shift. Let’s take a look at some of the key points.

What is ISPM-15 and why is it necessary?

ISPM 15 has been in place in the U.S. since its adoption in July, 2006. It is a program to ensure that solid wood packaging has been treated and certified so that it will not carry invasive pests internationally. Through specific markings, these wood products quickly signal to busy border officials that they have been treated, thus aiding in the goal of clearing the border in a timely fashion. The role of ISPM 15 in preventing the unintended spread of pests is a vital one. The devastation to forests and agriculture in many parts of the world has been huge already, with the potential for greater destruction if effective controls are not maintained.

What is exempt, and what is not?

Solid wood material thicker than 6 mm is covered by ISPM 15. Engineered wood, including plywood, or presswood, for example, is exempt.

What happens if…

If there are non-compliance issues with wood packaging, here is what you can expect:

  • Wood packaging material not having the ISPM 15 stamp must be re-exported.
  • Wood packaging material with the ISPM 15 stamp but having evidence of a wood boring pest. must be re-exported.
  • Wood packaging material that has the ISPM 15 stamp but is found with a non-wood boring pest may be fumigated by APHIS/PPQ.

Don’t forget the bracing and dunnage

While ISPM-15 stamp requirements are well understood for wood pallets and packaging, more infrequent shippers might not be aware that wood bracing components and dunnage are also covered by the program. Any solid wood components must be stamped to prevent loads from being rejected. One importer had a million dollar shipment of water slide components refused because of non-stamped wood bracing.

Be sure the used pallets you buy for export are compliant

Another area of concern has been used or recycled wood pallet compliance for international shipping. In this regard, warnings have been issued from USDA, as well as from Brepal, the British trade group that regulates EPAL pallets in the U.K and Ireland. Customs officials are on the alert for improperly marked or treated pallets. Pallet providers or others who alter ISPM 15 approved pallets and distribute them are liable for prosecution, and exporters who use non-compliant wood packaging may be subject to fees, fines and possible bans by trading partner nations. Violations to date have included civil penalties of up to $100,000 and felony convictions.

When it comes to wood pallets, customs brokers report that border inspectors often pay closer attention to individual used pallets having stamps from multiple countries, which have evidence of fresh replacement parts, or which are contaminated by soil or organic matter such as grass. Certified pallets are allowed to have up to one-third of their components replaced by certified components without recertifying the entire pallet (and so therefore might have stamps from the country of manufacture as well as from the country of repair) but from a compliance perspective it is preferable to buy a repaired pallet that has been retreated and freshly stamped, with the old stamps completely obliterated. Bottom line, it makes sense to purchase certified used pallets only from approved vendors - or to purchase new pallets.

U.S. - Canada ISPM 15 Exemption to End. While both the U.S. and Canada uphold ISPM 15 compliance for international shipments, movements between these countries has to date have been mutually treated as exempt from ISPM 15 requirements. Based on recent communications from U.S. and Canadian authorities, the exemption for Canada - U.S. shipments is now finally expected to be terminated in the next two years, following an informed compliance phase-in period. Soon these shipments will have to follow the same ISPM 15 stamp requirements as other international movements. For shippers moving freight across the Canada-U.S. border, now is the time to begin planning for that change.

While the ISPM 15 program generally runs smoothly, attention to these focus areas can help ensure a problem-free exporting experience.

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