CFIA's Wood Certification Programs -
Canadian Heat Treated Wood Products Certification Program (CHTWPCP)
Canadian Wood Packaging Certification Program (CWPCP)

Questions and Answers

1. General questions on the international requirements for the movement of wood packaging materials
2. Questions related to the application process for registration
3. Questions related to registration of a facility
4. Questions related to audit inspections
5. Questions pertaining to remanufacturing facilities
6. Questions related to dunnage
7. Questions related to the appropriate use of IPPC stamp and other HT stamps
8. Questions related to fees
9. Questions specific to the CHTWPCP
10. Questions specific to the CWPCP
11. Questions related to CFIA policy directives, reference documents
12. Questions related to quality manual elements
13. Questions related to Heat Treatment certificates
14. Questions related to Technical requirements of heat treating
15. Questions related to treatments

A. General questions on the international requirements for the movement of wood packaging materials

Q.1  We understand that there are international requirements for the movement of wood packaging materials. When did this take effect?

In March 2002, the International Plant Protection Convention's (IPPC's) Fourth Interim Commission on Phytosanitary Measures (ICPM 4) adopted new guidelines for the uniform regulatory control of wood packaging moving in international trade: International Standards for Phytosanitary Measures (ISPM) 15: Guidelines for Regulating Wood Packaging Material in International Trade. ISPM 15 describes guidelines for harmonized phytosanitary measures applicable to wood packaging material.

Q.2  What exactly are these international guidelines for the movement of wood packaging materials, as described in ISPM No. 15?

All non-manufactured wood packaging (e.g. pallets, containers, drums, etc.) shipped to any country that has adopted these requirements must be either:

• Heat treated or kiln dried to a minimum core temperature of 56°C for at least 30 minutes in a certified facility. Treated wood must display a recognized certification mark enabling identification of where and by whom the treatment has been carried out; or
• Fumigated with an approved chemical by a certified facility.

Packaging material comprised entirely of manufactured wood (e.g. veneer, oriented strand board, particle board, plywood, etc.) or non-wood material (e.g. plastic, metal, cardboard, etc.) are not regulated and do not require certification.

Q.3  Do the ISPM No. 15 wood packaging import requirements apply to all species of wood?

Yes, these guidelines apply to all species of both softwood and hardwood lumber.

Q.4  What are the consequences for exported Canadian wood packaging that does not comply with the wood packaging import requirements?

If Canadian wood packaging does not comply with the requirements, the following may happen:

• Refused entry (of the shipment) into the importing country; or
• Destruction of the wood packaging; or
• Treatment of the wood packaging at the port of entry; or
• Detention for extensive periods while the consignment is under quarantine.

Q.5  Who will enforce the international wood packaging import requirements?

Once the wood packaging arrives in a country which has implemented ISPM No. 15, the Plant Protection Organizations of that country may inspect the wood packaging materials to ensure the new import requirements are met.

Within Canada, the CFIA will use different measures to enforce the wood packaging regulations. The choice of the measure to be applied will vary according to the severity of the infraction. These may include the issuance of notices of non-compliance up to monetary penalties. The CFIA's intent is to ensure compliance with the phytosanitary requirements of importing countries and will take the appropriate actions to ensure that Canadian products move expeditiously. As such it is important that the integrity of the CWPCP be of the highest standards.

The Canada Border Services Agency (CBSA) is currently performing the inspections for wood packaging arriving in our major ports.

Q.6  Do the wood packaging import requirements apply to Canadian non-manufactured wood packaging shipped to a destination country?

Yes.

Q.7  What type of packaging materials are exempt from international IPPC wood packaging import requirements?

The international wood packaging requirements do not apply to:

• Manufactured wood (e.g. veneer, oriented strand board, particle board, plywood, etc.); or
• Non-wood material (e.g. plastic, metal, cardboard, etc.).

*Note: Packaging must be entirely comprised of one of these materials or a combination of these materials to be considered exempt from the international wood packaging import requirements. Packaging made from these exempt materials that also contain coniferous non-manufactured products are regulated and must be certified.

Q.8  What is non-manufactured wood?

Non-manufactured wood is untreated raw wood which is derived directly from the tree and has only undergone primary alterations (e.g. debarking, sawing, shaping, etc.). Non-manufactured wood is often used to construct wood packaging materials such as pallets, drums and spool cases.

Q.9  What is manufactured wood?

Manufactured wood is wood that is comprised wholly of wood based products that have been entirely created by wood glue (e.g. plywood), heat and pressure (e.g. particle board) or a combination thereof. Plywood, oriented strand board, particle board and veneer are examples of manufactured wood that are exempt from the EU softwood packaging import requirements.

Q.10  Does Canada have wood packaging import requirements?

Yes. Please review D-98-08 : Entry Requirements for Wood Packaging Materials Produced in All Areas Other Than the Continental United States.

Q.11  Did Canada participate in developing the International Standards for Phytosanitary Measures (ISPM) 15?

Yes. Canada participated in the development of ISPM 15: Guidelines for regulating wood packaging material in international trade, to reduce the risk of pest transmission into all countries, including Canada.

Q.12  What is the International Plant Protection Convention?

The International Plant Protection Convention (IPPC) is a multilateral treaty relating to plant health. The goal of the IPPC is to develop generalized methodologies to prevent and mitigate the introduction and spread of pests of plants and plant products. The IPPC provides a framework and a forum for international cooperation, harmonization and technical exchange between contracting governments dedicated to achieving and maintaining this goal.

Q.13  When did ISPM No. 15 come into effect in Canada?

The CFIA began the phase-in of enforcement of policy D-98-08: Entry Requirements for Wood Packaging Materials Produced in All Areas Other Than the Continental United States on January 2, 2004.

Q.14  Who should I contact for assistance?

Please contact a local CFIA office.

B. Questions related to the application process for registration

Q.1 Where can I get a copy of the application form for registration for the CWPCP?

The application form (CFIA/ACIA 5528) can be downloaded from the CFIA website.

Q.2 Where can I get a copy of the application form for registration for the CHTWPCP?

The application form (CFIA/ACIA 5340) can be downloaded from the CFIA website.

Q.3 There are three registration options indicated on the registration form for the CHTWPCP: a) minimum HT labelling b) ISPM No 15 marking c) brokers/shippers. For facilities that heat treat their own products, and also plan to consolidate or ship wood that was heat treated by another facility, what is the applicable option?

This facility would choose the heat treatment option. The ISPM check box is used to record the fact that the facility also wishes to have the option of marking dunnage with the ISPM no. 15 recognized mark and that it understands the expectations which come with this application. A 5 digit number will be issued to all facilities where a request is received via each Grading Agency and CLSAB.

C. Questions related to registration of a facility

Q.1 If a Heat treatment facility and the actual shipper are under the same ownership, but in two separate locations, are they required to obtain a two separate registration numbers or can they operate under one single registration certificate?

Here are some considerations. If the HT facility and Shipper are located next to each other and the owner can address all of the elements of the QSM 02 in their Quality Manual (which would consist of a section with the quality system in place at the HT facility and a section with the quality system in place at the shipping location), we could consider one registration number. It must be understood that if a serious non conformance (which may affect the integrity of the program and result in the suspension or cancellation of the registration number) is identified at one of the locations, both locations will be affected. If both locations are registered separately under two different registration numbers, one location may be able to continue to operate even though the other location may be suspended or cancelled.

Q.2 What is the logistical flow involved for the issuance of a facility number?

Grading Agencies will send the facility s application form for participation under the program to CLSAB and will sign-off on the facility s Quality Manual. The CLSAB will sign off on the application and will forward the application to the Area Network Specialist for approval. The completed application will be forwarded to the registration office in Ottawa for processing and issuance of a registration number. The registration certificate will be issued, faxed to the facility, the Service Provider, the Network Specialist and the official certificate will be mailed out to the actual facility.

Q.3 What will be the CLSAB process for registering facilities under the CHTWPCP?

Grading Agencies will send the facility s application form for participation under the program to CLSAB and will sign-off on the facility s Quality Manual. The CLSAB will sign off on the application and will forward the application to the Area Network Specialist for approval. The completed application will be forwarded to the registration office in Ottawa for processing and issuance of a registration number. The registration certificate will be issued, faxed to the facility, the Service Provider, the Network Specialist and the official certificate will be mailed out to the actual facility.

D. Questions related to audit inspections

Q.1 For CFIA audits of the facilities registered under the CHTWPCP, who will the audit team be comprised of?

The audit team members could include plant protection inspectors, regional program officers, and network specialists. All members are required to have passed the Understanding Audits training course, or other related ISO audit training sessions.

Q.2 Why are the audit checklists used by the Service Provider and the CFIA different?

CLSAB and Grading Agencies have checklists that are different from the CFIA. While the CFIA's checklist is to verify compliance of the facility to the program, the ultimate purpose of the checklist is to verify the Service Provider s ability to assure the facility s compliance to the program and to verify that the Service Provider fulfills its responsibilities under the program. All non-conformances found by the CFIA at the facility are to be followed-up by the Service Provider. The CFIA follow-up activities are conducted in conjunction with the Service Provider s actions to assure compliance.

Q.3 How will CFIA officially report on audit inspections?

An audit report cover sheet will be provided to field inspection staff and will be included in the QSM 06 document entitled "The CFIA Quality System Module for the Verification of the CHTWPCP and CWPCP Certification Program."

E. Questions pertaining to remanufacturing facilities

Q.1 A remanufacturing facility produces lumber products and stamps this product with their affiliated grading agencies stamp (KD-HT mark). This facility does not heat treat wood (i.e. does not have heat treatment chambers). Dunnage is another product that is manufactured at this facility, and this dunnage is stamped with the CA-XXXXX D-HT mark. The facility is now interested in expanding their product line, and would like to manufacture wood pallets, and stamp these with the ISPM No. 15 wood packaging recognized mark. Can their affiliated grading agency provide them with the wood packaging certification service?

Yes, facilities registered under the CHTWPCP can manufacture dunnage and pallets to meet ISPM No. 15 requirements. These activities will be overseen and audited by the facilities' grading agency.

Q.2 Can a service provider approved by the CFIA provide a facility that remanufactures wood packaging materials the ISPM wood packaging mark and other services under the Canadian Wood Packaging program (CWPCP)?

No, wood packaging facilities heat treating lumber for the manufacturing of their own wood packaging material, or heat treating the actual wood packaging material (i.e. wooden crates, pallets, boxes, etc) to meet the ISPM No. 15 standard, will have the option to register under the CWPCP or the CHTWPCP. Facilities which are exclusively in the business of producing wood packaging material and which do not provide the actual heat treatment will be required to register under the CWPCP.

Q.3 What procedure is required regarding traceability for facilities stamping fingerjoined dunnage with ISPM 15 stamp?

The facility must indicate in their quality manual and prove during audit inspections that the wood in the fingerjoined stock has been Heat Treated at a registered facility.

F. Questions related to dunnage

Q.1 Can the ISPM No. 15 mark be applied on dunnage?

For dunnage, the ISPM No. 15 mark must show D-HT (i.e. CA - XXXXX - D-HT).

Q.2a) Can a peeler core product be stamped with the ISPM No. 15 dunnage mark (i.e. CA - XXXXX - D-HT)?

The ISPM No. 15 dunnage mark can only be used on wood that has been heat treated and produced under either the CHTWPCP or the CWPCP.

Q.2b) Is there a mark for identifying peeler core dunnage?

There is no specific mark for identifying peeler core dunnage, other than the D-HT mark. (i.e. CA - XXXXX-D-HT) as described above.

Q.3 Under what conditions can the dunnage stamp D-HT be used?

The D-HT stamp must be applied on dunnage material, intended to brace a commodity as opposed to enclose or support a commodity. Each piece of dunnage must bear the D-HT mark. The D-HT stamp is not allowed on lumber intended for the manufacturing of wood pallets, or crates.

G. Questions related to the appropriate use of IPPC stamp and other HT stamps

Q.1 Is it necessary when marking lumber with the IPPC 5 digit number to also include the grading agency logo and mill number (the agency and mill mark would be a separate stamp)?

When marking lumber (dunnage) or other wood packaging material with the ISPM No. 15 international recognized mark, the 5 digit number issued by the CFIA must be used to identify the registered facility. The grading agency logo and mill number must not appear inside the ISPM No. 15 stamp, but it may appear anywhere outside this actual stamp.

Q.2 Can facilities which are registered under the CHTWPCP which are NOT wood packagers, heat treat wood packaging for facilities who are registered under the CWPCP, but mark the heat treated packaging (pallets) with the CHTWPCP registered facility mark?

A facility who is in the business of heat treating wood which is registered under the CHTWPCP, which also heat treats wood packaging material, can affix the ISPM No. 15 recognized mark on wood pallets or dunnage. That facility does not have to be registered under the 2 programs. If the facility supplies the heat treated wood to a wood pallet manufacturer, it only needs to identify the heat treated wood in accordance to the CHTWPCP for that purpose. It will be the responsibility of the wood packaging manufacturer to register under the CWPCP and affix the ISPM No. 15 recognized mark on the pallets if they are intended for export.

Q.3 Can any deviations of IPPC stamp be tolerated?

An example of the IPPC stamp is included in Appendix 1 of D-01-05 and also Appendix 4 of D-03-02. The limits of deviations were reviewed by the ISPM review group during their meeting in mid June in New York. Recommendations from that meeting will be proposed to the IPPC for incorporation into a revised ISPM No. 15 document. As the standard is revised Canada will incorporate changes in both its export and import policy directives.

Note: Countries may permit deviations from the standard established in ISPM No. 15, however as with all phytosanitary policies the extent to which a particular country may accept a deviation from the standard rests with the national plant protection organization of the importing country. As such CFIA advocates that producers do not deviate from the specific example and information provided in Appendix 1 of D-01-05.

Q.4 Under what conditions can the dunnage stamp (D-HT) be used?

The D-HT stamp must be applied on dunnage material, intended to brace a commodity as opposed to enclose or support a commodity. Each piece of dunnage must bear the D-HT mark on two opposing sides. The D-HT stamp is not allowed on lumber intended for the manufacturing of wood pallets, or crates.

Q.5 Can lumber stamped HT by an American agency accredited by the American Lumber Standards Committee be used by a Canadian remanufacturing facility under the CHTWPCP and be restamped HT using the Canadian agency stamp?

All remanufactured stock stamped HT must have been previously stamped HT by a facility accredited by the American Lumber Standards Committee.

H. Questions related to fees

Q.1 What CFIA fees are applicable under the CHTWPCP and the CWPCP?

Facilities registered under the CHTWPCP and CWPCP will be billed an annual registration fee of $400. For the CHTWPCP, the invoices will be mailed out annually in early June for payment by July 1 or shortly after new facilities are registered under this program. For the CWPCP, the invoices will be mailed out annually in early September for payment by October 1 or shortly after new facilities are registered under this program.

Q.2 Can a phytosanitary certificate be issued for wood packaging material?

If traceability can be demonstrated, a phytosanitary certificate can be issued under certain circumstances. Consult your local CFIA office for additional information on certification requirements for the respective country.

Fees to be charged for the inspection of wood packaging material will be in accordance with the CFIA Fees Notice:

"For an inspection of a facility conveyance or thing to meet the requirements of the Act and the Regulations, the applicable fee set out in this table or $86 per hour or part of an hour, whichever is the greater amount."

Fees charged for the issuance of a phytosanitary certificate will be in accordance with the CFIA Fees Notice:

(1) For a Canadian Phytosanitary Certificate, a Canadian Phytosanitary Certificate for Re-export or any other document issued in respect of a shipment:

a) if the customs transaction value of the shipment is not more than $1600, the cost is $7
b) if that value is more than $1600, the cost is $17

(2) for the re-issuance of a certificate, for an additional certificate or for each copy of a certificate, the cost is $7

I. Questions specific to the CHTWPCP

Q.1 Can a CHTWPCP registered facility provide a contract service to "certified" wood packagers, of also marking the pallets, as well as Heat Treating?

As long as the facility which is registered under the CHTWPCP heat treats wood in general, it can also use this authorization to heat treat wood pallets along with dunnage and affix the ISPM No. 15 mark. The facility buying that wood is not be required to be registered under the CWPCP, as the wood pallets would already be marked.

J. Questions specific to the CWPCP

Q.1  What is the Canadian Wood Packaging Certification Program?

The CWPCP is a CFIA approved program that registers and certifies facilities to produce non-manufactured softwood packaging that will meet the import requirements. Certified wood packaging facilities will be obligated to maintain an inventory control system and obtain treated wood from certified treatment facilities. Additionally, certified facilities will be obligated to mark treated wood packaging with a CFIA-approved stamp.

The CFIA maintains a list of approved heat treatment facilities. Materials obtained from these facilities meet international requirements and can be used to construct wood packaging.

For more information please review the Plant Protection Policy Directive D-01-05.

Q.2  Why has Canada developed a wood packaging certification program?

Canada has developed the Canadian Wood Packaging Certification Program to ensure continued market access for Canadian products which require the protection and the support of softwood packaging material destined for international markets.

Q.3  Who needs to register with the Canadian Wood Packaging Certification Program?

Companies that either produce new or re-used packaging that is destined for the international market.

Q.4  How do I register in the Canadian Wood Packaging Certification Program?

An application form must be completed and signed by a producer or re-user indicating that they are willing and able to comply with the terms and conditions of the CWPCP. A copy of the application form is attached as Appendix 2 within D-01-05. The completed form shall be submitted to a local office of the CFIA, accompanied with a copy of the facility's quality plan.

Once the application form and quality plan have been reviewed by the CFIA, a certification team will conduct a quality evaluation of the facility's operational procedures. Compliant facilities will be approved for certification and issued a stamp identification number.

The CFIA website has a list of certified Canadian wood packaging facilities.

Q.5  What is a quality plan?

A quality plan is a document detailing the quality processes operating in a facility that ensures that the facility consistently meets the standards for the CWPCP. Information regarding sources of wood supply, records verifying treatment, training of staff, segregation of treated and untreated products, procedures in dealing with non-conforming products, production processes, etc. must be outlined in the quality plan.

Q.6  Will each facility require a certification number?

Yes, each location producing wood packaging registered in the CWPCP will receive a certification number. If a company has five manufacturing plants across Canada, each plant will require registration in the CWPCP and will be issued unique certification numbers.

Q.7  What size of stamp is required to be placed on a certified pallet?

There is no specification as to size of the stamp applied to certified wood packaging. However, the stamp must be legible, visible, placed on a minimum of two sides of the packaging unit and in colors other than red and orange.

Wood Packaging Mark as defined by the IPPC (information may not be available in both official languages)

Q.8  What if I supply U.S. wood packaging facilities with Canadian lumber or re-manufactured lumber?

All Canadian coniferous lumber, either in bundles or custom cut (pre-cut) packages, exported to the U.S. to be used in a facility that produces wood packaging for export to the EU must meet the specifications of the non-manufactured softwood packaging enforcement regulations of the American Lumber Standard Committee. According to the American Lumber Standard Committee program, all lumber (U.S. or Canadian) entering a U.S. wood packaging facility must be labelled HT or KD-HT under the supervision of any agency accredited by the Board of Review. Each board of the bundle must be stamped to identify the Grading Agency, the Facility Number and the treatment (HT or KD-HT).

Q.9  Where can I get certified non-manufactured wood packaging?

The CFIA maintains a list of certified Canadian wood packaging facilities.

Q.10  What certification process should be used for moving companies and one time movers?

If moving companies are building crates or pallets from non-manufactured lumber for export, they too should become registered in the Canadian Wood Packaging Certification Program or source wood packaging from CWPCP facilities.

Q.11 There are manufacturers in Canada who receive wood crating which is partially assembled. The commodities intended for export are packaged and the wood crating is then completely assembled. Do these exporters need to be registered under the CWPCP? Can these exporters receive partially assembled, stamped pallet kits, then complete assembly once the export ready commodity is ready to be shipped overseas?

The above situation describes pallet kits. Pallet kits may be stamped with the ISPM No. 15 recognized mark only under the following conditions:
a) The pallet kit is composed of all necessary components to assemble into a single pallet, box, or crate; and
b) Each individual piece of lumber of the actual pallet kit is stamped with the CA mark, the facility registration no. and the HT mark or, each individual piece of lumber of the actual pallet kit is stamped with the Grading Agency mark and facility number and the HT mark; and
c) The pallet kit is sold directly to a facility or client which assembles the actual pallet; and
d) The client or facility s name is recorded in the pallet kit manufacturer's Quality Manual and pallet kit manufacturer conducts routine audits on its clients or assemblers as outlined in it s Quality Manual; and
e) The pallet must be assembled in Canada.

Q.12 Will we allow the marking of pallets kits under D-01-05?

Pallet kits may be stamped with the ISPM No. 15 recognized mark only under the following conditions:

a) The pallet kit is composed of all necessary components to assemble into a single pallet, box, or crate; and
b) Each individual piece of lumber of the actual pallet kit is stamped with the CA mark, the facility registration no. and the HT mark or, each individual piece of lumber of the actual pallet kit is stamped with the Grading Agency mark and facility number and the HT mark; and
c) The pallet kit is sold directly to a facility or client which assembles the actual pallet; and
d) The client or facility s name is recorded in the pallet kit manufacturer's Quality Manual and pallet kit manufacturer conducts routine audits on its clients or assemblers as outlined in it's Quality Manual; and
e) The pallet must be assembled in Canada.

Q.13 Can the ISPM No. 15 recognized stamp for wood packaging material be used off site?

No. All ISPM No. 15 compliant wood packaging material including dunnage must be stamped at the facility for which the registration has been issued.

K. Questions related to CFIA policy directives, reference documents

Q.1 Where can I obtain a copy of the document entitled QSM 02 - Quality System Requirements for Facility Registration under the Canadian Wood Packaging Certification program (CWPCP) or the Canadian Heat Treated Wood Products Certification Program (CHTWPCP)?

This document is posted on CFIA website, and can be found at the following link: (http://www.inspection.gc.ca/english/plaveg/for/qsm/qsm-02e.shtml).

Q.2 What is the status of the Kiln Evaluator-Protocol/Procedures Document?

Forintek Canada Corp. will develop this procedures document in conjunction with the CFIA. A step by step manual is planned which will allow interested parties to conduct kiln evaluations and to apply to CFIA for official recognition as Kiln Evaluators under the CWPCP and CHTWPCP.

L. Questions related to quality manual elements

Q.1 Can the facility Quality Manual have a generic mill position (i.e. egg manager, QC personnel, shipper etc.) instead of actual names on the Heat Treatment (HT) Certificate Signing Authority list? With the movement of employees it is difficult (at times impossible) to have a current list of employees that are authorized to sign certificates. The employees would still undergo training and documentation of this training would be kept on file.

The audit of the facility will determine if this is an acceptable option. Employees identified as having signed the heat treatment certificate will be required to show that are fully aware of their responsibilities under this program.

M. Questions related to Heat Treatment certificates

Q.1 Under what conditions are Heat Treatment (HT) certificates required?

As facilities get registered under the CHTWPCP, the HT certificates as specified in Appendix 1 of D-03-02 must be used for all exported shipments of wood products for countries requiring these as a condition of importation. This includes Korea. The EU HT certificate (Appendix 2) will only be used for wood products exported to countries in the European Union.

N. Questions related to Technical requirements of heat treating

Q.1 Are fan reversals necessary if the temperature is monitored on the EXIT air of the heat treatment chamber?

No, it is felt that the exit air is the coolest air, so monitoring the exit air would be the equivalent to monitoring fan reversals.

The dry bulb temperature sensors in all options (when specified) must be located on either side of the heat treatment chamber. It is understood that if a heat treatment chamber has a dry bulb temperature sensor on one side at 8 feet from one end and the next dry bulb temperature sensor is located 24 feet from the same end as the first dry bulb sensor but is not on the same side, it is located in the center of the heat treatment chamber, this would be calculated as one side.

Q.2 Forintek custom schedules for some mills reference PI-07 requirements (option A) but say the dry bulb can be located no more than 8 feet from either end (meaning one end). PI-07 says from each end, does this mean both ends?

Yes, the dry bulb must be located no more than 8 feet from both ends.

O. Questions related to treatments

Q.1 Why doesn't Canada use methyl bromide fumigation as an appropriate ISPM No. 15 treatment under the CWPCP?

In accordance with Canada's ratification of the United Nations Montreal Protocol on Substances that Deplete the Ozone Layer (1992), the CFIA does not promote the use of methyl bromide and as such a decision was made to exclude fumigation treatment as part of the certification program.