Government of Canada
Symbol of the Government of Canada
Skip to content | Skip to institutional links

Common menu bar links

Plants > Plant Protection Policy Directives > Forestry

Institutional links

D-01-05: The Canadian Wood Packaging Certification Program (CWPCP)

PDF (196 kb)

EFFECTIVE DATE: September 30, 2009
(5th Revision)

CANADIAN FOOD INSPECTION AGENCY
59 Camelot Drive
Ottawa, Ontario, Canada, K1A 0Y9
(Tel.: 613-225-2342; Fax: 613-228-6602)

Subject

This policy directive describes the Canadian Wood Packaging Certification Program (CWPCP); a certification system for facilities wishing to produce wood packaging material in accordance with the provisions of International Standard for Phytosanitary Measures No. 15, Regulation of Wood Packaging Material in International Trade. Participation to this program is strictly voluntary unless required under pest specific regulations or policies which regulate the movement of wood packaging material outside a regulated area of Canada.

Some National Plant Protection Organisations (NPPOs) may establish additional requirements where it has been technically justified through application of internationally recognized criteria.

Revisions contained in Revision 5

The policy directive has been revised to reflect the amendments made to the International Standards for Phytosanitary Measures (ISPM) No. 15. regarding repaired and remanufactured wood packaging (see sections 8.0 and 9.0), the requirements related to the use of debarked wood (see section 6.0) and the new marking requirements (see Annex 1). The International Plant Protection Convention (IPPC) and its Commission on Phytosanitary Measures (CPM-4) have put forth these revisions to provide further guidance to National Plant Protection Organization (NPPOs). The changes were adopted by CMP-4 in April 2009.

The policy directive was also revised to include the conditions under which a registered facility can make wood packaging materials for assembly in a non-registered facility (see section 10.0) as well as conditions under which a registered facility can make and stamp wood packaging materials outside of the registered facility (see section 11.0).

Revisions contained in Revision 4

The policy directive has been revised to update Appendix 3 with regards to the information related to the use of the Domestic Heat Treatment Certificate.

Revisions contained in Revision 3

This policy directive has been updated to allow for the certification of wood packaging material and dunnage produced in an area of Canada regulated for a quarantine pest, which is specified in a policy directive, to allow for movement outside the regulated area. (Section 9.0)

The specifications associated with the repair of wood packaging has been changed. (Section 7.0)

The Heat Treatment Certificate found in Appendix 3 has been modified to allow certification of wood pallet components for domestic movement as outlined in 5.1 (c).

In addition, the fees payable to the Receiver General of Canada is now in effect as of October 1st, 2006 or on application following this date, and on October 1st of each year thereafter.

Revisions contained in Revision 2

This policy directive has been updated to establish the specifications for the certification of a heat treatment facility for the specific purpose of heat treating wood packaging or heat treating lumber used in the construction of export wood packaging material.

The term "Verification Body" has been replaced by the term "Service Provider" and is defined within.

The term "Authorized Technical Laboratory" has been replaced by "Recognized Heat Treatment Evaluator" and has been redefined.

The inspection and auditing of facilities registered under this program will be the responsibility of the Service Provider approved and recognized by the Canadian Food Inspection Agency (CFIA). The CFIA, the National Plant Protection Organization of Canada, will retain the oversight role of this certification program. All new facilities will be required to apply to a Service Provider for participation under this program. All currently registered facilities will be required to submit a Quality Manual to a Service Provider registered under this program within six months following the selection of the necessary Service Provider.

The CFIA QSM No. 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)" and, QSM No. 03, "Quality System Requirements for the Service Provider approved under the CWPCP" are now referenced within this revision. These are supplementary documents developed to complement the CFIA Policy D-01-05, Canadian Wood Packaging Certification Program. Collectively, these manuals are specifically designed to enable a registered heat treatment facility to treat lumber and wood products under a quality systems program to meet an importing country's phytosanitary requirements.

Revisions contained in Revision 1

This directive is being updated to meet the phytosanitary measures of the International Plant Protection Convention; Guidelines for regulating Wood Packaging in International Trade, ISPM No. 15, March 2002.

Table of Contents

Review

This directive shall be reviewed every 2 years or unless otherwise needed. The next review date for this directive is September 30, 2011. The contact for this directive is Joanne Rousson. For further information or clarification, please contact the Canadian Food Inspection Agency (CFIA).

Endorsement

Approved by:


Chief Plant Health Officer

Amendment Record

Amendments to this directive will be dated and distributed as outlined in the distribution list below.

Distribution

Amendments to this directive shall be distributed as outlined in the distribution below.

  1. Directive mail list (Regions, PHRA, USDA)
  2. Provincial Government, Industry (via Regions)
  3. National Industry Organizations (determined by Author)
  4. CWPCP Listserv
  5. CWPCP Working Group
  6. Internet

Introduction

Wood packaging is essential for trade and the movement and protection of cargo and containerized goods. Wood packaging can accompany any article and represent a large group of products such as pallets, dunnage, boxes, crating, packaging blocks, drums, cases, load boards, pallet collars, and skids. Historically, these products were commonly produced from non-processed wood which lacked sufficient manufacturing or treatment to remove or eradicate pests present in the wood.

Canadian pest interception records have demonstrated that a large variety of pests can be transported with wood packaging and in many circumstances the pests have been able to survive. The Canadian pest risk assessment for the import of wood packaging has scientifically identified wood packaging as a significant pathway for the movement of quarantine insects and diseases of plants and trees.

Despite the development of a variety of import requirements for wood packaging, pests continue to move throughout the world on wood packaging. It is believed that the introduction of several invasive quarantine pests, for example, Asian Long-horned Beetle, Brown Spruce Longhorn Beetle, Emerald Ash Borer and the Pine Shoot Beetle, into North America are related directly to the movement of wood packaging from other areas of the world. As global trade continues, every importing country is at risk from the introduction of wood pests, which causes irreversible impacts to forest health and biodiversity.

In March of 2002, the International Plant Protection Convention (IPPC) adopted a wood packaging standard; Regulation of Wood Packaging Material in International Trade, (International Standards for Phytosanitary Measures [ISPM] No. 15). This standard recognizes the plant health risks associated with wood packaging and outlines approved phytosanitary measures. To target the plant health risk associated with wood packaging, the standard recommends that all wood packaging should be treated. To facilitate trade, treated wood packaging must be marked in a manner to identify the approved treatment and to provide traceability to the country of origin and the producing facility.

The CWPCP is a certification system that allows Canadian wood packaging facilities and treatment facilities to build wood packaging products that meet the provisions of ISPM No. 15. The final product will be marked with a Canadian wood packaging certification mark. This mark will be unique to each Registered Facility.

The CWPCP and The Technical Heat Treatment Guidelines and Operating Conditions Manual (PI-07) provide the specifications for the treatment and manufacturing of wood packaging material in accordance with the requirements of ISPM No. 15. The CWPCP uses a quality management systems approach designed to allow traceability of treated wood packaging material certified under this program to the actual treatment record, treatment facility, or the wood packaging facility.

Wood packaging produced under the specifications of this standard by CFIA registered facilities must also meet the conditions of delivery of the program recognized by the European Union (EU) as a derogation from the Phytosanitary Certificate requirements of Council Directive 2000/29/EC in respect of heat-treated wood of conifers originating from Canada to prevent the introduction of the Pinewood Nematode (Bursaphelenchus xylophilus) via wood packaging material.

The list of countries having indicated, through official World Trade Organization Notification that they have approved the standards with the ISPM No. 15, Regulation of Wood Packaging Material in International Trade, can be viewed on-line.

Note 1: Certain countries may have specific phytosanitary import requirements in addition to those specified in this document. Please consult the specific phytosanitary import requirements of the foreign country to verify if there are additional requirements.

Scope

This directive is intended for use by Canadian wood packaging facilities, custom brokers, freight forwarders, exporters, CFIA inspection staff and any CFIA Service Provider. It sets forth the necessary requirements and audit procedures for the certification of wood packaging used in the transport of consignments for export.

References

  • Glossary of Phytosanitary Terms, Publication No. 5, FAO, (updated annually)
  • ISO Guide 8402, Quality Systems Terminology
  • ISPM No. 15, Regulation of Wood Packaging Material in International Trade, FAO, 2009
  • CFIA (PI-07), The Technical Heat Treatment Guidelines and Operating Conditions Manual
  • QSM No. 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)
  • QSM No. 03, Quality System Requirements for the Service Provider approved under the CWPCP

Definitions, Abbreviations and Acronyms

Definitions for terms used in the present document can be found in the Plant Health Glossary of Terms.

1.0 General Requirements

1.1 Legislative Authority

The Plant Protection Act, S.C. 1990, c. 22
The Plant Protection Regulations, SOR/95-212
Canadian Food Inspection Agency Act (1997, c. 6)
Canadian Food Inspection Agency Fees Notice, Canada Gazette, Part 1 (05/13/2000)
Agriculture and Agri-Food Administrative Monetary Penalties Act, (1995, c. 40 )
Agriculture and Agri-Food Administrative Monetary Penalties Regulations, (SOR/2000-187)

1.2 Fees

When a wood packaging facility applies to participate in the CWPCP, the facility must pay the Service Provider for registration and audit services (for the purposes of this document, a Service Provider is an organization, company or person who has entered into a Service Contract with CFIA under the CWPCP and is accountable to the CFIA for the activities identified within the contract). The facility must also remit to the CFIA, a registration payment of $400.00 by separate cheque payable to the Receiver General of Canada, on application, and by October 1st of each year thereafter, for participation in the program, for audit and administrative services.

1.3 Regulated Pests

Wood packaging is a pathway for the movement of a number of serious pests to trees and shrubs. A list of regulated pests has been developed within the ISPM No. 15 and is provided in Appendix 2.

1.4 Regulated Commodities

Regulated commodities include all non-processed wood packaging and loose wood dunnage constructed from coniferous (softwood) and non-coniferous (hardwood) wood or combinations thereof to be exported from Canada to countries, other than the continental United States (U.S.), that have adopted ISPM No. 15 and all such material moving within Canada from an area where such products are regulated for a pest of quarantine concern to an unregulated area. This also includes wood crating, packaging blocks, drums, cases, load boards, pallet collars, and skids which can be present in almost any exported consignment, including consignments which would not normally be the target of phytosanitary inspection.

Veneer peeler cores, whether used directly or in the manufacturing of wood packaging materials, are also regulated and must be heat treated in accordance with requirements specified in Section 2.1.1 and marked with the ISPM No. 15 wood packaging mark.

All wood packaging material must be debarked (See Section 6.0 for more information on debarked wood).

1.5 Commodities Exempt

Wood packaging or loose wood dunnage produced wholly (100%) from processed wood are not subject to the requirements of this policy directive. Plywood, particle board, oriented strand board or veneer that were created using glue, heat and pressure or a combination thereof would be examples of such products.

Other exempt products include barrels for wine and spirits that have been heated during manufacturing, as well as gift boxes for wine, cigars and other commodities made from wood that has been processed and/or manufactured in a way that renders it free of pests.

Wood packaging material made from sawdust, wood wool, wood shavings and those made entirely from thin pieces of wood (6 mm or less in thickness) are also exempt. In addition, wood components permanently affixed to freight vessels and containers are exempt.

Some countries may have additional phytosanitary requirements for the import of processed wood. Please contact a local office of the CFIA for more specific information on a country's import requirements.

Note 2: Not all gift boxes and barrels are constructed in a manner that renders them pest free. For this reason, some of these products may be regulated within the scope of this directive. These include boxes for fruit and vegetables, barrels used in the transport of industrial commodities, etc. Please check with the importing NPPOs for any specific requirements relating to these types of commodities.

1.6 Regulated Areas

All areas of the world having adopted the standards prescribed in ISPM No. 15. Please contact a local office of the CFIA for more information on the ISPM No. 15 status in a specific importing country.

The domestic movement of wood packaging and loose wood dunnage within Canada may also be regulated if the wood packaging originates from areas regulated for specific pests and destined for the U.S. or other non-regulated areas of Canada. (Refer to section 13.0).

2.0 Specific Requirements

2.1 Approved Treatment Options

Presently, heat treatment and methyl bromide fumigation have been accepted internationally as approved measures under ISPM No. 15 in order to mitigate pest risks associated with wood packaging. Canada is a signatory of The Montreal Protocol on Substances that Deplete the Ozone Layer (1987) agreeing to the reduction and eventual phase-out of ozone depleting substances. Methyl bromide, an ozone depleting substance, has been undergoing phase-out since 1995. For this reason, methyl bromide fumigation will not be considered for approval under this program. Additional measures are being considered for approval under ISPM No. 15. (Refer to Annex 1 of ISPM No. 15 for treatments being considered.)

2.1.1 Heat Treatment (HT)

Under ISPM No. 15 requirements, wood used for the construction of export wood packaging material or the export wood packaging material itself must be heated in accordance with a specific time-temperature schedule that achieves a minimum temperature of 56ºC throughout the profile of the wood (including at its core) for a minimum of 30 minutes.

The heat treatment must occur at a facility approved by the CFIA and operating under the Canadian Heat Treated Wood Products Certification Program (CHTWPCP), D-03-02, or the Canadian Wood Packaging Certification Program (CWPCP), D-01-05.

The official list of all CFIA approved heat treatment facilities registered under the CWPCP is maintained on the CFIA web site. In addition, all CHTWPCP registered facilities are maintained on the CFIA web site.

2.1.2 Pesticide Treatment

Methyl bromide fumigation will not be considered for registration under this program. Where it is determined that this treatment option is the only viable option to meet the phytosanitary requirements of the importing country and where heat treatment is not practical as determined by a CFIA inspector and approved by the CFIA in Ottawa, a Phytosanitary Certificate may be issued for wood packaging materials in these specific instances. Shipments must be treated by a provincially licensed applicator and must be treated in accordance with Annex 1 of ISPM No. 15 (see references).

Facilities or operators wishing to obtain phytosanitary certification must contact the CFIA inspection office. (A list of CFIA inspection offices can be found on-line).

2.1.3 Other Treatment Options Under Consideration

When new treatment options are adopted for use by the IPPC or by importing countries, the CFIA will add these options to the program. Kiln-drying (KD), chemical pressure impregnation (CPI), thermal water bath or other treatments may be considered HT treatments provided that these treatments meet HT specifications as stated above.

3.0 Recognized Certification Marks

3.1 ISPM No. 15 Wood Packaging Recognized Mark

For the purpose of this document, the Wood Packaging Recognized Certification Mark is a mark developed in accordance to the wood packaging standard; Guidelines for Regulating Wood Packaging in International Trade, (ISPM No. 15), also referred to within this document as "wood packaging mark".

Once a wood packaging facility has been registered by the CFIA, a unique facility registration number will be assigned to the facility by the CFIA. This number acknowledges that the facility meets the official phytosanitary criteria for registration and will become part of their wood packaging mark recognized under ISPM No. 15. (Appendix 1).

The wood packaging certification mark must be legible, permanent and placed in a visible location on a minimum of two opposite sides of the article being certified. The wood packaging certification mark MUST be black.

The wood packaging certification mark may be stamped, labelled or branded to the wood packaging. Tags, hand written or other non-permanent applications of the mark are not permitted.

The wood packaging certification mark is non-transferable and ultimately provides traceability to the facility and the location where the treatment occurred. One facility registration number (Appendix 1) will be issued to each facility location.

The mark must include the information outlined in Appendix 1 of this directive.

4.0 Registration under the CWPCP

Wood packaging manufacturing facilities, wood packaging facilities treating lumber for the manufacturing of their own wood packaging material, or heat treating the actual wood packaging material (i.e., Crates, pallets, boxes, etc.) to meet the ISPM No. 15 standards, may apply for registration under the CWPCP. Facilities other than wood packaging facilities treating lumber for another facility, for the purpose of meeting the ISPM No. 15 standards, will be required to register under the CHTWPCP.

4.1 Eligible Applicants

Eligible applicants include those Canadian facilities handling wood products intended for the treatment or manufacturing of wood packaging material, ultimately destined for export to countries having specific phytosanitary certification requirements and those Canadian facilities located within an area regulated for a quarantine pest and handling wood packaging material intended to be moved out of the regulated area.

An applicant must be:

  • a Canadian citizen or permanent resident;
  • a person authorized under the laws of Canada to reside in Canada for a period of six months or more and who will have possession, care or control of the thing to be treated, manufactured or distributed; or
  • in the case of a corporation with a place of business in Canada, the applicant must be an agent or officer of the corporation who resides in Canada; and
  • the facility to be registered must be located in Canada.

4.2 Application for Participation

An application form must be completed in full, and signed by an eligible applicant. By signing the application form, the applicant agrees to comply with the terms and conditions of The Canadian Wood Packaging Certification Program (CWPCP).

Note 3: A copy of the application form (CFIA/ACIA 5528) can be obtained from the CFIA website or a CFIA Service Provider. The completed form shall be submitted to a CFIA Service Provider.

Note 4: The name of the Service Provider can be found on-line and a list of participants registered under the CWPCP as wood packaging facilities can be found on-line.

4.3 Submission of a Quality Management Systems Manual (herein referred to as the Manual)

A Registered Facility must operate under a quality management system that ensures consistent compliance with the phytosanitary requirements (heat treatment as specified above, records pertaining to treatment, documentation in support of certification and other related activities). The facility must document the procedures to be followed in the system to meet the conditions of the CWPCP. This documentation is the facility's Manual. For all new applicants, the Manual must be approved for use by a CFIA Service Provider and the CFIA.

Note 5: For guidelines on developing the Manual, refer to the Quality System Requirements for Facility Registration under the Canadian Wood Packaging Certification Program (CWPCP) or the Canadian Heat Treated Wood Products Certification Program (CHTWPCP), (QSM-02).

5.0 Heat Treatment Requirements

Facilities may achieve the phytosanitary standard for treatment specified in section 2.1.1 through a number of processing methods. The CFIA, Technical Heat Treatment Guidelines and Operating Conditions Manual (PI-07) has been developed to provide additional mandatory information to heat treatment facilities regarding the heat treatment chamber operating condition (e.g., to obtain Generic Heat Treatment Schedules), and further define the technical requirements to participate under the export certification program. The PI-07 is maintained on the CFIA web site.

In addition, facilities may achieve the phytosanitary standard for treatment specified in section 2.1.1 through a processing method which has been approved by a Recognized Heat Treatment Evaluator (e.g., to obtain Custom-made Heat Treatment Schedules). Details on this alternative processing method must be outlined in the facility's Manual. A Recognized Heat Treatment Evaluator is an organization, company or person that has been authorized by the CFIA to conduct a scientific analysis pertaining to the treatment of wood products. A list of Recognized Heat Treatment Evaluators can be found on the CFIA web site.

5.1 Identification of Treated Wood Products for the domestic market intended for the manufacturing of wood packaging material for export

Heat treated wood products moving in the domestic market, which is ultimately intended for the manufacturing of wood packaging material for export markets, other than the U.S., or regulated wood products originating from an area regulated for a quarantine pest which are intended to be moved out of that regulated area (requiring to be heat treated to a minimum temperature of 56°C throughout the profile of the wood [including at its core] for a minimum of 30 minutes) must have been heat treated by a facility registered under the CWPCP or the CHTWPCP, and must:

  1. be identified in a manner prescribed in the facility's Manual and accompanied by a Domestic Heat Treatment Certificate, or
  2. display a CHTWPCP recognized certification mark as described in section 2.3.1.3 of the directive D-03-02 on each wood bundle, bundle tag or on the bundle wrapper, or
  3. display the Canadian Lumber Standards Accreditation Board (CLSAB) accredited mark on each piece of lumber consisting of the grading agency logo, the facility registration number and the HT or KD-HT mark, which is recognized by the CFIA and appearing on the CFIA website.

Note 6: Registered Facilities must contact their Service Provider to obtain a blank copy of the Domestic Heat Treatment Certificate. An example of a Domestic Heat Treatment Certificate is available in Appendix 3.

The facility's Manual must specify the sources of wood being supplied to the facility. Treated wood used in the construction of certified wood packaging material must be marked to ensure traceability and must have been treated by a facility registered under the CHTWPCP or the CWPCP.

Treated wood material may be sourced from a shipper or broker not registered under the CHTWPCP or the CWPCP providing it is marked and secured to ensure that it can be traced to a registered treatment facility. The marking and the method to ensure traceability of the wood material must be outlined in the Manual of the manufacturing facility.

In cases where treated wood is re-manufactured by a third party before arriving at the wood packaging facility, the re-manufacturing facility will be required to register under the CWPCP. A Manual will be required to comply with the requirements of this program.

Heat treated wood originating from the U.S., which is to be used by a Registered Facility for the construction of certified export wood packaging material, must be marked in accordance with the official USDA Animal and Plant Health Inspection Service, Plant Protection and Quarantine Program (PPQ) wood packaging program. For information on PPQ's Wood Packaging Program, refer to the Internet. The registered facility must specify in its Manual a process for verifying that separation between treated and non-treated wood is consistently maintained and that the system of wood segregation is clearly known by facility employees. The segregation may include a physical barrier between lots, identification marks on lots or a distance separation between lots.

The wood packaging manufacturing facility performing the actual heat treatment must assure that the wood product has been heat treated to a minimum temperature of 56°C throughout the profile of the wood (including at its core) for a minimum of 30 minutes as outlined in section 5.0.

5.2 Treatment Records

Each facility shall maintain records that verify that each treatment has met the technical specifications outlined in the CWPCP. The facility shall indicate in the Manual the type of information to be maintained. Records are to be kept by the facility for a minimum of 2 years after treatment.

6.0 Use of Debarked Wood in the Manufacturing of Wood Packaging Materials

Irrespective of the type of treatment applied, all wood packaging material must be made of wood that has been debarked. To be consistent with ISPM No. 15 guidelines, when methyl bromide fumigation is used, the removal of bark must be carried out before fumigation. The presence of bark on the wood affects the efficacy of the methyl bromide fumigation.

Wood packaging material may contain any number of visually distinct small pieces of bark provided these are:

  1. less than 3 cm in width (regardless of the length of the piece) or
  2. if greater than 3 cm in width, the total surface area of the piece of bark must be less than 50 square cm (generally thought to be smaller than a credit card).

7.0 Re-Used Wood Packaging Material

All wood packaging that bears the official wood packaging certification mark from Canada or another country and has been constructed under the specifications of ISPM No. 15, which has not been repaired or remanufactured with new wood components, may be re-exported from Canada.

It is the obligation of the Canadian exporter to ensure that wood packaging material to be re-exported has met the import requirements of ISPM No. 15 and/or the importing country.

8.0 Repairs of Previously Certified Wood Packaging Material

Repaired wood packaging material is defined as wood packaging material that has had not more than one third of the original components replaced with new components. All repaired wood packaging material intended for export or domestic movement out of a regulated area for a quarantine pest must be repaired with wood which has been heat treated in a facility registered under the CHTWPCP or the CWPCP or must be traceable to an official ISPM No. 15 compliant certification program. The facility repairing the wood packaging must specify in its Manual the process used in ensuring compliance with the standards prescribed in this policy. In particular, the facility should identify the procedures taken to comply with the identification and segregation of repaired wood packaging from new or remanufactured wood packaging.

The repaired components of the ISPM No. 15 compliant wood packaging unit must have been heat treated to the prescribed HT standard. It is not necessary to re-treat the entire wood packaging unit if the original unit is traceable to an official ISPM No. 15 compliant certification program. Marks attesting to the original treatment and certification of the wood packaging unit may be obliterated. The official certification mark of the repairing facility must be permanently affixed to the wood used in the repair or, where previous certification marks have been removed, the official certification mark of the repairing facility must be applied to two (2) opposite sides of the repaired unit.

Where the wood packaging unit requiring repair is not traceable to an official ISPM No. 15 compliant certification program, the entire unit of wood packaging must be re-treated and marked in accordance with ISPM No. 15 as described in Appendix 1.

Note 7: A facility that is not registered under the CWPCP or the CHTWPCP which repairs ISPM No. 15 compliant wood packaging material must assure that all ISPM No. 15 recognized marks are permanently obliterated before use and cannot represent the wood packaging material as ISPM No. 15 compliant.

Note 8: As fumigation with Methyl Bromide is not an accepted treatment under the Canadian Wood Packaging Certification Program (CWPCP), wood packaging material to be repaired, which has originally been fumigated to meet the ISPM No. 15 standard, will require to be heat treated and re-marked accordingly in accordance with the CWPCP.

Note 9: Manufactured wood components are not regulated under ISPM No. 15 and this policy; therefore, the above procedures (i.e. not more than one third repaired rule) do not apply to manufactured wood components.

9.0 Remanufactured Wood Packaging Materials

Remanufactured wood packaging materials are defined as wood packaging materials that have had more than approximately one third of the materials replaced. Remanufactured wood packaging materials may incorporate new or used components or combinations thereof which may have been previously marked with the ISPM No. 15 wood packaging mark. To eliminate any confusion to the importing NPPOs, all previous wood packaging marks on the components must be permanently obliterated and the newly remanufactured wood packaging material must be retreated and a new mark applied.

The facility remanufacturing the wood packaging must specify in its Manual the process used in ensuring compliance with the standards prescribed in this policy. This assures that the unit has been heat treated to the prescribed Heat Treatment standards.

10.0 Wood Packaging Kits to be assembled at a non-registered facility

The registered facility is authorized to apply the wood packaging certification mark on a wood packaging material to be assembled at a non-registered facility situated in Canada provided the following conditions are followed:

  1. Each wood packaging kit is composed of all necessary components to assemble into a single wood packaging unit (i.e. box, pallet, crate); and
  2. Each individual piece of lumber of the actual kit is stamped with the CA mark, the facility registration number and the HT mark or, each individual piece of lumber of the actual wood packaging kit is stamped with the Grading Agency mark and facility number and the HT mark; and
  3. The wood packaging kit is sold directly to a facility or client which assembles the actual unit; the client is not authorized to modify the wood packaging kit in any way (no wooden components can be added or removed) and;
  4. The registered facility must follow the wood packaging assembly as defined in its Manual which is approved by CFIA and the Service Provider. In addition, the name of the client or assembling facility must be recorded in the Manual of the wood packaging kit fabricator. Kit fabricators must perform regular audits (following the process described in the registered facility's Manual) at the assembling facility (or at the client's facility) (at least one audit per year per facility); and
  5. The registered facility must keep records for a minimum of two (2) years of all kits sold containing (at minimum) the client name, the number of kits sold, the kits' type (dimensions) and the date of sale; and
  6. The kits must be assembled in Canada.

11.0 Production and assembly of wood packaging material outside of the registered facility and use of the certification mark

In certain special circumstances, the registered facility may manufacture or assemble wood packaging materials and stamp them with the wood packaging certification mark at non-registered facilities. This is only permitted if it is impossible to assemble the wood packaging materials at the registered facility; for example, if the wood packaging materials are too large to transport and must be assembled directly at the exporter's premise. However, this option must not be recurrent at the same non-registered exporter. If the non-registered exporter in question is planning to export on a regular basis (more than three times per year), the facility must be registered under the CWPCP.

The registered facility requesting these privileges must adhere to the following conditions:

  1. The assembling and marking procedures used by the registered facility must be defined in their Manual and approved by CFIA and the Service Provider; and
  2. The assembly and marking of the wood packaging materials at the non-registered facility must be performed by a trained and authorized employee from the registered facility or under its direct supervision, as described in the registered facility's Manual; and
  3. The registered facility must keep records for a minimum of two (2) years of all wood packaging materials assembled and marked off site, containing (at minimum) the client name, the number of units stamped off-site, the type (dimensions) of wood packaging and the fabrication date; and
  4. The wood packaging materials must be assembled and stamped in Canada.

12.0 Export Certification

All wood packaging material certified under the CWPCP must bear the internationally recognized mark as outlined in Appendix 1.

Registered Facilities will not be permitted to display their wood packaging certification mark on any products that require assembly in a foreign country.

Countries may have additional phytosanitary import requirements that are above and beyond the requirements of ISPM No. 15. All exporters are encouraged to consult a CFIA local office to verify the phytosanitary requirements for the respective countries.

In addition, countries may have different phytosanitary import requirements for heat treated wood products intended for use in the manufacturing of wood packaging material. Where countries require Phytosanitary Certificates to accompany shipments of heat treated wood products intended for use in the manufacturing of wood packaging material, a registered facility must provide to CFIA, a copy of the Heat Treatment Certificate(s) issued for the shipment or must be able to demonstrate that the wood products have been heat treated in accordance with the phytosanitary standard as described in this policy directive. CFIA may request additional supporting information such as charge/kiln records or may inspect the forest product for the presence of quarantine pests.

The American Lumber Standards Committee (Incorporated)(ALSC) is recognized as the certification authority in the U.S. Lumber entering the U.S. wood packaging certification process, must meet the prescriptions of the ALSC domestic production standards. This applies both to softwoods and hardwoods. Canadian ALSC accredited agencies can provide certification options which meet these criteria.

12.1 Wood Dunnage Export Certification

All wood dunnage exported shall be treated by a registered facility as prescribed in this policy and identified by a wood packaging certification mark as specified in Appendix 1. Each individual piece of dunnage material must display the required mark. Some dunnage may not be cut to final length until used; therefore, special considerations must be made to ensure the wood packaging mark is visible and intact. Small pieces of wood that do not include the wood packaging mark must not be used for dunnage. Application of the appropriate dunnage stamp may include:

  • applying multiple marks along the length of the wood in short intervals to ensure the wood packaging mark is intact after alterations, or
  • additional application of the wood packaging mark to treated dunnage after cutting provided the shipper (user) is registered under the CWPCP.

12.2 Export Certification for wood packaging material not manufactured under the CWPCP

There may be situations where a Phytosanitary Certificate is requested by exporters who are not registered under this program. In such instances, the exporters must comply with specific elements of this policy directive, and must be able to demonstrate that the wood products have been heat treated in accordance with the phytosanitary standard as described in this policy directive. The exporter must document the procedures to be followed in the system in its Manual to meet the conditions of the CWPCP. Elements to be included in the Manual will be identified in the The Quality System Requirements for Facility Registration under the Canadian Wood Packaging Certification Program (CWPCP) or the Canadian Heat Treated Wood Products Certification Program (CHTWPCP) or, (QSM-02).

13.0 Domestic Requirements for wood packaging material or dunnage originating in regulated areas for quarantine pests

Facilities may be required to register under the CWPCP or the CHTWPCP, if they are located in regulated areas for quarantine pests as specified in other CFIA policy directives, and where it has been determined that wood packaging or dunnage is a pathway for the introduction or spread of quarantine pests. The wood packaging material or dunnage produced in such circumstances must meet all the conditions described in this directive. For a list of pest specific policy directives, refer to CFIA's web site.

14.0 Non-Compliance

Export shipments containing wood packaging material must meet the requirements of the importing country. The interception of non-compliant wood packaging by a foreign government, may result in enforcement action by the foreign government. Non-compliant material will likely lead to delays in product delivery, treatment or disposal of non-compliant wood packaging including related costs. Facilities located within a regulated area for a quarantine pest and handling regulated wood products intended to be moved outside of the regulated area must also meet the requirements specified in all other applicable CFIA policy directives.

Failure to meet the phytosanitary import requirements of a foreign importing country is also a violation of Canadian law, specifically, the Plant Protection Regulations, and may lead to enforcement actions by the CFIA and suspension or cancellation from this program.

15.0 Recognition of the Service Provider

Subject to the Treasury Board Secretariat Policy on Alternative Service Delivery, CFIA may recognize an organization, company or person for the purposes of carrying out audits to verify the conformity of registered facilities to the CWPCP. Those recognized are referred to as a "Service Provider".

Upon acceptance by the CFIA of a satisfactory application, and upon any approvals required under the Alternative Service Delivery Policy, the Service Provider shall sign an agreement with the CFIA.

16.0 Responsibilities of the Service Provider

The Service Provider must adhere to the requirements outlined in the service contract with CFIA, the Quality System Requirements for the Service Provider Approved under the CWPCP-(QSM-03), and this policy directive. The Service Provider shall have in force a documented quality management system. The quality management system must provide for adequately trained staff, reports of inspection, frequency of audits, etc. The CFIA Service Provider should make its services available to facilities wishing to register under this program. The Service Provider must have a specific arrangement with registered facilities who have negotiated to contract with it, to permit the delivery of activities, audits, etc. as required to fulfil its role under this policy directive.

The CFIA Service Provider will conduct audits in the manner and rate set out in QSM-02 The Quality System Requirements for Facility Registration under the Canadian Wood Packaging Certification Program (CWPCP) or the Canadian Heat Treated Wood Products Certification Program (CHTWPCP) to verify that registered facilities are consistently meeting the requirements of the CWPCP.

The Service Provider is responsible for providing reports to the CFIA as outlined in QSM-03 and is responsible for ensuring that its audit reports properly and accurately reflect its findings. The Service Provider will immediately notify the CFIA, whenever it finds a registered facility is operating in such a manner as to compromise the integrity of the CWPCP.

Subject to the reporting to the CFIA, the Service Provider is required to maintain the confidentiality of all registered facilities. The Service Provider will cooperate with the CFIA when conducting audits of facilities or for other activities necessary in determining the compliance of facilities registered in this program.

The Service Provider will advise the CFIA if a registered facility ceases to operate under their agreement with the Service Provider or has withdrawn from the CWPCP.

17.0 Responsibilities of the CFIA

CFIA is ultimately responsible for registration, suspension or cancellation of registration of any facility registered in the CWPCP. Upon verification that the facility is capable of successfully meeting the requirements of this directive, the CFIA shall:

  1. issue to the wood packaging facility or treatment facility a specific facility registration number;
  2. approve the use of the facility's wood packaging certification mark by adding the facility's name to the official CFIA list of approved wood packaging facilities;
  3. in cooperation with the Service Provider, may conduct an evaluation audit of producing or heat treating facilities applying on the program;
  4. conduct system audits of the facilities as established in 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);
  5. conduct system audits on the Service Provider as outlined in (QSM-03), " Quality System Requirement for the Service Provider Approved under the CWPCP".

The CFIA reserves the right to conduct audits, at anytime during regular business hours, of registered facilities and the Service Provider operating under the CWPCP.

18.0 Appendices

Appendix 1: ISPM No. 15 Wood Packaging Recognized Mark

Appendix 2: List of Pests Targeted by Approved Measures

Appendix 3: Domestic Heat Treatment Certificate

Appendix 1

ISPM No. 15 Wood Packaging Recognized Mark

The wood packaging mark shown below (Fig. 1) shall certify that the wood packaging and/or loose wood dunnage material and/or any non-processed wooden articles, that bears these marks have been subjected to approved treatment measures. The mark will comprise the following required components:

  1. IPPC Recognized Symbol: the design of the symbol must closely resemble that of the examples below and be placed to the left side of all other components.
  2. Country Code: must be the International Organization for Standards (ISO) two-letter country code (indicated as "XX" in Fig. 1) and must be separated by a hyphen from the producer/treatment provider code.
  3. Producer/Treatment Provider Code: this is a unique code provided by CFIA (indicated as "00000" in Fig. 1). The code is five digits in length including "0" at the beginning. This code identifies the facility as a registered facility under the CWPCP or CHTWPCP.
  4. Treatment Code: the abbreviation for the specific treatment used (indicated as "YY" in Fig. 1). HT is the code for materials that are heat treated to a minimum temperature of 56°C throughout the profile of the wood (including at its core) for a minimum of 30 minutes. Other treatment types are not approved under the CHTWPCP or the CWPCP.

Image of International Standard for Phytosanitary Measures number 15 Wood Packaging Recognized Mark

Figure 1: Example of wood packaging recognized mark.

The size shape and position of the mark may vary from facility to facility but each mark must be:

  1. legible;
  2. permanent and not transferable;
  3. placed in a visible location and on at least 2 opposite sides of the article being certified;
  4. rectangular or square in shape;
  5. border line must be clear and divided by a vertical line separating the IPPC recognized symbol from the other components of the mark;
  6. for dunnage material, the mark must be visible on each individual piece.

The mark MUST be black in colour.

No other information may be contained within the wood packaging mark, such as producer trademark or logo of authorizing body. This is to ensure the consistency of the mark as an international symbol. Any additional information may be placed anywhere outside the IPPC wood packaging mark.

National Plant Protection Organizations of the importing countries may at their discretion request control numbers or other information used for identifying specific lots provided it is not confusing, misleading, or deceptive.

The wood packaging certification mark may only be applied by wood packaging facilities or treatment facilities approved by the CFIA and operating under the CWPCP or the CHTWPCP.

Some variations may be placed on the wood packaging mark. Please consult ISPM No. 15 for examples of such variations. Examples are located in Annex 2.

Appendix 2

List of Pests Targeted by Approved Measures

Specific insect species within the following families are known to be associated with wood and who are normally eliminated by Heat Treatment (HT) (Section 2.1.1) when used in accordance with the specifications identified within the policy.

Insects

Anobiidae
Bostrichidae
Buprestidae
Cerambycidae
Curculionidae
Isoptera

Lyctidae*
Oedemeridae
Scolytidae
Siricidae

* with some exceptions for Heat Treatment

Nematodes

Bursaphelenchus xylophilus

Appendix 3

Domestic Heat Treatment Certificate

Click on image for larger view
Image of a domestic heat treatment certificate

Figure 1: Use of Certificate


Top of Page
Important Notices