Wood Packaging – Questions and Answers
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What are the international standards for wood packaging materials?
The Commission on Phytosanitary Measures of International Plant Protection Convention (IPPC) adopts International Standards for Phytosanitary Measures (ISPMs) to protect plant resources from the spread of invasive pests moving in global trade. ISPM 15: Regulation of wood packaging material in international trade - PDF (505 kb) (originally adopted in 2002 and revised in 2009) (ISPM 15) details the minimum mandatory treatment requirements and a wood packaging marking system for the export of wood packaging materials constructed from non-manufactured wood (softwood and hardwood) from countries around the world.
What are the current requirements for wood packaging material entering Canada?
The current standards for wood packaging imports into Canada vary according to the originating country. All wood packaging materials originating from countries other than Canada or the continental United States on any mode of transport (air, rail, marine and road) must follow the requirements outlined in the Canadian Food Inspection Agency (CFIA) policy D-98-08: Requirements for the Entry of Wood Packaging Material into Canada (D-98-08).
Currently, wood packaging material imported from the continental United States is exempt from the requirements outlined in CFIA policy D-98-08. The CFIA and the United States Department of Agriculture Animal and Plant Health Inspection Service (USDA-APHIS) are collaborating on the development of a strategy that would involve a phase-in period for the eventual full implementation of the ISPM 15 standard for wood packaging material that moves between both countries. The CFIA import policy for wood packaging material (D-98-08) will be updated to reflect the full implementation of ISPM 15 (2009) for wood packaging material from the continental United States.
Questions and Answers related to CFIA Policy Directive D-98-08
What are wood packaging materials?
Wood packaging materials are wood or wood products (excluding paper products) used in supporting, protecting or carrying a commodity (includes dunnage). These include: wooden pallets, load boards, dunnage, crating, boxes, pallets, spacers, bearers, bracing, etc.
What wood packaging materials are regulated under D-98-08?
The regulations include all wood packaging materials constructed from wood of any plant species that is not processed. Processed wood are wood products which have been constructed using glue and heat. These include articles made from plywood, oriented strand-board, fibreboard, etc. Wood packaging made of a combination of processed wood and un-processed wood are also regulated by D-98-08.
Other wood articles including logs, wood with bark attached, lumber, wood chips, bark chips, decorative wood items, cones without seed and other forest product imports are also regulated by the CFIA in policy directive D-02-12: Import requirements for non-processed wood and other non-propagative wood products, except solid wood packaging material, from all areas other than the continental United States.
Is ship's dunnage regulated?
Yes. Ship's dunnage, also referred to as ship-borne dunnage, is wood used to brace cargo aboard a marine vessel. It is considered wood packaging material. Vessels may only discharge dunnage into Canada if it complies with the requirements specified in ISPM 15 and further described in policy directive D-98-08. The responsibility of ensuring ship's dunnage is compliant rests with Canadian berthing facilities that receive the off-loaded dunnage and the ship's agents in Canada. If non-compliant dunnage is discharged in Canada, the port facility may be held accountable for all actions taken to deal with the non-compliant dunnage.
Dunnage used to secure or support lumber is regulated in the same way as other wood packaging material.
What wood packaging materials are exempt under D-98-08?
Wood packaging materials made wholly (100%) of processed wood materials are exempt. Processed wood includes:
- particle board
- oriented strand board or fibre board
The following products are also exempt from the requirements:
- wood packaging materials made entirely from thin wood (6 millimetres or less in thickness)
- specific barrels for wine and spirits that have been heated during manufacture (check D-98-08 for conditions)
- 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 shavings, sawdust and wood wool used to stabilize a commodity
- wood components permanently attached to freight vehicles and containers (e.g. flat racks)
What are the requirements for Canadian importers of shipments with wood packaging entering Canada from all areas of the world except the continental US?
Importers are responsible for ensuring that wood packaging in shipments complies with Canada’s import requirements. It is a good practice to discuss these requirements with the exporter before the shipment is sent to Canada.
Wood packaging material entering Canada and originating from any country other than the continental United States, must meet the following requirements:
- The wood packaging material must be heat treated or fumigated using methyl bromide at rates specified in policy directive D-98-08.
- The wood packaging material must be debarked and if fumigated debarking must occur prior to fumigation as described in D-98-08.
- The treatment and marking must be under the authority of the National Plant Protection Organization (NPPO) of the country producing the wood packaging.
- The treated wood packaging material must bear an ISPM 15 mark.
For commodities with wood packaging that transit by the United States, must the wood packaging material comply with Canada's import requirements?
Yes, regardless of whether the commodity transits through the United States, all wood packaging material must meet Canada's import requirements.
What are the acceptable treatments for wood packaging coming into Canada?
Currently, heat treatment using conventional steam or dry kiln heat chamber (HT), heat treatment using dielectric heating (DT), and fumigation with methyl bromide (MB) are the only approved methods of treatment for the international movement of wood packaging material (Appendix 1 of D-98-08). The treatment must be completed prior to export under in a program approved by the National Plant Protection Organization of the country in which the wood packaging materials are produced. The CFIA is currently in the process of updating its policy directive D-98-08 to reflect the new heat treatment option with dielectric heating (DT).
For methyl bromide treatment, the removal of bark must be carried out before treatment because the presence of bark on the wood affects the efficacy of the methyl bromide treatment. For heat treatment the removal of bark can be carried out before or after treatment.
Although methyl bromide is viewed as an effective treatment for mitigating pest incidence in wood packaging material and has been adopted internationally as a treatment, the CFIA does not promote the use of methyl bromide for the treatment of wood packaging material in Canada in accordance with Canada's ratification of the United Nations' Montreal Protocol on Substances that Deplete the Ozone Layer (1992).
What are the current requirements for non-wooden boxes with wood parts coming into Canada?
If wood is used in the manufacture of a non-wooden box or box predominantly made from processed wood, the ISPM 15 mark may appear on the non-wood components. The importing facility is responsible for ensuring that all pieces of wood used to construct the box are treated in accordance to ISPM 15. If the wood components are not secured to the non-wooden box, then each piece of wood more than 6 mm in thickness must bear the ISPM 15 mark.
How does the CFIA check for compliance with the D-98-08?
Inspections are conducted by the Canada Border Services Agency (CBSA) or by the CFIA on shipments arriving in Canada. The CFIA or CBSA may re-direct the shipment to a facility where the commodity will be inspected, or order the shipment inspected at destination. They may also order the container or other shipping unit to remain sealed until they are able to inspect it.
Fees are applied to all inspection activities. Fees must be paid by the importer, or person in care and control of the shipment. Applicable fees for inspections of wood packaging material in shipments are set out in Table 1, Part 12, of the CFIA Fees Notice.
What happens when non-compliant wood packaging is found on a shipment intended for Canada?
Any shipments with non-compliant wood packaging material will be ordered removed from Canada. It may also be required to be treated to mitigate the risk of pest entry into Canada. Treatment does not make the shipment eligible for entry to Canada.
It is the responsibility of the importer, or person in care and control of the regulated articles, to ensure the non-compliant material is treated if required and promptly removed from Canada. Any costs associated with the inspection, treatment and disposal of non-compliant wood packaging material are the responsibility of the importer or person in care and control of the shipment.
What are the requirements for exporters shipping outside of Canada and the continental United States?
Wood packaging (e.g. pallets, containers, drums, etc.), excluding wood packaging made wholly from processed wood shipped to any country that has adopted ISPM 15 must be:
- Produced by or purchased from a facility approved by the national plant protection organization as complying with ISPM 15
- Heat treated to a minimum core temperature of 56°C for at least 30 minutes in a CFIA approved Heat Treatment facility.
- Debarked so that any number of visually separate and clearly distinct small pieces of bark remaining are less than 3 cm in width (regardless of the length), or if greater than 3 cm in width or length, the total surface area of any individual piece of bark should not exceed 50 square cm.
- Treated wood must be marked with an IPPC mark
What are the current requirements for exporters of shipments with wood packaging moving from Canada to the United States?
Currently the United States requires wood packaging to be:
- Free of living pests and signs of living pests, and
- Where the wood packaging does not bear the ISPM 15 mark, it must have been produced in either Canada or the U.S. The accompanying shipping documents must clearly indicate that the wood packaging was produced in either the U.S. or Canada or in both of those countries (as the case may be); or,
- Where the wood packaging was not produced in Canada or the United States it must possess an ISPM 15 mark.
- Wood packaging that has been repaired or re-manufactured in Canada must be marked in accordance with policy directive D-13-01: Canadian Heat Treated Wood Products Certification Program (HT Program).
What is required for re-used wood packaging that originated in Canada, but was shipped outside Canada or the continental United States and is now returning to Canada?
Any Canadian wood packaging material that has been shipped outside of Canada or the continental United States to a country that has adopted the ISPM 15 standard must adhere to the requirements Canadian Wood Packaging Certification Program as described in policy directive: D-13-01: Canadian Heat Treated Wood Products Certification Program (HT Program). Canadian origin wood packaging material returning to Canada must comply with the requirements listed in policy directive D-98-08 and therefore possess the ISPM 15 mark before re-entering Canada.
The exporter is responsible for ensuring that that all wood packaging in the shipment meets the required standards.
For more information about the import and export requirements for wood packaging material, please call your local CFIA office or 1-800-442-2342.
For more information about the enforcement of wood packaging requirements by the CBSA, please visit the CBSA website.
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