D-01-05: Canadian Wood Packaging Certification Program (CWPCP)
EFFECTIVE DATE: March 28, 2011
This 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 (ISPM) 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.
This directive has been revised to clarify the types of facilities that can register under this program as outlined in Section 4.0.
Additionally, Section 8, Note 11, has been revised to explain the procedures required for repairs to a wood packaging unit comprised of processed and regulated wood material.
Table of Contents
- Amendment Record
- Definitions, Abbreviations and Acronyms
- 1.0 General Requirements
- 2.0 Specific Requirements
- 3.0 Recognized Certification Marks
- 4.0 Registration under the CWPCP
- 5.0 Heat Treatment Requirements
- 6.0 Use of Debarked Wood in the Manufacturing of Wood Packaging Materials
- 7.0 Re-Used Wood Packaging Material
- 8.0 Repairs of Previously Certified Wood Packaging Material
- 9.0 Remanufactured Wood Packaging Materials
- 10.0 Wood Packaging Kits to be assembled at a non-registered facility
- 11.0 Production and assembly of wood packaging material outside of the registered facility and use of the certification mark
- 12.0 Export Certification
- 13.0 Domestic Requirements for wood packaging material or dunnage originating in regulated areas for quarantine pests
- 14.0 Non-Compliance
- 15.0 Responsibilities of the Service Provider
- 16.0 Responsibilities of the CFIA
- 17.0 Appendices
This directive shall be reviewed every 2 years or unless otherwise needed. For further information or clarification, please contact the Canadian Food Inspection Agency (CFIA).
Chief Plant Health Officer
Amendments to this directive shall be dated and distributed as outlined in the distribution below.
Amendments to this directive shall be distributed as outlined in the distribution below.
- Directive mail list (Regions, PHRA, USDA)
- Provincial Government, Industry (determined by Author)
- National Industry Organizations (determined by Author)
- CFIA website
Wood packaging material is essential for trade and the movement and protection of cargo and containerized goods. Wood packaging material 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 material and in many circumstances the pests have been able to survive. The Canadian pest risk assessment for the import of wood packaging material has scientifically identified wood packaging material 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 material, pests continue to move throughout the world on wood packaging material. 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 material 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.
The list of countries having indicated, through official World Trade Organization (WTO) Notification that they have adopted the standards with the ISPM No. 15, Regulation of Wood Packaging Material in International Trade.
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.
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 registration and phytosanitary requirements for the production of ISPM No. 15 compliant wood packaging material as well as how the program will be audited by the CFIA and the CFIA recognized Service Providers.
- ISPM No. 5, Glossary of Phytosanitary Terms, 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
- QMS-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)
- QMS-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 I (as amended from time to time)
- Agriculture and Agri-Food Administrative Monetary Penalties Act, (1995, c. 40)
- Agriculture and Agri-Food Administrative Monetary Penalties Regulations, (SOR/2000-187)
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 families of regulated pests has been developed from 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 that have adopted ISPM No. 15, in addition to 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.
Failure to meet the phytosanitary import requirements of a foreign importing country may result in enforcement action being taken by the foreign government against the non-compliant shipment that could result in delays at the port of entry and as a consequence refusal of entry. The export of non-compliant forestry products may also be subject to enforcement by the CFIA, as it is also a violation of the Canadian Law, specifically, the Plant Protection Act and Regulations, to export anything from Canada unless it meets the importing country's phytosanitary requirement.
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 material or loose wood dunnage produced wholly (100%) from processed wood are not subject to the requirements of this 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
Many areas of the world have 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 within Canada, of wood packaging material and loose wood dunnage may also be subject to pest specific plant protection regulations if the wood packaging material originates from areas regulated for specific pests and is to move to non-regulated areas of Canada (including destinations in the U.S.) (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, the use of methyl bromide fumigated material 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 56°C 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 website. In addition, all CWPCP registered facilities are maintained on the CFIA website.
2.1.2 Pesticide Treatment
As noted in Section 2.1, treatment with methyl bromide fumigation will not be considered for registration of facilities under this program. For more information, please contact the CFIA Regional inspection office.
2.1.3 Other Treatment Options Under Consideration
Should the IPPC revise ISPM No. 15 to include additional treatment options to mitigate risk of pests in wood packaging material, the CFIA will consider adding them to the CWPCP.
3.0 Recognized Certification Marks
3.1 ISPM No. 15 Wood Packaging Material Certification 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 mark may be stamped, labelled or branded to the wood packaging. Tags or other non-permanent applications of the mark are not permitted. The mark must not be hand drawn and the use of red or orange must not be used because these colours are used in the labelling of dangerous goods.
Where various components (i.e. treat wood products and process wood products) are integrated into a unit of wood packaging material, the resultant composite unit should be considered as a single unit for marking purposes. On a composite wood packaging material it may be appropriate for the mark to appear on the processed wood products to ensure that the mark is in a visible location and is of sufficient size. This approach to the application of the mark applies only to composite single units of wood packaging.
The ISPM No. 15 Certification mark on wood packaging material constitutes a document. This mark cannot be used for any purpose other than the CFIA's wood packaging certification programs. The mark, like a phytosanitary certificate attests to the phytosanitary status of the product on which it appears. The possession, custody, control or use of the wood packaging material bearing a false or improperly obtained ISPM No. 15 certification mark is prohibited and may be subject to enforcement actions by the CFIA under the Plant Protection Act and Regulations.
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. Should the facility be faced with organizational or structural changes e.g. name change, receivership or bankruptcy, the CFIA in consultation with the Service Provider will determine the future use of that registration number.
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 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 (as described in this directive).
Note 3: Some of the above listed facilities may have the choice to register either under the CWPCP or the CHTWPCP (as described in the Directive D-03-02).
Note 4: Facilities that are specifically heat treating lumber (i.e. sawn wood) or other forest products (i.e. wood chips, round wood, etc.) 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.
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 or manufactured, 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 5: A copy of the application form (CFIA/ACIA 5528) - PDF (147 kb) can be obtained from the CFIA website or a CFIA Service Provider. The completed form shall be submitted to a CFIA Service Provider.
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 example, 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. For all new applicants, the Manual must be approved for use by a CFIA Service Provider and the CFIA.
Note 7: For guidelines on developing the Manual, refer to the Quality System Requirements for Facility Registration under the Canadian Wood Packaging Certification Program (CWPCP), the Canadian Heat Treated Wood Products Certification Program (CHTWPCP) or (QMS-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 website.
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 website.
5.1 Identification of Heat Treated Wood Products to be used in the manufacturing of ISPM No. 15 compliant wood packaging material
Wood products of Canadian origin, that are destined to a registered facility for the manufacturing of ISPM No. 15 compliant wood packaging material must have been heat treated by a facility registered under either the CWPCP or the CHTWPCP. The wood must be traceable to the registered facility that provided the heat treatment in the following manner:
- Be identified in a manner prescribed in the facility's Manual (see Section 4.3) and accompanied by a Domestic Heat Treatment Certificate1, or;
- Display a CHTWPCP recognized certification mark as described in section 2.2.1 of the directive D-03-02 on each wood bundle, bundle tag or on the bundle wrapper, or;
- Display the Canadian Lumber Standards Accreditation Board (CLSAB) accredited mark on each piece of lumber consisting of the grading agency logo, the mill number and the HT or KD-HT mark, which is recognized by the CFIA.
Heat treated wood products may be sourced from a shipper or broker not registered under the CHTWPCP or the CWPCP, provided it contains a recognized mark (i.e. ISPM No. 15 Certification mark or CLSAB accredited mark) and is secured and purchased with the relevant documentation (i.e. copy of the Domestic Heat Treatment Certificate) to ensure that it can be traced to a facility registered under either the CHTWPCP or the CWPCP. 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 heat treated wood is re-manufactured by a third party before arriving at the registered wood packaging facility, the re-manufacturing facility must be registered under either the CHTWPCP or the CWPCP. A Manual will be required to comply with the requirements of this program and must specify how they will maintain the identity of the re-manufactured heat treated wood to ensure that it can be traced to the facility that did the heat treatment.
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.
Heat treated wood originating from the U.S., which is to be used by a Registered Facility for the construction of ISPM No. 15 compliant wood packaging material, must be marked in accordance with the official Heat Treatment program as administered by the American Lumber Standard Committee (ALSC). Therefore, the wood must have the HT mark and originate from a facility certified by one of ALSC's accredited agency or accompanied with a Phytosanitary Certificate issued by the United States Department of Agriculture-Animal and Plant Health Inspection Services (USDA-APHIS).
1 Registered Facilities must contact their Service Provider to obtain a blank copy of the Domestic Heat Treatment Certificate. The link to an example of a Domestic Heat Treatment Certificate is available in Appendix 3.
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
Wood packaging material must be made of wood that has been debarked. In accordance with ISPM No. 15, any number of visually separate and clearly distinct small pieces of bark may remain, provided these are :
- less than 3 cm in width (regardless of the length of the piece) or;
- 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 material must specify in its Manual the process used in ensuring compliance with the standards prescribed in this Directive. In particular, the facility should identify the procedures taken to comply with the identification and segregation of repaired wood packaging material from new or remanufactured wood packaging material.
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 8: 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 9: As fumigation with Methyl Bromide is not an accepted treatment under the 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 10: Wood packaging made from processed wood material are not regulated under ISPM No. 15 and this Directive; therefore, the above procedures (i.e. not more than one third repaired rule) do NOT apply to the use of processed wood material in the re-manufacture of wood packaging material.
Note 11: In a packaging unit comprised mainly of processed wood material (e.g. plywood) if the total amount of regulated components to be repaired is less than four (4) individual pieces it is not necessary to re-treat the entire unit. In this case it is only necessary to repair the broken pieces with compliant heat treated wood.
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 Directive. 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:
- Each wood packaging kit is composed of all necessary components to assemble into a single wood packaging unit (i.e. box, pallet, crate); and
- Each individual unit of lumber of the actual kit is stamped with the CA mark, the facility registration no. 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. For the purpose of this directive, pieces which are sub-assembled (pieces of a kit which are composed of multiple components) may be considered as an individual unit and will only require one stamp; and
- 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
- 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. A full set of assembly instructions and heat treatment requirements must be provided to the assembling facility; and
- 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
- 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.
The registered facility requesting these privileges must adhere to the following conditions:
- 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
- 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
- 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
- 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 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 United-States Lumber entering the United-States 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 Directive and identified by a wood packaging certification mark as specified in Figure 1 of 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 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 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 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 (QMS-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 Directives, and where it has been determined that wood packaging material 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 Directives, refer to the CFIA website.
Export shipments containing wood packaging material must meet the phytosanitary requirements of the importing country. The interception of non-compliant wood packaging by a foreign government, could result in the destruction or the return to origin of the entire shipment (not just wood packaging material). Non-compliant material would likely lead to delays in product delivery, treatment or disposal of non-compliant wood packaging including related costs. 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.
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 Directives.
15.0 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 (QMS-03), and this 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 Directive.
The CFIA Service Provider will conduct audits in the manner and rate set out in QMS-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) 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 QMS-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.
16.0 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:
- issue to the wood packaging facility or treatment facility a specific facility registration number;
- 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;
- in cooperation with the Service Provider, the CFIA may conduct an evaluation audit of the producing or heat treating facilities applying on the program;
- conduct system audits on the registered facilities;
- conduct system audits on the CFIA recognized Service Provider.
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.
Appendix 1: ISPM No. 15 Wood Packaging Material Certification Mark
Appendix 2: List of Pests Targeted by Approved Measures
Appendix 3: Domestic Heat Treatment Certificate
ISPM No. 15 Wood Packaging Material Certification 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:
- 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.
- 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.
- Producer/Treatment Provider Code: this is a unique code provided by CFIA (indicated as "00000" in Fig.). 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.
- 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.
The size shape and position of the mark may vary from facility to facility but each mark must be:
- permanent and not transferable;
- placed in a visible location and on at least two opposite sides of the article being certified;
- rectangular or square in shape;
- border line must be clear and divided by a vertical line separating the IPPC recognized symbol from the other components of the mark;
- for dunnage material, the mark must be visible on each individual piece.
The mark must not be hand drawn and RED or ORANGE must not be used because these colours are used in the labelling of dangerous goods.
No other information may be contained within the wood packaging certification mark, such as producer trademark, logo of authorizing body, date of treatment or marking to identify dunnage material.
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.
List of Pests Targeted by Approved Measures
Specific insect species within the following families are known to be associated with wood and which are normally eliminated by Heat Treatment (HT) (Section 2.1.1) when used in accordance with the specifications identified within the Directive.
* with some exceptions for Heat Treatment
Domestic Heat Treatment Certificate
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