D- 98-08: Entry Requirements for Wood Packaging Material into Canada

Effective Date: November 3, 2008
(8th Revision)

Subject

This directive provides the requirements for the entry for all wood packaging materials including dunnage, pallets or crating made from non-manufactured wood entering Canada from all areas except the continental United States (U.S.)

This revision is to assign the accurate responsibilities in the management of non-compliant ship borne dunnage (Section 4.1).

Table of Contents

Review

This directive will be updated as required. 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 below.

Distribution

  1. Directive mail list (Regions, PHRA, USDA)
  2. Provincial Government, Industry (via Areas)
  3. National Industry Organizations (determined by Author)
  4. Internet

Introduction

The risk represented by wood packaging materials and dunnage varies depending on the quality, conditioning and degree of finishing of the wood. The better the quality of wood used, the less likely it is that the wood packaging materials may be infested with serious pests. Many exotic plant pests have been intercepted on wood dunnage, pallets, crating or other wood packaging materials. Examples of plant quarantine pests intercepted include: Anoplophora chinensis, Anoplophora glabripennis, Ips typographus, Hylastes ater, Monochamus sp., Trichoferus campestris and others. The introduction of the Asian long-horned beetle (Anoplophora glabripennis), pine shoot beetle (Tomicus piniperda), emerald ash borer (Agrilus planipennis) and other exotic pests now established in parts of North America can be linked to international shipments containing wood packaging materials.

In March 2002, the Interim Commission on Phytosanitary Measures of the International Plant Protection Convention endorsed a standard prescribing uniform regulatory control of wood packaging materials moving in international commerce. This document titled: "ISPM No. 15, Guidelines for Regulating Wood Packaging Material in International Trade" recognizes the inherent pest risks associated with the international movement of untreated wood packaging materials. Although this standard does not obligate countries to establish regulatory controls, the guideline represents a mechanism by which any country may establish regulatory controls in a manner that is internationally harmonized. This Canadian import policy reflects the guidelines established in ISPM No. 15.

This policy does not regulate wood packaging materials originating in the U.S. As prescribed in ISPM No. 15, Canada has established bilateral phytosanitary measures with the U.S. Additionally, existing phytosanitary import measures applying to forest products produced in the U.S. provides sufficient phytosanitary protection to Canada.

Scope

This directive is for use by Canadian importers, Canadian customs brokers, CFIA inspectors, Canada Border Services Agency, foreign exporters and National Plant Protection Organizations.

References

  • ISPM No. 15, Guidelines for Regulating Wood Packaging Material in International Trade (2002) with modifications to Annex 1 (2006). Rome, 2002, FAO.
  • Canadian Food Inspection Agency. D-02-12, Import requirements of non-manufactured wood and other non-propagative wood products, except solid wood packaging material, from all areas other than the continental United States, Ottawa, 2005
  • Canadian Food Inspection Agency. D-03-02, Canadian Heat Treated Wood Products Certification Program (CHTWPCP), Ottawa, 2005.

    This directive supersedes D-98-08 (7th Revision).

    The requirements for the importation of other forest products (including lumber, decorative wood items, etc.) are provided in policy directive D-02-12.

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 Fees Notice, Canada Gazette: Part I (as amended from time to time)

1.2 Fees

The CFIA is charging fees in accordance with the Canadian Food Inspection Agency Fees Notice. For information regarding fees associated with imported product, please contact the Import Service Centre (ISC). Anyone requiring other information regarding fees may contact any local CFIA office or visit our Fees Notice Web Site.

1.3 Regulated Pests

Numerous. The following are examples of quarantine pests regulated by Canada and often associated with wood packaging:

Insects

Asian long-horned beetle (Anoplophora glabripennis)
Bark beetles (Ips typographus, Hylastes ater, Tomicus piniperda)
Boring beetles (Tetropium castaneum, Tetropium fuscum, Trichoferus campestris, Monochamus alternatus, Monochamus sp.)
Emerald Ash Borer (Agrilus planipennis (Fairmaire))
Gypsy moth (Lymantria dispar, Asian biotype)
Mulberry whit-spotted longicorn (Anoplophora chinensis)
Nun moth (Lymantria monacha)
Rosy gypsy moth (Lymatria mathura)
Sirex woodwasp (Sirex noctilio)
Other wood boring wasps (Sirex spp.)

Pathogens

Watermark disease of willow (Erwinia salicis)
Bacterial canker of poplar (Xanthomonas populi)
An unnamed disease affecting alder in Europe (Phytophthora sp.)
Sudden Oak Death (Phytophthora ramorum)
Dutch Elm Disease (Ophiostoma ulmi, O. novo-ulmi)

Any other pest listed on Canada's list of regulated pests. Canada's list of regulated pests may be obtained on the CFIA web site.

1.4 Regulated Commodities

Wood packaging materials constructed from the wood of any plant species that are not manufactured, including dunnage, pallets, spacers, bearers, crating, etc.

Note: wood packaging materials used for the transport of lumber are also regulated by this policy. However, logs, wood with bark attached, lumber, wood chips, bark chips, bamboo products, decorative wood items, cones without seed and other forest product imports are regulated by policy directive D-02-12.

1.5 Commodities Exempt

All wood packaging materials constructed entirely from manufactured wood including: dunnage, pallets, spacers, bearers, crating, etc. All wood packaging materials constructed of wood of less than 6 mm in thickness.

Wood packing (wood chips, sawdust or other processed wood product used to stabilize a commodity).

Manufactured Wood: Articles comprised wholly of wood-based products such as plywood, particle board, oriented strand board, veneer, wood wool etc., which have been created using glue, heat and pressure or a combination thereof.

1.6 Regulated Areas

All countries other than the continental U.S.

2.0 Specific Requirements

2.1 Entry of Untreated Non-Manufactured Wood Packaging Materials

The importation or movement in-transit through Canada of non-manufactured wood packaging materials which has not been treated in accordance with Appendix 1 (or those prescribed in the International Standard for Phytosanitary Measures No. 15) from any area of the world excluding the continental U.S. is prohibited.

The importation of non-manufactured wood packaging materials which has not been treated in accordance with Appendix 1 (or those prescribed in the International Standard for Phytosanitary Measures No. 15) originating from areas other than the continental U.S. but transiting through the continental U.S. and entering Canada is prohibited.

2.2 Entry of Treated Non-Manufactured Wood Packaging Materials

A Permit to Import is not required.

A Phytosanitary Certificate is not required. A Phytosanitary Certificate may be used as an alternative to the marking systems prescribed below.

All non-manufactured wood packaging materials (as defined in section 1.4) may enter Canada provided the material has been officially treated by one of the methods specified in Appendix 1. A logo or mark, officially endorsed by the NPPO of the country from which the wood packaging materials originates must be permanently affixed to each unit of wood packaging materials. More details on the mark are provided in Appendix 2. A Phytosanitary Certificate may be used in lieu of a logo or mark as prescribed above.

Replacement wood used in reconditioned wood packaging materials must be treated prior to export by a facility endorsed by the NPPO of the exporting country. The official mark of the facility conducting the treatment of the replacement wood must be affixed to the wood packaging materials.

The NPPO of the country from which the wood packaging materials originates must have a certification system in place for the approval and monitoring of facilities producing wood packaging materials to meet international standards. This certification system must ensure that the wood packaging materials or wood used in re-conditioned wood packaging materials are treated in accordance with one of the methods specified in Appendix 1. Facilities must be approved by the NPPO to affix a mark to the treated wood packaging materials. The system of marking must conform to the specifications laid out in Appendix 2. The NPPO must arrange to provide to CFIA on regular basis an updated list of facilities endorsed by the NPPO (e.g. an NPPO may arrange to provide a web-site address where lists are maintained).

Importers may determine eligible shippers of wood packaging materials by visiting the CFIA Web Site.

Ship borne dunnage should be officially treated by one of the methods specified in Appendix 1. It is recognized that not all countries possess the capacity to treat ship borne dunnage as per the specifications identified in this policy. Non-compliant ship borne dunnage must be retained aboard the marine vessel or disposed off in the manner specified in Section 4.1.

3.0 Inspection Requirements

Inspectors will verify that non-manufactured wood packaging materials are marked appropriately or accompanied by appropriate certification documents and that the non-manufactured wood packaging material does not contain any pests or signs of living pests.

4.0 Non Compliance

As of July 5th, 2006, any non-compliant wood packaging materials (excluding ship borne dunnage) entering Canada will be ordered removed from Canada. Additional enforcement measures may be applied to importers or those person or organization having custody of non-compliant wood packaging.

Permitting the entry of non-compliant wood packaging results in increased risks of pest establishment in Canada and increased uses of pesticide treatments including methyl bromide to remove associated pests. Canada is a signatory to the Montreal Protocol and is taking steps to reduce its overall use of methyl bromide. However, where wood packaging may pose an immediate risk for the entry of a pest, the CFIA or CBSA will order treatment of the non-compliant wood packaging, as prescribed in Appendix 1, prior to it being ordered removed from Canada.

All costs incurred in the disposition of non-compliant wood packaging are the responsibility of the person or organization having custody of the non-compliant wood packaging materials at the time of entry to Canada (including port or berthing facilities receiving untreated ship borne dunnage).

4.1 Ship Borne Dunnage

Non-compliant ship borne dunnage must be secured on the marine vessel so that pests may not escape while in Canadian waters (e.g. under tarp, cover or within closed holds or containers) or at the port area in a container secured against the escape of pests (e.g. a closed disposal bin) until inspected by the CBSA. Failure to hold ship borne dunnage appropriately may result in additional enforcement measures being applied to the person or organization having custody of the dunnage.

Alternatively, the CBSA may permit non-compliant ship borne dunnage to enter and be moved to a facility that safely disposes or processes the material in accordance with the conditions specified in Appendix 3. However, to ensure that ship borne dunnage does not pose a risk for the entry of a pest, the CFIA or CBSA will order treatment of non-compliant ship borne dunnage, as prescribed in Appendix 1, prior to disposal or processing. The port facility or parties responsible for the marine vessel offloading the dunnage must obtain a movement certificate (as specified in Appendix 5) that permits the movement of the dunnage to a CFIA approved disposal or processing facility. The disposal or processing facility must have completed an "Application for Participation in the Non-Compliant Ship Borne Dunnage Disposal or Processing Program" (Appendix 4) and this application must have been approved by an inspector of the CFIA prior to the non-compliant ship borne dunnage being granted entry to Canada.

Port facilities and ship's agents unable to comply with these requirements must ensure that non-compliant ship borne dunnage is sealed aboard the vessel and not discharged into Canada. Failure to comply with the requirements may result in stringent enforcement measures being applied to the person or organization having custody of the dunnage, including Canadian agents acting on behalf of the marine vessel, the master or officers of the marine vessel, port authorities or those contracted to handle the dunnage.

Any movement of non-compliant ship borne dunnage must be authorized by the CBSA on movement certificates issued to the person or organization having custody of the non-compliant item. Facilities may be permitted to move multiple shipments of non-compliant ship borne dunnage on a master Movement Certificate issued to the facility (a sample is contained in Appendix 5). Movement certificates shall specify the location and the specific conditions by which the ship borne dunnage may be moved.

5.0 Appendices

Appendix 1: Approved Methods of Treatment for Entry into Canada

1. Heat Treatment

All wood packaging materials material must be heated to a minimum internal wood core temperature of 56°C for 30 minutes. Kiln-drying, chemical pressure impregnation, or other treatments may be used as a means of achieving heat treatment provided that the above temperature and time requirements are met.

or

2. Fumigation

Wood may be fumigated with methyl bromide at normal atmospheric pressure at the following rates:

Wood may be fumigated with methyl bromide at normal atmospheric pressure at the following rates
Temperature Dosage
(g/m3)
Minimum Concentration
(g/m3) at:
2 hours
Minimum Concentration
(g/m3) at:
4 hours
Minimum Concentration
(g/m3) at:
12 hours
Minimum Concentration
(g/m3) at:
24 hours
21°C or above 48 36 31 28 24
16°C or above 56 42 36 32 28
10°C or above 64 48 42 36 32

The minimum temperature must not be less than 10°C and the minimum exposure time must be at least 24 hours. Monitoring of concentrations must be carried out at a minimum of 2, 4 and 24 hours after application of the fumigant.

Appendix 2: Systems Acceptable for the Marking of Treated Wood Packaging Materials

Wood packaging material that has been treated by one of the methods specified in Appendix 1 and in a manner that is officially endorsed by the NPPO of the country from which the wood packaging materials originates may be permitted entry into Canada provided the wood packaging materials material is marked as follows:

1. The mark must at minimum include:

  • the IPPC symbol for treated wood packaging materials (as per Annex II of the International Standard for Phytosanitary Measures No. 15: Guidelines for Regulating Wood packaging materials Material in International Trade) as reproduced here.

    International Plant Protection Convention symbol for treated wood packaging materials

    Where XX represents the International Standards Organization two letter country code for the country in which the wood packaging is produced and 000 represents the official certification number issued to the facility producing the compliant wood packaging by the National Plant Protection Organization and YY represents the treatment carried out (e.g. HT for heat treated wood or MB for methyl bromide treated wood).

  • Any other marking system provided by the NPPO of the country in which the wood packaging materials is produced, provided a template of the officially endorsed symbol has been provided to the CFIA prior to any shipments being received.

2. NPPOs or producers may at their discretion add control numbers or other information used for identifying specific lots. Other information may also be included provided it is not confusing, misleading, or deceptive.

3. Markings should be:

  • legible
  • permanent and not transferable (tags are not allowed)
  • placed in a visible location on at least two opposite sides of the article being certified.

4. The colors red or orange should be avoided.

5. Reconditioned wood packaging materials must be treated and contain the marks of the facility approved to perform the re-treatment.

Appendix 3: Methods For The Disposal or Processing of Non-compliant Ship Borne Dunnage

1. Methods for the Disposal or Processing of Non-compliant Ship Borne Dunnage

CBSA may permit the movement, disposal or processing of non-compliant ship borne dunnage provided that facilities capable of meeting the standards prescribed herein exist to conduct the disposal or processing. All costs incurred in the certification, inspection, monitoring, transport, disposal and/or processing of this material must be absorbed by the person or organization having custody of the ship borne dunnage at the time of entry into Canada. The material must be disposed of or processed in a manner that prevents the entry or introduction of pests into Canada. The following methods may be used to dispose or process non-compliant ship borne dunnage:

  • incineration; or
  • deep burial within a period prescribed by an inspector but not exceeding 3 days to a depth of no less than three metres that will not be disturbed, (non-compliant ship borne dunnage must be immediately covered with soil/dirt); or
  • processing to produce wood by-products such as wood dust, wood mulch (where the mulch is not to be distributed into the environment as a soil additive), wood fuel, paper mulch, recycled fibre wood and oriented strand board.

The CBSA is responsible for monitoring the disposal of ship borne dunnage.

2. Storage of Non-Compliant Ship Borne Dunnage While Awaiting Disposal or Processing

Non-compliant ship borne dunnage must be, at all times stored in a closed container that is effective in preventing pests from entering into the environment. Storage areas of non-compliant ship borne dunnage must be isolated from other domestic wood commodities, material that has already undergone processing and adjacent forested lands by no less than 30 metres. Storage is only permitted until the material can be appropriately disposed or processed as specified in 1 above. An inspector will specify the time limit for storage on a Movement Certificate issued to the person or organization having custody of the ship borne dunnage.

3. Transportation of Non-compliant Ship Borne Dunnage from Point of Entry to the Site of Disposal or Processing

Regardless of the process (described in section 1 of Appendix 3) by which non-compliant ship borne dunnage is to be handled, the material may only be moved, by a transporter that is approved by CFIA as specified on a Movement Certificate issued to the person or organization having custody of the non-compliant ship borne dunnage. The wood must be moved in a closed container directly to the site at which disposal or processing is going to take place.

4. Specific Requirements for Disposal or Processing

Facilities storing, disposing or processing non-compliant ship borne dunnage by the methods described in Section 1 of Appendix 3 must comply with the following specifications:

  • The designated facility (facility officially approved by the CFIA to perform activities stated in this policy) undertaking disposal or processing must have completed an Application for Participation as specified in Appendix 4. This application, if accepted by CFIA, shall be signed by an inspector confirming the facility's participation in the program. Until the facility is approved, non-compliant imported ship borne dunnage may not be moved to the facility.
  • Designated facilities must undertake all disposal or processing in a Canadian establishment designated on the Application for Participation
  • Designated facilities must afford inspection staff full co-operation for the purposes of carrying out audits, inspection, sample collection, product inspections, interviews of staff, etc.
  • CFIA will only permit deep burial, if the non-compliant ship borne dunnage is buried at a minimum depth of 3 metres (must be covered with 3 metres of soil). The wood must be buried at a site where the re-excavation of the material will not occur and where any covenants required on land title to ensure that re-excavation does not occur can be completed. Wood must not be left exposed within the burial pit.
  • Any ship borne dunnage that is not processed, including secondary products produced during processing, must be disposed of in the manner approved by a CFIA inspector as specified in the Application for Participation in the Non-compliant Ship Borne Dunnage Disposal and Processing Program (Appendix 4).
  • The period in which disposal or processing may be carried out may be extended by a CBSA inspector, provided the designated facility has additional mechanisms to mitigate the distribution of pests or there exists environmental conditions which preclude the distribution of pests (e.g. periods may be extended during the winter in some parts of the country). A CBSA inspector will provide in writing the period by which disposal or processing must be completed.
  • Designated facilities must immediately notify a local CFIA office upon the detection of any unusual pests on non-compliant ship borne dunnage at the disposal or processing facility.
  • The designated facility must maintain records pertaining to the handling, storage, processing or disposal of non-compliant ship borne dunnage for a minimum of 2 years. 

Appendix 4 : Application for Participation in the Non-Compliant Ship Borne Dunnage Disposal and Processing Program

Name of Facility Undertaking Processing or Disposal:

Name of Principle Contact Person:

Title:

Address:

City:

Province:

Telephone:

Facsimile:

E-mail:

1. Type of Processing or Disposal (check):

Deep burial to a minimum of 3 m 

Chipping not exceeding 2.5 cm2 

Production of wood fuel 

Production of laminated or heat treated products (e.g. wafer board, oriented strand board, etc.

Heat treatment as per the conditions outlined in D-03-02, Canadian Heat Treated Wood Products Certification Program (CHTWPCP) for export 

Other (describe process):

2. Areas where ship borne dunnage is stored prior to disposal or processing:

Storage areas are closed and preclude pest escape: 

Storage areas are isolated from forested lands or other wood products: 

3. Indicate time required between receipt of non-compliant ship borne dunnage and time to process:

4. Indicate what components of the non-compliant wood are not processed and how they are to be disposed of:

Conditions for the Disposal or Processing of Non-compliant Ship Borne Dunnage:

  1. All non-compliant ship borne dunnage will be disposed or processed in the manner described above within a period specified by an inspector on a Movement Certificate.
  2. Any non-compliant ship borne dunnage that is not used for processing as described above, will be disposed in the manner described in 4 above.
  3. The person or facility indicated above will keep records of all shipments of non-compliant ship borne dunnage received (e.g. shipping invoices, copies of movement certificates, etc.) and records of when these shipments were processed, treated or disposed off. Records will be maintained for a minimum of 2 years.
  4. Should a pest be found on non-compliant ship borne dunnage or in the facility, the CFIA will be immediately notified.
  5. A designated facility must have in its employ sufficient competent staff to undertake the requirements specified here and in the Application for Participation.

I, the owner/person in possession, care, or control of the above named facility have read and understood all the conditions and obligations stated herein by which I may dispose or treat non-compliant ship borne dunnage in accordance with the Non-Compliant Ship Borne Dunnage Disposal and Processing Program.

Further, I am and shall be responsible for and shall indemnify and save harmless Her Majesty the Queen in Right of Canada, including the Department of Canadian Food Inspection Agency, Her Officers, Servants, Employees, Successors and Assigns, from and against all manners of actions, causes of action, claims, demands, loss, costs, damages, actions or other proceedings by whomsoever made, sustained, brought or prosecuted in any manner based upon, caused by, arising out of, attributable to or with respect to any failure, inadvertent or otherwise, by act or omission, to fully comply with the said conditions and requirements.

Dated , in the year  at , Province of 


Applicant's Signature

Verification of Facility Procedures and Processes and Application Approved by:


Inspector's Signature
Canadian Food Inspection Agency


Date


Date of Expiration

Appendix 5: Sample of Certificate Authorizing Movement of Non-Compliant Ship Borne Dunnage

Click on Image for Larger View

Image: sample of certificate authorizing movement of non-compliant wood packaging