New USDA Regulations for Wood Packaging Material Entering U.S.

Effective 9/16/05
(September 8, 2005)

September 16, 2005 is the date the new USDA regulations take effect for wood packaging material (WPM) entering the United States. If your goods are arriving in the United States on or after September 16, 2005, any WPM must be treated and marked with the IPPC (International Plant Protection Convention) logo, the two letter ISO code for the country that treated the WPM, the unique number assigned by the national plant protection agency of that country to the producer of the wood packaging material, and an abbreviation showing the type of treatment (e.g., HT for heat treatment; MB for methyl bromide). An example of the marking can be found in the final rule published in the Federal Register on September 16, 2004: Rules and Regulations.

The United States is only one of 162 countries that will require heat treatment or methyl bromide fumigation of WPM. Pest infestation in the low grade wood typically used in WPM is a global problem; agriculture and forests have been harmed worldwide. Many exporters must already comply with other countries' regulations. Canada and Mexico will also be implementing the ISPM 15 requirements on September 16, 2005.

You will not need a wood packaging material statement on your documents. You will not need a fumigation certificate (these requirements for WPM from China and Hong Kong will no longer be in effect on September 16, 2005). Instead, The Animal and Plant Health Inspection Service (APHIS) will be visually inspecting cargo. If the WPM is not marked with the IPPC marking, the goods must be re-exported. The WPM may not be treated or destroyed in the United States. Re-exportation is the only option and a costly one at that. You may arrange to have your merchandise separated from unmarked WPM, but only if approved by APHIS. APHIS will charge a fee for this, and you will incur other costs (the unmarked WPM still needs to be re-exported).

WPM includes, but is not limited to pallets, skids, dunnage, crating, packing blocks, drums, and cases. The new regulations do include some exemptions. Manufactured wood, such as plywood, veneer, fiberboard and particle board, is exempt from the treatment and marking requirements. Pieces of wood less than 6 millimeters (0.24 inches) in any dimension are exempt. WPM from Canada, loose wood materials (shavings or excelsior), and whisky and wine barrels are all exempt. Note that if your goods are shipped through Canada, the WPM must still be marked. The Canadian exemption is for WPM originating in Canada.

Additional information regarding the new WPM regulations may be found in previous issues of Shap Talk - December 2004, March 2005, April 2005, and July 2005 at Samuel Shapiro & Company.

Make sure your purchase orders, contracts, and letters of credit include a requirement that all WPM furnished by your suppliers is properly marked. Or consider using alternative packing materials such as plastic, metal, or manufactured wood.

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