North American Regulations for packaging materials

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1 North American Regulations for packaging materials The North American Plant Protection Organisation (NAPPO) has announced the implementation of a new regulation, applicable for all shipments arriving in the USA, Canada and Mexico. At this stage, these three countries are at different development levels of this new regulation, which are as follows: USA The U.S. Department of Agriculture, Animal and Plant Health Inspection Service (APHIS) has issued a final rule, effective September 16, 2005, that will affect all goods imported into the U.S. using regulated wood packaging material ( regulated WPM ). The rule will require all regulated WPM imported into the U.S. to be either heat treated or fumigated with methyl bromide and marked with an approved international mark certifying treatment. With immediate effect (February 1, 2006) all non-compliant woodpackaging materials are rejected to enter the U.S. and will be re-exported to country of origin. Regulated wood packaging material is defined as wood packaging material other than manufactured wood materials, loose wood packing materials, and wood pieces less than 6 mm thick in any dimension, that are used or for use with cargo to prevent damage, including, but not limited to, dunnage, crating, pallets, packing blocks, drums, cases, and skids. For further details, please refer to section general requirements down below. Important Note: With respect to the U.S. 24 hour rule for Ocean Cargo destined to the U.S., all treatment and marking of SWPM must be done prior to the container is being sealed. Any re-sealing at port locations will cause the cargo to qualify as high risk and consequently subject to examination at origin or destination port. Canada The Canadian Food Inspection Agency (CFIA) has already issued their Directive D , which came into effect on January 02, This Canadian import policy reflects the guidelines established in ISPM15 (International Standard of Phytosanitary Measures). This policy does not regulate wood packaging materials originating in the USA.

2 Any regulated material found to be in non-compliance with the import requirements specified above will be ordered returned to origin. Any cost incurred in the disposition of non-compliant wood packaging materials are the responsibility of the entity in care and control of the materials at the time of entry into Canada. Please use this link to Directive D for further reference: Mexico As per announcement of October 18, 2005, the Mexican Secretary of Environment and Natural Resources (SEMARNAT) puts in place a modification to the introduction date of wood packaging rules for the importation of wood packaging material as well as wooden products. The new introduction dates will be - wooden products: February 01, wood packaging material: July 05, 2006 Nevertheless the declaration of wooden packaging material in each import customs clearance declaration is already obligatory. This will be arranged by the customs broker designated by the Mexican importer. The Mexican customs authorities together with the Secretary of Environment reserve the right to inspect the wooden packaging material, which in case of non-compliance with the already stipulated rules, can be rejected. Related charges, once they occur, will be debited to the responsible party as per IncoTerm. General Requirements The standard has established guidelines for wood packaging material in international trade, indicating that 1. all wooden packaging must be bark free; 2. all wooden packaging material must be subject to a specific quarantine treatment, such as heat treatment or fumigation. Importation into both Canada and the USA under a general IPPC Permit (assigned to the treatment facility) means that NO paperwork, certificate, or importer document needs to accompany the SWPM/Regulated WPM.

3 Qualified fumigation must be marked on the packaging, showing details of the processing agent. This has to be arranged by the shipper prior to stuffing and delivery of the container to the terminal. Regulated WPM, whether for actual use in packing or imported as cargo, may be imported in accordance with the following conditions: - Fumigated (MB) with methyl bromide in an enclosed area for at least 16 hours at certain dosages. Following fumigation, fumigated products must be aerated to reduce the concentration of fumigant below hazardous levels; or - Heat-treated (HT) to achieve a minimum wood core temperature of 56 C for a minimum of 30 minutes. Such treatments may employ kiln-drying, chemical pressure impregnation, or other treatments that achieve this specification through the use of steam, hot water, or dry heat. These guidelines cover materials that are not manufactured, including pallets, boxes, cable drums, crating, cases, load boards, spacers, pallet collars and skids which can be present in almost any imported consignment. The importation or movement in-transit of untreated non-manufactured wood packaging materials from any area of the world is prohibited. Marking for approved measures: The mark shown below is to certify that the wood packaging material that bears the mark has been subjected to an approved measure.

4 The mark should at minimum include the: IPPC Symbol (as reproduced above); XX = ISO two letter country code (e.g. Germany = DE) 000 = the unique number assigned by the NAPPO of that country to the producer (or fumigation cy) of the wood packaging material; YY = IPPC abbreviation disclosing the type of treatment (e.g. HT for Heat treatment or MB for Methyl Bromide ). Markings should be: - according to the model shown here; - legible; - permanent and not transferable; - placed in a visible location, preferably on at least two opposite sides of the article being certified; The use of red or orange should be avoided since these colours are used in the labelling of dangerous goods. All components of recycled, remanufactured or repaired wood packaging material must be treated and contain the marks of the facility approved to perform the re-treatment. Exceptions: The definition of regulated WPM excludes the following materials: - manufactured wood materials, such as fiberboard, plywood, whiskey and wine barrels, oriented strand board or veneer that have been created using glue, heat and pressure or a combination thereof - pieces of wood that are less than 6 mm (0.24 ) in any dimension, as they are too thin to present any significant pest risk. This exclusion will exempt from regulation many types of small boxes used to ship fruit or other articles. Non-Compliance: Any regulated material found to be in non-compliance with the import requirements specified above will be subject to rejection measures, quarantine, return to origin or treatment at destination, or even incineration. Any cost incurred in the disposition of non-compliant wood packaging materials are the responsibility of the entity arranging the shipment at origin. Please refer to country specific provisions.

5 Division of cost according to Incoterms: According to Incoterms 2000, it is the obligation of shipper to provide at his own expense packaging and to arrange for appropriate marking (unless it is usual for the particular trade to make the goods of the contract description available unpacked). With fumigation being a part of the packaging, it is in case of all contract terms the responsibility of shipper to arrange packaging and marking. Please recommend customers to explicitly regulate the packaging and fumigation responsibilities within their contracts of sale. Essen, Product Management Sea Freight Hans-Michael Dietmar Background: In recent years, there has been increasing concern about the spread of pests, such as the Asian long-horn beetle and the Pine Wood Nematode, since wood packaging material made of unprocessed raw wood provides a pathway for the introduction and spread of such pests. A few years ago there was a major incident, when the Asian longhorn beetle was discovered in the U.S. Having made its way there in the wood packaging imported from China, with the result that avenues of trees in Chicago and New York had to be immediately felled so as to control the spread of this pest. The pest has not yet been eradicated and felling continues. In order to protect their trees and forests, a number of countries and trading blocs have taken regulatory action to control the import of wood packaging. At the present time, at least fourteen countries and the EU have taken such action, and the regulations differ in each case, with the results that exporters are finding it extremely difficult to understand the regulations that apply when exporting to such countries. A case in point, is Australia, which requires specific heat treatment of wood packaging, and there are many other specific regulations, such as those applicable to Argentina and Brazil. Although the necessary introduction of Phytosanitary regulations will inevitably lead to an increase in the cost of wooden pallets and packaging, this increase will still result in wood packaging being considerably cheaper than alternatives, such as plastic packaging. It is highly likely that most other nations and trading blocs will implement ISPM15 in the near future (China, the European Union). It is, therefore, imperative to all users and purchasers of wooden packaging that they plan now, so as to ensure that their wood packaging used in future shipments is fully compliant with the regulations.

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