European Union Regulations for packaging materials

Transcription

1 European Union Regulations for packaging materials From March 01, 2005 onwards, all import shipments for the EU territory (25 member states as per Annex) have to comply with the wood packaging standard ISPM15. Any wood packaging not treated will be subject to quarantine, thus delays and extra costs are inevitable. As communicated with circular dated 05. March 2005, EU member states incurred delay in transforming EU regulation into law of the individual member states. However, additional countries are introducing the law in fast sequence, so that it is difficult to give a review on the implementation status of all individual EU countries. Irrespective of the implementation status of remaining countries, governments already recommend to use only wood packaging in accordance with the ISPM15 Standard. Please inform your customers and support compliance accordingly. The EU requirement for complete debarking of imported wood packaging material shall only apply from March 01, General Requirements Cargo arriving in the European Union after March 01, 2005 has to comply with the requirements for wood packaging under ISPM 15. The standard has established guidelines for wood packaging material in international trade, indicating that 1. all wood packaging material must be bark free (requirement postponed until March 01, 2006); 2. all wood packaging material must have been subjected to a recognized method of treatment (heat treatment or fumigation); 3. the wood shall display a mark to prove compliance with the standard; Requirement of further documentation will be at the discretion of individual member states, communicated as provisions are published.

2 Treatment Options: - Fumigation (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-treatment (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. Wood Packing Material: These guidelines cover materials that are not manufactured, including pallets, boxes, cable drums, crating, cases, load boards, spacers, pallet collars and skids, actually in use in the transport of objects of all kinds. Dunnage: Until December 31, 2007 wood used to wedge or support non-wood cargo shall be made of bark-free wood that is free from pests and signs of live pests. Until then, there will be no requirements for further treatments. Exceptions: - Raw wood of 6mm thickness or less; - manufactured wood packaging made wholly of wood-based products such as plywood, particle board, oriented strand board or veneer that have been created using glue, heat and pressure or a combination thereof; - Wood packaging material coming from Switzerland. Marking: The qualified treatment 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. The mark shown below is to certify that the wood packaging material that bears the mark has been subjected to an approved measure.

3 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 registration number assigned for the company that manufactured or treated the wood used for the wooden packaging; YY = IPPC abbreviation disclosing the type of treatment (e.g. HT for Heat treatment or MB for Methyl Bromide ). DB = The letters DB shall be added to the abbreviation of the approved measure to confirm the use of debarked round wood. 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 retreatment. China Origin: Wood packaging made of coniferous wood will continue to require a phytosanitary certificate, in addition to treatment and marking.

4 Breach of the rules: The importation or movement in-transit of untreated non-manufactured wood packaging materials from any area of the world except Switzerland is prohibited. Any regulated material found to be in non-compliance with the import requirements specified above will be subject to quarantine, return to origin or treatment at destination. Any cost incurred in the disposition of non-compliant wood packaging materials are the responsibility of the entity arranging the shipment at origin. 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. 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 long-horn 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. 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. At the present time, a large number of nations (Australia, China, India, Canada, Mexico, New Zealand, Nigeria, Philippines, South Africa, South Korea, Turkey and the USA) announced the implementation of ISPM15 even though regulations may differ. Specific regulations apply for importation in Brazil and Argentina. The members of the European Union will require to comply with ISPM15 for all imports from Non-European origins. 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.

5 Annex IPPC ( International Plant Protection Convention ), an international treaty relating to plant health, to which 127 governments (as of 26 February 2004) currently adhere. The Convention has been deposited with the Food and Agriculture Organization of the United Nations (FAO). The purpose of the IPPC is to secure common and effective action to prevent the spread and introduction of pests of plants and plant products, and to promote appropriate measures for their control. NPPO RPPO ISPM15 ( National Plant Protection Organisation ), the official services established by governments to discharge the functions specified by the IPPC ( Regional plant protection organizations ) which may function as coordinating bodies on a regional basis. International Standards for Phytosanitary Measures EU Member states: Belgium, Denmark, Germany, Estonia, Finland, France, Greece, Great Britain, Ireland, Italy, Latvia, Lithuania, Luxemburg, Malta, Netherlands, Austria, Poland, Portugal, Hungary, Sweden, Slovakia, Slovenia, Spain, Czech Republic, Cyprus