In July of 2005, US Customs and Border Protection (CBP) conducted a special operation to determine the baseline level of WPM compliance. CBP estimates that 50% of WPM arriving in the United States does not meet the requirements of revised import regulations (ISPM #15). Therefore, based on this estimate, CBP will perform phased-in compliance enforcement of the USDA WPM regulations.

September 16, 2005: The Customs and Border Protection (CBP) will notify importers of non-compliant wood packing material until February 1, 2006, but take no other action unless infestation is noted.

February 1, 2006: CBP will begin rejecting shipments (repacking non-compliant pallets and crates and re-exporting the non-compliant packaging) at the cost of the importer.

July 5, 2006: Full enforcement. All wood packing material must be treated and marked. Non-compliant, regulated wood packing material will not be allowed to enter the United States.

APHIS-PPQ sources advise the trade community to complete the importers statement on a separate document (i.e. company letterhead) for ease in reference by CBP Inspectors. The following language is acceptable: “All WPM associated with this shipment was made from trees harvested in the Canada and further processed into WPM manufactured in Canada.” If WPM is of U.S. origin, the above statement should be adjusted accordingly. Canada is expected to announce a similar requirement shortly.

The statement will not eliminate inspection for pests; both Canada and the United Sates will still be inspecting WPM from all countries.

• Importers are advised to use caution
• Validate any manufacturer's claims. Talking with references can help you spot problems and issues.
• Fraudulent use of the IPPC mark may result in legal action(s)
• For purposes of enforcement, and absent acceptable proof to the contrary, CBP will consider the country of origin of merchandise coming from Canada to be the country of origin of the accompanying WPM.

• Shipments of new or used pallets will still be considered WPM and are subject to the rule.
• USDA has grandfathered in all wine crates for vintage years preceding 2006. This means that wine crates for any wine with a vintage year through 2005 are exempt from treatment and marking requirements. Wines of vintage years 2006 and beyond will be required to be in crates that have been treated and marked.
• Articles of wood that are manufactured to transport a specific non-regulated commodity (i.e. fuel gauges, armaments, ammo boxes) are not considered to be WPM and are not required to be treated or marked.
• WPM that are part of any bundle of imported lumber are exempted from the rule. Other than WPM used in the transport of bundled lumber (i.e. pallets or planks) are not exempted and are regulated WPM.

• IPPC mark should be placed on at least two sides of the articles
• The use of red or orange should be avoided, since these colors are used in the labeling of dangerous goods
• All component materials of recycled, remanufactured, or repaired WPM should be treated and marked
• Parties involved in U.S. import transactions should ensure suppliers and shippers are aware of these requirements

Furthermore, APHIS-PPQ has a toll free number available for questions pertaining to the importation of wood packing material. In the United States and in some Canadian locations the toll free number is 866-738-8197. International callers may call (USA Country Code - 011) 301-734-5376. This service will be active from September 1, 2005 through October 16, 2005, with a possible extension.

For more information regarding this alert, please your local Deringer office at 800-448-8108.