TRADE ALERT

TRADE ALERT

REVISED WOOD PACKING MATERIAL (WPM) IMPORT REGULATIONS TAKE EFFECT

SEPTEMBER 16, 2005

Effective September 16, 2005 the Plant Protection and Quarantine branch (PPQ) of the United States Department of Agriculture/Animal & Plant Inspection Services (APHIS) will implement revised import regulations for wood packing material (WPM). The revised import regulations for WPM will be consistent with International Standards for Phytosanitary Measures (ISPM). Regulated WPM is defined as wood packaging material other than manufactured wood materials, loose wood packing materials, and wood pieces less than 6 mm (0.24") thick in any dimension, that are used in supporting, protecting, or carrying a commodity. Examples of affected wood packing materials are dunnage, crating, pallets, packing blocks, drums, cases, and skids.

The regulation requires WPM coming into the United States to be:

Heat-treated to a minimum wood core temperature of 56˚ C for a minimum of 30 minutes or fumigation with methyl bromide.

Marked with the International Plant Protection Convention (IPPC) logo.

WPM imported after September 16, 2005 without the IPPC mark must be exported. Treatment or destruction will not be permitted. Unmarked WPM may be separated from the commodity being imported, if the examining Customs & Border Protection (CBP) officer determined separation could be done without pest escape. Importers failing to comply with these guidelines will subject their freight to immediate exportation.

Exemptions

WMP made of manufactured wood material (e.g. particle board, plywood, oriented strand board)

Wine and whisky barrels

WPM made of thin pieces of wood (6 mm/0.24" or less e.g. many types of small boxes used to ship fruit or other articles)

WPM used by the United States Department of Defense to package non-regulated articles, including commercial shipments pursuant to a DOD contract

WPM made of wood of Canadian origin

WPM from Canada

If WPM from Canada is made of Canadian origin wood, commercial shipments must be accompanied by an importer statement indicating the WPM wood is derived from trees harvested in Canada (per 7 CFR 319.40-3(a) (2)).

Determining the origin of the wood packing material will be difficult. However, APHIS is aware that Canada is implementing the ISPM requirements for WPM imported into Canada, and has acknowledged that they will allow WPM from Canada to enter the United States without IPPC marking.

WPM from Canada on cargo transiting the United States under a Transportation and Exportation (T&E) Bond should be appropriately marked in Canada to meet the WPM requirements of the country of destination. Otherwise CBP may require the cargo to be transferred to US. WPM appropriately marked to meet the WPM requirements of the country of destination. The determination and transfer would take place at the US port of "Exportation".

Deringer recommends that shippers and importers familiarize themselves with the revised WPM regulations to avoid the charges associated with the separation of the WPM from the cargo, as well as the shipping charges associated with the exportation of cargo.

For additional information, please refer to the following resources:

APHIS Final Rule:

http://a257.g.akamaitech.net/7/257/2422/06jun20041800/edocket.access.gpo.gov/2004/pdf/04-20763.pdf

Deringer's consulting & regulatory affairs group offers a full scope of services to support importers/exporters, carriers, and supply chain partners. For more information regarding this alert, please call 518-297-3511, or email us at consulting@anderinger.com.