Wood Crating, Pallets, and All Non-Manufactured Wood Packing Material
We Certify and Stamp to European Union Regulations;
Wood Packing Materials to Europe
European Union Measures for Coniferous
Non-Manufactured Wood Packing Material
Updated November1, 2005
The Commission of the European Communities has adopted emergency measures requiring the treatment and marking of all new and used coniferous (e.g. pine, spruce, fir) non-manufactured wood packing material (NMWP) originating in the United States, Canada, China, or Japan and departing on or after October 1, 2001, to prevent the introduction of the pinewood nematode. Hardwoods are exempt from the EU emergency measure. The pinewood nematode is a microscopic eelworm which has caused extensive mortality in pines in Japan and China. rn
(Since NMWP made entirely of hardwoods are exempt from the EU emergency measure, no marking of this material is required. The National Wooden Pallet and Container Association (NWPCA), the largest organization of wooden packaging professionals in North America is developing an optional mark for "hardwood only" NMWP. )
European concern over the possible introduction and establishment of the pinewood nematode has heightened over the past couple of years after an outbreak in Portugal and interceptions of the pinewood nematode in NMWP from the United States, Canada, China, and Japan. The source of the outbreak in Portugal has not been positively identified but packaging material is believed to have been the likely pathway.
The EU emergency measures allow three treatment options for coniferous NMWP: heat treatment (HT), fumigation or chemical pressure impregnation (CPI). In all cases treated wood must bear a mark indicating the organization that treated the NMWP and the location of that organization. The EU requires that the HT program be an official program with official marks.
The International Plant Protection Convention, which is recognized by the World Trade Organization as the official international plant protection organization, is now considering a draft international standard with measures very similar to those of the EU that would apply to all NMWP, coniferous and hardwood. The draft standard, which is being circulated for country comment, is tentatively scheduled for adoption in April 2003. Interested parties should review the standard and comment on the rule.
All three of the treatment options approved by the European Union are available to exporters in the United States. APHIS recommends the use of the heat-treatment (HT) option since that is the only "long term measure" currently listed in the IPPC draft standard.
The Heat Treatment (HT) Program
The American Lumber Standards Committee (ALSC) in coordination with APHIS and the NMWP industry has developed an official program for the HT option. The program will require SWPM assemblers to enroll with a grading agency affiliated with the ALSC and to acquire HT marked lumber from approved lumber mills. The program will include on-site inspections of NMWP manufacturing facilities to verify compliance. On-site inspections will be done by inspection agencies accredited by ALSC. The ALSC's policy on NMWP and NMWP enforcement regulation are available for review. Two official marks have been approved for the agencies: one mark for NMWP using 100% HT treated lumber and another mark for NMWP containing heat treated coniferous lumber and untreated non-coniferous wood (HTC/NHTNC). Contact one of the agencies listed below if interested in participating in the HT program.
As of August 1, 2001, the American Lumber Standards Committee has accredited the following organizations to participate in the HT program:
National Hardwood Lumber Association, Memphis, TN 901-377-1818
Northeastern Lumber Manufacturer's Association, Cumberland Center, ME 207-829-6901
Northern Softwood Lumber Bureau, Cumberland Center, ME 207-829-6901
Pacific Lumber Inspection Bureau, Federal Way, WA 253-835-3344
Package Research Laboratory, Rockaway, NJ 973-627-4405
The Packaging Department, Bloomington, MN 952-967-9400
Redwood Inspection Service, Novato, CA 415-382-0662
Timber Products Inspection, Conyers, GA 770-922-8000
West Coast Lumber Inspection Bureau, Portland, OR 503-639-0651
Western Wood Products Association, Portland, OR 503-224-3930
Fumigation of NMWP
Regarding fumigation, the EU emergency decision does not specify any particular fumigant or an officially approved mark, but it does require an officially recognized technical specification. In the United States the Environmental Protection Agency (EPA) is responsible for registering and establishing technical specifications ("labeling") for pesticides. All fumigants are restricted-use pesticides and they may only be purchased and applied by licensed commercial pesticide applicators. And, although it is a violation of Federal law for commercial applicators to apply a pesticide in a manner inconsistent with the EPA label, it is the State, not the Federal government, that licenses commercial applicators.
Because of these considerations, APHIS is advising exporters as follows:
- Fumigation may be used to meet the EU treatment requirement for coniferous NMWP.
- Fumigation must be done by licensed pesticide applicators following the EPA-approved label specification of the fumigant used.
- Methyl bromide is the fumigant recommended by APHIS, but any fumigant labeled for wood fumigation may be used.
- The name of the pest control company/applicator, the two-letter code for the state of origin, and the state pesticide applicator number should be shown on the coniferous NMWP.
- For fumigated NMWP APHIS has developed a recommended mark which has been officially endorsed by the NWPCA.
NMWP Made with CPI Wood
Environmental concerns surrounding pressure-impregnated wood make its large-scale use problematic. For instance, the Netherlands has recently prohibited the commercial importation of wood impregnated with copper compounds because of environmental issues. In spite of this the EU emergency measures do not require a specific chemical treatment or an official mark for NMWP made with CPI coniferous wood. The European Union does not require treatment of non-coniferous wood so NMWP may be made of untreated non-coniferous wood and CPI coniferous wood. In most cases, CPI wood contains quality marks and is a distinct color (due to the treatment process) so it cannot be mistaken for untreated wood. Like fumigants, CPI chemicals are regulated by the EPA and may only be applied by facilities that are licensed by the State governments. APHIS recommends the following for NMWP facilities that use CPI coniferous wood:
- NMWP assemblers must use coniferous wood that is pressure impregnated by a licensed wood preserver using a treatment officially approved by the American Wood Preservers Association.
- NMWP assemblers should mark each piece of NMWP (pallet, crate, spool, etc.) with a mark indicating the name of the location of the NMWP assembler.
- APHIS has developed recommended marks that have been endorsed by the NWPCA for NMWP assemblers using pressure impregnated coniferous wood. Please note that the recommended mark for NMWP made entirely of CPI wood is different than the mark for NMWP made of mixed CPI coniferous and non-treated non-coniferous wood.
PART: SPECIAL NOTICES OFFADD: Naval Inventory Control Point - Mechanicsburg, Code M2522, PO Box 2020, Mechanicsburg, PA 17055-0788 SUBJECT: EUROPEAN UNION (EU) RESTRICTIONS INVOLVING NON-MANUFACTURED WOOD PACKAGING (NMWP) AND PALLETS DESC: A requirement that "all wood pallets and wood containers produced of non-manufactured wood shall be constructed from Heat Treated (HT to 56 degrees Centigrade for 30 minutes) material and certified by an accredited agency recognized by the American Lumber Standards Committee (ALSC) in accordance with Non-Manufactured Wood Packaging policy and Non-manufactured Wood Enforcement Regulations both dated May 30, 2001" must be included in all solicitations and contracts where wooden pallets and containers may be used to ship material to U.S. forces and for Foreign Military Sales (FMS) customers in Europe. This requirement is necessary in order to comply with the Emergency Measure adopted by the commission of the European Communities (CEC) that became effective October 1, 2001. Membership in the CEC includes Austria, Belgium, Denmark, Finland, France, Germany, Greece, Italy, Luxembourg, Ireland, The Netherlands, Portugal, Spain, Sweden and the United Kingdom. The United Nations (UN) International Plant Protection Convention (IPPC) is drafting a similar measure to establish international standards for NMWPM and the prevention of various wood pests with an anticipated effective date of April 2003. NMWPM is defined as non-manufactured wood pallets, skids, boxes, and crates that have not had sufficient processing to kill pests present in the raw wood. One of the approved methods for eliminating this pest is to heat-treat (HT) the wood so the core temperature of each piece of treated wood will reach 56 degrees C for 30 minutes (56/30). The requirement may be added by incorporation into local palletization clauses, palletization sheets, or packaging requirements. At such time when the requirement is incorporated into material specifications and/or MIL-STD-2073-1, its inclusion in local clauses will no longer be necessary for solicitations and awards that include MIL-STD-2073-1. Refer to ' http://www.aphis.usda.gov/ppq/wpm/export/index.html
' for questions and material sources.
Phytosanitary Requirements for Wood Packaging Material requirements to European Unionrn
Updated November 1, 2005
Packaging Materials: Effective March 1, 2005 the European Union requires all newly assembled, repaired or recycled unprocessed raw wood packaging materials (hardwood and softwood) entering the EU to be either heat treated or fumigated and officially marked under ISPM15.
Dunnage: Hardwood and softwood dunnage is required to be either heat treated or fumigated and officially marked under ISPM15 OR if not treated and marked be bark free and free from signs of live pests. After December 31, 2007 all dunnage will be required to be treated and officially marked under ISPM15.
Wood packaging materials including dunnage less than 6 mm and processed wood produced from glue, heat, and pressure or a combination thereof (ie Oriented Strand Board, plywood, etc) are exempt from treatment and marking.
For questions pertaining to treatment and marking of WPM under the Heat Treatment program contact the American Lumber Standard Committee (ALSC) at 301-972-1700 or one of the accredited agencies listed at the ALSC website. Questions pertaining to where HT lumber may be purchased, how to become certified, costs pertaining to enrollment, required marks etc. may be directed to the ALSC or any of the inspection agencies.
Questions pertaining to treatment and official marking of wood packaging materials under the fumigation program may be directed to the National Wood Pallet and Container Association (NWPCA) at (703) 519-6104.