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IPPC Standard Q&A

Over the past couple of years, pest outbreaks have been traced back to transport packaging, which has led governments around the world to crack down on non-manufactured wood packaging materials including pallets, dunnage and crates. Numerous countries have established restrictions to stop the introduction of foreign pests, creating a complicated maze of regulations. The United Nations through the International Plant Protection Convention (IPPC) created a voluntary global standard on March 2002 (ISPM 15). It applies only to wood packaging materials (both coniferous and non-coniferous) made with solid wood not engineered wood products (plywood, OSB, etc.) or corrugated when used in international trade. The international standard does not apply to wood packaging material manufactured solely for domestic use.

The Pallet Enterprise staff has researched the IPPC standard and has developed a list of the most frequently asked questions and answers related to this topic.

IPPC Global Standard
1.) What is the international standard and who is responsible for creating it?
The International Plant Protection Convention (IPPC), a treaty among 115 countries and administered by the Food and Agriculture Organization of the United Nations, has approved a voluntary standard that requires all solid wood packaging material (both coniferous and non-coniferous) to be treated and marked. Approved phytosanitary measures include heat treatment and methyl bromide fumigation. The international standard sets specific treatment requirements. For example, heat-treated lumber/packaging must be heated at the core to 56 degrees Celsius for 30 minutes. Adoption of the IPPC standard will take place over the next couple of years as each member country develops its own regulations.

2.) When will the international standard take effect?
Global leaders met in Rome in March of 2002 and finalized the standard requiring treatment for both coniferous (softwood) and non-coniferous (hardwood) solid wood packaging materials. Adoption of the standard has been left up to each country. Some countries may act quickly. Other countries may never adopt the standard.

The projected goal for the U.S. government to implement the new IPPC standards is April or may of 2004. This will only impact wood packaging materials shipped into the United States. The U.S. Department of Agriculture Animal and Plant Health Inspection Service (APHIS) had intended on formally adopting the standard by January 2004. The delay will not impact the decision to implement the IPPC standard; instead it will just give industry a couple of extra months to comply. Even though the United States will not begin enforcing the new standard until later in the year it will start issuing notices to the governing agencies of foreign countries about noncompliant shipments starting in January 2004. The U.S. government will follow its current policy until the new standard goes into effect. The Canadian and U.S. governments are coordinating the implementation of the IPPC program while Mexico appears to be lagging somewhat behind its NAFTA neighbors.

Your compliance timetable depends on your customers and where they send their packaging. It all depends on when the momentum builds for compliance. As the EU, North America and other industrialized markets move to implement the standard, many packaging users will apply increased pressure on suppliers to only provide them with certified packaging. The standard does not set implementation deadlines and leaves it up to the member countries to require compliance. Plus, not every country belongs to the IPPC. For example, China is not a member at this time. At the time of publication, China's government officials have committed to adopting the IPPC standard in the near future.

3.) Will there be a grace period when countries implement the IPPC standard?
Although the European Union (EU) restrictions for coniferous wood packaging materials from the U.S. went into effect in October 2001, most countries in the EU phased in requirements over at least a one-year period, but there was never any official notice of the phase in period. According to official sources, both the United States and the EU will likely phase in the IPPC compliance for imports.

4.) Will third world countries have the same restrictions as industrialized countries?
Yes, but realistically, poorer countries may not be able to comply as quickly as industrialized nations. Thus, third world countries may be given more time to comply. These details will be negotiated on a country to country basis.

5.) What treatment methods will be acceptable?
According to government sources, the international standard allows for two treatment methods heat treatment and fumigation with methyl bromide. Heat treatment will likely become the most popular method due to environmental concerns caused by methyl bromide used to fumigate packaging. The standard calls for heat-treated material to be heated to 56 degrees Celsius for 30 minutes. This can be achieved by using a dry kiln or any other approved heat treatment chamber/device.

6.) Are engineered wood products covered by the global standard?
The IPPC standard only impacts packaging using solid wood (both coniferous and non-coniferous). Engineered wood products such as corrugated, plywood, OSB, etc. are exempt.

7.) How will the standard impact the lumber and pallet markets?
The heat treatment requirement creates an opportunity for coniferous (softwood) lumber to grab more of the pallet market because a significant amount of coniferous pallet lumber is already kiln dried and therefore meets the heat treatment standard. But it is still too early to tell how drastic any market changes will be. The new international standards will require the industry to change practices and add lumber treatment capacity.

8.) Should we switch to material other than solid wood for our packaging?
In most cases, wood pallets remain a viable if not the best option for international transit. You must factor in much more than just the phytosanitary regulation issue. Even after being treated, marked wood pallets will remain cost competitive compared to most alternatives. Corrugated pallets may be a sound option for some shipments (especially air freight) where water and moisture damage is not a significant concern. Most plastic pallets will remain too expensive for one-way use.

9.) How does treated/certified wood packaging materials have to be marked?
Companies seeking to provide packaging treated in accordance with ISPM 15 must be registered and inspection by authorized certification agencies. In the United States, the American Lumber Standard Committee is overseeing the inspection agencies for the heat treatment program while the National Wooden Pallet & Container Association (NWPCA) is leading the oversight program for fumigation. Your inspection agency should be able to give you more information about the mark needed to satisfy the ISPM 15 requirements.

10.) Which countries are likely to ask for bark-free or debarked material?
The IPPC standard does not call for wood packaging material to be debarked. But individual countries can request all incoming material be bark-free by showing scientific justification for such measures. In its draft proposal, the EU requires that wood packaging material be bark free. While this is a requirement that is more stringent than the current IPPC standard, it is not clear at this time if the EU will remove this provision in its final published standard. The U.S. government is hopeful that it can convince the EU to drop the bark free requirement according to one official government source.

11.) If I comply fully with the IPPC standard as it reads now, will the countries that currently have regulations in place accept those shipments?
Shipments must comply with the regulations in place for the particular country importing from the U.S. at the time of transit. Complying with the IPPC standard will not guarantee that your shipment will pass through customs if the importing country has more stringent requirements than the IPPC standard. The IPPC standard is available for individual countries to adopt. It has no effect on a country’s border policies until adopted by a country. For instance, countries with "higher" standards (ex: Australia) would keep their current requirements until the IPPC standard is adopted in Australia. But since the IPPC standard is more stringent than the EU standard (that is, it covers all wood types, not just coniferous) appropriately treated and marked wood would be acceptable for the EU.

12.) Can I apply the markings as shown even if there is no grading agency oversight process established within my country right now?
No, since the National Plant Protection Organization (NPPO), of the exporting country is responsible for oversight of the program, the use of marks must be coordinated with the NPPO. APHIS is the NPPO for the U.S. Companies that use the marks improperly will be investigated and could be fined.

13.) Do we have to treat packaging material shipments between NAFTA countries (Canada, US, Mexico)?
The proposed U.S. program calls for a special relationship with Canada while Mexico will be treated like any other country. The similarity between the United States and Canada in their forest ecosystems, pest structures and quarantine procedures has led to this exception. Non-manufactured wood packaging originating in either country will not have to be marked or treated in accordance with the IPPC standard to flow freely across the border. Shipments destined for other countries should be marked and treated.

14.) What will be the requirements for shipments to/from countries that are NOT part of the IPPC?
Each country sets its own phytosanitary regulations. Packaging will have to meet the requirements of the importing country. Even if a country does not require wood packaging material coming from the U.S. to comply with the IPPC standard, when APHIS begins implementing the IPPC standard, these countries would need to comply with the international standard to trade with the U.S.

15.) After the IPPC standard becomes effective, will I still be able to ship materials that were treated and marked per EU regulations or other country regs? (ex: pallets marked "China Treated" that were fumigated before).
APHIS anticipates that the EU and China will require wood packaging materials to be marked in accordance with the international standard.

16.) How stable is this standard? What is the timetable for potential changes to it?
The standard will change from time to time. There is a 3-year cycle for review of existing standards and the necessary adjustments will be made where needed.

17.) Will lumber shipped as a commodity be affected by the IPPC standard?
The IPPC standard only applies to the trade of non-manufactured wood packaging material used in the transport of commodities. Many countries, including the U.S., have separate requirements for logs and lumber.

18.) What are the requirements for dunnage?
Dunnage should be marked and treated under one of the approved measures. At a minimum, dunnage must be made from bark free wood and free of pests and signs of live pests. Dunnage includes blocking and bracing used to secure or support the commodity.

19.) Are there any countries where wood packaging fumigated with methyl bromide is not welcome?
In its proposed regulation, China is requiring that coniferous (softwood) wood packaging material coming from countries or regions where pinewood nematode occurs must be heat treated. China will accept other IPPC approved treatment methods from areas where the pinewood nematode has not been a problem. If this provision is part of China’s final rule, solid wood packaging material coming from the United States and Canada would have to be heat treated not fumigated. The Republic of Korea has a similar requirement in its draft standard.

Currently, APHIS is not aware of any countries that are rejecting fumigation with methyl bromide as an option for treating wood packaging. Fumigants volatize off very quickly, thus unless the fumigation is done in transit, there is little danger of the fumigant being associated with the packaging.

20.) Will methyl bromide be phased out of use for wood packaging materials due to environmental concerns?
While it is true that methyl bromide is being phased out due to environmental concerns, the chemical will be available for quarantine applications such as solid wood packaging. The Environmental Protection Agency (EPA) has released a final rule exempting quarantine and preshipment (QPS) use of methyl bromide from the phaseout regulation.

21.) Should pallet companies register as a licensed fumigator?
Being licensed as a professional fumigator and certifying proper fumigation of wood packaging materials under the phytosanitary regulations are two separate things. States/localities administer the licensing program for becoming a professional fumigator. Licensing requirements differ from state to state and usually involve extensive training classes, inspections, fees, etc. Industry experts agree that most pallet companies will opt not to become licensed as fumigators due to the high cost. Instead, most will hire a licensed fumigator to handle the treatment, and the pallet company would simply be certified as a provider of properly fumigated wood packaging materials.

22.) How much does fumigation cost per truckload?
The cost to fumigate is based on the cubic foot volume. Prices can vary in different regions depending on local regulations. Due to government mandated phase out of methyl bromide, fumigation costs keep going up each year. Typical fumigation costs range from $250-400 per trailer load of pallets depending on the market price.

23.) How does weather affect fumigation treatment?
ISPM 15 require that the temperature be 52°f or hotter in order to fumigate wood packaging. Cold temperatures render methyl bromide ineffective because the pests must have a high enough respiration rate for them to breath in the gas. The lower the temperature, the more gas and treatment time may be required to achieve the desired result. Methyl bromide comes as a liquid and must be heated to become a gas.

24.) What is the typical treatment time for pallets using fumigation?
The typical exposure time of gas is 24 to 72 hours depending on the dosage used. It takes three to six hours (high side) of preparation and 12-24 hours to clear product of gas.

25.) Is fumigation or heat treatment time sensitive? If so, for which countries/regions?
In theory, any fumigated pallet can be re-infested with termites or other wood-eating insects. Australia and New Zealand have time sensitive treatment requirements. Currently, APHIS is not aware of other countries taking this point of view.

26.) Does recycled/remanufactured packaging have to be re-treated and re-marked?
Recycled pallets must be re-certified and re-marked. Previous marks must be removed. According to APHIS, recycled pallets must be completely re-treated even if only one board is replaced.

27.) If you suspect someone is fraudulently marking wood packaging materials with a HT stamp, what should you do?
Mark fraud is a serious offense. Copyright law protects phytosanitary marks. Companies found guilty of mark fraud could be heavily fined. ALSC will investigate all reported cases of fraud. If you suspect fraud, call the ALSC at 301/972-1700.

28.) When will the new no-bug logo be ready?
The IPPC suspended use of the familiar no-bug logo after problems arose concerning the copyright of the mark. The no-bug logo originally proposed by the IPPC has been copyrighted by an American company, which would impact its use in the United States. The IPPC has selected a new logo and is keeping it secret until the mark has been successfully copyrighted in various countries. The new mark will likely be ready soon.

29.) If you have a pallet that has been made with non-certified heat treated lumber and is currently in use, can the pallet be marked and shipped as certified without having to be re-treated?
Made with treated lumber is not the same as being produced under the APHIS/ALSC program for wood packaging materials. Any unmarked pallet must be treated before it can be marked, and only a company participating in the APHIS certification program can apply the mark.

30.) There are a number of HT treatment technologies available on the market. How can you be sure if various technologies will pass inspection requirements?
Start by talking with your inspection agency. Find out if your inspection agency has ever inspected and approved the use of the various treatment options that you are considering. Recently, one inspector told the Pallet Enterprise that most of the commercially available options will work if setup properly. The only problem he reported with some systems has been poor air circulation. But most manufacturers have fixed these problems. Make sure to validate any manufacturer claims. Talking with references can help you spot any problems and better select the proper treatment option for you.

Please keep in mind that printed material may be outdated. Contact the USDA Animal and Plant Health Inspection Service, your inspection agency or the National Wooden Pallet & Container Association to be sure that you have the latest information.

Updated: March 20, 2003