International Pest Management/Wood Packaging – Packaging User

Pest Management Issue History 

Recent outbreaks of pests have been traced back to transport packaging, which has led governments around the world to start cracking down on solid wood packaging including pallets and crates. Numerous countries have established restrictions to stop the introduction of foreign pests, creating a complicated maze of regulations. The United Nations has stepped in to create one global standard. It will only apply to packaging made with solid lumber not engineered wood products (plywood, OSB, etc.) or corrugated.

The European Union (EU) has developed emergency requirements to prevent the spread of the pinewood nematode to Europe. The EU measures impact coniferous, non-manufactured wood packaging including pallets, crates and dunnage exported from the United States, Canada, Japan and China. The EU started to implement these restrictions on Oct. 1, 2001. However, the level of implementation and timing is left up to each member country. Affected packaging must be properly treated and marked.

Impact on Packaging Users 

The standard will likely increase the cost of wood pallets for international shipment, create a new classification of international pallet, and require additional paperwork for everyone involved. Some packaging users may switch to non-SWPM to avoid border delays. Be aware that the European Union started in October of 2001 to implement emergency measures for coniferous SWPM. A global standard governing all SWPM (both coniferous and non-coniferous) will likely be approved on March of 2002 and slowly implemented worldwide over a 2-3 year timeframe.

Action Steps

Evaluate your international transport packaging needs and consider your options. Designate someone in your company to study the issue and how it will impact your export packaging. Discuss the pending standards with packaging suppliers.

Below is a question and answers fact sheet for the international pest issue. The information is divided into two sections - the global standard and the EU emergency measures.

Global Standard

 1.) What is the international standard and who is responsible for creating it?

The International Plant Protection Organization (IPPO), a division with the United Nations, has finalized a proposed standard that would require all solid wood packaging (both coniferous and non-coniferous) to be treated and marked. Treatment methods include kiln drying, heat treatment, chemical pressure impregnation and fumigation with methyl bromide. 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. Implementation of the IPPO standard will take place over a couple of year period as each member country develops its own procedures.

2.) When will the international standard take effect?

The international standard will be voted on at the IPPC’s meeting at the end of March 2002. According to U.S. government officials, it will likely be adopted. Implementation would then be left up to each member country. Realistically, most countries will take 1-2 years to implement the standard if not longer. However, some countries in Europe may be more aggressive in implementing the standard.

3.) Will third world countries have the same restrictions as industrialized countries?

The global standard will impact all IPPC member countries including some third world nations. Realistically, poorer countries will 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 country to country.

4.) What treatment methods will be acceptable?

The international standard allows for various treatment methods including kiln drying, heat treatment, chemical pressure impregnation and fumigation. The preferred method is heat treatment to 56 degrees Celsius for 30 minutes. This can be achieved by using a dry kiln or any other approved heat treatment chamber. In some cases, fumigation or chemical pressure impregnation or other treatment methods will be allowed as long as the importing country approves. However, experts stress that fumigation will become the exception, not the rule. The primary chemical used in fumigation is methyl bromide, which has been banned for many applications by the Montreal Protocol because it is an ozone depleting substance.

5.) Are engineered wood products covered by the global standard?

The proposed global standard only impacts packaging using solid lumber (both coniferous and non-coniferous). Engineered wood products such as corrugated, plywood, OSB, etc. are exempt.

6.) How will the standard impact the lumber and pallet markets?

The heat treatment requirement creates an opportunity for coniferous 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. Many countries, including the United States, lack the kiln capacity to handle the coming demand for treated pallet lumber. There may be a supply shortage if the proposed regulations go through and are strictly enforced.

7.) Should we switch to material other than solid wood for our packaging?

In most cases, solid wood pallets remain a viable if not the best option for international transit. You must factor in much more than just the bug export issue. Even 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. Pallets made from engineered lumber products may work for some applications. But these engineered products can be expensive and have drawbacks as well.

EU Emergency Measures

1.) Do the EU emergency measures apply to both coniferous and non-coniferous solid wood packaging?

The EU emergency measures apply only to solid wood coniferous packaging. All coniferous solid wood packaging must be marked and treated. If a pallet contains both coniferous and non-coniferous lumber, the coniferous material must be treated while the non-coniferous lumber does not.  For pallets that contain both coniferous and non-coniferous lumber, the American Lumber Standards Committee (ALSC) and the U.S. government have developed a mark that allows companies to only have to treat the coniferous lumber in the pallet. This mark is available through any of the accredited grading agencies under the ALSC guideline.

2.) Do engineered wood products or corrugated packaging fall under the EU emergency restrictions?

The EU requirements exempt engineered wood products including plywood, particle board, oriented strand board, venner, corrugated ,etc because they do not carry pests. The processes used to manufacture these products kill any pest that may be living in the original wood fiber.

3.) What exactly has to be marked and how?

There has been some confusion related to what does and does not have to be marked and treated. Non-coniferous (hardwood) lumber in pallets does not have to be treated even if a pallet contains some coniferous (softwood) lumber. Initially, the U.S. government did require all the material in a pallet containing both coniferous and non-coniferous lumber to be treated if it carried the treatment mark. Industry organizations succeeded in working with the U.S. Department of Agriculture to change this policy. For pallets that contain both coniferous and non-coniferous lumber, the American Lumber Standards Committee (ALSC) and the U.S. government have developed a mark that allows companies to only have to treat the coniferous lumber in the pallet. The non-coniferous lumber in a mixed pallet does not have to be treated. This mark is available through any of the accredited grading agencies under the ALSC guideline.  

Also, the U.S. government has developed a mark for pallets treated with fumigation or chemical pressure impregnation. There is no enforcement authority or accreditation process through the ALSC for these two marks. However, the EU does require that a licensed applicator be used. To ensure tracking ability, the marks require the license number of the fumigator or CPI applicator.   

The National Wooden Pallet & Container Association (NWPCA) has developed a mark for hardwood pallets. The hardwood mark is used for pallets that do not have any coniferous components in it. There is no enforcement authority behind this mark. It is used primarily to help border authorities distinguish non-coniferous and coniferous packaging. You will be responsible for making your own stencil based on the NWPCA guidelines. The U.S. government has approved the NWPCA hardwood mark and is encouraging the European Union to accept it.

 The only real issue that is left up to debate at this point is what does and does not have to be marked. Currently, coniferous lumber (each board) used to manufacture solid wood packaging must be marked once it is treated. If treated lumber then moves from the original sawmill to a remanufacturer, the remanufactured lumber (each board) must also carry the treatment mark. Then the packaging manufacture must mark the packaging (two outside faces) with the appropriate treatment mark before it can be used for export to Europe. If the lumber is manufactured, remanufactured and then used to produce packaging all by one company at one location, then the individual boards do not have to carry the treatment mark. Once treated lumber is transported from one location to another (even if it is all handled by one company) then the individual boards must be marked. 

Industry has pointed out that while this policy may make enforcement easier, it drives up the cost of compliance. The NWPCA has proposed that resellers be allowed to segregate and bundle certified lumber, marking the bundles, rather than each piece, in two places. The U.S. and Canadian processes are somewhat different. Canadian companies should contact the appropriate Canadian accreditation agencies for complete guidelines.

4.) Who is responsible for overseeing the certification program in the United States?

The Department of Agriculture's Animal and Plant Health Inspection Service (APHIS) is responsible for compliance in the U.S. and has turned the certification process for heat treatment over to the American Lumber Standard Committee (ALSC), a quasi-government standards body for the for the lumber industry.

5.) When do the EU emergency measures take effect?

The EU emergency measures officially went in effect on October 1, 2001. But the enforcement of the restrictions is left up to the individual member countries. Thus, some countries may be more flexible than others. European leaders have indicated that they want the targeted countries to comply as quickly as possible but do not want this issue to jeopardize normal trade relations.

6.) What treatment methods are allowed for shipments to the EU?

The ALSC, in conjunction with APHIS, has developed standards and a certification process to ensure compliance with the European requirements. The ALSC and APHIS have developed a certification program for heat treatment but not for other treatment methods. Companies can use either fumigation or chemical pressure impregnation as long they follow the guidelines outlined by the EU. However, ALSC will not certify these methods as part of its official program. 

The U.S. government has developed a mark for pallets treated with fumigation or chemical pressure impregnation. There is no enforcement authority or accreditation process through the ALSC for these two marks. However, the EU does require that a licensed applicator be used. To ensure tracking ability, the marks require the license number of the fumigator or CPI applicator.  

 The National Wooden Pallet & Container Association (NWPCA) has developed a mark for packaging containing no coniferous lumber. This mark has no enforcement authority or certification process connected with it.

7.) Will enforcement vary from country to country within the EU?

Yes, although the EU is crafting the emergency standard for Europe, implementation is left up to each member country. Some European countries, such as Spain and Germany, will likely be strict when it comes to enforcement whereas France may be more flexible according to the NWPCA. Port authorities will be required to make the judgement of what shipments contain coniferous wood packaging. For lighter looking hardwoods, there may be some confusion depending on how well the particular customs agent knows the different lumber species. Some shippers may want to send paperwork with each load to confirm that the packaging is made of only non-coniferous wood. However, there is no established certification system to carry this out right now.

8.) What will happen to loads shipped on non-certified coniferous-based solid wood packaging?

The EU has indicated that any coniferous solid wood packaging that does not comply with the requirements will be refused entry, destroyed or treated to eliminate the risk of the pinewood nematode prior to entry. This will likely necessitate the off-loading of any cargo from the packaging and may cause considerable delay.

9.) What are the differences between the EU emergency measures and the International Standard?

Beyond the emergency measures, international governments are working under the auspices of the United Nations to develop standards to prevent the spread of pests through transport packaging. This standard will be voted on at an international meeting in late March 2002. U.S. government officials expect it will pass and become the global standard for all countries that are members of the International Plant Protection Convention. The international standard will cover both coniferous and non-coniferous solid wood packaging. Implementation will take place gradually over a 1-3 year period after the international community adopts the standard.

10.) What are the member sates of the European Union?

There are fifteen member states of the European Union. They are: Austria, Belgium, Denmark, Finland, France, Germany, Greece, Italy, Luxembourg, Ireland, The Netherlands, Portugal, Spain, Sweden and the United Kingdom.

11.) Will documentation besides the marking of the pallets and lumber be required for movement of solid wood packaging into Europe?

No other documentation will have to accompany the export shipment. The EU emergency measures require the affected packaging to be marked (stamped, branded, labeled, etc.) to indicate proper treatment. This is designed to be a paperless system according to the USDA. Lumber and packaging manufacturing facilities will have to keep paperwork for the treated lumber. Sawmills and remanufacturing operations must keep records on the treatment facilities and the shipments of treated lumber. Packaging manufacturers must be able to show that they received the appropriate amount of treated lumber for the export packaging produced.

12.) What happens to the pallets, cables, spools, dunnage, crates, etc. currently in use or in inventory?

The EU ha stated that existing pallets and other solid wood packaging must meet the same requirements as new packaging. Some companies are investigating the option of purchasing modular heat treatment equipment to handle the problem. Existing packaging can also be fumigated.

13.) Who should be concerned about the EU emergency measures?

Any company in the U.S., Canada, China or Japan that exports to Europe or supplies lumber or packaging for European exports should be concerned.

14.) Do Europallets made in Europe but shipped to the U.S. or Canada fall under the EU emergency restrictions?

No! Pallets made in Europe can be turned around and shipped back to Europe without having to be treated or marked as long as you can verify that the pallet was made in Europe. Europallets are marked to indicate the country of origin. As long as the mark indicates that the pallet was made in Europe, the pallet is exempt from the emergency measure. This may one of your best options to meet the EU requirements in the short term while U.S. packaging suppliers ramp up for the new restrictions.

 Please keep in mind that printed material may be outdated. Contact the USDA Animal and Plant Health Inspection Service, your certification agency or the NWPCA to be sure that you have the latest information.

Updated: December 15, 2001