Bug Update: EU Emergency Measures

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 adopted 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.

Our staff has researched the EU emergency measures and has developed a list of the most frequently asked questions and answers related to this topic. Also, we are providing a list of the accrediting agencies and other resources you may need to deal with the pest management regulations for non-manufactured wood packaging.

EU Emergency Measures
1.) Do the EU emergency measures apply to both coniferous and non-coniferous solid wood packaging materials?
The EU emergency measures apply only to non-manufactured wood coniferous (softwood) packaging materials. If a pallet contains both coniferous and non-coniferous lumber, the coniferous material must be treated while the non-coniferous wood does not. For pallets that contain both coniferous and non-coniferous wood, 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 inspection 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) wood in pallets does not have to be treated even if a pallet contains some coniferous wood. For pallets that contain both coniferous and non-coniferous wood, 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 wood in the pallet. The non-coniferous wood in a mixed pallet does not have to be treated. This mark is available through any of the inspection 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 non-coniferous pallets. The non-coniferous 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.

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.

Please note that 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 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. 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 worked under the auspices of the United Nations to develop a standard to prevent the spread of pests through transport packaging. This standard was approved at an international meeting in late March 2002. The international standard covers both coniferous and non-coniferous solid wood packaging. Adoption of the standard is left up to each IPPC member country.

10.) What are the member states 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 has 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.

15.) How often must the lumber and pallet manufacturing plants be inspected?
In the United States, heat treatment facilities must be inspected every month. In Canada, the government is only requiring quarterly inspections. Inspection criteria differ from country to country.

16.) What is the typical certification cost for heat treatment?
This varies depending on the agency that you use. Some agencies charge a flat rate per inspection. Others charge per 1,000 board feet of treated lumber per inspection.

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: November 6, 2002