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U.S. On the Verge of Implementing EU Emergency Measures
Update of EU Requirements
By Chaille Brindley
Date Posted: 9/1/2001
The spread of insects internationally through wood packaging has been a brewing issue for more than a year. The European Union (EU) is set to put in place new requirements for some solid wood packaging exported to Europe. These requirements will take affect Oct. 1 and will impact primarily coniferous-based solid wood packaging shipped from the U.S., Canada, China and Japan. The EU's emergency measures are being implemented to stop the spread of the pinewood nematode, a microscopic eelworm that has caused extensive mortality in pines in Japan and China. 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. The source of the outbreak in Portugal has not been positively identified but packaging material is believed to have been the likely pathway. Pallets, crates, boxes and containers made of softwood lumber from these selected countries must be heat treated, kiln dried, pressure treated or fumigated with approved chemicals.
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 solid wood packaging.
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. However, if packaging is to carry the heat treatment mark governed by the American Lumber Standards Committee (ALSC), all solid lumber used in manufacturing the packaging must be treated. For example, if a pallet contains both coniferous and non-coniferous lumber, the entire pallet must be treated for the pallet to carry the treatment mark. Packaging made entirely of non-coniferous lumber does not need to be marked or treated. Currently, the U.S. Department of Agriculture (USDA) and the ALSC are working to develop a mark for pallets with both treated coniferous and non-treated, non-coniferous lumber. According to sources, the mark (HTC-NHTNC) must be approved by the ALSC's board. It is uncertain when and even if the HTC-NHTNC mark will approved. But all sides are hopeful for a remedy soon.
2.) Does 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, veneer, 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?
The lumber (each board) used to manufacture the 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.
The treatment mark includes the no-bug logo, the treatment method, the name of the accreditation agency, the mill identification number, and the country of origin code. The National Wooden Pallet & Container Association (NWPCA) has been given the option by the USDA to develop marks for other special situations/alternative treatment methods including pressure treated lumber, fumigated material and packaging made only of non-coniferous wood. The NWPCA is studying the viability of the USDA's suggestion. The NWPCA's executive committee would have to vote on such action before any marks could be developed. The ALSC has not setup certification processes for the three afore mentioned special situations.
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 over to the American Lumber Standard Committee (ALSC), a quasi-government standards body for the industry.
5.)When do the EU emergency measures take effect?
The EU emergency measures officially go 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.) How does the certification process work?
The ALSC has picked ten accrediting agencies to handle the treatment certification process. Most of these are either national or regional softwood or hardwood lumber grading agencies. The agencies will conduct an initial certification process and carry out monthly inspections. The initial process takes less than a day and is currently being offered. Inspectors will look to ensure that the treatment facilities are working properly and that the packaging manufacturer is using treated lumber. Inspectors will not be measuring moisture content of lumber or looking for the presence of the pests.
7.) 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. However, the ALSC and APHIS guidelines only recognize heat treatment as an authorized treatment method. Heat treatment is the only method that would not require international bilateral agreement because it has no potentially adverse environmental consequences. 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. Currently, the U.S. Department of Agriculture (USDA) and the ALSC are working to develop a mark for pallets with both treated coniferous and non-treated, non-coniferous lumber. According to sources, the mark (HTC-NHTNC) must be approved by the ALSC's board. It is uncertain when and even if the HTC-NHTNC mark will approved. But all sides are hopeful for a remedy soon.
The National Wooden Pallet & Container Association (NWPCA) has been given the option by the USDA to develop marks for other special situations/alternative treatment methods including pressure treated lumber, fumigated material and packaging made only of non-coniferous wood. The NWPCA is studying the viability of the USDA's suggestion. The NWPCA's executive committee would have to vote on such action before any marks could be developed.
8.) How often must the lumber and pallet manufacturing plants be inspected?
In the United States, facilities must be inspected every month. In Canada, the government is only requiring quarterly inspections. Inspection criteria differs from country to country. The EU allowed the exporting country to develop its own procedures as long as the EU approved them first.
9.) What is the typical certification cost?
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.
10.) Will enforcement vary from country to country within the EU?
There remains a significant amount of confusion on the details of the EU emergency measures. 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.
11.) 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.
12.) 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. These standards are in the draft stage and are scheduled for approval in April 2003. The coming international standard will apply to all countries and will cover both hardwood and coniferous solid wood packaging. According to the USDA, heat treatment will be the only universal option. Arrangements to allow fumigation or chemical pressure impregnation would have to be negotiated between the exporting and the importing countries.
13.) 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.
14.) 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.
15.) 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.
16.) 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. Also, the U.S. Department of Defense (DOD) is going ahead with an even more aggressive implementation strategy than the EU measures. The DOD does not want any non-certified pallets effective August 15.
17.) Besides dry kilns, is there other heat treatment options available?
Yes, PEST-HEAT has developed a treatment chamber designed to help companies treat pallets in order to meet the EU import requirements. The chamber uses heat to kill pests including the pinewood nematode. The PEST-HEAT system has been certified by Timber Products Inspection for heat treating packaging to the EU emergency requirements.
ACCREDITING AGENCIES FOR THE SOLID WOOD PACKAGING ISSUE
The following agencies have been approved by the American Lumber Standards Committee for certifying lumber manufacturers, remanufacturers and packaging manufacturers.
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