Wood Packaging – Questions and Answers

Table of Contents

1. Need for wood packaging material import requirements
2. Information about the implementation of ISPM No. 15 between Canada and the United States
3. Information for Canadian importers of wood packaging material
4. Information for exporters of wood packaging material
5. Information about inspection and penalties for wood packaging material

A. Need for wood packaging material import requirements

Q.1 Why has Canada established import requirements for the entry of wood packaging material?

In March 2002, the International Plant Protection Convention's (IPPC) Fourth Interim Commission on Phytosanitary Measures (ICPM 4) adopted new guidelines for the uniform regulatory control of wood packaging moving in international trade: International Standards for Phytosanitary Measures (ISPM) No. 15 (Revised 2009): Regulation of wood packaging material in international trade. ISPM No. 15 describes guidelines for harmonized phytosanitary measures applicable to wood packaging material. As a member of the IPPC, Canada has fully adopted in 2006 this international standard as its national import policy directive for all wood packaging material originating from all countries except the continental United States.

The requirements for wood packaging materials produced in all areas of the world other than the continental United States are provided in Directive D-98-08.

Canada and the United States agreed in 2006 not to apply requirements to wood packaging material originating from and moving between the two countries. This exemption remains in force, however, both countries have agreed to begin implementation of ISPM No. 15 for wood packaging material moving between Canada and the United States in the near future.

Q.2 Why are regulations needed to control wood packaging material moving internationally?

Many invasive plant pests have been intercepted on wood dunnage, pallets, crating or other wood packaging material imported into Canada. Examples of plant quarantine pests intercepted include the citrus longhorned beetle (Anoplophora chinensis), the Asian long-horned beetle (Anoplophora glabripennis), some bark beetles (Ips typographus, Hylastes ater, Monochamus sp.), and a boring beetle (Trichoferus campestris). The introduction of the Asian long-horned beetle (Anoplophora glabripennis), the pine shoot beetle (Tomicus piniperda), and the emerald ash borer (Agrilus planipennis) can be attributed to wood packaging material moving internationally in trade. The establishment of an invasive species can heavily impact on ecosystems and forests and requires considerable investments for its management (prevention, detection and control, eradication, reforestation, etc.).

To date, wood packaging material moving between Canada and the continental United States has been exempted because the existing pest-specific regulatory policies were providing sufficient protection. However, with the number of invasive species which had been introduced to both countries, each has agreed to remove this exemption in order to better protect our forest resources.

Q.3 What items are considered wood packaging material?

Any of the following that is made from non-manufactured wood: dunnage, pallets, spacers, bearers, crating, etc., including wood bracing not permanently attached to freight vehicles or containers (e.g. flat rack and flatbed containers). All modes of transport are subject to the conditions of the Directive D-98-08: air, rail, marine and road. Please also see Q.4 below.

Q.4 Are there wood packaging materials that are exempt from these requirements?

Yes. Wood packaging material made wholly of processed wood material, such as plywood, particle board, oriented strand board or veneer that has been created using glue, heat or pressure, or a combination thereof; paper or cardboard products; or non-wood articles are not regulated. The following products are also exempt from the requirements:

• wood packaging materials made entirely from thin wood (6 mm or less in thickness);
• barrels* for wine and spirit that have been heated during manufacture;
• gift boxes for wine, cigars and other commodities made from wood that has been processed and/or manufactured in a way that renders it free of pests;
• wood shavings, sawdust and wood wool used to stabilize a commodity; and
• wood components permanently attached to freight vehicles and containers.

* Not all barrels are exempt. The requirements for the importation of decorative wood barrels are provided in Directive D-02-12.

Wood packaging material made of bamboo is not regulated under Directive D-98-08. Bamboo products must meet the requirements of Directive D-02-12.

Q.5 Is ship's dunnage regulated?

Yes. Ship's dunnage, also referred to as ship-borne dunnage, is wood used to brace cargo aboard a marine vessel. It is considered wood packaging material. Vessels may discharge dunnage which complies with the requirements specified in Directive D-98-08. The responsibility of ensuring ship's dunnage is compliant rests with Canadian berthing facilities and the ship's agents in Canada. If non-compliant dunnage is discharged in Canada, the port facility may be held responsible for ensuring that dunnage is brought into compliance through removal from Canada.

Dunnage used to secure or support lumber is regulated in the same way as other wood packaging material.

B. Information about the implementation of ISPM No. 15 between Canada and the United States

Q.1 Why are Canada and the United States removing exemption to ISPM No. 15 now?

Discussions with USDA-APHIS to remove the current exemption which has existed for wood packaging material moving between Canada and the United States began in early 2008. At that time, Canada and the United States agreed to terminate the exemption with respect to ISPM No. 15 for wood packaging material due to the number of pests likely introduced on wood packaging material prior to 2006 which now occurs in both countries. Some of these pests have continued to expand presumably moving on untreated wood packaging material. To further reduce the risk of pest distribution, both countries support moving to an implementation of ISPM No. 15 in North America.

Q.2 What is the target date for implementation of ISPM No. 15?

Canada and the United States are not immediately removing the exemption, but intend to implement ISPM No. 15 over a period of time to allow industry to become compliant with the new requirements. Canada and the United States will implement ISPM No. 15 import requirements at the same time.

Timelines for implementation of ISPM No. 15 have not yet been determined. Further discussions on the schedule are planned between authorities in Canada and the United States. The CFIA recognizes the importance of an implementation schedule that is sensitive to both ensuring protection of the Canadian resource base while preventing unnecessary disruption of trade.

More details will be released to industry as soon as they are available. If you would like to receive information on the future implementation of ISPM No. 15, please sign up to receive email notification.

Q.3 What do I need to do to ensure I export compliant wood packaging material to the United States?

Upon full implementation of the ISPM No. 15 Standard, wood packaging material exported to the United States will need to meet the following requirements:

1. The wood packaging material must be heat treated. Requirements for the export of certified wood packaging material are provided in Directive D-01-05.
2. The treated wood packaging material must bear an internationally recognized mark (IPPC mark - see Appendix 1 of D-01-05).
3. The wood packaging material must be debarked as described in Section 6.0 of Directive D-01-05.

Wood packaging material produced in accordance with another country official certification program can also enter the United States.

Please note that wood packaging material built with HT wood must be stamped with the IPPC mark to meet the United States import requirements.

To obtain further information on becoming an approved producer of certified wood packaging, please call your local office of the CFIA.

C. Information for Canadian importers of wood packaging material

Q.1 What do I need to do to ensure foreign wood packaging material is compliant for entry into Canada?

Wood packaging material entering Canada and originating from any country other than the continental United States, must meet the following requirements:

1. The wood packaging material must be heat treated or fumigated using methyl bromide at rates specified in Directive D-98-08;
2. The treatment or a process of treatment must be officially endorsed by the National Plant Protection Organization (NPPO) of the exporting country;
3. The treated wood packaging material must bare an internationally recognized mark (IPPC mark). In lieu of this mark, the consignment may be accompanied by a Phytosanitary Certificate specifying the treatment used, see Appendix 1 of D-98-08;
4. The wood packaging material must be debarked as described in Appendix 1 of ISPM No. 15.

Q.2 If I'm an importer, how do I know if the goods I receive meet the wood packaging material requirements?

Importers should contact their exporters to determine if the wood packaging material they are using complies with Canada's import requirements. Many countries have indicated that they have systems in place to meet Canada's import requirements. Information about the implementation of ISPM No. 15 in other countries can be found on the IPPC website

Q.3 If imported commodities are shipped on wood packaging material originating in the United States only, must they meet these requirements?

In 2006, both Canada and the United States agreed not to regulate wood packaging material moving between the two countries. At this time, requirements for treatment will not be applied to Canadian wood packaging material moving to the continental United States or vice versa. There is no declaration required by Canada or the United States to verify the origin of the wood.

However, with the number of invasive species being introduced to both countries, Canada and the United States have agreed to remove this exemption. Timelines for implementation of ISPM No. 15 have not yet been determined. If you would like to receive information on the future implementation of ISPM No. 15, please sign up to receive email notification.

Q.4 If I import goods that transit by the United States, must the wood packaging material comply with Canada's import requirements?

Yes, regardless of whether the commodity transits through the United States, all wood packaging material produced in a country other than the United States must meet Canada's import requirements.

Q.5 I am importing wood packaging material from a country that does not have a system in place to meet the standards of Canada's import requirements. Am I exempt from the requirements?

No. Wood packaging material must be compliant with Canada's import requirements.

Options for obtaining compliant wood packaging include:

• obtaining compliant wood packaging material from neighbouring countries with certification systems in place;
• obtaining the commodity from other sources capable of providing compliant wood packaging material;
• re-using compliant wood packaging that has entered the country of export, etc.

Q.6 I export and import commodities. Often my Canadian wood packaging material is sent offshore before returning to Canada. Must it still meet these import requirements?

As an exporter, Canadian law requires that you meet the importing country's phytosanitary import requirements. Requirements for the export of certified wood packaging material are provided in Directive D-01-05.

If you are shipping untreated wood packaging material overseas to countries not requiring treatment, the wood packaging material returning to Canada must meet the requirements specified in the Directive D-98-08. As such, to ensure that the wood packaging material has not become infested in the destination country, either directly or by replacement of some wooden components, the wood packaging material must be treated and certified either prior to export or before returning to Canada.

For more information, please call your local office of the CFIA.

Q.7 Does the wood packaging material need to be debarked?

Yes. Irrespective of the type of treatment applied, wood packaging material must be made of debarked wood. Any number of visually separate and clearly distinct small pieces of bark may remain if they are less than 3 cm in width (regardless of the length); or greater than 3 cm in width with the total surface area of an individual piece of bark less than 50 cm².

For methyl bromide treatment, the removal of bark must be carried out before treatment because the presence of bark on the wood affects the efficacy of the methyl bromide treatment. For heat treatment the removal of bark can be carried out before or after treatment.

Q.8 Methyl bromide treatment is expensive, are there any other acceptable treatments?

Acceptable methods of treatment are described in Appendix 1 of D-98-08. Currently, heat treatment and fumigation with methyl bromide are the only approved methods of treatment for entry into Canada.

Please note that, in accordance with Canada's ratification of the United Nations' Montreal Protocol on Substances that Deplete the Ozone Layer (1992), the CFIA does not promote the use of methyl bromide for the treatment of wood packaging material in Canada. However, methyl bromide is viewed as an effective treatment for mitigating pest incidence in wood packaging material and has been adopted internationally as a treatment.

Q.9 I import wine and/or spirits. Are the wooden barrels/finished display boxes regulated?

The requirements for wooden barrels and finished display boxes are provided in Directive D-02-12. In general, barrels containing spirits are not regulated. Barrels for other purposes, such as packaging or decorative use, are regulated.

Q.10 If non-wooden boxes are reinforced on the inside with wooden parts, can the IPPC mark be placed on the exterior sides of the box? Must it be placed on the individual wooden components?

If the wooden components are secured to the non-wooden box (staples, nails, glue, etc.) and the only way for the wood to be removed is by destroying the box, then the mark may appear on the outside of the box (on 2 sides). The facility is responsible for ensuring that all pieces of wood used to construct the boxes are treated in accordance to ISPM No. 15. If the wooden components are not secured to the non-wooden box (i.e. with staples, nails, glue, etc.) each piece of wood more than 6 mm in thickness must bear the IPPC mark.

Q.11 If the wood packaging material attached to my importation is not compliant, am I as the importer, responsible?

Yes. Any shipments with non-compliant wood packaging material will be ordered removed from Canada. The responsibility of the importer or person in care and control of the regulated articles is to ensure that the non-compliant wood packaging material is promptly removed from Canada. Any costs associated with the removal of the material from Canada must be borne by the importer or person in care and control of the goods.

D. Information for exporters of wood packaging material

Q.1 What are the import requirements for wood packaging material for foreign markets?

Each country may have unique import requirements for wood packaging material. Please contact a local office of the CFIA to determine the wood packaging import requirements for the specific country. You may also obtain information about the implementation of ISPM No. 15 in other countries by consulting the IPPC website.

The majority of Canada's trading partners have adopted the ISPM No. 15 requirements for the importation of wood packaging material.

The requirements include:

1. The wood packaging material must be heat treated. Requirements for the export of certified wood packaging material are provided in Directive D-01-05.
2. The treatment or a process of treatment must be officially endorsed by the NPPO.
3. The treated wood packaging material must bear an internationally recognized mark (IPPC mark - see Appendix 1 of D-01-05).
4. The wood packaging material must be debarked as described in Section 6.0 of Directive D-01-05.

To obtain further information on becoming an approved producer of certified wood packaging, please call your local office of the CFIA.

Q.2 Which facilities in Canada produces ISPM No. 15 compliant wood packaging material for export?

We can find a list of all facilities in Canada that are certified to produce wood packaging material in accordance with ISPM No. 15.

E. Information about inspection and penalties for wood packaging material

Q.1 How will you know if my imported wood packaging material is compliant?

Canada is conducting inspections to verify compliance. Both tailgate and destuffing inspections will be used. The Canada Border Services Agency is currently performing these inspections for wood packaging material arriving in major Canadian marine ports.

Tailgate inspection: an examination conducted by simply opening the doors of a conveyance such as a container or railcar.

Destuffing inspection: complete unloading of the contents of a conveyance.

Q.2 If a consignment contains wood packaging material, what will happen to it when it enters Canada?

The shipment may be re-directed to a facility where the commodity will be inspected. The shipment may be ordered to be inspected at destination. The inspection staff may order the container or other shipping unit to remain sealed until they are able to inspect it. Upon inspection, the Canada Border Services Agency will determine whether the conditions for entry have been met.

Any costs associated with the inspection, treatment and disposal of non-compliant wood packaging material are the responsibility of the importer or person in care and control of the shipment.

Q.3 If the wood packaging material attached to my shipment is not compliant, what penalties will be imposed?

Any wood packaging material that does not have the approved mark or found to be infested will be refused entry into Canada. It may also be treated to mitigate the risk of pest entry prior to being ordered removed from Canada.

Important: Treatment prior to being ordered removed is strictly to mitigate the risk of pest escape into Canada. This treatment is not intended to render the wood packaging material compliant with Canadian import, domestic or export requirements and as such may not enter Canada once treated. Canada will not issue a Phytosanitary Certificate for this action. All wood packaging material must comply with ISPM No. 15 standards prior to entry into Canada.

All costs associated with non-compliant wood packaging material are the responsibility of the importer or person in care and control of the regulated articles.

Q.4 What will be the charge for inspection of containers for wood packaging material to verify conformity for entry into Canada?

For wood packaging material found within containers imported to Canada, the applicable fee is $18 per lot. A lot, in the case of cargo containers, is defined as "three units or less that are owned by one person" and "in any other case, a number of units of a single thing that is or will be transported by a conveyance or a person and that is owned by one person."

Q.5 What fees apply if wood packaging material is found to be non-compliant for entry into Canada?

Fees are applied to all inspection activities. Fees must be paid by the importer or person in care and control of the shipment. Applicable fees are set out in Table 1, Part 12, of the CFIA Fees Notice, All other direct costs associated with control/enforcement actions for wood packaging material, (transportation, deep burial, etc.) must be paid by the importer or person having the possession, care or control of the wood packaging material.

Q.6 Who do I contact for further information?

For questions related to how to meet the import and export requirements for wood packaging material, please call your local office of the CFIA or 1-800-442-2342.

For questions about the enforcement of the wood packaging requirements, please visit the Canada Border Services Agency (CBSA) website.