WOODEN PACKAGING EXPORT REQUIREMENTS
Recent concerns over insects and disease spreading across international boundaries has forced many countries to enact strict import requirements for pallets. Please click the links above for updated requirements for each country.
Information Provided by Robert A. Peters, Technical Resource Director National Wooden Pallet and Container Association (NWPCA)
The Brazilians have
removed the U.S. from the requirements for a
certificate for Solid Wood Packing Material (SWPM) due to the
was accomplished through the combined efforts of USDA-APHIS and the US
to Brazil, and with support from the National Wooden Pallet and
Association and the American Forest and Paper Association.
modification is contained in Inter-Ministerial # 146 dated 12 Apr. 2000.
modification was published in today's Diario Oficial and takes effect
Min. Agr. and Customs will notify port, airport, and border station
of the new provision relevant to U.S. origin wood packing
regulation includes a stipulation that should the Chinese or
Longhorn Beetle (ALB) (= Anoplophora glabripennis) be introduced and
in U.S. states (other than New York and Illinois which are under
control) or should the detection in Brazil of the pest in material
the United States occur, then these events would imply the
of a requirement of a Phytosanitary Certificate accompanying
wrapping, and support material of solid wood from the U.S
validity of the removal of the US from the list of countries
must provide certificates is contingent on periodic inspection by
and upon corresponding procedures to reduce the phytosanitary risk
solid wood packing and supports.
note: Solid Wood Packing Material (SWPM) must continue to be bark
On March 15, 2000, Brazil's Ministry of Agriculture issued an "operational
directive," in response to USDA's Animal and Plant Health Inspection
Service's (APHIS) refusal to issue phytosanitary certificates for pallets
and other wood packaging entering Brazil, (See the February 1, 2000 issue of
Pallets In Brief, "Brazilian Regulations Present Quandary," page 1).
Editor's note: The following description of the Brazilian "directive" was
received by NWPCA from the logistics department of a U.S. corporation with
facilities in Brazil. It is a summary, not a translation.
Since each port of entry and airport appears to be implementing the
requirements a bit differently, the Ministry has issued some clarifying
instructions. Three possibilities are considered for shipments arriving on
solid wood pallets without a Phytosanitary Certificate from the country of
1.) Exchange the incoming pallet at the port of entry and incinerate it;
2.) Allow shipments on pallets that cannot be exchanged at the port of
entry, to be moved to the importer's facility, as long as the importer signs a
commitment form that says they will incinerate the pallets; or
3.) Refuse the shipment and send it back to the country of origin.
The use of methyl bromide is no longer generally available for quarantine
purposes in Brazil. But, the airports seem to have a special authorization
to work with methyl bromide, so they continue to exchange and fumigate the
In cases where the pallet and load cannot be separated at an airport, the
Ministry is allowing the importer to sign a commitment form to allow the
shipment to move to its destination and send the pallets back for fumigation
or incineration within 48 hours.
U.S. Department of Agriculture officials continue to hear that Brazil is
inclined to remove both the U.S. and Japan from the current requirements.
When this will officially occur is not clear.
As of February 4, a high ranking USDA/APHIS official reported that,
in the absence of an official export certificate (PPQ Form 577, which APHIS
will not issue), shipments are apparently being allowed to travel to their
destination, but after the goods are off-loaded the packing material is being
fumigated or incinerated. Treatments of wood packaging here in the states,
because it is not verified by the PPQ form is of marginal value to the
Brazilians. USDA/APHIS hopes to resolve the discrepancies between the
regulations and what is being enforced "on the ground" by the end of
Since both the U.S. and Brazil are parties to the International Plant
Protection Convention, they are required to ensure that any phytosanitary
measures can be technically justified. USDA/APHIS officials have traveled to
Brasilia to made the case that; since the Asian Longhorned Beetle is "under
official control" here in the U.S., Brazil should be asking for special
shipping requirements only for material coming from within the official
quarantine areas of Chicago and Long Island. NWPCA is sending a letter to
the Brazilian Agricultural officials in support of the USDA/APHIS position.
The Chinese Entry-Exit Inspection and Quarantine officials have
reported to the US government that, during January 2000 less than 10% of the
import shipments were in compliance with the new Chinese coniferous wood
packing material treatment requirements. Vigorous enforcement action is
expected to begin on March 1, 2000. Please be aware!
In addition to making the statements about non-solid wood and non-coniferous
wood on your invoices and packing slips; the Chinese are requiring the same
statement to be made on your company letterhead and signed by an official of
your company. Note: This also applies to your customers' shipments. That
is, the Chinese will look for signed statements on the business letterhead of
both the pallet provider and the pallet user.
Background: Australian solid wood packing material requirements are
developed and implemented by the Australian Quarantine and Inspection
Service of the Department of Agriculture, Fisheries and Forestry. The
latest requirements dated March 15, 2001 can be read in their entirety at: http://www.affa.gov.au/corporate_docs/publications/cover_page/quarantine/border/cargo.html
Summary: Packing material can either be:
 permanently immunized or "treated"
[2) treated using "non-permanent" methods
Non-permanent treatments include;
a) Methyl bromide (CH3Br),
b) Sulphuryl fluoride (SO2F2)
 Heat Sterilization
Note: Please complete 4. Certificate starting in the middle of page 4 (on
the faxed pages). Remember that timber treated by one of the "non-permanent"
methods must be packed in a container or shipped within 21 days of
New Requirement: In an effort to reduce the amount of methyl bromide used in
pallet treatments Australia has indicated that:
"From 1 September 2000 AQIS will initiate a monitoring
program for consignments covered by certificates for methyl bromide
treatments carried out below 10°C (50°F)".
Acceptable Pallets for shipping to Australia
Hardwood will need to be treated starting October 2004.
The European Union (EU) has published Emergency Requirements which become
effective on October 1, 2001. The emergency requirements apply to
coniferous wood only (softwood-pine, spruce, etc.) and are designed to stem the influx of solid wood
material containing the pinewood nematode. Beginning October 1, 2001, all
solid wood pallets (softwood only) and containers shipped to any EU nation from the U.S.,
Canada, China or Japan, must be:
1. Heat treated to a core temp of 56°C for at least 30 minutes;
and marked to indicate location of treatment;
· 2. Pressure (impregnated) treated; and marked to indicate
location of treatment.
*Important note- requirement does not pertain to 100% new hardwood pallet. Exporter should contact their pallet supplier for a letter stating pallets are manufactured from 100% hardwood. If exporting on used pallets, pallets would most likely need to be heat-treated- since the origin of the lumber can not be certified.
Hardwood will need to be treated starting October 2004.
Additional Information http://www.forestry.gov.uk/website/oldsite.nsf/ByUnique/HCOU-4U4J4L
Finland Considers Heat-Treatment Requirements
In light of actual Pinewood Nematode interceptions, Finland has advised the
U.S. Department of Agriculture Animal and Plant Health Inspection Service,
(USDA-APHIS) that they are strongly considering restrictive actions deemed
necessary in order to protect their pine forests. Additionally, Finland
reported that its entry requirements may include certification and measures
that require that the wood be either heat-treated (56 degrees Celsius for 30
minutes), kiln dried (KD) or fumigated.
NWPCA has learned that several shipments made to Finland in February
contained pallets with bark and/or grub holes larger than three millimeters
across. Upon arrival of these shipments, Finland destroyed the imported
coniferous material. To date, Finland is the only country to report this
On March 28, USDA-APHIS notified NWPCA that they have received six more
"Notifications of Interception of a Consignment from a Third Country" from
Finland since mid-February. These latest notifications were issued for U.S.
origin pallets not meeting EU requirements.
All U.S. pallet manufacturers please note, the European Union's Solid Wood
Packing Material requirements are as follows:
· For coniferous wood pallets, when not traded as commodities in themselves,
do not require a Phytosanitary Certificate. But, the wood must be stripped
of its bark, and shall be free from grub holes, caused by the genus
Monochamus spp. (non-European). The grub holes are defined as those which
are larger than three millimeters across, and the pallets shall have a
moisture content expressed as a percentage of dry matter, of less than 20 %
at the time of manufacture.
For hardwood pallets, when not traded as commodities in themselves, the
USDA-APHIS has been advised that there are no current EU regulations.