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.

UPDATED 8/4/03

Information Provided by Robert A. Peters, Technical Resource Director National Wooden Pallet and Container Association (NWPCA)

Brazil: 

4/17/00

The Brazilians have removed the U.S. from the requirements for a

phytosanitary certificate for Solid Wood Packing Material (SWPM) due to the

Asian Longhorned Beetle.  

This was accomplished through the combined efforts of USDA-APHIS and the US

Ambassador to Brazil, and with support from the National Wooden Pallet and

Container Association and the American Forest and Paper Association. 

 

The modification is contained in Inter-Ministerial # 146 dated 12 Apr. 2000.

This modification was published in today's Diario Oficial and takes effect

immediately.  

The Min. Agr. and Customs will notify port, airport, and border station

inspectors of the new provision relevant to U.S. origin wood packing

materials. 

The regulation includes a stipulation that should the Chinese or

Asian Longhorn Beetle (ALB) (= Anoplophora glabripennis) be introduced and

established in U.S. states (other than New York and Illinois which are under

official control) or should the detection in Brazil of the pest in material

from the United States occur, then these events would imply the

reestablishment of a requirement of a Phytosanitary Certificate accompanying

packing, wrapping, and support material of solid wood from the U.S 

The validity of the removal of the US from the list of countries

which must provide certificates is contingent on periodic inspection by

APHIS, and upon corresponding procedures to reduce the phytosanitary risk

from solid wood packing and supports.

 

Editors note: Solid Wood Packing Material (SWPM) must continue to be bark

free, and apparently free of live pests.

3/31/00

Brazil Responds:

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

origin:

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

pallets.

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.

2/10/00

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

February.

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.

China:  

2/10/00

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.

Australia:

3/31/01

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:

[1] permanently immunized or "treated"

[2) treated using "non-permanent" methods

Non-permanent treatments include;

[1] Fumigation

a) Methyl bromide (CH3Br),

b) Sulphuryl fluoride (SO2F2)

[2] 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

treatment.

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 10C (50F)".

Acceptable Pallets for shipping to Australia

EU

Hardwood will need to be treated starting October 2004.

8/04/03

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 56C for at least 30 minutes;

and marked to indicate location of treatment;

or

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

happening.

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.

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