Customs 101: Wood Packaging Materials
The use of wood packaging material (WPM) in international trade is regulated by many countries including Canada and the United States in order to prevent the spread of pests and pathogens. The WPM treatment rules, referred to as ISPM 15, were developed under the auspices of the International Plant Protection Convention and apply all WPM including pallets, crates, dunnage and all other wood materials that are used to carry, support, brace or protect cargo.
NB: These rules do not apply to WPM made entirely from “manufactured” wood (eg. plywood) or non-wood materials (eg. plastic or metal). A complete list of exemptions can be found in the links provided below. If in doubt, comply with the rules!
Here is a brief summary of the WPM rules, Customs administrative policies and best practices as they relate to:
- All shipments imported into Canada from all countries other than from the continental United States; and
- All shipments moving northbound and southbound between Canada and the continental United States.
References are provided at the end of this notice for additional information.
1. WPM rules for shipments to Canada, including shipments passing in transit through Canada to another country, from all countries other than from the continental United States.
- These rules apply to all WPM unless the packaging is wholly comprised of exempt materials.
- Exempt materials means
- “manufactured wood” such as plywood, veneer or particle board that has been created using glue, heat and/or pressure;
- wood chips, sawdust or other processed wood product used to stabilize a commodity;
- packaging constructed entirely of wood of less than 6mm in thickness.
- All WPM must be free of soil and bark.
- All WPM must be free of pests (live or dead insects, eggs or pathogens) or any evidence of pest activity.
- All WPM must be heat treated or fumigated with methyl bromide in accordance with ISPM 15 standards.
- Each treated article of WPM or piece of blocking, bracing or dunnage must be visibly, legibly and permanently marked or stamped with the IPPC logo in the prescribed manner on at least two sides of the article that is being certified. The mark or stamp must be applied by a licensed WPM manufacturing facility, in accordance with the International Standard for Phytosanitary Measures (ISPM) No. 15 (2009).
- Although Canada (but not the United States) may accept a Phytosanitary Certificate instead of the IPPC mark or stamp on WPM originating from certain countries, Milgram strongly recommends that all WPM be marked or stamped in accordance with ISPM 15.
- Canada will not, in any case, accept a Phytosanitary Certificate for WPM from the People’s Republic of China. Only duly marked or stamped WPM will be admitted.
2. Special WPM rules for trade between Canada and the United States
- WPM moving between Canada and the continental United States is currently exempt from the treatment and marking requirements of ISPM 15.
- However, as a matter of Customs policy, best business practices and in order to minimize the risk that the goods will be held at the border for inspection or rejected as inadmissible, shippers and carriers must comply with the following:
a. Shipments from Canada to the United States
- The WMP must be free of soil, bark and pests or evidence of pests.
- If any ISPM 15-marked WPM is used, all of the WPM in that shipment must be marked.
- If all of the WPM is unmarked and all of the wood originates in Canada or the United States and has never been outside of Canada or the United States, the shipper should make a specific declaration on both the bill of lading and commercial invoice stating that all of the unmarked WPM in the shipment is of Canadian or US origin.
- If any of the WPM originates or has been outside of Canada or the United States, all of the WPM in the shipment must be treated and marked in accordance with ISPM 15.
- CHEP pallets may be used, subject to these same rules. However, it is not permissible to mix marked and unmarked CHEP pallets or CHEP and non-CHEP pallets in the same shipment.
b. Shipments from the United States to Canada
- The WPM must be free of soil, bark and pests or sign of pests.
- ISPM 15-marked WPM should be used whenever possible.
- If the shipment contains any unmarked WPM, a statement on the bill of lading or invoice should certify that all of the WPM originates in Canada or the continental United States.
- Any WPM that originates outside Canada or the United States must be treated and marked in accordance with ISPM 15.
c. Canada & the United States-Looking ahead
- The WPM exemption between Canada and the United States is expected to be rescinded in or about 2013. Shippers and carriers are encouraged to begin using compliantly marked WPM or wood substitutes such all metal, plastic or compressed paper packaging materials as soon as possible.
3. The high price of non-compliance with Canada’s WPM rules
The consequences of non-compliance with Canada’s WPM rules are severe. An ocean container that contains any non-compliant WPM will be refused entry into Canada and all of its contents will be ordered to be exported, including any compliant shipments in the same container, even if those compliant shipments are consigned to a different importer.
For Canadian import requirements for wood packaging materials produced in all areas other than the continental United States, click here.
For the Wood Packaging Materials page on US Customs and Border protection website with links to guidelines, FAQ’s and legislation in the Federal Register, click here.
Sources: CFIA, CBSA, CBP, US Federal Register