New Wood Packaging Material Rules

New Wood Packaging Material Rules

Wood Packaging Material Rules and Regulations

Regulations surrounding the importation of wood and wooden products have been in existence for a very long time, but wood packing materials have not always been viewed with the same level of scrutiny that other wooden products have. Even as early as 2005, wood packing regulations were implemented but it wasn’t until many years later they were meaningfully enforced. 

This transition from the loosely enforced regulations that existed in 2005 to the rules and enforcement as they exist now in Canada and the United States represents a significant evolution based on research and expanded policy, and they are an excellent example of the living process these regulations can go through. 

From dunnage rulings to US Customs pallet requirements, it is worth knowing what enforcement of these regulations was like at the time, how it’s changed, and what it might mean for you as an importer today. 

A Brief History of Wood Packaging Material Regulations

In 2005, Canada and the US, along with their governing bodies - the CFIA and the USDA, had relatively loose enforcement when it came to rules surrounding internationally-bound packaging materials. The reason for this is varied and complex, but part of it is that there were several challenges faced by governing bodies when it comes to these kinds of materials, including: 

  • The difficulty involved in tracing the origin of these materials, 
  • The fact that shipping companies routinely reuse these materials, 
  • and the fact that packing materials make many more border crossings than standard goods. 

Around 2011, further research was done surrounding the transport of these materials with an eye toward the proliferation of pests and diseases. The result was clear -  there was cause for concern. Ultimately, it was obvious that a more proactive approach to these import requirements would be necessary, and these regulations would need to be more strictly enforced. 

Over the course of the next few years, an increased effort to enforce wood packaging material regulations began, and it was characterized by periods of soft launches, informed compliance, and, finally, full enforcement. 

In the early days, while this renewed effort was still in its infancy, Customs would simply delay and warn importers about the new regulations, but as it stands today, the situation is very different. Those asking, “What are the advantages and disadvantages of wood packaging?” should consider that these regulations are now fully enforced, and manufactured packing materials must meet the International Standards for Phytosanitary Measures No. 15 (ISPM 15). 

Failure to comply can end with refused entry, and should pests be detected, it may require the whole shipment to be treated at an additional cost to the importer before it is returned to the exporting country. 

What is Wood Packaging Material? 

Wood packaging materials are any wood or wood-based products that are used in the shipping of goods. Whether it’s crossing is ground, sea, or air-based - any wood-based packaging material is subject to these regulations. A few examples of items include:

  • Wooden Crates, 
  • Dunnage, 
  • Wooden pallets
  • Wooden boxes
  • Loose wooden packing
  • Packing blocks
  • Drums
  • Cases

What are the Requirements under ISPM 15?

Fortunately, making wooden packing materials compliant with ISPM 15 is not overly complicated. For it to cross between Canada and the US, three things must happen to the packaging. 

  1. The wood must be debarked. 
  2. It must be fumigated with methyl bromide or heat treated. 
  3. It must be stamped or branded with an approved mark from an accredited inspection agency. 

Are there any Exceptions to ISPM 15 Regulations? 

Wood material exemptions can be extended when the materials are heavily processed or otherwise atypical. For example, composite wood products like chipboard, cardboard,  and wood thinner than 6mm are exempt from ISPM 15. Similarly, wood packing materials like chips, sawdust, or other highly processed wood products used to sterilize a commodity can be exempted from these regulations. These products aren’t at the same risk for pests or diseases as solid wood packaging. 

In a similar vein, these regulations do not apply to all packaging like plastic or paper, and wood of Canadian origin entering from Canada must be pest-free, but it does not require the ISPM 15 marking. 

For more information on ISPM 15’s exceptions, check out our Q&A on the subject. 

What this Can Mean for You

These requirements have been in full enforcement for many years at this point, and it is unlikely that you will find a wood packaging manufacturer unregistered as ISPM 15 compliant. Still, it is always worth doing your due diligence and ensuring your packaging meets these regulations.

As a transporter, it also might be worth your time to investigate alternative packing materials, such as plastics or paper, as they do not run the risks that wooden materials might. Without the additional processing, they might also be more cost-effective in the long run. 

Finally, keep an eye on trusted resources, like this blog, for updates on regulations as they change. We’ve always got our finger on the pulse of any regulation changes, and you can count on us to keep you informed. 

If you have any questions about ISPM 15, be sure to check out the official resource. For questions about anything in the world of international trade, please do not hesitate to contact our Trade Compliance Team today. We have a wealth of information that will make your next international trade venture easy and headache-free.

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About Author
April Collier

April Collier is a Trade Compliance Specialist with Pacific Customs Brokers Inc. with over 36 years of experience in international trade. April has been a valued member of the PCB team for 18 years, having taking the lead in implementing the Compliance department for US imports. Her current responsibilities include advising and coaching clients on a variety of regulatory compliance matters, and include expertise in Antidumping & Countervailing matters. In addition to her regular duties, April is also the CTPAT coordinator for PCB.

While we strive for accuracy in all our communications, as the Importer of Record it is incumbent upon your company to ensure that you are aware of the requirements under the new regulations so that you maintain compliance as always.
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