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European Union Emergency Measures for Coniferous Non-Manufactured Wood Packing Material

This document originally appeared at: http://www.aphis.usda.gov/ppq/swp/eunmwp.html
Date Modified: 2002-04-16

The Commission of the European Communities has adopted emergency measures requiring the treatment and marking of all new and used coniferous (e.g. pine, spruce, fir) non-manufactured wood packing material (NMWP) originating in the United States, Canada, China, or Japan and departing on or after October 1, 2001, to prevent the introduction of the pinewood nematode. Hardwoods are exempt from the EU emergency measure. The pinewood nematode is a microscopic eelworm which has caused extensive mortality in pines in Japan and China.

(Since NMWP made entirely of hardwoods are exempt from the EU emergency measure, no marking of this material is required beyond a recommended mark and reference to the material on the bill of lading or invoice. The National Wooden Pallet and Container Association (NWPCA), the largest organization of wooden packaging professionals in North America has developed an optional mark for “hardwood only” or non coniferous NMWP.) This optional mark has been accepted by the European Union Commission. The mark can be designated as NC-US and may be applied by the assembler of NMWP.

European concern over the possible introduction and establishment of the pinewood nematode has heightened over the past couple of years after an outbreak in Portugal and interceptions of the pinewood nematode in NMWP from the United States, Canada, China, and Japan. The source of the outbreak in Portugal has not been positively identified but packaging material is believed to have been the likely pathway.

The EU emergency measures allow three treatment options for coniferous NMWP: heat treatment (HT), fumigation or chemical pressure impregnation (CPI). In all cases treated wood must bear a mark indicating the organization that treated the NMWP and the location of that organization. The EU requires that the HT program be an official program with official marks unique to the grading agencies listed under the heading herein of the Heat Treatment (HT) Program.

All three of the treatment options approved by the European Union are available to exporters in the United States.

The Heat Treatment (HT) Program

The American Lumber Standards Committee (ALSC) in coordination with APHIS and the NMWP industry has developed an official program for the HT option. The program will require SWPM assemblers to enroll with a grading agency affiliated with the ALSC and to acquire HT marked lumber from approved lumber mills. The program will include on-site inspections of NMWP manufacturing facilities to verify compliance. On-site inspections will be done by inspection agencies accredited by ALSC. The ALSC’s policy on NMWP and NMWP enforcement regulation are available for review. Two official marks have been approved for the grading agencies: one mark for NMWP using 100% HT treated lumber and another mark for NMWP containing heat treated coniferous lumber and untreated non-coniferous wood (HTC/NHTNC) combined. Contact one of the agencies listed below if interested in participating in the HT program and for further details of registering with the agencies:

As of August 1, 2001, the American Lumber Standards Committee has accredited the following grading agencies and related organizations to participate in the administering of the HT program:

California Lumber Inspection Service, Lodi, CA 209-334-6956
National Hardwood Lumber Association, Memphis, TN 901-377-1818
Northeastern Lumber Manufacturer’s Association, Cumberland Center, ME 207-829-6901
Northern Softwood Lumber Bureau, Cumberland Center, ME 207-829-6901
Pacific Lumber Inspection Bureau, Federal Way, WA 253-835-3344
Package Research Laboratory, Rockaway, NJ 973-627-4405
The Packaging Department, Bloomington, MN 952-967-9400
Redwood Inspection Service, Novato, CA 415-382-0662
Timber Products Inspection, Conyers, GA 770-922-8000
est Coast Lumber Inspection Bureau, Portland, OR 503-639-0651

Please call any of the listed agencies in your area for further information and further details of the heat treatment program

Fumigation of NMWP

Regarding fumigation, the EU emergency decision does not specify any particular fumigant or an officially approved mark, but it does require an officially recognized technical specification. In the United States the Environmental Protection Agency (EPA) is responsible for registering and establishing technical specifications (“labeling”) for pesticides. All fumigants are restricted-use pesticides and they may only be purchased and applied by licensed commercial pesticide applicators. And, although it is a violation of Federal law for commercial applicators to apply a pesticide in a manner inconsistent with the EPA label, it is the State, not the Federal government, that licenses commercial applicators.

Because of these considerations, APHIS is advising exporters as follows:

Fumigation may be used to meet the EU treatment requirement for coniferous NMWP.
Fumigation must be done by licensed pesticide applicators following the EPA-approved label specification of the fumigant used.
Methyl bromide is the fumigant recommended by APHIS, phosphine is an approved fumigant by the EU as well. Always follow manufacturer’s instructions when applying any restricted chemicals.
The name of the pest control company/applicator, the two-letter code for the state of origin, and the state pesticide applicator number should be shown on the coniferous NMWP.
For fumigated NMWP APHIS has developed a recommended mark which has been officially endorsed by the NWPCA, and accepted by the European Union Commission. The recommended mark can be developed as a stencil or stamp and be applied by the assembler of coniferous or by the licensed fumigator.

NMWP Made with CPI Wood

Environmental concerns surrounding pressure-impregnated wood make its large-scale use problematic. For instance, the Netherlands has recently prohibited the commercial importation of wood impregnated with copper compounds because of environmental issues. In spite of this the EU emergency measures do not require a specific chemical treatment or an official mark for NMWP made with CPI coniferous wood. The European Union does not require treatment of non-coniferous wood so NMWP may be made of untreated non-coniferous wood and CPI coniferous wood. In most cases, CPI wood contains quality marks and is a distinct color (due to the treatment process) so it cannot be mistaken for untreated wood. Like fumigants, CPI chemicals are regulated by the EPA and may only be applied by facilities that are licensed by the State governments. APHIS recommends the following for NMWP facilities that use CPI coniferous wood:

NMWP assemblers must use coniferous wood that is pressure impregnated by a licensed wood preserver using a treatment officially approved by the American Wood Preservers Association.
NMWP assemblers should mark each piece of NMWP (pallet, crate, spool, etc.) with a mark indicating the name of the location of the NMWP assembler. The mark can be applied by the assembler.
APHIS has developed recommended marks that have been endorsed by the NWPCA for NMWP assemblers using pressure impregnated coniferous wood. Please note that the recommended mark for NMWP made entirely of CPI wood is different than the mark for NMWP made of mixed CPI coniferous and non-treated non-coniferous wood.

For more information:

A list of frequently asked questions for NMWP going to the European Union has been prepared or e-mail PPQ your question at nmwp@aphis.usda.gov. For a list of NMWP facilities participating in the program, contact on of the listed ALSC Affiliated Grading Agencies.

You may also contact any APHIS USDA Contact Point Officer for assistance on existing plant health requirements of wood packing materials destined to the European Union as was as to other destinations.