Guidelines for Regulating Wood Packaging Material in International Trade
Frequently Asked Questions
This document originally appeared at: http://www.aphis.usda.gov/ppq/swp/SWP_FAQs.html
Date Modified: 2002-04-16
- When will it become effective?
The standard is now in place (approved March 15, 2002) but it doesn't become effective until the receiving countries enact the appropriate regulations.
- Do providers have a license or a
stamp?
HT "providers" must be registered with the ALSC enforcement
agencies. APHIS is still determining how to provide oversight over the fumigation
program.
- Will there be new requirements for
proving that the material was fumigated?
There will be a program to monitor activities of fumigators
providing services under the program.
- Which countries are likely to ask
for bark-free or debarked material?
We are guessing here, but the European Union countries are the
ones who supported the "debarking" requirement in the IPPC meeting. It is unclear
if they would adopt the debarking provision for all countries rather than on
a "technical justification" basis for particular countries.
- Does this rule apply to all species
of wood?
It is not a rule; it is a standard. But yes, it does apply to
all species of wood.
- What about using peeler cores?
Peeler cores are specifically exempted from other treatments
but wood packing material manufactured from peeler cores would need to be marked
under the program.
- At the time of effectivity, what
about wood materials that are already enroute? (will there be a grace period?)
The standard doesn't address this but our expectation is that
there would be a phased in implementation period for each country.
- Is there a plan for a revision of
the standard after implementation issues are fully surfaced?
No plan for revision as such, but standards are reviewed every
three years.
- Exactly how do users get a copy
of the specifications for
Heat Treatment?
There is no specification (other than the standard) at present but the ALSC enforcement rules can be downloaded from the APHIS web site or the ALSC web site.
- If I comply fully with the IPPC
standard as it reads now, will the countries that currently have regulations
in place accept those shipments? (rationale, the IPPC standard is more encompassing
than many regulations).
Not until they adopt regulations that are consistent with the
IPPC standard. For instance, countries with "higher" standards (e.g.., Australia)
would keep their current requirements until the IPPC standard is adopted in
Australia. But since the IPPC standard is more stringent than the EU standard
(that is, it covers all wood types, not just coniferous) appropriately treated
and marked wood would be acceptable for the EU.
- Can I apply the markings as shown
even if there is no grading agency oversight process established within my country
right now?
No, since the National Plant Protection
Organization (NPPO), of the exporting country (in this case APHIS), is responsible
for oversight of the program, the use of marks must be coordinated with the
NPPO. Companies that use the marks improperly will be investigated and possibly
fined.
- When will the wooden pallet industry
truly be ready to heat treat softwoods AND hardwoods per this standard?
The softwood industry is already complying substantially with
the measures since the EU program has now been in effect for 6 months. The hardwood
industry is now the main focus of further efforts. It is unclear when the hardwood
industry will be "truely" ready but the National Hardwood Lumber Association
(NHLA) is a member of the ALSC heat treatment program.
- What is the estimated cost increase
for heat treated materials compared with untreated?
This is not a quarantine issue. Please consult the National
Wood Pallet and Container Association (NWPCA).
- Can we still use untreated materials
on shipments between NAFTA countries (Canada, US, Mexico)?
Canada, the US and Mexico still need to harmonize their entry
requirements and this issue is still far from settled. But even if untreated
materials are allowed for within-NAPPO movements, it is the market for wood
packing that will be control the issue. APHIS expects that shipments between
the US, Canada and Mexico will have to meet the conditions of the international
standard since many of the products are shipped on to third countries.
- When will countries that currently
require Govt. issued paper certifications for heat treatment/fumigation switch
to the paperless marking protocol? (priority on China)
APHIS is discussing harmonization of wood packing requirements
with China in an upcoming bilateral meeting (scheduled for May, 2002).
- What will be the requirements for
shipments to/from countries that are NOT part of the IPPC?
They will have to meet the requirements of the importing country.
- What is being done to review and
approve other treatment methods such as irradiation?
APHIS is not involved in the development of new technology for
wood treatment. However, the IPPC technical panel will meet periodically to
review new treatments.
- After the IPPC standard becomes
effective, will I still be able to ship materials that were treated and marked
per EU regulations or other country regs? (example: pallets marked "China
Treated" that were fumigated before).
The presumption is that the packing materials will have to be
marked in accordance with the international standard.
- Even though the IPPC standard defines
a paperless protocol for compliance, are there any suggested statements that
we should put on shipping documentation to assist inspectors? Example: "All
packaging within this shipment complies with IPPC standards" (along with
bug symbol).
APHIS makes no such recommendation at this time. Any such statements
will be at the request of importing countries
- How stable is this standard? What
is the timetable for potential changes to it?
The standard will change from time to time. There is a 3 year
cycle for review of existing standards and the necessary adjustments will be
made where needed.
- Will lumber shipments being shipped
as a commodity in itself be affected?
The IPPC standard only applies to the export of non manufactured
wood packaging material used in the transport of commodities.
- Are there any requirements for
dunnage?
Dunnage should be marked and treated under one of the approved
measures of heat treatment or fumigation. If not treated under one of these
measures, at a minimum wood will be required to be made from bark free wood
and free of pests and signs of live pests. Dunnage includes blocking and bracing
used to secure or support the commodity.
