Update on EU's Implementation of ISPM 15 for Wood Packaging Material, Etc

(The EU and other countries, including the U.S., have committed to enforce ISPM 15 entitled, "Guidelines for Regulating WPM in International Trade." ISPM 15 calls for regulated WPM to be either heat treated or fumigated with methyl bromide and marked in a certain way certifying treatment. ISPM 15 does not require debarking.)

Highlights of EU's ISPM 15 Requirements, Certain Debarking Measures, Etc.

APHIS and APHIS sources have provided the following guidance regarding the EU's March 1, 2005 implementation of ISPM 15 and debarking requirements:

Certain WPM must be treated & marked under ISPM 15. APHIS' update states that effective March 1, 2005, the EU will require all newly assembled, repaired or recycled unprocessed raw WPM (hardwood and softwood) entering the EU to be either heat treated or fumigated and officially marked under ISPM 15.

Debarking & "DB" marking requirements. In addition to the ISPM 15 requirements, APHIS explains that effective March 1, 2005, the EU is requiring that all WPM, including dunnage, be debarked and marked "DB."

(Due to controversy surrounding the EU debarking requirement, APHIS states that U.S. WPM will not contain the "DB" symbol. APHIS sources add that the U.S. hopes that the EU's debarking and 'DB' marking requirements will be postponed for one year, and that a decision regarding such a postponement could be made at an upcoming February 28, 2005 EU meeting.)

Alternative option for hardwood & softwood dunnage. According to APHIS, effective March 1, 2005, for hardwood and softwood dunnage, the EU will allow as a temporary alternative to the above, that dunnage meet the requirements of being bark-free and free from signs of live pests.

(APHIS sources state that "dunnage" refers to individual pieces of loose, unmanufactured wood used for blocking and bracing cargo.)

After December 31, 2007 however, all dunnage will be required to be treated and marked. APHIS sources note that it is expected by that time technology would be in place to mark each foot of each piece of dunnage or certain agencies, organizations, or companies would have authority to stamp pieces of dunnage during packing or loading.

Treatment/marking exemptions. WPM, including dunnage, less than 6 mm and processed wood produced from glue, heat, and pressure or a combination thereof (i.e. Oriented Strand Board, plywood, etc.) are exempt from treatment and marking.

EU Has Not Informed U.S. Gov't How New Requirements Will be Enforced

APHIS sources state that the U.S. government is not aware of how the EU will begin enforcing these requirements on March 1, 2005. These sources state that EU member states have not indicated whether the March 1, 2005 effective date will be applied by date of entry or if a "grace period" will be applied to shipments that are "on the water" prior to the effective date.

These sources note that enforcement could vary from country to country, but added that the APHIS WPM Web page (www.aphis.usda.gov/ppq/swp) would be updated as details are made available. APHIS sources recommend that in order to avoid uncertainties associated with using WPM, materials such as plastics and exempt WPM should be used where possible.

(See ITT's Online Archives or 02/10/05 news, 05021015, for BP summary of various countries' implementation and enforcement of ISPM 15 treatment and marking requirements for WPM.)

APHIS Update (dated 02/15/05) available at http://www.aphis.usda.gov/ppq/swp/eunmwp.html

FAS Update (dated 02/11/05) available at www.useu.be/agri/woodpack.html

European Commission Directive 2004/102/EC on ISPM 15, etc. (dated 10/05/04) available at http://europa.eu.int/eur-lex/lex/LexUriServ/site/en/oj/2004/l_309/l_30920041006en00090025.pdf