Date: Thursday, September 15, 2005

Re:	WOOD PACKING MATERIAL - UPDATE
	Implementation dates of the wood packing standard

Dear NASA Member:

The implementation date for the new Wood Packing Rules for imports entering the U.S. is September 16, 2005. Customs had previously announced that they would reject any WPM that was not properly marked. However, Customs has reversed its position, announcing that effective September 16, 2005, the shipper will be notified of any non-compliant WPM, and that the shipment will be held ONLY if infestation is found on the WPM. On February 1, 2006, CBP will begin rejecting shipments -- repacking non-compliant pallets and crates and re-exporting the non-compliant packaging at the cost of the importer. After July 5, 2006, all WPM (including dunnage) must be treated and marked or it will be re-exported.

Below, for your reference, is the latest list of implementation dates for exports.

New Wood Packing Material Requirements

The United States has signed onto an international agreement on import requirements for Wood Packing Materials (WPM) – both hardwood and softwood – used in international trade. The objective of the participating governments was to develop a uniform standard to control pests in wood packaging material used in global trade. This standard itself is non-binding, thus it is up to the countries which sign onto the Agreement to pass legislation implementing the requirements set forth in the standard.  Each country is moving at its own pace, a fact which makes it difficult to provide a single, firm implementation date for U.S. exports. For imports, the U.S. will begin implementation on September 16, 2005.

What is required? Under the standard (“ISPM 15”), all wood packing material must be heat treated or fumigated in accordance with the standard. Once treated the materials must display a specified mark developed by the International Standards Committee, which has been trademarked for this purpose. This mark is proof that the materials have been treated.  While no paper certification is required under ISPM 15, individual countries may impose additional requirements. For example, the EU has announced that beginning March 1, 2006 they will require all WPM to also be debarked. In China and South Korea, imports from the U.S. and other countries that are host to the pinewood nematode, must either use heat treatment OR fumigate for a minimum of 24-hours.

What is covered? The standard applies to all unprocessed wood or wood products (excluding paper products) used in supporting, protecting or carrying a commodity.  This includes pallets, dunnage, crating, packing bloacks, drums, cases, load boards, pallet collars, and skids.  Please note that it applies to all wood packing material – not just softwood.

Effective Date -- Imports. Implementation is set for September 16, 2005 (see chart for more details). We suggest that importers plan well in advance to assure the availability of properly treated and marked WPM in the originating country. Countries that have already implemented the international standard will likely have an abundance of compliant WPM. In other countries it may be more difficult to obtain compliant WPM for shipments to the U.S.

Effective Date – Exports. Compliance for outbound shipments is mandated by the implementation dates of our many trading partners. There is no single source of information for these implementation dates, but we do our best to monitor actions and advise accordingly. Attached is our latest list of implementation dates.

If you are having difficulty obtaining compliant WPM for exports, you should contact either the American Lumber Standards Committee (ALSC), charged with implementing the heat treatment program in the U.S. or the National Wood Pallet & Container Association (NWPCA), charged with implementing the fumigation program.

Best regards,

North American Shippers Association (NASA)
Joan Barrett
NASA Administrator