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CWPCA Responds to Border Exemption Elimination Proposal
Canadian pallet industry raises concerns about the proposal to eliminate the ISPM 15 border exemption for wood packaging material crossing the U.S./Canadian border.
By Chaille Brindley
Date Posted: 2/1/2011
As announced in the January issue of the Pallet Enterprise, the U.S. and Canadian governments are working on developing a schedule to eliminate the current ISPM 15 exemption for solid wood packaging material (WPM) moving across the U.S./Canadian border. Although this does not come as a surprise since both governments have been in talks about ending the trans border exemption for a while, not everyone is happy with the proposed timetable and the potential for trade barriers to be erected in the name of plant health.
The draft timeline has pushed up the full implementation date to the summer of 2012 whereas the two countries had previously agreed to implement ISPM No.15 for shipments of WPM across the U.S./Canadian border by no earlier than January 2013.
Both the U.S. and Canadian pallet industry trade associations have come out in favor of ending the exemption. However, the Canadian Wooden Pallet & Container Association (CWPCA) indicates it would prefer the bilateral exemption to terminate according to the original 2013 timing. The Canadian pallet association stated it could live with an accelerated schedule as long as provision are in place to ensure that border policies do not turn into an unnecessary trade barrier.
The National Wooden Pallet & Container Association, the U.S. pallet trade association, could not be reached for comment.
The CWPCA recently took issue as well with some of the reasoning for pushing for eliminating the exemption considered about the implications that WPM from Canada is a major risk factor for the spread of notable invasive species in the United States. The CWPCA stated, “It is misleading to claim that WPM originating in Canada is the source of the increasing entry of invasive pests into the United States.”
Given the “lack of proof about pests coming from Canada,” the CWPCA has asked why the U.S. officials are in such a rush to adopt these measures.
The CWPCA has raised concerns about arbitrary decisions by border officials to hold up WPM even if it bears a valid IPPC stamp. Instead, the CWPCA wants assurance that no export on WPM will be delayed if the WPM bears a valid IPPC stamp. This would require border officials to be properly trained to ensure a smooth transition and to identify WPM shipments from non-certified facilities, which will help ensure the viability of the official certification process.
The current proposal provides a time-lag between full implementation for wooden pallets and containers compared with dunnage, which has a later date. The CWPCA stated, “To avoid any possibility of confusion or unintended delays, a consolidated deadline of July 2012 (or later) should apply to full implementation for all WPM and dunnage moving across our border.”
The CWPCA also called for informed compliance to start as soon as possible to get as many people on board with the new requirements as quickly as possible. When it comes to the cost of the program, the CWPCA has encouraged governments to provide economic assistant to defer some of the costs associated with an accelerated time frame.
Regarding the industry impact, the CWPCA estimates that the Canadian pallet industry will be required to pay $30 million a year to heat treat new WPM for export, based on an annual shipment of 26 million units to the United States, of which 80% now will need to be heat treated at a unit cost of $1.25 for softwood and $2 for hardwood. The CWPCA suggests that heat treatment costs run higher in Canada than they do in the United States due to the fact that the average ambient temperature is much lower in Canada compared to many parts of the United States.
Looking at the overall economic impact, the CWPCA believes costs may run higher than the U.S. government has estimated. This could especially be true if managing treated and untreated inventories becomes impractical for WPM companies and their clients.
The CWPCA said, “It will soon be impractical for WPM manufacturers to segregate wood for domestic and for continental use, and the ensuing need to HT all wood will impose even more costs on industry and consumers.”