Although its been in discussions for a couple of years, the U.S. government recently published its intention to end the exemption under ISPM 15 for wood packaging material (WPM) coming from Canada. This cross-border exemption has been in place since both countries started policing wood packaging material years ago due to concerns about the spread of wood pests. Both governments have been in talks for the last few years about ending this exemption in hopes to hinder the spread of the emerald ash borer (EAB), Asian longhorned beetle (ALB), among other pests.
Based on the original discussions, the suggested end for the exemption had been 2013. But the newest proposed schedule pushes up the timetable. It calls for the draft policies to be published by spring 2011 with the final rule established and the phase-in approach begun by fall/winter 2011.
Here is the proposed implementation schedule that we have obtained through unofficial channels and is subject to change:
Proposed Implementation Schedule
Phase 1 (late 2011- early 2012) – written notification of non-compliance for all wood packaging
Phase 2 (spring 2012) – pallets and crates fully implemented; continue written notification for dunnage entries only.
Phase 3 (summer 2012) – begin full implementation of all wood packaging, which means all noncompliant packaging would be rejected at the border.
The U.S. government published its intent to end the exemption in the Federal Register on December 2nd. Currently, the government is taking comments
on the proposal until January 31, 2011.
The U.S. Animal and Plant Health Inspection Service (APHIS) stated, “The less restrictive importation requirements for WPM imported into the United States from Canada are based on the premise that the forests in the United States share a common forested boundary with Canada and, therefore, share, to a reasonable degree, the same forest pests.”
Explaining why the exemption should be eliminated, APHIS pointed to a pest risk analysis that found “many North American forest pests, both indigenous and non-indigenous, occur in both Canada and the United States. Some of these are unique forest pests and pathogens that are established in Canada and have the potential to be introduced or reintroduced into the United States via the movement of WPM, while others are pests that also occur in the United States but are subject to official control in order to prevent their further spread.”
Among the pests of concern are the brown spruce longhorned beetle, European oak borer, EAB, ALB, European woodwasp, the fungus Ophiostoma tetropii, and vascular wilt.
U.S. officials found that the removal of the exemption would have a minimal impact on consumers’ costs because “the cost of a pallet is a very small share of the bundle of goods transported on pallets.”
The Canadian government is also harmonizing the elimination of the ISPM 15 exemption for U.S. shipments and has generally followed the lead of APHIS. This means that once in place, U.S. WPM and loads shipped to Canada will have to meet the ISPM 15 standard.
Canadian pallet companies are somewhat concerned that the removal of the exemption could lead to problems at the border. Bill Eggertson, executive general manager of the Canadian Wood Pallet & Container Association (CWPCA), said, “Our members are adamant that this not be used as a hidden trade barrier.” He suggested that the ISPM 15 mark should be treated just like a passport. If a pallet has a valid stamp, it should go through the border without delay or unnecessary hassles.
Eggertson also said, “We would prefer the original schedule, if it has to be accelerated, we question the basis, primarily the risk assessment conducted by the U.S. government.”
The National Wooden Pallet & Container Association did not return requests for its opinion on the issue.
Tom Searles of the American Lumber Standard Committee, the organization which oversees the heat treatment program in the United States, said that this proposed exemption was intended to eliminate confusion resulting from localized quarantines along the border that just don’t work and complicate trade.
Searles said, “The EAB was sort of a driver on this one.”
Some in the industry have suggested that the trans-border exemption helped facilitate trade and its elimination will do little to really prevent the spread of invasive species. After all, bugs don’t really respect border crossings and the two countries share contiguous borders. But at the same time, officials suggest that any effort to slow down the spread of these pests may help plant health experts get ahead of the problems and reduce the potential impact.
Pallet suppliers should stay in contact with their certification agencies to know the latest official information and to prepare customers for any changes in the future.
