Ask Camelot: Solid Wood Packing Material Compliance

Imagine you placed an order from overseas. The goods took months to produce. They took another month in transit. For fun, only a few weeks to get unloaded and on the train. And just as you think it’ll arrive in a matter of days, the container is stopped at the border because the packing material inside the container isn’t properly marked as having been heat treated or fumigated in the country of origin for pests. 

For reasons entirely outside your control after you’ve promised the contents to clients, USDA delivers the bad news – the goods are refused entry and cannot be remediated, but must be returned to the country from which they came.

No fumigation, no removal of the wood, just sent back with all the return costs and a penalty for the importer.

This seemingly unthinkable scenario has been happening with increasing frequency to a number of importers – and we feel awful for them. 

And it all comes down to…a stamp.

No stamp, no entry. 

The United States Department of Agriculture’s APHIS inspectors are in charge of keeping invasive pests out of the United States. There are any number of insects or seaborne creatures that have or are wreaking havoc on our trees, crops and bodies of water.

If you’re in and around the Great Lakes like us, this comes in the form of such hits as the Asian Carp, Asian longhorn beetle, Zebra Mussels and the Emerald Ash Borer. All three of these invasive species were not native to the United States, but hitched their way here.

Of all the agencies we work with, the ones focused on plants, animals, flora and fauna have really the least sense of humor and take their jobs seriously.

The regulation is ISPM-15, or the International Standard of Phytosanitary Measures. 

They’re here on USDA’s website. From their site: “All wood packaging material entering or transiting the United States except wood of Canadian origin entering from Canada, must be heat-treated or fumigated and be marked with an approved logo certifying that it has been appropriately treated. Shipments containing non compliant wood packaging material will not be allowed to enter the United States.”

CBP also maintains a page on their website that details the liquidated damage penalties and other regulations.

In short, any kind of solid wood packing material used in an international shipment by air or sea must be marked as having been heat treated or fumigated to prevent them from carrying unseen pests into America.

This includes – but is not limited to – pallets, crating and dunnage, or packaging / blocking / bracing materials inside the container meant to prevent the cargo from shifting while in transit.

The marking takes the form of a stamp that identifies both the country of origin and the identity of the entity that treated the wood. Early in the regulatory history of this, bad actors were counterfeiting these marks, but USDA inspectors have a way of accessing a database that verifies their authenticity and other details.

Source: CBP WPM FAQ

If a shipper cannot procure or ensure the SWPM is authentic or compliant, there are other alternative materials. Importers may consider using alternatives to wood packaging material. The following products are not subject to USDA regulation:

• Plywood or press board
• Plastic pallets
• Oriented strand board
• Hardboard
• Parallel strand lumber
• Synthetic foam
• Metal frames
• Inflated dunnage
• Masonite veneer

Not unlike missing or incorrect country of origin marking, non-compliant WPM is one of the easiest violations for a CBP inspector to find. The regulations have been in place for so long that it is something that should be standard practice for shippers in international commerce today. 

Sometimes the commodity tips off the packaging material. Any description of “machinery” will likely mean that there is wood inside the container and is a more likely target for inspection. 

For help understanding these regulations or in crafting communication and processes to ensure that shippers are complying with one of the few regulatory requirements that can actually send cargo back to origin, contact Camelot today.