U.S. Animal & Plant Health Inspection Service (APHIS) sources have confirmed that effective July 5, 2006, APHIS and U.S. Customs and Border Protection (CBP) will begin "Full Enforcement" of their Wood Packing Material (WPM) Implementation Plan.

The U.S. and other countries have committed to enforce the International Standards for Phytosanitary Measures (ISPM) 15 entitled "Guidelines for Regulating Wood Packaging Material in International Trade". ISPM calls for affected WPM to be either Heat Treated or Fumigated with Methyl Bromide and marked in a certain way certifying treatment. There are certain exemptions for most WPM from Canada, and a limited exception from Mexican Border States.

All shipments in violation of the guidelines will be ordered exported if the Port Director determines that it is not feasible to separate merchandise from the violative WPM, or if such separation is not requested. APHIS sources added that the Port Director could also determine that it is not feasible to separate merchandise due to staffing limitations.

Wood packaging materials covered by the ruling include wooden packaging materials such as pallets, crates, boxes, and pieces of wood used to support or brace cargo. These materials are also referred to as solid wood packing material (SWPM), which is defined as wood packing materials other than loose wood packing materials, used or for use with cargo to prevent damage, including, but not limited to, dunnage, crating, pallets, packing blocks, drums, cases, and skids.

According to CBP, dunnage presents unique challenges. Often, pieces are cut to fit a load and may, during that process, be separated from the IPPC marking. Other times, during the course of transit, dunnage is broken, crushed, abraded, or otherwise damaged. Pieces will likely be separated from their compliance mark. For purposes of this regulation CBP states that it intends to exercise its discretionary authority so that if it believes that cut or damaged pieces of dunnage are part of a larger piece of properly marked wood, CBP will determine that the unmarked dunnage has been treated and marked, and consider it to be non-violative.

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