Wood Packaging Material Violations

June 14, 2024

CBP Agriculture is experiencing a rise in violations related to Wood Packaging Material (WPM), particularly for untreated or unmarked WPM. As a result, they are increasingly imposing penalties and liquidated damages for non-compliance with WPM regulations.

The USDA’s Animal and Plant Health Inspection Service sets standards for Wood Packaging Material (WPM) imported into the U.S. through 7 CFR 319.40. Regulated WPM must be treated and marked under an official program overseen by the country of export.

WPM includes wood products used for supporting, protecting, or carrying cargo. Wood packaging made of exempt materials but combined with solid wood components must still be treated and marked. Marks vary by country and treatment establishment, including the IPPC trademarked symbol, country code, producer number, and treatment abbreviation.

Unmarked WPM is considered untreated and non-compliant, requiring immediate export. The importer is responsible for all expenses related to non-compliant WPM, including separation from compliant WPM or merchandise. The USDA advises companies to adopt these best practices to avoid shipment delays or destruction.

An Emergency Action Notice (EAN) will be issued when a WPM violation is discovered. A WPM violation occurs when WPM entering the U.S. does not adhere to the required treatment under the “Guidelines for Regulating Wood Packaging Material in International Trade” of the International Standards of Phytosanitary Measures (ISPM-15); the WPM regulations; and any associated amendments, revision or exemptions identified by the U.S. Department of Agriculture, Animal and Plant Health Inspection Service (APHIS).

Tips for Importers:

Ask your wood packaging material provider if they are ISPM 15-compliant and accredited. Review the certification provided by the exporting country’s national plant protection organization (NPPO).
Provide information to the exporter on the ISPM 15 standard.
Share regulation information with the exporter to assist them in becoming compliant. The NPPO will have information on the local program.
Require ISPM 15 compliance in the contract.
Require exporters to inspect the wood packaging material for signs of pests when delivered or before use.
Do a cost benefit analysis if considering alternatives to wood packaging material (such as plastic, particle board, or plywood).
Understand there is a cost for noncompliance, including penalties, demurrage, re-export costs, and production delays.
Increase your exporters’ awareness about ISPM 15 issues, so they look for the official ISPM mark on the wood packaging material and any signs that pests could be present.

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