Frequently
Asked Questions (FAQ’s) Regarding Wood Packing restrictions.
Answers
Specific to EU Directive 2000/29/EC, effective 01 October 2001.
1.
I ship on corrugated pallets. Am I
affected?
2. Will US local pallet and crate suppliers need a 3 digit ID
number?
3. Will local pallet and crate suppliers in Japan, Canada and
China need a 3 digit ID number?
4. What if my local pallet supplier has never heard of this?
5. What Happens if I don't Comply with the EU Requirements?
6. Is paper Certification required for shipments?
7. Will other documentation (certificates, statements on bills of
lading, etc.) be required for movement of NMWP to Europe?
8. Are the EU countries requiring documentation to identify
non-regulated packing materials, such as pallets manufactured of hard wood,
oriented strand board, plastics, etc.?
9. What about shipments through a third country?
10. Can I temporarily bypass full in-compliance markings?
11. Is there a short term solution to by-pass requirements for
Coniferous woods?
12. Won't the approved agency mark be sliced off the raw lumber
when building the pallet?
13. What are full in-compliance markings?
14. My supplier buys wood from Home Depot.
Is that OK?
15. What are the emergency measures adopted by the European
Union?
16. Isn't fumigation a bad thing?
17. What about all the pallets, cable spools, etc. currently in
use or in inventory?
18. Will there be a heat treatment certificate like the one used
for China?
19. What are the differences between the EU emergency measures
and the International Standard?
20. I buy pallets in Malaysia or Singapore, am I affected by EU
Oct2001 requirements specifically?
21. Will other wood items be affected?
22. Is anyone looking at a non-wood solution?
23. With so many pallet specs, how many different pallets do I
need to stock?
24. What countries are restricted in shipping?
25. What are the member states of the European Union?
26. What is NMWP
27. What is MWPM
28. What is the ALSC
29. What is USDA
30. What is Coniferous
31. What is Non-Coniferous "NC"
1.
I ship on corrugated pallets. Am
I affected?
No.
That's great. Share your success with us.
2.
Will US local pallet and crate suppliers need a 3 digit ID number?
Yes.
3.
Will local pallet and crate suppliers in Japan, Canada and China need a 3 digit
ID number?
Probably
yes for now: definitely yes in the long term.
Individual country NPPOs are responsible for establishing accreditation
procedures. International draft
standards will likely be implemented that follow the same 3 digit assignment
scheme. More info will be posted
when known.
4.
What if my local pallet supplier has never heard of this?
1.
Give
them a copy of the Certification and Enforcement pdf documents from the CPP web.
2.
Check
their credentials.
5.
What Happens if I don't Comply with the EU Requirements?
Big
trouble. Non-compliance may result
in delayed customer shipments, lost revenue, and problems with the authorities.
The EU has indicated that any coniferous NMWP that does not comply with
the requirements can be refused entry,
destroyed, or treated to eliminate the risk of the pinewood nematode prior to
entry. This will likely necessitate the off-loading of any cargo from the bad
wood, and may cause considerable delay or product damage through mis-handling.
Enforcement may or may not be gradual.
6.
Is paper Certification required for shipments?
No,
for shipments from US, Canada, or Japan.
Yes, for shipments from China.
It must be a Govt authorized certification of the treatment applied.
7.
Will other documentation (certificates, statements on bills of lading, etc.) be
required for movement of NMWP to Europe?
No
other documentation is required. The EU emergency measures require NMWP to be
marked to indicate who treated the wood and where it was treated. This is
designed to be a "paperless" system which is
intended to eventually be applied globally.
Progress is good; further success will depend upon individual countries
accepting the proposal. Note that
certification is required if fumigating.
8.
Are the EU countries requiring documentation to identify non-regulated packing
materials, such as pallets manufactured of hard wood, oriented strand board,
plastics, etc.?
No,
but companies may include a statement about composition of the non-regulated
packing materials on the bill of lading or the invoice.
The best insurance to keep shipments moving through customs is to mark
all wood material as per standards listed on the CPP web.
Expect that the strong recommendations for marking will become a
legislated mandate in either 2002 or 2003.
The easiest way to meet in-compliance marking standards is to begin
requiring suppliers to properly mark wood products now.
Following
the marking standards for HT, NC and MWPM as noted in the MWPM Markings.pdf
document is strongly encouraged. Agilent
wood suppliers following this simple stenciling routine will enable the quick
and efficient movement of materials across borders. Additional restrictions coming soon will make marking of wood
a priority. Packaging professionals
can greatly support their logistics and trade companions by marking all wood
materials to the standard.
9.
What about shipments through a third country?
If
the manifest or bill of lading indicates that the shipment originated in the
United States or another regulated country, the shipment will have to comply
with the emergency measures.
If
the brown boxes indicate COO from a restricted country, customs may assume the
pallet is suspect. In this case,
everyone has a reason to follow the in-compliance marking standards.
It is expected that shipments to Non-EU
consignees traveling in bond via an EU country will not be affected but this
cannot be affirmed at this time.
10.
Can I temporarily bypass full in-compliance markings?
Yes.
Options include but are not limited to:
1:
buy only non-coniferous (“hardwood”)
material and stamp the material "NC".
2:
buy heat-treated coniferous wood
(“softwood”) and stamp the material with "HT" COO and ID#".
All pallet and crate
suppliers should be able to meet full marking standards by October 1, 2001.
11.
Is there a short term solution to by-pass requirements for Coniferous woods?
Yes.
Buy non-coniferous material (hardwood).
Most pallets in the US are Non-Coniferous
(“hardwood”).
12.
Won't the approved agency mark be sliced off the raw lumber when building the
pallet?
Yes.
However, each individual pallet manufacturer must enroll in the ALSC
certification program. Once
approved, the local pallet plant will have their own 3 digit ID number.
The local pallet and crate supplier will then be allowed to stencil the
container on two sides with full in-compliance markings!
13.
What are full in-compliance markings?
For
example, a heat-treated coniferous (softwood) pallet would have a stencil of:
EIPS bug-free symbol, HT, ISO Country of Origin, 3 digit ID and Accredited
Agency logo.
14.
My supplier buys wood from Home Depot. Is
that OK?
Possibly.
It is the responsibility of the local supplier to create a supply chain
that can be audited and pass accreditation procedures.
Only wood that has been stamped HT or KD-HT by
the mill should be considered.
15.
What are the emergency measures adopted by the European Union?
The
emergency measures require that all new and used NMWP originating from the four
countries be:
·
heat treated or kiln-dried to a minimum core
temperature of 56C for at least 30 minutes in a closed chamber or kiln which has
been tested, evaluated and approved officially for this purpose;
·
pressure treated with an approved chemical in
accordance with an officially recognized technical specification; or
·
fumigated with an approved chemical in accordance
with an officially recognized technical specification. See IMPORTANT FUMIGATION note.
·
All coniferous NMWP must also display a mark
enabling the identification of the treatment facility and the location of the
facility. In the case of heat treated coniferous NMWP the use of the mark will
be limited to NMWP manufacturers participating in the APHIS-ALSC program.
16.
Isn't fumigation a bad thing?
Yes,
in so very many ways. Additionally,
fumigation violates Corporate Environmental standards
and violates support of the Montreal Protocol with regard to Ozone Depleting
Substances.
The
official program between the United States Government and the NMWP industry does
not include fumigation or CPI wood because
(1)
methyl
bromide
is being phased out in the United States under the Montreal Protocol, and
(2)
because
of the environmental and disposal problems associated with CPI wood.
It
is recommended that new coniferous NMWP be produced under the ALSC program using
heat treated or heat treated and kiln dried wood.
HT wood will meet the proposed International Standard for NMWP for any
international movement. Fumigation may be the only viable method in China; provide
certification with shipments.
17.
What about all the pallets, cable spools, etc. currently in use or in inventory?
The
EU has stated that existing pallets, etc. must meet the same requirements as new
pallets. Some companies are planning on purchasing modular heat treatment
equipment and to register with an ALSC approved grading agency so that they can
treat existing packing materials. Existing pallets, crates, etc., can also be
fumigated. Please refer to the APHIS PPQ Treatment manual for current guidelines
on methyl bromide and tarpaulin
fumigations.
There are also portable heat treatment facilities (example:
http://www.pestheat.com
)
which may be viable for treating wood packing materials already assembled.
18.
Will there be a heat treatment certificate like the one used for China?
No.
EIPS, NWPCA, ALSC, APHIS all have lobbied the IPPC to move to one
paperless global standard. Progress is good but success is not yet assured for the draft
international standard. If
all shippers to the EU fully and properly implement the marking standards then
governing authorities Internationally will be more inclined to allow paperless
processes to continue. Bear in mind that these emergency measures exist
because earlier regulations to mitigate the problem (ex:
requirements for bark free, free of grub holes, etc.) failed to solve the
problem.
19.
What are the differences between the EU emergency measures and the proposed
International Standard?
·
The European Union emergency measures, which will
go into effect on October 1, 2001, cover only coniferous NMWP and only cover
four countries (the United States, Canada, Japan and China). In addition they
allow treatment of NMWP by fumigation, by chemical pressure impregnation or by
heat treatment. This is the ONLY
NEW standard that must be followed.
·
The DRAFT International Standard covers both
hardwood and softwood, applies to ALL countries, and dictates heat treatment of
ALL NMWP. Arrangements to allow
fumigation or chemical pressure impregnation would have to be negotiated between
the exporting country and the importing country.
(The draft IPPC standard treats HW and SW the same, requires both to be
heat-treated and both to use the same in-compliance markings as noted on the CPP
site.)
20.
I buy pallets in Malaysia or Singapore, am I affected by EU Oct2001 requirements
specifically?
No.
But see shipments through a third country note.
It is recommended to apply the marking scheme globally regardless of
origin or destination so that non-affected shipments can also be identified. Note: The
regulations generally restrict SHIPMENTS from a given country regardless of the
true origin of the packaging materials.
For example: If a
shipment from the US utilized pallets made in Mexico which were stamped Mexico,
they may still be technically be affected but the markings will be helpful to
the inspectors. Conversely,
shipments from Mexico utilizing pallets made in the US may technically not be
affected. It is unclear how this
will be handled in the EU but that is how it has worked with the China and US
regulations to date despite the obvious mismatch of what must have been
intended.
21.
Will other wood items be affected?
Items
such as furniture, doors, and walnut instrument cases are not regulated under
the EU emergency measures.
22.
Is anyone looking at a non-wood solution?
Yes.
Many alternatives are constantly being reviewed
by Packaging Engineers. The costs and performance of these alternatives must be
balanced against the logistical advantages associated with avoiding
certifications, chain of custody business controls and so on. The closer we get to a true seamless, paperless
process and consistently applied regulations globally the easier it will be to
continue using non-manufactured wood.
Until that time, there are compelling reasons to shift to non-wood
alternatives. Suppliers
should seek pre-approval and conduct trial shipments or pre-testing prior to
implementing alternative materials unilaterally.
Alternative materials are attractive from a compliance perspective but
could represent a large cost increase that isn’t justified in all cases.
23.
With so many pallet specs, how many different pallets do I need to stock?
That
is a business decision. One
case would have you buying different materials for each region of the world you
ship to. This way you would avoid
spending extra money on heat-treated wood when you are not exporting.
A
second case is to leverage all purchases into one in-compliance pallet.
This would be an easier process to follow in-house rather than
determining which pallet must go with each shipment.
The
EIPS pallet solution will drive us into one pallet that meets all global
regulatory standards.
24.
What countries are restricted in shipping to the EU?
The
United States, Canada, Japan, and China (Note:
Including Hong Kong but not Taiwan)
25.
What are the member states of the European Union?
Fifteen
member states of the European Union are: Austria, Belgium, Denmark, Finland,
France, Germany, Greece, Italy, Luxembourg, Ireland, The Netherlands, Portugal,
Spain, Sweden and the United Kingdom.
Note:
If additional countries join the EU at a later date then these would be
subject to existing EU regulations.
26.
What is NMWP
Non-Manufactured
Wood Packing (NMWP), also called solid wood packing material or SWPM, is defined
as "wood packing other than that comprised wholly of wood-based
products such as plywood, particle board, OSB, veneer, etc., which has been
created using glue, heat, and pressure or a combination thereof."
In other words, NMWP is real, solid wood, like a 2x4.
NMWP is NOT ground up trees. Very
confusing.
27.
What is MWPM
Manufactured
Wood Packing Materials are wood-based products such as plywood, particle board,
OSB, veneer, etc. In other words, ground-up AND PROCESSED trees.
28.
What is the ALSC
American
Lumber Standard Committee. http://www.alsc.org
29.
What is USDA
United
States Department of Agriculture. APHIS,
Animal and Plant Health Inspection Services, under USDA is tasked with the bug
issues. http://www.aphis.usda.gov/ppq/swp
30.
What is Coniferous
Coniferous
wood is a needle bearing species (softwood) and is subject to pinewood nematode
infestation. This is the primary concern of the EU at
this time since real infestations have been found in several EU countries.
31.
What is Non-Coniferous "NC"
Not
coniferous. NC wood is leaf bearing
species (hardwood) and is subject to Asian Longhorned beetle infestation.