What is Non-Manufactured Wood Packing?

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, oriented strand board, veneer, wood wool, etc., which has been created using glue, heat, and pressure or a combination thereof." For the purpose of the European Union' s emergency measures NMWP includes coniferous pallets, crating, packing blocks, drums, cases, load boards, pallet collars, skids, etc., but not dunnage.

Why is NMWP being regulated by the European Union?

The European Union has for many years required coniferous NMWP from countries infested with the pinewood nematode to be free of bark, free of grub holes larger than 3 mm, and heat treated. After an outbreak of pinewood nematode in Portugal in 1999, Finnish authorities surveyed NMWP arriving from infested countries. Four countries (the United States, Canada, China and Japan) were found to be shipping coniferous NMWP that did not conform to the EU requirements. The EU has adopted emergency measures as a means to assure that NMWP does not pose a risk of spreading PWN.

Will I be affected?

EU imports from the United States were valued at $169.2 billion in 1999. We expect that a significant portion of U.S. exports will be affected by the measures since most goods are transported using NMWP (e.g. pallets, boxes, crates). It is estimated that upward of 30 percent of the 450 million new pallets produced annually and a higher percentage of the new pallets used for exports are made entirely of, or partially of, coniferous lumber. A significant proportion of the pallets and containers already in circulation also are made entirely of or partially of coniferous lumber.

What happens if my NMWP does not comply with the EU's requirements?

The EU has indicated that any coniferous NMWP that does not comply with the requirements will 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 non-complying NMWP and may cause considerable delay.

What are the member states of the European Union?

There are fifteen member states of the European Union. They are: Austria, Belgium, Denmark, Finland, France, Germany, Greece, Italy, Luxembourg, Ireland, The Netherlands, Portugal, Spain, Sweden and the United Kingdom.

Who will enforce the European Union emergency measures?

The member states of the European Union will enforce the regulation.

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 56° C 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. • 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.
What mark on lumber will be accepted by the European Union attesting that the wood has been heat treated?

Under ALSC, grademarks on lumber bearing the indication KD-HT will be accepted as proof of heat treatment.

Are other marks on NMWP materials required?
Yes. Pallet and crating manufacturers must also place an official "no bug" mark on the NMWP materials constructed from heat-treated lumber. To qualify for this mark, pallet and crating assemblers must enroll with a grading agency affiliated with ALSC. For a list of agencies accredited to offer inspection and stamping services to NMWP assemblers, go to the APHIS site. While WWPA is accredited to offer such services, it currently has no NMWP assemblers enrolled.

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 (stamped, branded, labeled, etc.) to indicate who treated the wood and where it was treated. This is designed to be a "paperless" system.

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.

What will USDA do to facilitate compliance with the EU emergency measures?

USDA is working with the American Lumber Standards Committee (ALSC), the lumber grading agencies and the National Wooden Pallet and Container Association to develop a voluntary program for heat treated wood prior to the October 1 implementation date. This program will cover new and used pallets and will require NMWP produced in this program to be manufactured wholly of heat treated or kiln dried/heat treated wood or will require the participating facility to heat treat existing NMWP. The EU emergency measures have provisions for fumigation and for chemical pressure impregnation (CPI).

Will these options be available?

Currently the program that APHIS and the US NMWP industry is developing 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. The US NMWP industry recommends that new coniferous NMWP should be produced under the ALSC program using heat treated or heat treated and kiln dried wood since that material could be used under the proposed International Standard for NMWP for any international movement. APHIS is still studying the possibility of a fumigation program for existing coniferous NMWP.

What happens with regards to the thousands of pallets, cable spools, etc. currently in use or in inventory?

The EU has stated that existing pallets, etc. will have to 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. Fumigation of existing coniferous NMWP is also being investigated as a possible option. What is the status of NMWP received from Europe? NMWP that is clearly marked as being from Europe will be acceptable. Other coniferous NMWP will be subject to enforcement.

How will NMWP shipped via a third country be handled?

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.

What is the effective date of the EU decision?

The emergency measures are effective October 1, 2001. This means that materials shipped on or after October 1 are subject to regulation.

What role will the exporters play in the process?

Exporters need to be aware of the emergency measures and be sure that their shipments utilizing coniferous NMWP comply with these measures.

How will freight forwarders be involved?

Freight forwarders will need to advise the exporters of the emergency measures and be aware that shipments may be held on arrival in Europe.

How will lumber shipments be affected?

Lumber shipments will not be affected any more than any other cargo.

Will items made of wood (besides NMWP) be affected?

Items such as furniture, doors, handicrafts, etc. are not regulated under the EU emergency measures and will not have to be treated.

Is APHIS going develop a heat treatment certificate like the one used for China?

No. The EU emergency measures specifically require marking of coniferous NMWP to show compliance. These emergency measures require that heat treated NMWP be officially marked and APHIS and the ALSC have developed a program using official stamps with coded markings to show that NMWP complies with the emergency measures. The emergency measures for fumigated or chemical pressure impregnated NMWP does not require official markings.

Do any other countries regulate non-manufactured wood packing?

In addition to the United States Department of Agriculture, which has federal regulations that require all NMWP to be free of bark and apparently free of insects or treated, the European Union has recently adopted emergency measures to regulate coniferous SWPM from the United States, Canada, China and Japan. These measures will go into effect on October 1, 2001. The International Plant Health Convention is in the process of adopting an international standard for coniferous and hardwood NMWP which is expected to become effective in April 2003.

What are the differences between the EU emergency measures and the 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.

The International Standard, scheduled for approval is June 2003 for China and July 2003 for the European Union, will cover both hardwood and conifereous NMWP, will apply to all countries, and (currently) will only allow heat treatment as a universal option. Arrangements to allow fumigation or chemical pressure impregnation would have to be negotiated between the exporting country and the importing country. Who should I contact for additional information? Questions concerning the NMWP program should be directed to USDA/APHIS/Export Services (301-734-8537), USDA/FAS/Forest and Fisheries Products Division (202-720-0638) or the American Lumber Standard Committee (301-972-1700).