Unseen invaders lurking within millions of pieces of wood packaging material (WPM) pose a grave threat to global ecosystems. For shippers and importers, ensuring compliance with WPM regulations is not just a legal requirement but a critical step in safeguarding the delicate balance of our environment. The Pallet Enterprise recently sat down with U.S. Customs and Border Protection (CBP) agriculture specialists Stephen Brady and Annaliese Blecha to shed light on the inspection processes and key steps shippers can take to reduce the incidence of WPM violations.
Understanding Wood Packaging Material (WPM) Compliance
The International Standards for Phytosanitary Measures No.15(ISPM-15) is a set of guidelines developed by the International Plant Protection Convention (IPPC) to address the spread of pests and diseases through wooden packaging materials used in international trade. ISPM-15 mandates the treatment of wooden packaging, such as pallets and crates, with approved methods to reduce the risk of introducing or spreading harmful organisms across borders, ensuring the safety of global trade.
Responsibility of Importers
Importers of record are liable for any fines or costs associated with non-compliant WPM detected at U.S. borders. Ensuring compliance with regulations is crucial to avoid penalties and delays.
WPM Inspection and Compliance
Importers can do their own preliminary inspections of WPM before shipping. They should look for obvious signs of non-compliance, such as the lack of proper treatment stamps, presence of frass (wood dust), entry or exit holes, or live pets in the packaging.
Reputable WPM Suppliers
Importers should buy WPM from reputable companies that adhere to (ISPM-15). Properly treated and stamped pallets help ensure compliance.
Dead vs. Live Pests
Dead pests inside WPM are considered compliant since some wood-boring insects may remain even after treatment. However, the presence of live pests can lead to automatic re-export since CBP does not allow anyone to manipulate the WPM once pests have been discovered.
WPM Non-Compliance Challenges
Non-compliance with wood packaging material regulations can affect the efficiency of imports reaching their destination. Some of the obstacles non-compliant importers face are:
- Delays and Inspections: Non-compliant WPM may cause delays and enhance inspections, particularly if the stamps are questionable or if there are signs of possible infestations.
- Impact of Non-Compliance: Non-compliant WPM can result in significant fines, as both the U.S. Department of Agriculture (USDA) and (CBP) can penalize the importer of record.
- History of Compliance: Importers’ past compliance history may influence the level of scrutiny they receive during inspections.
- Countries of Concern: Certain countries such as Mexico, China, and Turkey, have been identified as top concerns for non-compliant WPM.
The Role of ISPM –15 Compliance
For importers, adhering to ISPM-15 regulations, conducting proper inspections, and working with reputable suppliers are crucial to avoiding delays, fines, and potential reputational risks associated with non-compliant wood packaging material. Ensuring compliance with WPM requirements helps prevent the spread of invasive pests and ensures the smooth flow of imports into the United States.
The (ISPM-15) treatment program appears to be effective in reducing incidents of live quarantine pests in WPM. Awareness and outreach efforts have contributed to increased compliance.
ISPM - 15 and CTPAT
Adhering to ISPM-15 regulations is essential to CTPAT members. According to CTPAT Bulletin, Agriculture Security MSC 8.1 proved to be one of the highest areas of non-compliance in 2022. CTPAT members are required to meet the following standards:
- Written procedures designed to prevent visible pest contamination to include compliance with Wood Packaging Materials (WPM) regulations.
- Measures regarding WPM MUST meet the International Plant Protection Convention’s (IPPC) International Standards for Phytosanitary Measures No. 15 (ISPM 15).
- Visible pest prevention measures MUST be adhered to throughout the entire supply chain.
CTS has seen companies importing multi-million dollar shipments such as incredibly expensive robotics for high value projects that get held up and re-exported to Asia or Europe for WPM violations. There’s little that can be done, and this type of delay can set projects back by weeks or months. We have also seen rail logistics providers significantly impacted when one or more train cars coming across the border need to get disconnected and then set aside before proceeding with the rest of the train into the interior. These are big, expensive delays that can occur based on this “afterthought” of WPM. Because pallets are crucial instruments of international traffic it is best to be informed early on and comply with the ISMP-15 regulations.
The CT Strategies team of former CBP CTPAT Supply Chain Security Specialists (SCSS) and Directors help companies successfully navigate CBP’s CTPAT program. Using insights from over 80 years of combined CBP operational and policy knowledge, we leverage our first-hand CTPAT supply chain security experience and connections to current CBP leadership, so you can save time and money and get the most out of your CTPAT membership.