Geo. S. Bush & Co., Inc.
News Bulletin
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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 (PWN = Bursaphelenchus xylophilus) 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 NMWP that did not conform to the EU requirements. The EU has adopted emergency measures as a means to assure that the NMWP does not pose a risk of spread of 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. export 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 the 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 coniferous NMWP originating from the four countries be:
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 NMPW 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? Ÿ Yes, but the
official program developed by APHIS and ALSC for the US NMWP industry only
includes heate-treated NMWP. This is because (1) methyl bromide is being
phased out in the United States under the Montreal Protocol, and (2) there
are environmental and disposal problems associated with CPI wood. Ÿ APHIS recommends that new coniferous NMWP be produced under the ALSC program using heat treated or heat treated and kiln dried wood since heat treatment is the only "long-term treatment" approved under the proposed International Standard for NMWP for any international movement. Ÿ Fumigation of coniferous NMWP for
movement to EU member states may be done by any licensed fumigator using a
fumigant approved for wood fumigation.
Such NMWP must be marked with the name and location of the treatment
facility. APHIS recommends methyl
bromide for such fumigations. Please
refer to the APHIS PPQ treatment manual for current guidelines on methyl
bromide and tarpaulin fumigations. 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. 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. 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. Materials shipped before October 1 with a bill of lading as proof and arriving in EU after the effective date are not affected. 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 can I be sure my product is properly packed? Advise your pallet supplier to contact one of the grading agencies listed in the NMWP Summary Page and to enroll in the heat treatment program or follow the recommended guidelines for fumigation or Chemical Pressure Impregnation. How will lumber shipments be affected? Lumber shipments will not be affected any more than any other cargo. (Coniferous lumber can only be exported to the European Union with a heat treatment certificate from a participating mill or a Federal Phytosanitary Certificate.) 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 heat treated. In addition manufactured products such as plywood pressed hardwood etc do not fall under the scope of the EU measure. Our Wood boxes are manufactured from a mix between
coniferous NMWP materials and hardwood NMWP materials. How are they affected
by the EU emergency measure? If the NMWP is made of any coniferous materials it would be subject to treatment.
Is coniferous NMWP transshipped through a EU country with
a final destination to a non EU country affected? Shipments with coniferous NMWP transiting a EU country and not making customs entry are not affected by the EU emergency measure. 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 nonmanufactured wood
packing? In addition to the United States Department of Agriculture, which has federal regulations which require all NMWP to be free of bark and apparently free of insects or treated, China regulates coniferous NMWP from the United States. Australia requires all NMWP to be fumigated. Many other countries, including Brazil, Argentina and Russia, have indicated an interest in imposing stricter restrictions on NMWP. 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?
Is there a listing of lumber mills whereby heat treated coniferous lumber may be purchased? APHIS does not have information pertaining to lumber mills providing HT marked wood. Heat treated coniferous lumber with the required HT stamp must first be requested of the mill. It is the HT stamp that the listed grading agency facilities will first be looking for when applying the grading agency official mark Does the European Union require coniferous NMWP to be bark free under
the new emergency measures? Who Should I Contact for Additional Information? Additional questions concerning the NMWP program may be directed to USDA/APHIS/Export Services by e-mail or phone (301-734-8537), USDA/FAS/Forest and Fisheries Products Division (202-720-0638) or the American Lumber Standard Committee (301-972- 1700).
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