Being Prepared At The Border

European Union Emergency Heat Treatment Compliance
November 20, 2001
by Larry Miller
Carr Lumber and Manufacturing
Bedford Park, IL

Crated shipments or shipments on wooden pallets going to the European Union, China and Australia can be stopped at the border if they do not have the proper paper certification or stamps. This certification or stamps tell customers the solid wood packaging material has been heat treated to meet their requirements. The world is going to this program in the next 12 to 18 months. Do not take a chance. Foreign customs have said they can turn back, repackage or destroy items that do not meet this standard. It will pay off to check into this requirement. Your customers need to know these laws and how they will affect their business now and in the future.

Background

The European Union (EU), which consists of Austria, Belgium, Denmark, Finland, France, Germany, Greece, Italy, Luxembourg, Ireland, The Netherlands, Portugal, Spain, Sweden and the United Kingdom, has adopted an emergency measure requiring treated softwood to be used for non-manufactured wood packaging (NMWP) on or after October 1, 2001.
World Trade Organization (WTO) is reviewing the international standard for the heat treating of softwood and hardwood NMWP. This WTO program is due out April 1, 2003 but may be on the fast track for mid 2002.
The previous standard adopted in 1993 was as follows: Designed to regulate softwoods, strict enforcement on all wood shipments (lumber and NMWP), bark free, no grub holes and less than 20% moisture content. There was a decided lack of enforcement on this standard and the North American Pinewood Nematode spread to Japan, Korea, China and Taiwan with no natural enemies. The Pinewood Nematode was found in Portugal in 1998 with no way of determining if the pest was from Asia, Canada or the U.S. The EU issued emergency measures effective October 1, 2001 requiring all new and used softwood NMWP originating in the U.S., Canada, China and Japan to be treated with heat, chemically impregnated or fumigated and marked accordingly.

United States Official Program Summary

The EU turned over the compliance portion of the standard to the USDA Animal Plant Health Inspection Service (APHIS). APHIS, in cooperation with the American Lumber Standards Committee (ALSC), developed the U.S. standard that will meet and exceed what the EU and the WTO need. The ALSC monitors and oversees the lumber grading agencies who currently control and certify lumber mills grade stamps. They will now certify the heat treating mills and Solid Wood Packaging Manufacturers (SWPM) as well. Each SWPM must enroll with a grading agency if they are using softwood in their products. Each SWPM will have a unique number assigned to each facilities location on a stamp. They then will stamp the completed product.

Types of Treatments

All of the below options are currently available for exporters. HT is the only universal standard for EU and the only one listed in the WTO standard due out April 2003.
Heat Treatment (HT): All softwood be heat treated to a core temperature of 132 degrees for 30-minutes. WTO standard will require IIT softwood and hardwood.
Pressure Treatment (PT): Pressure impregnated with an approved chemical in accordance with an officially recognized technical specification.
Fumigated Treatment (FT): Fumigated with an approved chemical in accordance with an officially recognized technical specification.

100% Softwood Crating

The program requires packaging assemblers to enroll with any one of the 10 currently approved U.S. grading agencies. In order to use the "bug free" quality mark the packaging assemblers must buy heat treated wood or heat treat the finished product. In order to use the "bug free" quality mark the assembler is required to keep records and submit to on-site monthly inspections by the grading agency they subscribe to. The mark is required on a minimum of two opposing faces of the completed packaging product.

Hardwood and Softwood Combinations

Hardwood and Softwood combinations require a different quality mark to show the softwood in the product has been HT and the rest is non-treated hardwood. This mark is HTC/NHTNC and stands for Heat Treated Coniferous/Non Heat Treated Non Coniferous. Coniferous is softwood and non-coniferous is hardwood. Assemblers of these type of products have to enroll in the same program as those who use the "bug free" stamp.

100% Manufactured Wood Crating

Manufactured wood or wood that has been manufactured with heat, glue and/or pressure currently does not need any certification since the heat used in the manufacturing process exceeds the EU standards. Examples are plywood, OSB or glue lam beams.

100% Hardwood Crating

The EU standard does not cover hardwood. The National Wooden Pallet and Container Association (NWPCA) is developing a quality mark that indicates the product is 100% hardwood. Assemblers could put this mark on their products without certifying with ALSC approved agency for now.

Fumigation (FT) Program

Fumigation is an option and has been recognized for now by APHIS. The WTO standard does not have FT as an option. EPA is responsible for registering and establishing technical specifications and individual states licenses applicators in their area. Methyl bromide is the fumigant currently recognized by APHIS. The name of the pest control company/applicator, the two letter code for the state of origin, and the state pesticide applicator number should be shown on the softwood NMWP. APHIS has developed a recommended mark which has been officially endorsed by the NWPCA.

Pressure Treated (PT) Program

The EU does not specify the method of treatment required. Some countries (The Netherlands is a current example) have prohibited CCA treatments due to the use of copper. The EPA is currently reviewing the use of CCA treatments in wood use as a whole. APHIS recommends the following for the use of treated wood: the use of a treatment by a licensed wood preserver through The American Wood Preservers Association (AWPA). Each piece of a treated packaging material must have the name of the assembler. APHIS has developed recommended marks that have been endorsed by the NWPCA for treated products. For other information contact the AWPA.

FAQ's

Q: What happens to existing packaging?
A: It has to conform through IIT or FT or stay out of the EU. Large batch quantities may require FT due to time constraints. HT is the safest program.

Q: Does "dunnage" have to comply with the standard?
A: No, currently it is exempt. EU will make a determination on this in the future.

Q: If I buy and manufacture packaging using IIT lumber do I automatically comply?
A: No. You must certify to use the "bug free" stamp through an approved ALSC agency.

Q: What happens if we do not comply?
A: The EU has indicated they will refuse entry, destroy or treat themselves prior to entry.

Q: Other than the bug stamp is there other documentation needed?
A: No, the EU requires the product to be stamped to show who treated the wood and where. This has been designed to be a paperless program.

Q: What is the effective date?
A: All items shipped on or after October 1, 2001.

Q: Is this the same standard as China has currently?
A: NO. China still requires a paper certificate to follow the shipment. They may accept WTO standard when it is presented.

Q: Is this the same standard as Australia?
A: No. Australia requires all wood packaging to be fumigated or heat treated. The heat treated standard is a higher temperature than the EU requires. There is documentation required to follow each shipment.

Q: Who can meet the IIT standard now?
A: Only those assemblers who have subscribed to an ALSC agency and have been certified to use the "bug free" stamp or the IITC/NHTNC stamp. This can be done by buying heat treated lumber, heat treating their own lumber or using manufactured products. eb