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Wood Crating, Pallets, and All Non-Manufactured Wood Packing Material http://www.aphis.usda.gov/ppq/wpm/export/index.html
We Certify and Stamp to European Union Regulations;Wood Packing Materials to EuropeEuropean
Union Measures for Coniferous
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| The Commission of the
European
Communities has adopted
emergency
measures requiring the treatment and marking of all new and used
coniferous (e.g. pine, spruce, fir) non-manufactured wood packing material
(NMWP) originating in the United States, Canada, China, or Japan and
departing on or after October 1, 2001, to prevent the introduction of the
pinewood nematode. Hardwoods are exempt from the EU emergency measure. The
pinewood nematode is a microscopic eelworm which has caused extensive
mortality in pines in Japan and China.
(Since NMWP made entirely of hardwoods are exempt from the EU emergency measure, no marking of this material is required. The National Wooden Pallet and Container Association (NWPCA), the largest organization of wooden packaging professionals in North America is developing an optional mark for "hardwood only" NMWP. ) European concern over the possible introduction and establishment of the pinewood nematode has heightened over the past couple of years after an outbreak in Portugal and interceptions of the pinewood nematode in NMWP from the United States, Canada, China, and Japan. The source of the outbreak in Portugal has not been positively identified but packaging material is believed to have been the likely pathway. The EU emergency measures allow three treatment options for coniferous NMWP: heat treatment (HT), fumigation or chemical pressure impregnation (CPI). In all cases treated wood must bear a mark indicating the organization that treated the NMWP and the location of that organization. The EU requires that the HT program be an official program with official marks. The International Plant Protection Convention, which is recognized by the World Trade Organization as the official international plant protection organization, is now considering a draft international standard with measures very similar to those of the EU that would apply to all NMWP, coniferous and hardwood. The draft standard, which is being circulated for country comment, is tentatively scheduled for adoption in April 2003. Interested parties should review the standard and comment on the rule. All three of the treatment options approved by the European Union are available to exporters in the United States. APHIS recommends the use of the heat-treatment (HT) option since that is the only "long term measure" currently listed in the IPPC draft standard. The Heat Treatment (HT) Program The American Lumber Standards Committee (ALSC) in coordination with APHIS and the NMWP industry has developed an official program for the HT option. The program will require SWPM assemblers to enroll with a grading agency affiliated with the ALSC and to acquire HT marked lumber from approved lumber mills. The program will include on-site inspections of NMWP manufacturing facilities to verify compliance. On-site inspections will be done by inspection agencies accredited by ALSC. The ALSC's policy on NMWP and NMWP enforcement regulation are available for review. Two official marks have been approved for the agencies: one mark for NMWP using 100% HT treated lumber and another mark for NMWP containing heat treated coniferous lumber and untreated non-coniferous wood (HTC/NHTNC). Contact one of the agencies listed below if interested in participating in the HT program. As of August 1, 2001, the American Lumber Standards Committee has accredited the following organizations to participate in the HT program: National Hardwood Lumber Association, Memphis, TN 901-377-1818 Fumigation of NMWP Regarding fumigation, the EU emergency decision does not specify any particular fumigant or an officially approved mark, but it does require an officially recognized technical specification. In the United States the Environmental Protection Agency (EPA) is responsible for registering and establishing technical specifications ("labeling") for pesticides. All fumigants are restricted-use pesticides and they may only be purchased and applied by licensed commercial pesticide applicators. And, although it is a violation of Federal law for commercial applicators to apply a pesticide in a manner inconsistent with the EPA label, it is the State, not the Federal government, that licenses commercial applicators. Because of these considerations, APHIS is advising exporters as follows:
NMWP Made with CPI Wood Environmental concerns surrounding pressure-impregnated wood make its large-scale use problematic. For instance, the Netherlands has recently prohibited the commercial importation of wood impregnated with copper compounds because of environmental issues. In spite of this the EU emergency measures do not require a specific chemical treatment or an official mark for NMWP made with CPI coniferous wood. The European Union does not require treatment of non-coniferous wood so NMWP may be made of untreated non-coniferous wood and CPI coniferous wood. In most cases, CPI wood contains quality marks and is a distinct color (due to the treatment process) so it cannot be mistaken for untreated wood. Like fumigants, CPI chemicals are regulated by the EPA and may only be applied by facilities that are licensed by the State governments. APHIS recommends the following for NMWP facilities that use CPI coniferous wood:
PART: SPECIAL NOTICES OFFADD: Naval Inventory Control Point - Mechanicsburg, Code M2522, PO Box 2020, Mechanicsburg, PA 17055-0788 SUBJECT: EUROPEAN UNION (EU) RESTRICTIONS INVOLVING NON-MANUFACTURED WOOD PACKAGING (NMWP) AND PALLETS DESC: A requirement that "all wood pallets and wood containers produced of non-manufactured wood shall be constructed from Heat Treated (HT to 56 degrees Centigrade for 30 minutes) material and certified by an accredited agency recognized by the American Lumber Standards Committee (ALSC) in accordance with Non-Manufactured Wood Packaging policy and Non-manufactured Wood Enforcement Regulations both dated May 30, 2001" must be included in all solicitations and contracts where wooden pallets and containers may be used to ship material to U.S. forces and for Foreign Military Sales (FMS) customers in Europe. This requirement is necessary in order to comply with the Emergency Measure adopted by the commission of the European Communities (CEC) that became effective October 1, 2001. Membership in the CEC includes Austria, Belgium, Denmark, Finland, France, Germany, Greece, Italy, Luxembourg, Ireland, The Netherlands, Portugal, Spain, Sweden and the United Kingdom. The United Nations (UN) International Plant Protection Convention (IPPC) is drafting a similar measure to establish international standards for NMWPM and the prevention of various wood pests with an anticipated effective date of April 2003. NMWPM is defined as non-manufactured wood pallets, skids, boxes, and crates that have not had sufficient processing to kill pests present in the raw wood. One of the approved methods for eliminating this pest is to heat-treat (HT) the wood so the core temperature of each piece of treated wood will reach 56 degrees C for 30 minutes (56/30). The requirement may be added by incorporation into local palletization clauses, palletization sheets, or packaging requirements. At such time when the requirement is incorporated into material specifications and/or MIL-STD-2073-1, its inclusion in local clauses will no longer be necessary for solicitations and awards that include MIL-STD-2073-1. Refer to ' http://www.aphis.usda.gov/ppq/wpm/export/index.html
' for questions and material sources.
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