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Canadian Wood Packaging Certification Program (CWPCP)

CFIA directive D-01-05, ISPM 15 wood packaging rules and quality system requirements for facilities.

The Canadian Wood Packaging Certification Program (CWPCP) is a quality management program designed to allow certified producers to construct wood packaging products to meet a phytosanitary standard (ISPM No. 15).

Documentation Requirements

D-01-05 The Canadian Wood Packaging Certification Program for Export

QSM-02

Quality System Requirements For Facility Registration

QSM-03 Quality System Requirements for Service Provider approved under the CWPCP

This directive describes the Canadian Wood Packaging Certification Program (CWPCP); a certification system for facilities wishing to produce wood packaging material in accordance with the provisions of International Standard for Phytosanitary Measures (ISPM) No. 15, Regulation of Wood Packaging Material in International Trade. Participation to this program is strictly voluntary unless required under pest specific regulations or policies which regulate the movement of wood packaging material outside a regulated area of Canada.

Some National Plant Protection Organisations (NPPOs) may establish additional requirements where it has been technically justified through application of internationally recognized criteria.

This directive has been revised to clarify the types of facilities that can register under this program as outlined in Section 4.0.

Additionally, Section 8, Note 11, has been revised to explain the procedures required for repairs to a wood packaging unit comprised of processed and regulated wood material.

Review This directive shall be reviewed every 2 years or unless otherwise needed. For further information or clarification, please contact the Canadian Food Inspection Agency (CFIA).

Introduction Wood packaging material is essential for trade and the movement and protection of cargo and containerized goods. Wood packaging material can accompany any article and represent a large group of products such as pallets, dunnage, boxes, crating, packaging blocks, drums, cases, load boards, pallet collars, and skids. Historically, these products were commonly produced from non-processed wood which lacked sufficient manufacturing or treatment to remove or eradicate pests present in the wood.

Canadian pest interception records have demonstrated that a large variety of pests can be transported with wood packaging material and in many circumstances the pests have been able to survive. The Canadian pest risk assessment for the import of wood packaging material has scientifically identified wood packaging material as a significant pathway for the movement of quarantine insects and diseases of plants and trees.

Despite the development of a variety of import requirements for wood packaging material, pests continue to move throughout the world on wood packaging material. It is believed that the introduction of several invasive quarantine pests, for example, Asian Long-horned Beetle, Brown Spruce Longhorn Beetle, Emerald Ash Borer and the Pine Shoot Beetle, into North America are related directly to the movement of wood packaging material from other areas of the world. As global trade continues, every importing country is at risk from the introduction of wood pests, which causes irreversible impacts to forest health and biodiversity.

In March of 2002, the International Plant Protection Convention (IPPC) adopted a wood packaging standard; Regulation of Wood Packaging Material in International Trade, International Standards for Phytosanitary Measures (ISPM) No. 15. This standard recognizes the plant health risks associated with wood packaging and outlines approved phytosanitary measures. To target the plant health risk associated with wood packaging, the standard recommends that all wood packaging should be treated. To facilitate trade, treated wood packaging must be marked in a manner to identify the approved treatment and to provide traceability to the country of origin and the producing facility.

The CWPCP is a certification system that allows Canadian wood packaging facilities and treatment facilities to build wood packaging products that meet the provisions of ISPM No. 15. The final product will be marked with a Canadian wood packaging certification mark. This mark will be unique to each Registered Facility.

The CWPCP and The Technical Heat Treatment Guidelines and Operating Conditions Manual (PI-07) provide the specifications for the treatment and manufacturing of wood packaging material in accordance with the requirements of ISPM No. 15. The CWPCP uses a quality management systems approach designed to allow traceability of treated wood packaging material certified under this program to the actual treatment record, treatment facility, or the wood packaging facility.

The list of countries having indicated, through official World Trade Organization (WTO) Notification that they have adopted the standards with the ISPM No. 15, Regulation of Wood Packaging Material in International Trade.

Note 1: Certain countries may have specific phytosanitary import requirements in addition to those specified in this document. Please consult the specific phytosanitary import requirements of the foreign country to verify if there are additional requirements.

Scope This directive is intended for use by Canadian wood packaging facilities, custom brokers, freight forwarders, exporters, CFIA inspection staff and any CFIA Service Provider. It sets forth the registration and phytosanitary requirements for the production of ISPM No. 15 compliant wood packaging material as well as how the program will be audited by the CFIA and the CFIA recognized Service Providers.

1.0 General Requirements

1.1 Legislative Authority The Plant Protection Act, S.C. 1990, c. 22 The Plant Protection Regulations, SOR/95-212 Canadian Food Inspection Agency Act (1997, c. 6) Canadian Food Inspection Agency Fees Notice, Canada Gazette, Part I (as amended from time to time) Agriculture and Agri-Food Administrative Monetary Penalties Act, (1995, c. 40) Agriculture and Agri-Food Administrative Monetary Penalties Regulations, (SOR/2000-187) 1.2 Fees When a wood packaging facility applies to participate in the CWPCP, the facility must pay the Service Provider for registration and audit services (for the purposes of this document, a Service Provider is an organization, company or person who has entered into a Service Contract with CFIA under the CWPCP and is accountable to the CFIA for the activities identified within the contract). The facility must also remit to the CFIA, a registration payment of $400.00 by separate cheque payable to the Receiver General of Canada, on application, and by October 1st of each year thereafter, for participation in the program, for audit and administrative services.

1.3 Regulated Pests Wood packaging is a pathway for the movement of a number of serious pests to trees and shrubs. A list of families of regulated pests has been developed from the ISPM No. 15 and is provided in Appendix 2.

1.4 Regulated Commodities Regulated commodities include all non-processed wood packaging and loose wood dunnage constructed from coniferous (softwood) and non-coniferous (hardwood) wood or combinations thereof to be exported from Canada to countries that have adopted ISPM No. 15, in addition to all such material moving within Canada from an area where such products are regulated for a pest of quarantine concern to an unregulated area. This also includes wood crating, packaging blocks, drums, cases, load boards, pallet collars, and skids which can be present in almost any exported consignment, including consignments which would not normally be the target of phytosanitary inspection.

Failure to meet the phytosanitary import requirements of a foreign importing country may result in enforcement action being taken by the foreign government against the non-compliant shipment that could result in delays at the port of entry and as a consequence refusal of entry. The export of non-compliant forestry products may also be subject to enforcement by the CFIA, as it is also a violation of the Canadian Law, specifically, the Plant Protection Act and Regulations, to export anything from Canada unless it meets the importing country's phytosanitary requirement.

Veneer peeler cores, whether used directly or in the manufacturing of wood packaging materials, are also regulated and must be heat treated in accordance with requirements specified in Section 2.1.1 and marked with the ISPM No. 15 wood packaging mark.

All wood packaging material must be debarked (See Section 6.0 for more information on debarked wood).

1.5 Commodities Exempt Wood packaging material or loose wood dunnage produced wholly (100%) from processed wood are not subject to the requirements of this directive. Plywood, particle board, oriented strand board or veneer that were created using glue, heat and pressure or a combination thereof would be examples of such products.

Other exempt products include barrels for wine and spirits that have been heated during manufacturing, as well as gift boxes for wine, cigars and other commodities made from wood that has been processed and/or manufactured in a way that renders it free of pests.

Wood packaging material made from sawdust, wood wool, wood shavings and those made entirely from thin pieces of wood (6 mm or less in thickness) are also exempt. In addition, wood components permanently affixed to freight vessels and containers are exempt.

Some countries may have additional phytosanitary requirements for the import of processed wood. Please contact a local office of the CFIA for more specific information on a country's import requirements.

Note 2: Not all gift boxes and barrels are constructed in a manner that renders them pest free. For this reason, some of these products may be regulated within the scope of this directive. These include boxes for fruit and vegetables, barrels used in the transport of industrial commodities, etc. Please check with the importing NPPOs for any specific requirements relating to these types of commodities.

1.6 Regulated Areas Many areas of the world have adopted the standards prescribed in ISPM No. 15 Please contact a local office of the CFIA for more information on the ISPM No. 15 status in a specific importing country.

The domestic movement within Canada, of wood packaging material and loose wood dunnage may also be subject to pest specific plant protection regulations if the wood packaging material originates from areas regulated for specific pests and is to move to non-regulated areas of Canada (including destinations in the U.S.) (Refer to section 13.0).

2.0 Specific Requirements

2.1 Approved Treatment Options Presently, heat treatment and methyl bromide fumigation have been accepted internationally as approved measures under ISPM No. 15 in order to mitigate pest risks associated with wood packaging. Canada is a signatory of The Montreal Protocol on Substances that Deplete the Ozone Layer (1987) agreeing to the reduction and eventual phase-out of ozone depleting substances. Methyl bromide, an ozone depleting substance, has been undergoing phase-out since 1995. For this reason, the use of methyl bromide fumigated material will not be considered for approval under this program. Additional measures are being considered for approval under ISPM No. 15 (Refer to Annex 1 of ISPM No. 15 for treatments being considered).

2.1.1 Heat Treatment (HT) Under ISPM No. 15 requirements, wood used for the construction of export wood packaging material or the export wood packaging material itself must be heated in accordance with a specific time-temperature schedule that achieves a minimum temperature of 56°C throughout the profile of the wood (including at its core) for a minimum of 30 minutes.

The heat treatment must occur at a facility approved by the CFIA and operating under the C