ISPM 15: The Wood Packaging Rule That Stops Shipments

Non-compliant pallets are the most avoidable cause of a stopped shipment and one of the most expensive. ISPM 15 is the international standard governing wood packaging material in trade, and customs and plant protection officers enforce it at the border on the mark alone.

What the standard covers

Solid wood packaging used to carry, protect or support cargo: pallets, crates, boxes, dunnage, drums and blocking. It must be treated and marked.

Two treatments are the ones marked on US-bound wood: heat treatment, marked HT, and methyl bromide fumigation, marked MB. Methyl bromide is restricted or prohibited in a growing number of countries. Dielectric heating is also recognized for certain material. Treated wood carries the IPPC mark: the wheat symbol, the country code, the producer or treatment provider code, and the treatment code.

The US rule in 7 CFR 319.40-3

For cargo entering the United States, the rule sits in 7 CFR 319.40-3(b). It applies to regulated wood packaging material whether it packs regulated or nonregulated goods or is imported as cargo itself, and it sets three conditions for entry under the general permit:

1. The wood packaging must have been treated in accordance with 7 CFR part 305.
2. It must carry a visible, legible and permanent mark, preferably on at least two opposite sides of the article, approved by the International Plant Protection Convention.
3. The mark must include a unique graphic symbol, the ISO two-letter country code of the producing country, a unique number the national plant protection agency assigns to the producer, and the treatment abbreviation (HT or MB).

An inspector at the port of first arrival can order the immediate re-export of wood packaging that arrives without the required mark. The only listed exception is wood packaging the US Department of Defense uses under its own contracts.

What is exempt

Manufactured wood based materials that have been processed enough to eliminate the pest risk are outside the standard. That includes plywood, oriented strand board, particleboard, veneer and wood wool. Wood pieces less than 6 mm thick in any dimension are also excluded. The USDA APHIS list of alternative materials that the agency does not regulate as wood packaging names plywood or pressboard, plastic pallets, oriented strand board, hardboard, parallel strand lumber, synthetic foam, metal frames, inflated dunnage, masonite veneer and laminated veneer lumber.

Paper, plastic and metal packaging are not affected.

The mark is what gets inspected

Inspectors look for the mark, not for a certificate. The stamp must be legible, permanent and, preferably, on at least two opposite sides of the item. APHIS illustrates the marking violations it finds: illegible stamps, stamps not properly positioned on the lumber, missing borders around the stamp, incorrect logos, and completely unmarked material. Other failures that stop containers:

• Pallets repaired with untreated timber, which invalidates the original mark unless the repair is treated and re-marked
• Marks that are painted over, sanded, split across boards or applied with a stencil that does not match the registered format
• Dunnage and blocking inside the container that nobody checked, because attention went to the pallets
• Bark present on the wood, which is not permitted under the standard

What happens when a shipment fails

The options at the border are limited and all of them cost money: re-export the entire consignment, treat and re-mark under supervision where the destination allows it, strip and re-palletize at the port, or destroy the packaging. Meanwhile the container accrues demurrage and the consignee waits. A re-export order under 7 CFR 319.40-3(b)(3) applies to the wood packaging that lacks the mark.

Enforcement is not proportional to the value of the wood. A single untreated piece of dunnage holds a full container, because the inspector acts on the packaging and not on the cargo value.

What counts as wood packaging material

The definition in 7 CFR 319.40-1 lists the articles by function: wood packaging material used with cargo to prevent damage, including dunnage, crating, pallets, packing blocks, drums, cases and skids. It excludes three groups:

• Manufactured wood materials, such as plywood and particleboard.
• Loose wood packing materials, which have their own entry condition: dry loose wood packing enters under the general permit subject to the port inspection rules in 319.40-9.
• Wood pieces less than 6 mm thick in any dimension.

Anything else made of solid wood that touches the cargo counts, including the blocks and bracing that secure the load inside the container.

What the port inspection does

Under 7 CFR 319.40-9, all imported regulated articles are inspected at the port of first arrival. Four rules in that section govern what follows:

• If the inspector finds signs of plant pests, the article is cleaned or treated as the inspector requires and stays subject to reinspection, cleaning and treatment until the requirements are met.
• If the article is so infested that it cannot be cleaned or treated, the entire lot can be refused entry.
• Nobody moves an imported regulated article from the port until an inspector notifies the person, in writing or through an electronic database, that it complies or that further treatment is required elsewhere.
• Any imported article can be sampled for plant pests at the port.

The wood packaging mark sits at the front of this process: a legible mark lets the inspector move on to the cargo, and a missing mark lets the inspector order immediate re-export under 319.40-3(b)(3). A hold at the terminal consumes the container's free days, and the daily charges start once they run out.

The order of checks from supplier to port

1. Purchase order: names ISPM 15 compliance, the treatment (HT or MB) and the right to refuse unmarked pallets.
2. Before loading: photographs of the pallet marks from at least two sides, and of the dunnage.
3. At the consolidator: receiving staff check marks on every pallet before stuffing.
4. At the port of first arrival: inspection by the plant protection officer under 319.40-9.
5. At your warehouse: the same mark check on every pallet that enters stock, so export shipments do not carry unmarked wood.

The same standard applies at every destination that adopts ISPM 15, so a pallet that passes the US rule carries a mark other adopting countries read. Confirm the destination's own rules before a shipment because each national plant protection organization enforces the standard itself.

Where each failure is found

Buying compliance instead of hoping for it

Specify ISPM 15 compliant packaging in your purchase orders, not in a conversation. Ask suppliers to photograph the marks before loading. Instruct your warehouse to reject inbound pallets without a legible mark, because a pallet that enters your stock unmarked will leave on an export shipment. Where the destination is strict and volumes are small, plywood or pressed pallets remove the question entirely, and the standard pallet sizes reference lists the footprints those pallets come in.

For consolidated cargo the risk compounds: one shipper's untreated pallet holds the whole container, affecting everyone in the box. That is one more reason consolidators check pallets at receipt, as covered in LCL container shipping.

A pre-loading checklist

1. Every pallet, crate and block shows the full mark: symbol, country code, producer number, HT or MB.
2. The mark is on at least two opposite sides of each pallet.
3. No pallet shows repair boards without their own mark.
4. No wood shows bark.
5. Dunnage, bracing and blocking inside the container carry marks, or are plywood, pressboard, plastic or metal.
6. The packing list states the packaging type, so the broker and the inspector read the same description.

Treated wood marks are separate from cargo certificates. A fumigation of the goods themselves is documented on a fumigation certificate, and some destinations also ask for a phytosanitary or inspection certificate for the cargo.

FAQ

What is ISPM 15?

An international phytosanitary standard requiring treatment and marking of solid wood packaging used in international trade. In the United States it is enforced through 7 CFR 319.40-3. The accepted treatments are heat treatment (HT), with a core temperature of 56 C held for at least 30 minutes, and methyl bromide fumigation (MB).

Does it apply to plywood pallets?

No. Manufactured wood such as plywood, OSB and particleboard is exempt, as are wood pieces less than 6 mm thick in any dimension. Solid-wood pallets, crates, dunnage and skids are covered regardless of their age, because the standard applies to the wood, not to the cargo.

What does the IPPC stamp show?

The wheat symbol, the country code, the registered producer or treatment provider code and the treatment method, HT or MB. The mark must be permanent, legible and placed on at least two opposite sides of the wooden item.

Is a fumigation certificate required?

The mark on the wood is the evidence. Some destinations request a phytosanitary certificate for the cargo itself, which is separate.

Can a repaired pallet keep its original mark?

Only if the repair uses treated material and the pallet is re-marked. Repairs with untreated timber void compliance.

What does a US inspector do with unmarked wood packaging?

The inspector at the port of first arrival can order its immediate re-export under 7 CFR 319.40-3(b)(3), in addition to the other port-of-arrival procedures.

Which materials can replace wood pallets?

Plywood or pressboard, plastic pallets, oriented strand board, hardboard, parallel strand lumber, synthetic foam, metal frames, inflated dunnage, masonite veneer and laminated veneer lumber, per the APHIS list.

Does dunnage inside the container need a mark?

Yes. Dunnage, crating, packing blocks and skids are all wood packaging material under 7 CFR 319.40-1, so each solid wood piece carries the mark or is replaced by plywood, pressboard, plastic or metal.

What happens to a container held at the port for wood packaging?

The container sits under the inspector's hold until the article is cleaned, treated or ordered re-exported. The hold uses free days, so demurrage and detention charges accrue while the packaging is resolved.

Shipping on wooden pallets into strict markets? Ask us to check your packaging spec before the container is stuffed.