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.

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.

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.

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.

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.

The member states of the European Union will enforce the regulation.

The emergency measures require that all new and used NMWP originating from the four countries be:

• heat treated or kiln-dried to a minimum core temperature of 56â C for at least 30 minutes in a closed chamber or kiln which has been tested, evaluated and approved officially for this purpose;
• pressure treated with an approved chemical in accordance with an officially recognized technical specification; or
• fumigated with an approved chemical in accordance with an officially recognized technical specification.
• All coniferous NMWP must also display a mark enabling the identification of the treatment facility and the location of the facility. In the case of heat treated coniferous NMWP the use of the mark will be limited to NMWP manufacturers participating in the APHIS-ALSC program.

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.

No, but companies may include a statement about composition of the non-regulated packing materials on the bill of lading or the invoice.

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 official program between APHIS and the US NMWP industry does not include fumigation or CPI wood because (1) methyl bromide is being phased out in the United States under the Montreal Protocol, and (2) because of the environmental and disposal problems associated with CPI wood.

APHIS recommends that new coniferous NMWP be produced under the ALSC program using heat treated or heat treated and kiln dried wood since that material could be used under the proposed International Standardfor NMWP for any international movement.

Fumigation of coniferous NMWP for movement to EU member states may be done by a 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.

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.

NMWP that is clearly marked as being from Europe will be acceptable. Other coniferous NMWP will be subject to enforcement.

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.

The emergency measures are effective October 1, 2001. This means that materials shipped on or after October 1 are subject to regulation.

Exporters need to be aware of the emergency measures and be sure that their shipments utilizing coniferous NMWP comply with these measures.

Freight forwarders will need to advise the exporters of the emergency measures and be aware that shipments may be held on arrival in Europe.

Advise your pallet supplier to contact one of the grading agencies listed in the NMWP Summary Page and to enroll in the program.

Lumber shipments will not be affected any more than any other cargo.

Items such as furniture, doors, handicrafts, etc. are not regulated under the EU emergency measures and will not have to be heat treated.

No. The APHIS/ALSC program is based on use of official stamps with coded markings to show that NMWP complies with the emergency measures. This is specifically required by the EU emergency measures and is consistent with the draft international standard.

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, the European Union has recently adopted emergency measures to regulate coniferous NWPM from the United States, Canada, China and Japan. These measures will go into effect on October 1, 2001. 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.

• The European Union emergency measures, which will go into effect on October 1, 2001, cover only coniferous NMWP and only cover four countries (the United States, Canada, Japan and China). In addition they allow treatment of NMWP by fumigation, by chemical pressure impregnation or by heat treatment.
• The International Standard, scheduled for approval in April 2003, will cover both hardwood and conifereous NMWP, will apply to all countries, and (currently) will only allow heat treatment as a universal option. Arrangements to allow fumigation or chemical pressure impregnation would have to be negotiated between the exporting country and the importing country.

Questions concerning the NMWP program should 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). For a list of NMWP facilities participating in the program, contact an American Lumber Standards Committee (ALSC) affiliated Grading Agency.