In 2005, Customs Border and Protection (CBP) put forth a set of requirements and guidelines regulating the import of all wood packaging material (WPM) into the United States. WPM or wood packaging material refers to all wood or wood-based materials used in the packing, supporting and carrying of products.
What is Wood Packaging Material (WPM)?
WPM includes boxes, containers, crates, dunnage, pallets, boards, bins and even loose pieces of wood used in casing cargo, all of which may potentially carry harmful timber pests such as snails, termites, borers and fungal decay to name a few.
These pests, once introduced into a foreign ecosystem can wreak havoc on it and threaten entire forests and agricultural lands as well as gravely affect many industries. Thus protecting the environment and the local economy from these insects and pests is a huge concern of the US government and CBP and the big picture goal of CBP in penalizing uncertified WPM is to try to encourage importers from using alternate materials for packaging. Alternatives to wood packaging material (WPM) include plywood, press board, plastic pallets, oriented strand board, hardboard, parallel strand lumber, synthetic foam, metal frames, inflated dunnage, and masonite veneer.
Per the 2005 guidelines and regulations, all importers and trade companies utilizing wood packaging were expected to adhere to the law which demanded that certain procedures be followed before the said ‘imported’ material was allowed to cross the border.
However, due to a fairly flexible policy which allowed as many as five violations of the WPM before the authorities issued a penalty, many violators got away with not following the guidelines.
As a result of so many instances of violations, starting in November 2017, the US will enforce the requirements and guidelines by issuing penalties. Customs will carry out vigorous checking of WPM lots, and companies will be penalized on the very first violation of the requirements and guidelines. Customs is hoping by penalizing companies on the first violation, that it will also become their last violation.
What does the Wood Packaging Material (WPM) Regulation Require?
The WPM regulation requires importers to carry out certain preventative measures which will safeguard the ecosystem from any possible hazards.
Before the shipment even enters the US, it is to be completely treated, i.e., fumigated with chemicals such as Methyl Bromide or physically with heat. The treatment must occur by an approved vendor, who will certify the treatment by marking the WPM in a clearly legible and visible way.
Examples of WPM Marks
The mark should be permanent, made on at least two sides of the commodity and also have approval under the International Plant Protection Convention in its International Standards of Phytosanitary Measures.
Any WPM failing to comply with these regulations will be immediately penalized and exported back to the place of origin, and all the costs and charges of the export will fall on the party responsible as well. 
Please note that an importer must BOTH treat the wood packaging material AND have it certifiable marked. If the Wood Packaging Material (WPM) is a 100% pest free but isn’t marked, or even properly marked, i.e., the mark isn’t legible, it will still be sent back. Similarly, a marked but infested WPM will be considered improper and meet the same fate.
Once the notice stating the violation is issued to the importer through the Emergency Action Notification, the importer will only have a short window of time to move the shipment and any further delay will incur additional penalties.
If you have any questions regarding the enforcement of the WPM regulations and guidelines, we are happy to help. Call or 303‑365‑1000 or email us.