Guidelines for Following the European Union’s Emergency Measures for Coniferous Non-Manufactured Wood Packing Material

Gatti & Associates
June 2003

As of July 2002, the European Union has required the treatment and marking of all new and used coniferous (pine, spruce, fir, etc.) non-manufactured wood packing material (NMWP) originating in the U.S., Canada, China or Japan.  The emergency measures were put into place to prevent the introduction of the pinewood nematode (a microscopic eelworm that has severely damaged pines in China and Japan) into the EU countries.  NMWP made from hardwoods are exempt from treatment and marking.

This article provides an overview of the requirements necessary to comply with the EU measures.  The EU has approved three types of treatment methods for NMWP – heat treatment, fumigation, and pressure treatment, each of which is detailed below.

Heat Treatment

The heat treatment program requires assemblers to enroll with a grading agency associated with the American Lumber Standard Committee (ALSC) and use heat treated lumber from approved mills.  The lumber must be treated at a minimum core temperature of 56 degrees Celsius for at least 30 minutes.  It must then be marked as either 100% HT treated lumber or as a combination heat treated lumber and untreated non-coniferous wood, depending on the type.  The following agencies are accredited by the ALSC for participation in the heat treatment program:

   - National Hardwood Lumber Association in Memphis, Tennessee – (901) 377-1818
   - Northeastern Lumber Manufacturer’s Association in Cumberland Center, Maine – (207) 829-6901
   - Northern Softwood Lumber Bureau, Cumberland Center, Maine – (207) 829-6901
   - Pacific Lumber Inspection Bureau, Federal Way, Washington – (253) 835-3344
   - Package Research Laboratory, Rockaway, New Jersey – (973) 627-4405
   - The Packaging Department, Bloomington, Minnesota – (952) 967-9400
   -Redwood Inspection Service, Novato, California – (415) 382-0662
   -Timber Products Inspection, Conyers, Georgia – (770) 922-8000
   -West Coast Lumber Inspection Bureau, Portland, Oregon – (503) 639-0651

Fumigation

The European Union follows the lead of the U.S. Environmental Protection Agency (EPA) in use of approved pesticides for fumigation treatment.  Fumigation must be performed with an EPA-approved chemical in accordance with an "officially recognized technical specification." 

All fumigants are restricted-use pesticides that may only be purchased (and used) by licensed commercial pesticide applicators.  It should be noted that licensing for applicators is done by the individual state governments and not by the federal government.  The Animal and Plant Health Inspection Service (APHIS), an agency of the U.S. Department of Agriculture (www.aphis.usda.gov) recommends the following:

   - Fumigation may be used to meet the EU treatment requirement for coniferous NMWP.
   -Fumigation must be done by licensed pesticide applicators following the EPA-approved label specification of the fumigant 
      used.
   -  Methyl bromide is the fumigant recommended by APHIS, phosphine is also an approved fumigant by the EU.
   -  The name of the pest control company/applicator, the two-letter code for the state of origin, and the state pesticide  
     applicator number should be shown on the coniferous NMWP.
   -  For fumigated NMWP, APHIS has developed a recommended and officially-endorsed mark that has been accepted by
      the EU.  The recommended mark can be developed as a stencil or stamp and be applied by the assembler or the licensed
     fumigator.

Pressure Treatment

The third approved treatment for NMWP is pressure treated coniferous lumber.  This is the least desirable method because several EU countries (most notably, the Netherlands) have environmental restrictions on certain treated woods.  The EU does not require a specific mark or treatment type.  Chemicals used for pressure treating the wood are regulated by the EPA and may only be applied by state-licensed facilities.  Similar to fumigation, the chemical must be approved in accordance with an officially recognized technical specification.  APHIS issued the following recommendations for pressure treated woods:

   - NMWP assemblers must use coniferous wood that is pressure impregnated by a licensed wood preserver using a treatment
     officially approved by the American Wood Preservers Association.
   -  NMWP assemblers should mark each piece of NMWP (pallet, crate, spool, etc.) with a mark indicating the name of the
      location of the NMWP assembler.  The mark can be applied by the assembler.
   -  APHIS has developed recommended marks for NMWP assemblers using pressure impregnated coniferous wood.  There
      is also a separate mark for mixed treated and untreated wood.