The threat of invasive species like the Asian Long-Horned Beetle and the Emerald Ash Borer continues to devastate U.S. forests, and it’s not just an environmental issue—it’s also a significant concern for global trade. Both the U.S. Department of Agriculture (USDA) and U.S. Customs and Border Protection (CBP) enforce stringent regulations on wood packaging materials to prevent these pests from entering the country. These rules require that all solid wood packaging materials (WPM) used in imports must be treated to prevent the introduction of harmful insects that can wreak havoc on ecosystems and economies alike. The costs of non-compliance are steep: infested or improperly marked packaging can result in fines, forced re-export of goods, and severe delays, all of which strain the supply chain and harm the importer’s reputation.
Under the International Standards for Phytosanitary Measures No. 15 (ISPM 15), WPM must be either heat-treated or fumigated with methyl bromide before it can be used for shipping to the United States. This treatment ensures that insects cannot survive the shipping process and lay eggs that might later lead to infestations. The treated wood must bear the official IPPC marking, which includes the country code, the manufacturer’s code, and the treatment method (HT for heat-treated or MB for methyl bromide). This marking is essential in proving that the packaging complies with the necessary international standards.
If CBP or USDA inspectors discover non-compliant wood packaging material, whether it’s due to improper treatment or fraudulent markings, the result is often an Emergency Action Notice (EAN) that requires the immediate re-export of the entire shipment. This can be a significant disruption, especially for businesses that rely on timely deliveries. Moreover, the discovery doesn’t necessarily have to include live insects; visible damage such as exit holes, feeding marks, or frass (the residue left by wood-boring insects) is enough to trigger an EAN. These regulations exist to protect not just the environment but the economic well-being of the U.S. forestry and agricultural industries, which suffer billions of dollars in losses due to invasive pests.
It’s also important to note that while processed wood products—such as plywood, particleboard, or other engineered wood—are exempt from these regulations, solid wood packaging continues to be widely used. This is where the responsibility falls on importers to ensure that their foreign suppliers are using compliant materials. Communication with suppliers is critical to prevent costly errors, and it’s often advisable to switch to processed wood or even plastic pallets where feasible, as these materials eliminate the risk of pest infestation altogether.
Heightened Inspections: A Growing Challenge for Importers
In recent years, CBP has increased inspections on incoming shipments, particularly focusing on wood packaging material. This heightened scrutiny is part of a broader effort to protect U.S. agriculture and natural resources, but it has also resulted in a greater number of shipments being delayed. Importers should be aware that even fully compliant packaging can be subjected to random inspections, and if pests or signs of infestation are found, they face the prospect of lengthy export procedures. In some cases, shipments that use WPM marked as treated can still fail inspection if the treatment wasn’t properly applied or if fraudulent markings were used. As such, importers are strongly encouraged to verify that their suppliers adhere to the proper standards at every step of the supply chain.
Given this growing trend of increased oversight, it’s essential for companies involved in international trade to be proactive. Many businesses are choosing to transition to alternative packaging materials, such as plastic or processed wood, which are exempt from ISPM 15 and therefore avoid the risk of non-compliance altogether. Plastic pallets, for instance, are becoming increasingly popular due to their durability and exemption from pest-related regulations. Additionally, many packaging manufacturers are developing high-strength processed wood alternatives that can bear heavy loads, further reducing the need for traditional solid wood materials.
The CTPAT and Environmental Protection
Another key consideration is the Customs Trade Partnership Against Terrorism (CTPAT) program, which reinforces the importance of security and compliance in the global supply chain. As part of CTPAT, companies are encouraged to ensure that their suppliers meet both USDA and CBP requirements, particularly regarding the use of compliant wood packaging. While the primary goal of CTPAT is to enhance security, the program also plays a role in environmental protection by emphasizing the importance of preventing the spread of invasive species. Non-compliant wood packaging can lead to delays, extra costs, and even sanctions, all of which disrupt trade and harm the environment.
Moreover, protecting U.S. forests from invasive species aligns with broader environmental goals, as healthy forests play a critical role in carbon sequestration, biodiversity, and supporting ecosystems. As environmental concerns become more pressing, the role of regulatory bodies like the USDA and CBP in safeguarding natural resources has never been more important. Importers should view compliance not just as a regulatory obligation, but as a vital part of their commitment to sustainability and responsible global trade.