D-14-02: Certification Program for the Export of Hardwood Species Regulated for Agrilus spp. to the European Union

Transitioning to a new name: Hardwood Export Program

In the next few months, this program will be renamed to the Hardwood Export Program.

Effective date: July 18, 2024
(5th Revision)

This directive describes the Canadian certification program established to meet the phytosanitary import requirements for some host species of Agrilus spp as prescribed in the Commission Implementing Decision of the European Union (EU) 2019/2072 of 28 November 2019.

This directive lays down all the necessary requirements exporters need to meet for the export of ash and birch lumber based on a systems approach.

This directive has been revised to remove reference to the derogations previously granted to Canada and United States with regards to ash (Agrilus spp). The phytosanitary requirements for the export of ash lumber are now integrated into the EU's main regulation (Commission Implementing Decision 2019/2072 of 28 November 2019).

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Introduction

On June 17, 2014, the European Union (EU) published the Commission Implementing Directive 2014/78/EU which revised phytosanitary import requirements under EU Plant Health Directive 2000/29/EC. The directive, which entered into force on October 1, 2014, prescribes new requirements for importing ash (Agrilus spp), birch (Betula spp), Japanese walnut (Juglans ailantifolia), Japanese elm (Ulmus davidiana), and Japanese wingnut (Pterocarya rhoifolia) wood to the EU to prevent the entry and spread of emerald ash borer (Agrilus plannipenis) and bronze birch borer (Agrilus anxius).

To facilitate the export of sawn wood of host species regulated by the EU, the Canadian Food Inspection Agency (CFIA) has established this certification program similar to an existing audit-based systems approach for the import and domestic movement of sawn wood of host species of Agrilus planipennis (D-03-08).

On March 17, 2016, after bilateral discussions with the EU, Canada was granted a derogation for the export of ash wood originating or processed in Canada (Commission Implementing Directive 2016/412 (EU)). The export option under the EU derogation includes heat treatment/kiln drying (HT/KD) for the production of a compliant product under a systems approach.

On February 3, 2017, the EU granted a similar derogation to the US for the export of ash wood: Commission Implementing Decision (UE) 2017/204.

The derogation has been renewed for Canada and the United States in 2018 and 2020 and has now been made permanent under the main EU legislation.

Scope

This directive is intended for use by CFIA inspectorate and registered Canadian exporters intending to export regulated wood products to the EU under the certification program.

References

Definitions, abbreviations and acronyms

Definitions of terms used in the present document can be found in the Plant health glossary of terms.

1. General requirements

Legislative authority

Plant Protection Act, S.C. 1990, c.22
Plant Protection Regulations, SOR/95-212
Canadian Food Inspection Agency Fees Notice, Canada Gazette, Part 1 (05/13/2000)

Fees

The CFIA charges fees in accordance with the Canadian Food Inspection Agency Fees Notice. Anyone requiring further information regarding fees may contact their local CFIA office or visit the CFIA's Fees Notice website.

Regulated pests

  • Emerald ash borer (Agrilus plannipenis)
  • Bronze birch borer (Agrilus anxius)

Regulated products

Round or sawn wood products (poles, sawn wood, cants, etc.) of the following species are regulated to prevent the entry and spread of:

  1. Emerald ash borer:
  2. Bronze birch borer:
    • Betula spp.

Regulated areas

All areas of Canada are regulated. The EU does not recognize Pest Free Areas for emerald ash borer (EAB) in Canada and the US; therefore Pest Free Areas cannot be used as a basis for phytosanitary certification of Canadian or United States (U.S.) origin ash to the EU. Exporters intending to export regulated products from all areas of Canada or the US must comply with the requirements specified in Section 2 of this policy directive.

The Bronze birch Borer occurs in all areas of Canada and the U.S., therefore all areas of Canada and the U.S. are regulated by the EU.

2. Export requirements

Facilities intending to export regulated products to the EU originating or processed in Canada must register with the CFIA under directive D-14-02. A registration form (Appendix 1) must be completed to register a facility. Facilities are required to develop a Preventive Control Plan (PCP, previously known as Quality Manual (QM)). Guidelines for development of a PCP can be found in Appendix 2. Before registration is granted, CFIA will verify if the facility meets the requirements of the certification program.

Under the certification program, facilities must describe their operating procedures in detail in their PCP indicating how they will meet the phytosanitary requirements, including all the treatments, as well as other elements such as labelling, traceability and segregation procedures for EU compliant sawn wood.

Facilities currently registered in a CFIA forestry certification program including the Emerald Ash Borer Approved Facility Compliance Program for import under directive D-03-08, or the Heat Treatment (HT) program under directive D-13-01, may amend their PCP to add a module describing the specific procedures used to address the export requirements specified in directive D-14-02.

2.1 Phytosanitary requirements for the export of ash lumber

Export shipments must be accompanied by a CFIA-issued phytosanitary certificate. Shipments of ash wood must meet all of the following elements and processing requirements:

  • ash wood is produced from debarked round wood; and
  • ash wood has been debarked to ISPM 15 tolerance (pieces of bark are less than 3 cm in width (regardless of length) or if they are greater than 3 cm in width, the total surface area of each individual piece of bark is less than 50 cm2); and
  • ash wood is heated through its profile to at least 71 °C for 1200 minutes (20 hours) in a heat chamber approved by the CFIA, or by an agency approved by the CFIA; and
  • ash wood has a final moisture content of 10% or less; and has been in a kiln for at least a 2 week period; and
  • each bundle of wood must visibly display both a bundle number and a label with the words 'HT-KD' or 'Heat Treated-Kiln Dried'. That label must be issued by, or under the supervision of, a designated officer of the registered facility after verifying that the processing requirements set out above have been complied with; and
  • the bundle number(s) and the registered facility name must also be on the phytosanitary certificate; and
  • facilities must undergo a Preventive Control Inspection (PCI, previously known as audit) by the CFIA or an agency approved by the CFIA, once a month ; and
  • facilities must agree to have their information posted on the CFIA's website as per EU requirements .
  • facilities must perform and record pre-audit of shipments to confirm all the requirements have been met. CFIA may also conduct pre-inspection or verify the facilities' reports during a Preventive Control Inspection.

For the re-export of ash wood originating in the U.S., the wood must be processed in a registered facility in Canada or the US and meet all the above conditions. Ash wood imported from the U.S. must meet the import requirements under directive D-03-08.

For the re-export of ash wood processed in a registered facility in the US, re-export certification may be based on:

  • a USDA-APHIS issued phytosanitary certificate with an Additional Declaration as specified in the EU regulation

Or

  • a NHLA (National Hardwood Lumber Association) certificate certifying that the wood meets all the EU requirements. The Inspector must verify the list of registered facilities on the USDA-APHIS website

Refer to directive D-99-06 for processes to receive a phytosanitary certificate or a phytosanitary certificate for re-export or contact your local CFIA Office.

2.2 Phytosanitary requirements for the export of birch lumber

Debarking and cambium/sapwood removal

Export shipments must be accompanied by a CFIA issued phytosanitary certificate.

Shipments of birch wood must meet the following requirements:

  • bark and at least 2.5 cm of outer sapwood has been removed in a facility registered by the CFIA

In order for the CFIA to certify shipments of birch wood originating in the U.S. and issue a phytosanitary certificate for re-export, the wood must be:

  • processed in a registered facility under directive D-14-02 in Canada; or
  • accompanied by a USDA-APHIS-issued phytosanitary certificate certifying the removal of bark and at least 2.5 cm of outer sapwood and with the appropriate additional declaration under Commission Implementing Regulation (EU) 2019/2072.

Refer to directive D-99-06 for processes to receive a phytosanitary certificate or a phytosanitary certificate for re-export, or contact your local CFIA office.

3. CFIA oversight

3.1. Preventive Control Inspections (PCI)

The CFIA or an agency approved by the CFIA will conduct preventive control inspections (PCI: previously known as audits) of facilities participating in directive D-14-02 to determine compliance with the facility's Preventive Control Plan (PCP) and section 2 of this directive.

The CFIA -PCI will be on a quarterly basis for facilities exporting birch lumber, and twice a year for those exporting ash lumber under this Directive.

3.2 Non-compliance

Non-compliant products will not be certified by the CFIA. The exporter may choose to ship the commodity to another destination provided that it complies with the phytosanitary requirements of the receiving country.

Appendix 1: Registration Form for the Certification Program for the Export of Regulated Hardwood Species to the European Union (EU)

Registration form can be found at:

CFIA/ACIA 5745 - Application for Registration under the Certification Program for the Export of Hardwood Species Regulated for Agrilus spp. to the European Union – Policy Directive D-14-02

Appendix 2: Elements that must be identified in the facility's Preventive Control Plan (PCP)

Facilities that intend to ship hardwood lumber of genera regulated under directive D-14-02 (i.e. ash and birch) to the EU must register under this certification program. All elements relevant to meeting EU import requirements must be identified and described in the facility's Preventive Control Plan (PCP) (PCP: previously known as Quality Manual (QM)) to provide assurances to the CFIA that lumber produced under this certification program meets EU import requirements.

The PCP must outline the procedures and processes implemented by a facility to control the phytosanitary risk of pest spread associated with the movement of regulated products.

The PCP must include all of the elements of a facility's operations that relate to pest risk mitigation. Details of these requirements are described below.

A quality management system that follows International Organization for Standardization guidelines or a similar management system may also be approved as a PCP.

1. General requirements

1.1 Facility identification

The PCP must provide the facility name, address, a contact name and information of each facility location where regulated products are received and processed.

1.2 Organization of Preventive Control Plan (PCP)

A table of contents page is required to improve the organization of the PCP.

1.3 Preventive Control Plan modifications

The Facility must have a CFIA-approved and up-to-date copy of the PCP with an assigned version number and date of revision. Subsequent changes must have a new version number and replace previous versions. When the PCP is altered, the updated version must be sent to the CFIA for approval prior to implementation. Where repeated updates are required, an amendment log must be kept to document changes. A copy of the amendment log must be attached to the PCP. Facility employees must be trained and informed of the procedure changes and the changes made to the PCP once they have been approved by the CFIA.

2.0 Administration

2.1 Program Manager

The PCP must identify a Program Manager (PM) (previously named as Certification Manager (CM)) and an alternate to the PM. The PM is the official contact with the CFIA and is responsible for developing the PCP, enacting changes and updates, providing training to employees with roles and responsibilities under the certification program and conducting optional internal audits. The PM will also be responsible for meeting with the CFIA and assigning employee to accompany and assist during preventive control inspections. The PM and the alternate must have expertise in identification of tree genera (logs and lumber). This expertise could be obtained from experience or education and must be described in the PCP (for example, number of years of experience, courses taken, etc.).

2.2 Employee responsibilities

The PCP must identify the employee members responsible for ensuring that the facility meets the export requirements. Position titles and a description of responsibilities in relation to this program must be documented.

3.0 Employee training

The PCP must describe the training procedures of employee responsible for procedures to meet the export requirements. This includes the specific training elements and the intervals between training sessions. The training records must include the names of the employees trained, and the training topics covered. An example of a training record must be appended to the PCP.

Information on the signs and symptoms of Agrilus spp., a copy of the facility's PCP, and this directive (D-14-02) must be accessible to all facility employee that contributes to meeting export requirements.

4.0 Phytosanitary elements (Phytosanitary critical control points)

Phytosanitary elements are mandatory steps where regulated products must be processed in accordance with the certification program. Phytosanitary elements were known before as the phytosanitary critical control points. These may include stages where regulated products are received, segregated, processed and shipped.

Facilities are encouraged to conduct internal audits following critical processing elements (for example, inspection of lumber to ensure bark and wane are removed, or review of charge reports). If the facility does internal audits, the PCP must identify all phytosanitary elements and outline how the facility will conduct the internal audits of the elements to verify that regulated products are processed in accordance with the certification program. The facility could develop a flow diagram to identify elements. Inspection and audit records of these elements must be current and complete.

Employee must fully understand their roles and responsibilities regarding phytosanitary elements.

4.1 Receiving regulated products

The PCP must document how incoming regulated products are identified upon receipt. Procedures may include signing off on incoming shipping documents, and applying unique markings for loads of regulated products. The facility must keep a record/inventory of incoming regulated products.

Import of regulated articles and their domestic movement must be according to directive D-03-08. Facilities must indicate in the PCP how they will meet the import and domestic requirements.

4.2 Segregation

Facilities must have procedures in place to ensure treated lumber destined for the EU is segregated and clearly marked with a unique identifier from lumber destined for domestic movement or export to other countries Segregation methods may include physical barriers such as fencing designating areas identified with specific signage or other identification as described by the facility.

Logs from a Canadian regulated area for EAB coming in for processing must also be segregated where a facility is located in a Canadian area that is not regulated area for EAB.

A site plan may be included with the PCP to identify the location of these specific areas.

4.3 Processing/treatment procedures

Treatment/processing measures to generate compliant products are outlined in section 2.0 of this directive.

The PCP must indicate the processing procedures used to generate compliant regulated products and the procedures used to confirm that the processing conditions are met.

Facilities in Canadian areas that are not regulated for EAB must process all ash material before the end of the low risk season (Before March 31) as per directive D-03-08 to prevent pest spread.

4.4 Traceability of regulated products

Facilities may be required to show the origin of lumber in order to meet the certification requirements to export to some countries. For these specific situations, it is mandatory that procedures be instituted to allow the confirmation of origin. The CFIA may refuse to issue a Phytosanitary Certificate if the origin cannot be confirmed.

Facilities must be able to trace back the bundles of lumber going to the EU throughout the complete chain of processes to make the lumber compliant with the respective option chosen. This includes the traceability of movement of product (within and between facilities/mills) as well as the processing steps between the raw wood, the debarking, the heat treatment, and the kiln drying, as well as the labelling of the final product, as applicable.

4.5 Debarking

The facility must adjust the debarking equipment to remove the required amount of bark whether for meeting the ISPM 15 tolerance or the removal of bark and an additional 2.5 cm of the cambium/sapwood, depending on the option chosen for the export of regulated product. The PCP must describe the audit procedures throughout the process to guarantee debarking meets the EU's phytosanitary requirements for debarking.

If the registered facility is receiving sawn wood from another facility/mill, they must provide proof that lumber was produced from debarked logs as per the ISPM 15 tolerance for bark.

4.6 Heat treatment and kiln drying

Facilities must meet the treatment requirements of at least 71 °C for 1200 minutes (20 hours) through the profile of the wood and a final moisture content of 10% or less.

The PCP must describe the kiln layout, including dimensions, direction of air flow, and location of all sensors and how it meets the kiln verification parameters of PI-07. An example of the charge report, showing the calculations used to confirm that heat treatment requirements are met must also be included in the PCP.

Heat treated lumber to the EU under the systems approach must be segregated from heat treated lumber meeting 56 °C /30 min destined to other markets. Bundles must be marked and given a unique identifier which can be traced back to original material and the associated treatment process (Kiln charge report).

The moisture readings as well as the drying period of at least two weeks must be recorded in a way that can be traced back to the bundles destined to the EU.

If the facility receives heat treated lumber from another HT facility, both must be registered under directive D-14-02 and all copies of the kiln charge reports and the information of the HT facility must be kept for traceability and preventive control inspection purposes.

4.7 Labelling

Each bundle of treated wood must visibly display both a bundle number and a label with the words 'HT-KD' or 'Heat Treated-Kiln Dried' and given a unique identifier for EU eligibility. The label must be issued by, or under the supervision of, a designated officer of the registered facility after verifying that the processing requirements have been complied with.

5.0 Other control activities

Other control activities implemented by the facility that may impact the integrity of the certification program must be included in the PCP.

6.0 Records and documentation

Facilities are required to maintain records that track all activities related to this certification program for a minimum of three (3) years. Examples of these records include incoming shipping documents (requirement for sources of incoming wood destined for export), movement certificates and log journals, audit records for incoming regulated products in non-regulated areas, training records, sales records for regulated products sold, preventive control inspections reports and corrective actions.

Also for the purposes of this program, facilities must keep records of procedures for verification by the CFIA or an agency approved by the CFIA, including the duration of treatment, temperatures during treatment, when parameters of schedule H in PI-07 was achieved and the final moisture content for each specific bundle to be exported.

6.1 Supplier list

Facilities must maintain a list of all suppliers, including U.S. suppliers from where regulated products will be sourced. Changes made to the suppliers list must be documented. Contact your local CFIA office for more information.

6.2 Transportation of non-compliant regulated products

Regulated products must be transported under the conditions outlined in directive D-03-08, Section 2 for domestic movement and Section 3 for imports. The PCP must outline how the facility will meet the requirements for transport of regulated products. If facilities registered in the certification program are issued a Movement Certificate to allow the domestic movement of regulated products, the PCP must indicate the specific procedures and employees responsible for the care and control of theses certificates. Specific information such as the movement certificate number, product, quantity, date of shipment, and origin/destination of shipment, must be maintained for each shipment transported under the authority of the Movement Certificate.

Facilities using their own vehicles to transport non-compliant regulated products outside of a Canadian regulated area must outline the procedures (for example, cleaning of trailer after unloading regulated products) used to control the risk of pest spread.

6.3 Non-compliance

The facility must specify an internal process for addressing and recording non-compliances.

A non-compliance record must include the following information:

  • description of the non-compliance (identification of cause)
  • date of occurrence
  • employees involved
  • corrective actions taken to control and mitigates risks and prevent recurrence
  • deadline for when the corrective action must be completed
  • signature of approval by the Program Manager

An example of the facility's non-compliance record must be included in the PCP.

6.4 Clean-up and disposal of by-products

Facilities in Canadian areas not regulated for EAB that are handling products from Canadian regulated areas for EAB must specify that processing, treatment, clean-up and disposal of regulated products will be completed by March 31, which is the end of the low-risk period. Procedures to contact CFIA once the final clean-up is completed must be outlined in the PCP. Completion of clean-up and disposal activities will be verified by the CFIA.

6.5 Pest notification

Live EAB or signs of EAB damage, may be encountered by facility employee during the processing of regulated products. All facilities must clearly specify in their PCP a commitment to notify the CFIA immediately if EAB in any life stage or signs of EAB, are found on regulated products sourced from Canadian areas not regulated for this pest.

6.6 Audits

Facilities are encouraged to conduct audits on a routine basis. Audits are internal checks that verify all procedures are carried out as outlined in the facilities' PCP. The audits should include an audit of all the phytosanitary elements and should be recorded. If audits are conducted, a copy of the audit log must be included in the PCP.

Audit reports must be made available to the CFIA during preventive control inspections.

7.0 Preventive Control Plan (PCP) review

Prior to registration, a review of the PCP will be conducted by the CFIA to verify that all prescribed elements of this appendix are addressed. If the registered facility changes any of its practices, the PCP must be amended and submitted to the CFIA for review and re-approval.

8.0 Evaluation Inspection

An evaluation Inspection is a systemic examination conducted by the CFIA, to verify that a facility is capable of consistently meeting requirements as outlined in the facility's PCP. Once the CFIA approves the PCP and a facility receives good standing in the Evaluation Inspection, the facility will be registered under the certification program.

9.0 Preventive Control Inspections and reviews

Once registered, a facility will be inspected by the CFIA or by an agency approved by the CFIA, to verify compliance with the facility Preventive Control Plan and section 2 of this directive. Preventive Control Inspections by the CFIA will be on a quarterly basis for facilities exporting under the debarking/cambium removal for birch lumber, or twice a year for those exporting ash lumber.

10.0 Cancellation, reinstatement and voluntary withdrawal

Facilities that are unable to address the necessary corrective actions or have a total failure of their PCP management system will be notified in writing by the CFIA and will be immediately removed from the certification program.

Cancelled facilities will be removed from the CFIA list of registered facilities.

To be reinstated, cancelled facilities must submit a new application and a revised PCP. The facility must also receive a good standing on the evaluation inspection.

Facilities that voluntarily withdraw from the certification program need to provide a written notification to the CFIA.

Individuals or companies that do not comply with the Plant Protection Act and Plant Protection Regulations may be subject to additional actions, including enforcement actions.

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