D-14-02: Hardwood Export Program

Effective date: September 9, 2025 (6th revision)

This directive describes the Canadian 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 2019/2072 of 28 November 2019. It also applies to countries that have adopted similar import requirements such as the United Kingdom (UK) and Türkiye.

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.

Latest revisions

This directive has been renamed and revised to reflect changes in terminology to support the integration of the Hardwood Export Program into the CFIA's digital platform. No changes have been made to the requirements of the program.

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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 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, the UK and Türkiye under the 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

1.1 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)

1.2 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 page.

1.3 Regulated pests

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

1.4 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.

1.5 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 (US) 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 US, therefore all areas of Canada and the US are regulated.

2. Export requirements

Facilities intending to export regulated products originating or processed in Canada, to the EU, the UK or Türkiye must register with the CFIA on the Hardwood Export Program by submitting a service request through their My CFIA account. Facilities are required to develop a preventive control plan (previously known as quality manual). Guidelines for development of a preventive control plan can be found in Appendix 1. Before registration is approved, CFIA will verify if the facility meets the requirements of the program (see section 3 for further information).

My CFIA uses the term "preventive control inspection" in place of "audit" and "terms and conditions" in place of "requirements".

Under the program, facilities must describe their operating procedures in detail in their preventive control plan, 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 compliant sawn wood.

Facilities currently registered in a CFIA forestry program including the emerald ash borer program under directive D-03-08, or the heat treatment program under directive D-13-01, may amend their plan 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 an 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 the importing country's 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 an audit.

For the re-export of ash wood originating in the US, 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 US 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 importing country's regulation

    Or

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

To understand how to receive a phytosanitary certificate or a phytosanitary certificate for re-export:

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 US and issue a phytosanitary certificate for re-export, the wood must be:

  • processed in a registered facility under this program 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 the importing country's regulation.

To understand how to receive a phytosanitary certificate or a phytosanitary certificate for re-export:

2.3 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.

3.0 CFIA oversight

3.1 Audit

The CFIA or an agency approved by the CFIA will conduct audits of facilities participating in the program to determine compliance with the facility's preventive control plan and section 2 of this directive.

The CFIA audit will be on a quarterly basis for facilities exporting birch lumber, and once a month for those exporting ash lumber under the program.

3.1.1 Preventive control plan review

Prior to the approval of a facility's registration, a review of the preventive control plan will be conducted by the CFIA to verify that all prescribed elements of appendix 1 are addressed. If the registered facility changes any of its practices, the preventive control plan must be amended and submitted to the CFIA for review and re-approval.

3.1.2 Authorization audit

Once the CFIA approves the preventive control plan and a facility receives good standing in the authorization audit, the facility's registration will be approved under the program.

3.1.3 Systems audit

Once registration is approved, a facility will be audited by the CFIA or by an agency approved by the CFIA, to verify continued compliance with the facility's preventive control plan and section 2 of this directive.

3.1.4 Suspension, reinstatement, cancellation and voluntary withdrawal

If a facility audit has determined that the registered facility no longer meets the requirements of the program, their registration status will be suspended. The CFIA shall notify the registered facility of the action to be taken and identify the deficiencies that require correction action(s) to be taken.

Once all necessary corrective actions developed by the facility have been implemented and approved by the CFIA, a facility may be reinstated on the program. The facility must re-submit a revised preventive control plan identifying the corrective actions they have taken. The CFIA will conduct a follow up audit at the facility to determine if the corrective actions address the non-conformances.

Facilities that are unable to address the necessary corrective actions or have a total failure of their preventive control plan management system will immediately have their registration on the program cancelled (revoked).

Facilities that voluntarily withdraw from the program or whose registration is cancelled by CFIA, will be removed from the CFIA list of registered facilities.

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.

Appendix 1: Elements that must be identified in the facility preventive control plan

Facilities that intend to ship hardwood lumber of genera regulated under directive D-14-02 (ash and birch) must register under this program. All elements relevant to meeting importing country's requirements must be identified and described in the facility's preventive control plan ( previously known as quality manual) to provide assurances to the CFIA that lumber produced under this program meets importing country's import requirements.

The preventive control plan 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.

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

A phytosanitary management system that follows International Organization for Standardization guidelines or a similar management system may also be approved as a preventive control plan.

1. General requirements

1.1 Facility identification

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

1.2 Organizing the plan

A table of contents page is required to improve the organization of the preventive control plan.

1.3 Modifying the plan

The facility must have a CFIA-approved and up-to-date copy of the preventive control plan with an assigned version number and date of revision. Subsequent changes must have a new version number and replace previous versions. When the preventive control plan 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 preventive control plan. Facility employees must be trained and informed of the procedure changes and the changes made to the preventive control plan once they have been approved by the CFIA.

2.0 Administration

2.1 Program manager

The preventive control plan must identify a program manager (previously named as certification manager) and an alternate to the program manager. The manager is the official contact with the CFIA and is responsible for developing the preventive control plan, enacting changes and updates, providing training to employees with roles and responsibilities under the program and conducting optional internal audits. They will also be responsible for meeting with the CFIA and assigning employee to accompany and assist during audits. The program manager 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 preventive control plan (for example, number of years of experience, courses taken, etc.).

2.2 Employee responsibilities

The preventive control plan 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 preventive control plan 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 preventive control plan.

Information on the signs and symptoms of Agrilus spp., a copy of the facility's preventive control plan, 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 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 preventive control plan 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 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 preventive control plan 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 preventive control plan how they will meet the import and domestic requirements.

4.2 Segregation

Facilities must have procedures in place to ensure treated lumber destined for export under the program 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 emerald ash borer coming in for processing must also be segregated where a facility is located in a Canadian area that is not regulated area for the pest.

A site plan may be included with the preventive control plan 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 preventive control plan 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 emerald ash borer 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 being exported 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 preventive control plan must describe the audit procedures throughout the process to guarantee debarking meets 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 preventive control plan 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 preventive control plan.

Heat treated lumber 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 for export under the program.

If the facility receives heat treated lumber from another heat treatment facility, both must be registered under directive D-14-02 and all copies of the kiln charge reports and the information of the heat treatment facility must be kept for traceability and audit 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 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 program must be included in the preventive control plan.

6.0 Records and documentation

Facilities are required to maintain records that track all activities related to this program for a minimum of 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, audit 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 US 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 preventive control plan must outline how the facility will meet the requirements for transport of regulated products. If facilities registered in the program are issued a movement certificate to allow the domestic movement of regulated products, the preventive control plan must indicate the specific procedures and employees responsible for the care and control of these 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 preventive control plan.

6.4 Clean-up and disposal of by-products

Facilities in Canadian areas not regulated for emerald ash borer that are handling products from Canadian regulated areas for the pest 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 preventive control plan. Completion of clean-up and disposal activities will be verified by the CFIA.

6.5 Pest notification

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

6.6 Internal Audits

Facilities are encouraged to conduct internal audits on a routine basis. Audits are internal checks that verify all procedures are carried out as outlined in the facilities' preventive control plan. 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 preventive control plan.

Audit reports must be made available to the CFIA during audits.

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