D-98-08: Entry Requirements For Wood Packaging Material Into Canada

Effective date: November 10, 2023
10th version

Subject

This directive provides the requirements for the entry into Canada of all wood packaging material (WPM) including dunnage, pallets, or crates from all areas except the continental United States (U.S.).

Revisions

This directive has been revised in January 2023 and in November 2023.

The January 2023 revision included specific import requirements for dunnage entering Canada via marine vessels. Entry of non-compliant dunnage and the presence of live pests in wood packaging material and shipborne dunnage increases risk to Canada's forest and plant resource base. A shipborne dunnage management program has been developed to address this significant risk.

This directive was also revised to reflect the amendments made to the International Standards for Phytosanitary Measures (ISPM) 15 regarding approved treatments associated with wood packaging material, as well as the mark and its application (see Appendix 1). The International Plant Protection Convention (IPPC) and its Commission on Phytosanitary Measures have adopted these revisions in 2018 to provide further guidance to National Plant Protection Organizations (NPPO).

The November 2023 revision addresses questions from industry stakeholders with regards to shipborne dunnage. The use of phytosanitary certificates (section 5) and the scope of the program in relation to marine containers (section 5.2) have been clarified. In addition, the notification process for ships entering Canadian waters with the intent to discharge dunnage has been improved by providing the coordinates of CFIA local offices and a ship notification template (section 5.2.1 and appendix 3). A flow chart summarizing how shipborne dunnage is managed in Canada has also been added (Appendix 9).

This document supersedes all previous versions of directive D-98-08.

On this page

• 1. Legislative authority
• 2. Definitions, abbreviations and acronyms
• 3. Introduction
• 4. Scope
  • 4.1 Regulated pests
  • 4.2 Regulated articles
  • 4.3 Regulated areas
• 5. Phytosanitary entry requirements
  • 5.1 Wood packaging material certification system
  • 5.2 Specific phytosanitary entry requirements for shipborne dunnage
• 6. Shipborne dunnage program
  • 6.1 Permit to Import
  • 6.2 Preventive Control Plan
  • 6.3 Discharge and monitoring
  • 6.4 High and low risk periods
  • 6.5 Storage requirements
  • 6.6 Movement requirements
  • 6.7 Disposal or processing of shipborne dunnage
  • 6.8 Records
• 7. Inspection procedures
  • 7.1 Wood packaging material, excluding shipborne dunnage
  • 7.2 Shipborne dunnage inspection procedures
• 8. Non-compliance
  • 8.1 Wood packaging material, excluding shipborne dunnage
  • 8.2 Shipborne dunnage
• 9. References
  • 9.1 Fees
  • 9.2 Supporting documents
• Appendix 1: Wood Packaging Material requirements for entry into Canada
• Appendix 2: Designated terminals and facilities under the shipborne dunnage program
• Appendix 3: CFIA offices and ship notification template
• Appendix 4: Application for the shipborne dunnage program
• Appendix 5: Shipborne dunnage program: elements of a Preventive Control Plan
• Appendix 6: Permit to Import conditions for the shipborne dunnage program
• Appendix 7: High and low risk periods impacts on the shipborne dunnage program
• Appendix 8: Approved disposal methods
• Appendix 9: Shipborne dunnage flowchart

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 I (as amended from time to time)

2. Definitions, abbreviations and acronyms

Definitions for terms used in the present document can be found in the International Standard for Phytosanitary Measures 5 (ISPM 5): Glossary of phytosanitary terms or in the Canadian Food Inspection Agency (CFIA) Plant Health Glossary of Terms.

3. Introduction

The risk represented by wood packaging material and dunnage varies depending on the quality, conditioning, and degree of finishing of the wood. Many exotic plant pests have been intercepted on wood dunnage, pallets, crates, or other wood packaging material in North America. Examples of plant quarantine pests intercepted include: citrus long-horned beetle (Anoplophora chinensis), Asian long-horned beetle (Anoplophora glabripennis), European spruce bark beetle (Ips typographus), black pine bark beetle (Hylastes ater), velvet long-horned beetle (Trichoferus campestris), Monochamus sp., and others. The introduction into parts of North America of the Asian longhorned beetle (Anoplophora glabripennis), brown spruce longhorn beetle (Tetropium fuscum), emerald ash borer (Agrilus planipennis), and other exotic pests can now be linked to international shipments containing wood packaging material.

In 2009, the Commission on Phytosanitary Measures of the International Plant Protection Convention adopted a standard prescribing uniform regulatory control of wood packaging material moving in international commerce. This standard titled: "ISPM 15, Regulation of Wood Packaging Material in International Trade (PDF)" recognizes the inherent pest risks associated with the international movement of untreated wood packaging material. Although this standard does not obligate countries to establish regulatory controls, the guideline represents a mechanism by which any country may establish regulatory controls in a manner that is internationally harmonized. This Canadian import directive reflects the guidelines established in ISPM 15 as updated in 2018.

In order to mitigate the risk of pests associated with non-compliant dunnage, the CFIA has established a new shipborne dunnage program providing specific requirements for the safe discharge and disposal of shipborne dunnage in all ports of Canada.

4. Scope

4.1 Regulated pests

Numerous pests regulated by Canada could be associated with wood packaging material, including shipborne dunnage. Insects are the most commonly detected pests, but fungi and bacteria can also be associated with imported material. The list of pests regulated by Canada can be found on the CFIA website.

4.2 Regulated articles

Wood packaging material (WPM) constructed from wood of any plant species not meeting the exemptions listed in section 4.2.1.

This includes, but is not limited to, dunnage, pallets, spacers, bearers, crates, and wood bracing not permanently attached to freight vehicles or containers (for example: flat rack and flatbed containers).

Note: WPM used for the transport of logs and lumber is also regulated by this policy.

4.2.1 Commodities that are exempt from phytosanitary import requirements

The following articles are considered to be a low risk and are exempt from the requirements of this directive:

• wood packaging material made entirely from thin wood of 6 mm or less in thickness
• wood packaging material made entirely from processed wood such as plywood, particle board, oriented strand board, or veneer that has been created using glue, heat, pressure, or any combination thereof
• wood shavings, sawdust, and wood wool used to stabilize a commodity
• gift boxes for wine, cigars and other commodities made from wood that has been processed and/or manufactured in a way that renders it free of pests barrels for wine and spirits that have been heated during manufacturing
  Note: not all barrels are exempt. The requirements for the importation of decorative wood barrels are provided in directive D-02-12
• wood components permanently attached to freight vehicles and containers
• WPM coming directly from the continental U.S., including dunnage, made entirely of continental U.S. origin wood or Canadian origin wood in trade between the 2 countries is exempt from the treatment and marking requirements (section 5)

Note: information on the implementation of ISPM No. 15 (2009) for wood packaging moving between Canada and the United States is maintained on the CFIA website.

4.3 Regulated areas

All countries excluding the continental United States (U.S.).

5. Phytosanitary entry requirements

To be admissible into Canada, including movement in-transit through Canada, all wood packaging material (WPM), including dunnage, must:

• be constructed with debarked wood; and
• be treated using 1 of the approved methods listed in Appendix 1; and
• bear an IPPC mark that meets the requirements as specified in Appendix 1

A phytosanitary certificate is not required, but may be used in lieu of the marking system prescribed below. Phytosanitary certificates must specify all applicable treatment details in the treatment section. If heat treatment was applied, an additional declaration must confirm each piece of wood has attained a minimum temperature of 56 degrees Celsius throughout the profile of the wood (including at its core) for a minimum of 30 minutes.

In certain cases, it is industry practice to cut pieces of dunnage to accommodate for the size and shape of the commodity they are supporting. Such pieces may no longer bear the ISPM 15 mark and may not be recognized as compliant by the CFIA. Consequently, a phytosanitary certificate may also be issued by the exporting country's NPPO to confirm that pieces of WPM showing no ISPM-15 mark in a shipment were cut from properly treated and marked pieces. Otherwise dunnage pieces with no ISPM 15 mark may be considered non-compliant.

Important note: the phytosanitary certificate must provide a clear link to the WPM or dunnage being imported (or discharged). Where this linkage cannot be made, the WPM or dunnage may be considered non-compliant.

A Permit to Import is not required, except for shipborne dunnage (see section 5.2).

Note: by way of bilateral arrangement, a phytosanitary certificate is not accepted for the entry of wood packaging material originating from the People's Republic of China.

5.1 Wood packaging material certification system

The NPPO of the country from which the wood packaging material originates must have a certification system in place for the approval and monitoring of facilities producing wood packaging material to meet ISPM 15.

This certification system must ensure that the wood packaging material or wood used in the repair or remanufacture of wood packaging material is in accordance with 1 of the methods specified in Appendix 1.

Facilities must be approved by the NPPO to affix a mark to the treated wood packaging material. The system of marking must conform to the specifications laid out in Appendix 1.

Many countries have indicated that they have systems in place to meet Canada's import requirements. Click here for more information about the implementation of ISPM 15 in other countries.

The requirements for treatment and marking of wood packaging material that is reused, repaired or remanufactured are described in section 4.3 of ISPM 15. Please consult the IPPC website for up to date information.

5.2 Specific phytosanitary entry requirements for shipborne dunnage

Shipborne dunnage must meet the entry requirements as specified in section 5 above. Additionally, shipborne dunnage is only permitted to be discharged^{Footnote 1} at a port terminal that is designated through registration in the shipborne dunnage program, further described in section 6. The port terminals that are designated are listed in Appendix 2.

Wood packaging material that remains associated with the imported commodity after being discharged in Canada is considered to be WPM whereas any WPM that is separated from the commodity at the port of entry is considered to be shipborne dunnage.^{Footnote 4}

Note: as per section 4.2.1, shipborne dunnage made entirely of continental U.S. origin wood or Canadian origin wood coming directly from the continental U.S. is exempted from the entry requirements, including discharge under the shipborne dunnage program.

5.2.1 Notification requirements for vessels planning to discharge shipborne dunnage in Canada

The vessel owner is responsible for ensuring, where a marine vessel intends to discharge dunnage in Canada, that a notification is made to the CFIA office (as listed in Appendix 3) closest to the discharge port at least 96 hours prior to the vessel's arrival in Canadian waters.

At the time of notification, the following information must be provided to the CFIA, either directly, via the vessel's Canadian agent, or any other means:

• name of the vessel and name of the owner of the vessel (a copy of the ship's particulars can be provided)
• name of the shipping agent in Canada
• destination port, including terminal where applicable, in Canada
• estimated dates of discharge of the dunnage
• country of origin of the dunnage (could be unknown) and cargo
• copy, if applicable, of any phytosanitary certificate associated with dunnage to be discharged

The representatives of marine vessels may use the template provided in appendix 3 to notify the CFIA of the above information. The template is not mandatory and is meant to aid with communication of the required information. Any other format may be used, provided that all required information is communicated.

6. Shipborne dunnage program

The shipborne dunnage program allows port terminals in Canada to accept the discharge of shipborne dunnage at their facility, as per section 5.2. A Permit to Import is required.

Fees for inspection and movement authorization will be charged as per the Plant Protection Fees schedule.

Appendix 9 provides a flowchart on how shipborne dunnage is managed in Canada.

6.1 Permit to Import

Any Canadian individual or corporation willing to take care or control of dunnage to be discharged at any given Canadian port terminal can apply for a Permit to Import under the shipborne dunnage program.

Applicants^{Footnote 2} must apply for and receive a Permit to Import prior to shipborne dunnage being discharged at the corresponding port terminal(s). Details on the Permit to Import application process are available on the CFIA website.

Applicants must also complete an application for the shipborne dunnage program (Appendix 4).

The shipborne dunnage program process is initiated when an application for a Permit to Import is submitted to the CFIA. The nearest local CFIA office will contact the applicant to complete the registration process.

The Permit to Import will be issued once the CFIA has approved the Preventive Control Plan (PCP) and the facility has passed an evaluation inspection, as described in section 7.2.1. The local CFIA office must authorize the application for the shipborne dunnage (Appendix 4) to confirm approval.

A list of designated port terminals approved to manage shipborne dunnage is provided in Appendix 2.

6.2 Preventive Control Plan

As part of the Permit to Import issuance process, the applicant must develop, implement, and maintain a PCP as described in Appendix 5 of this directive. The PCP must be submitted to the CFIA local office (see Appendix 3) for review and approval.

The PCP is a written document that describes the system-based approach developed and implemented by the applicant to ensure that risks associated with shipborne dunnage are mitigated. The PCP must include processes for receiving, inspecting, segregating, storing, moving, and ultimately disposing or processing of shipborne dunnage. Traceability must be addressed and detailed at each step. The PCP must include details on how employees responsible for work in the shipborne dunnage program are trained, as well as how the effectiveness of training is monitored, and a record of training that is delivered.

The PCP must include a procedure for amendments that describes how and when the CFIA will be informed of changes to the manual that affect the integrity of the plan. Minor editorial changes (for example: typos) do not need to be communicated to CFIA.

The specific import conditions will be outlined on the Permit to Import as per Appendix 6.

6.3 Discharge and monitoring

6.3.1 Visual monitoring and reporting

Shipborne dunnage must be visually monitored by designated terminal staff to identify materials that do not meet the entry requirements as described in section 5. Dunnage that

• is missing the ISPM 15 mark (as per Appendix 1 ), unless a valid phytosanitary certificate was provided; or
• has bark above the acceptable threshold (as per Appendix 1 ); or
• is found to have live pests or signs of live pests, such as frass
• does not meet entry requirements and is considered to be non-compliant

The PCP must describe how the dunnage will be visually monitored by trained staff during the discharge process. If shipborne dunnage not meeting entry requirements is found, the designated terminal must notify the CFIA local office. The CFIA will determine if a commodity inspection is required. If an inspection is required, the shipborne dunnage not meeting entry requirements must be:

• presented in a manner that will allow for safe and efficient inspection by the CFIA; and
• identified and kept segregated from dunnage discharged from other vessels, if applicable

Shipborne dunnage not meeting entry requirements will be disposed of according to the designated terminal's PCP, or as otherwise specified by the CFIA inspector.

6.3.2 Live pests or signs of live pests detected

Where live pests or signs of live pests are found in association with shipborne dunnage, notification must be made immediately to the CFIA local office (see Appendix 3). The PCP must specify the control measures that will be immediately taken to avoid the escape or movement of injurious pests from the dunnage already discharged and from any dunnage still remaining on the vessel. Infested dunnage, including dunnage and associated goods still in the holds, may be ordered to be treated prior to movement or disposal. The PCP must specify how the designated terminal will respond to the detection of a live pest.

Note: a vessel may be ordered to be removed from Canada or refused entry in Canada if it is infested or suspected to be infested with live pests.

6.4 High and low risk periods

For the revision of this directive, the CFIA examined an expansive list of insects and pathogens relevant to Canada to address the risks associated with shipborne dunnage and to determine risk periods and other factors that may impact risk. Although opportunities to establish and spread exist year-round for most pests, the winter months are the lowest-risk period in all regions of Canada. Cold temperatures minimize the spread and growth of most insects, vectors, or pathogens associated with dunnage. During the warmer months, the risk of establishment and spread of pests is much higher and that risk increases with time of exposure. Combined with practical and operational considerations, this analysis has resulted in the introduction of high and low risk periods to all ports of Canada.

The high risk periods are as below:

• March 1 to November 15 for British Columbia ports
• March 15 to October 31 for other ports of Canada

The low risk period occurs outside the dates specified above. Storage (section 6.5), movement (section 6.6), and disposal / processing requirements (section 6.7) are dependant on the time of the year and location of the designated terminal. Appendix 7 summarizes the impact of high and low risk periods on the shipborne dunnage program.

6.5 Storage requirements

6.5.1 General requirements

The PCP must describe where and how discharged dunnage will be stored. All discharged dunnage must be identified and segregated from any other kind of wood material. Any wood material with unknown identity or that has been co-mingled with dunnage is considered to be dunnage and must be handled as such.

6.5.2 Specific requirements for high risk period

During the high risk period, the PCP must describe how dunnage will be secured to prevent the escape of pests during and after the discharge process. If the storage container is to be opened or accessed at any time at the designated terminal, the PCP must describe the mitigation measures that will be taken to prevent the escape of pests.

Shipborne dunnage must be transported to a disposal or processing facility within 72 hours of completion of discharge.

6.5.3 Specific requirements for low risk period

During the low risk period and unless otherwise ordered by a CFIA inspector, discharged dunnage does not need to be secured and can be stored with no limitation of time, provided it is completely disposed of or processed prior to the end of the low risk period. It is permitted to store dunnage in another place than the designated terminal, as long as this is described in the PCP (see section 6.6.3).

6.5.4 Specific requirements for temporary storage facility

During the low risk period, it is possible to store shipborne dunnage in a temporary location. The PCP must specify the temporary location and how the facility will ensure the care and control of the dunnage during storage. Shipborne dunnage must be identified and kept segregated from any other kind of wood material and must be stored so as to avoid any loss of material. The facility must retain records of stored dunnage and the dunnage must be entirely disposed of before the end of the low risk period.

During the high risk period, storage of shipborne dunnage in a temporary location is not permitted.

6.6 Movement requirements

6.6.1 General movement requirements

The movement of shipborne dunnage is not permitted without prior written approval of the CFIA local office (see Appendix 3 for a list of CFIA offices). The dunnage may only be transported following the issuance of a movement certificate (or other document as determined by the CFIA) and under the specified conditions.

The PCP must describe how the dunnage will be transported during low and high risk periods. All shipborne dunnage must be identified and kept segregated from any other wood material at all times. Any other kind of wood material that is unidentified or has been co-mingled with shipborne dunnage must be disposed of or processed in the same manner as the shipborne dunnage.

A designated terminal may include a third party contractor for the transport of dunnage in their PCP. The contractor will be subject to evaluation and inspection by the CFIA as part of the designated terminal PCP assessment.

6.6.2 Designated transport company

A third party contractor can be recognized as a "designated transport company" by submitting an application form as per Appendix 4 to the CFIA local office with all required information. A PCP covering transport requirements must also be submitted to the CFIA local office for review and approval. Designated transport companies will be inspected as per section 7.2.1.

Designated terminals must refer to the designated transport company's PCP to cover movements in their own PCP.

6.6.3 Requirements for movement to a disposal or processing facility

The dunnage must be transported directly to the site where disposal or processing is going to occur.

During the high risk period, shipborne dunnage must be transported in such a manner so as to avoid any pest escape during transport. During the low risk period, shipborne dunnage must be covered so as to prevent the loss of material during transport.

The PCP must describe how the transporter will prevent the escape of pests in the event of an accident or other extraordinary incident during the transport of the container from the designated terminal to the disposal or processing destination.

6.6.4 Requirements for movement to another designated terminal

Shipborne dunnage discharged in a designated terminal may be moved to another designated terminal to be further managed under the provision of the shipborne dunnage program. Dunnage must be identified and its location known and recorded.

During the high risk period, shipborne dunnage to be transported must be secured in a manner to prevent pest escape at all times. During the low risk period, shipborne dunnage must be covered so as to avoid any loss of material during transport.

Shipborne dunnage that has had live pests or signs of live pests detected must not be moved until mitigation measures have been taken.

The PCP of both designated terminals must describe how the dunnage will be stored at the destination terminal prior to disposal or processing (within 72 hours after completion of discharge).

6.7 Disposal or processing of shipborne dunnage

6.7.1 General requirements for disposal or processing

Discharged dunnage must be disposed of or processed in a manner as described in Appendix 8.

The disposal or processing facility must be capable of disposal or processing shipborne dunnage in a manner that prevents the introduction and spread of pests into Canada.

All shipborne dunnage must be identified and kept segregated from any other wood material at all times. Any other kind of wood material that is unidentified or has been co-mingled with shipborne dunnage must be disposed of or processed in the same manner as the shipborne dunnage.

Designated terminals using a designated disposal or processing facility must refer to the designated disposal or processing facility's PCP to cover that section in their PCP (a list of designated disposal facilities can be found in Appendix 2). Otherwise, all required information about disposal or processing need to be included in their own PCP.

Disposal or processing facilities will be inspected as per section 7.2.1.

During the high risk period

Shipborne dunnage must be stored in such a manner as to prevent any pest escape until the time it is disposed of or processed. The time limit for storage should not exceed 2 days (48 hours) following receipt of the dunnage at the disposal or processing facility.

During the low risk period

Shipborne dunnage must be completely disposed of or processed before the end of the low risk period.

6.7.2 Designated disposal facility

Facilities that intend to dispose or process shipborne dunnage can be recognized as a "designated disposal or processing facility" by submitting an application form as per Appendix 4 to the CFIA local office. In addition, a PCP covering disposition or processing must be submitted to the CFIA local office for review and approval.

6.7.3 Requirements for dunnage reused as dunnage

During the high risk period shipborne dunnage discharged in Canada as per section 5.2 cannot be reused as dunnage.

During the low risk period reuse is possible provided:

• the dunnage has been visually monitored by the designated terminal as per section 6.3.1, and
• the dunnage is in compliance with section 5, and
• the vessel leaves Canada (Canadian waters) prior to the end of the low risk period

The PCP must describe how the designated facility will ensure that the conveyance with reused dunnage onboard will leave Canada prior to the high risk period.

6.8 Records

The PCP must detail all receiving, visual monitoring, and shipping records, along with any other documents that directly pertain to the shipborne dunnage program. Records must be maintained by the designated facility for a period of 2 years, and must be provided to a CFIA inspector upon request.

7. Inspection procedures

7.1 Wood packaging material, excluding shipborne dunnage

Inspection of WPM may be done at the point of entry by the Canadian Border Services Agency (CBSA), or at other locations by the CFIA. This inspection may be done separately or in conjunction with the import of other regulated commodities.

The inspection will verify:

• that required IPPC marks are applied or appropriate certification has been provided
• that wood is debarked
• that the WPM is free from the presence of live pests or signs of live pests (such as frass)

7.2 Shipborne dunnage inspection procedures

Shipborne dunnage may be subject to inspection by the CBSA or the CFIA. The purpose of the inspection is to verify:

• that shipborne dunnage is only discharged in terminals that are covered by valid import permits issued under the shipborne dunnage program
• effective implementation of the shipborne dunnage program
• that required marks are applied or appropriate certification has been provided
• that wood is debarked
• that the dunnage is free from the presence of live pests or signs of live pests (such as frass)

7.2.1 Shipborne dunnage program

Initial evaluation

CFIA inspectors will evaluate the PCP submitted by facilities applying to be a designated terminal, transporter or disposal/processing facility and will conduct an evaluation preventive control inspection (PCI) to assess that the facility can implement the steps as described in their PCP.

Program delivery

CFIA inspectors will conduct surveillance PCI in designated terminals to assess adherence to the PCP during discharge of shipborne dunnage at least 2 times per year, with at least 1 being performed during high risk period. The inspection frequency may be increased if deemed necessary by the inspector. Designated transport companies and designated processing/disposal facilities are subject to the same inspection frequency. At least 1 surveillance PCI will be scheduled at the beginning of the high risk period to assess the proper transition from the low risk period.

CFIA inspectors will perform an evaluation PCI once a year to assess the facility's adherence to the conditions of the Permit to Import and their PCP as written. Designated transport companies and designated processing/disposal facilities will also be inspected for the same purpose. This inspection will review the whole PCP.

When a designated terminal reports non-compliant dunnage, the dunnage will be subject to inspection by the CFIA or CBSA.

7.2.2 Commodity inspection of dunnage

As per section 5.2, shipborne dunnage is only permitted to be discharged in Canada under the authority of a Permit to Import and approval in the shipborne dunnage program and must be disposed of or processed. On an exceptional basis, the discharge of shipborne dunnage at a port terminal where the shipborne dunnage program has not been put in place may be permitted upon prior written approval, provided an inspection is delivered by a CFIA or CBSA inspector and found compliant with entry requirements (section 5).

Requirements:

• rationale for the exemption must be provided
• dunnage must be a small proportion of the shipment
  Whole vessel loads will not be inspected under this option

The designated terminal (or other responsible party) must also:

• submit a request for inspection to the CFIA local office at least 72 hours (3 days) in advance
• present the dunnage in a safe manner that allows a thorough and efficient inspection
• ensure that the inspection occurs immediately after discharge
• ensure that each dunnage piece can be inspected

The CFIA may approve the request if all of the above conditions are met and operational capacity allows for the inspection.

If the shipborne dunnage meets entry requirements, written authorisation will be issued. Fees for inspection and movement authorization will be charged as per the Plant Protection Fees schedule.

8. Non-compliance

The CFIA will follow the Compliance and Enforcement Policy when informing regulated parties, assessing and monitoring compliance, and responding to instances of non-compliance. Any costs incurred due to non-compliance or violation (disposition, removal, etc.) will be the responsibility of the owner, importer, or the person having possession, care, or control of the thing.

Notifications of non-compliance will be issued in accordance with D-01-06: Canadian Phytosanitary Policy for the Notification of Non-compliance and Emergency Action.

8.1 Wood packaging material, excluding shipborne dunnage

WPM that does not meet entry requirements as per section 5 is considered to be non-compliant. Where the CBSA finds non-compliant WPM at the time of entry into Canada, the guidelines as specified in sections 41-50 of D19-1-1 will be followed. Where the CFIA finds non-compliant WPM, the material may be ordered treated prior to disposal or removal from Canada.

8.2 Shipborne dunnage

8.2.1 Discharge of dunnage in Canada

Dunnage discharged into Canada that does not comply with the phytosanitary requirements as listed in section 5 , or dunnage discharged in ports, terminals, or locations that are not designated under the shipborne dunnage program are considered to be violations of section 7 of the Plant Protection Act.

Violations of the Plant Protection Act are subject to compliance and enforcement controls, including monetary penalties. Dependant on the type of violation, the owner of the vessel, the agent, or any other individual or corporation may be identified as the responsible party.

Non-compliant dunnage may be ordered treated prior to discharge, disposal or removal from Canada.

8.2.2 Shipborne dunnage program

Designated terminals found not to be in compliance with any 1 of the conditions set out in their Permit to Import or the Plant Protection Act andregulations may have their Permit to Import cancelled.

Designated terminals, transporters and disposal/processing facilities may be removed from the program if found not to be in compliance with any 1 of the conditions set out in the shipborne dunnage program or the Plant Protection Act and regulations.

Violations of the Plant Protection Act are subject to compliance and enforcement controls, including monetary penalties.

9. References

9.1 Fees

The CFIA charges fees in accordance with the Canadian Food Inspection Agency Fees Notice, including for inspections associated with the shipborne dunnage program. Fees may also be collected by the CBSA on behalf of the CFIA. For information regarding fees associated with inspection and movement of regulated articles, please contact a local CFIA office or visit the Fees Notice web page.

9.2 Supporting documents

• IPPC secretariat. 2018. Regulation of Wood Packaging Material in International Trade (2009) with modifications to Annex 1 and 2 (2018) – (PDF). International Standard for Phytosanitary Measures No. 15. Rome. Food and Agriculture Organization (FAO) on behalf of the Secretariat of the International Plant Protection Convention.
• IPPC Secretariat. 2021. Glossary of phytosanitary terms. International Standard for Phytosanitary Measures No. 5. Rome. FAO on behalf of the Secretariat of the International Plant Protection Convention.
• Canadian Food Inspection Agency. Plant health glossary of terms. Ottawa.
• Canadian Food Inspection Agency. 2017. D-02-12, Phytosanitary Import requirements for non-processed wood and other wooden products, bamboo and bamboo products originating from all areas other than the continental United States. Ottawa.
• Canadian Food Inspection Agency. 2015. D-13-01: Canadian Heat Treated Wood Products Certification Program (HT Program). Ottawa.
• Canadian Border Service Agency. 2019. Memorandum D19-1-1 (Food, plants, animal and related products). Ottawa.

Note: the requirements for the importation of forest products other than wood packaging material and dunnage (including lumber, decorative wood items, etc.) are provided in directive D-02-12.

Appendix 1: Wood Packaging Material requirements for entry into Canada

Use of debarked wood

Irrespective of the type of treatment applied, wood packaging material, including dunnage, must be made of debarked wood. For the purpose of this directive, any number of visually separate and clearly distinct small pieces of bark may remain on debarked wood if they are:

• less than 3 cm in width (regardless of the length); or
• greater than 3 cm in width, with the total surface area of an individual piece of bark less than 50 square cm

Approved methods of treatment

Accepted treatments are those listed in annex 1 of IPSM 15. At the time of publication of this directive, accepted treatments were as below. Please refer to annex 1 of ISPM 15 for details regarding these treatments.

• Heat treatment using a conventional steam or heat chamber
• Heat treatment using a dielectric heating
• Fumigation using methyl bromide
• Fumigation using sulphuryl fluoride

Treatments cannot be inspected directly, but can be assessed by verifying the IPPC mark and if no live pests or signs of live pests (such as frass) can be detected.

Marking of treated wood packaging material

Wood packaging material that has been treated by 1 of the methods specified above and in a manner that is officially endorsed by the NPPO of the country from which the wood packaging material originates may be permitted entry into Canada provided the wood packaging material is marked as per annex 2 of ISPM 15. Examples of acceptable marks are provided in figure 1.

• The mark must at minimum include:
  the IPPC symbol for treated wood packaging material (as per annex 2 of the "International Standard for Phytosanitary Measures No. 15, (2009) Regulation of Wood Packaging Material in International Trade") as reproduced here.
  • the design of the symbol must be presented to the left of the other components
  • the country code (XX)
    The country code must be the International Organization for Standardization (ISO) two-letter country code for the country in which the wood packaging material is produced. It must be separated by a hyphen from the producer/treatment provider code.
  • the producer/treatment provider code (000)
    The producer/treatment provider code is a unique code assigned by the NPPO to the producer of the wood packaging material or the treatment provider who applies the marks or the entity otherwise responsible to the NPPO for ensuring that appropriately treated wood is used and properly marked. The number and order of digits and/or letters are assigned by the NPPO.
  • the treatment code (YY)
    The treatment code is an IPPC abbreviation for the approved measure used (HT = heat treatment, DH = dielectric heating, MB = methyl bromide fumigation and SF = sulphuryl fluoride fumigation). The treatment code must appear after the combined country and producer/treatment provider codes. It must appear on a separate line from the country code and producer/treatment provider code, or be separated by a hyphen if presented on the same line as the other codes.
• Other information
  Other information (for example: control numbers) may also be included provided it is not confusing, misleading, or deceptive. Such information may be provided adjacent to but outside of the border of the mark.
• The mark must be:
  • legible (illegible marks are considered non-compliant)
  • durable and not transferable (tags are not allowed)
  • rectangular or square in shape and contained within a border line with a vertical line separating the symbol from the code components
  • placed in a location that is visible when the wood packaging material is in use, preferably on at least 2 opposite sides of the wood packaging unit
  • the mark must not be hand drawn
• • Dunnage pieces cut before use
  • Special consideration of legible application of the mark to dunnage may be necessary because treated wood for use as dunnage may not be cut to final length until loading of a conveyance takes place. It is important that shippers ensure that all dunnage used to secure or support commodities is treated and displays the mark described in this appendix, and that the marks are clear and legible. Small pieces of wood that do not include all the required elements of the mark should not be used for dunnage.
  • Options for marking dunnage appropriately include:
    • application of the mark to pieces of wood intended for use as dunnage along their entire length at very short intervals (Note: where very small pieces are subsequently cut for use as dunnage, the cuts should be made so that an entire mark is present on the dunnage used)
    • additional application of the mark to treated dunnage in a visible location after cutting, provided that the shipper is authorized in accordance with section 4 of ISPM 15

Figure 1. Examples of acceptable variants of the required components of the mark

Appendix 2: Designated terminals and facilities under the shipborne dunnage program

The following lists include all CFIA-approved terminals and facilities certified under the shipborne dunnage program.

List of designated terminals

Discharge of shipborne dunnage in Canada is only permitted in designated terminals as per their respective PCP. It is not permitted to discharge shipborne dunnage anywhere else in Canada.

List of designated transport companies

Designated transport companies are permitted to move shipborne dunnage from one location in Canada to another, as per their respective PCP.

List of designated disposal facilities

Designated disposal facilities are permitted to dispose of or process shipborne dunnage as per their respective PCP.

Appendix 3: CFIA offices and ship notification template

Contact a local CFIA office

You can contact a local CFIA office by telephone or by email.

Ship notification template

Download the ship notification template (PDF – 403 kb)

Marine vessels representative may use this template for notification as per section 5.2.1.

Notify the CFIA of an upcoming ship dunnage discharge by sending the following information by email to your local port's CFIA office:

• Agency name:
• Agency address:
• Contact person:
  • Telephone:
  • E-mail:
• Name of vessel:
• Call letters of vessel:
• Owner of the ship:
• Planned dunnage discharge date:
• Location of discharge of dunnage:
  • Port:
  • Terminal:
• Description and origin of cargo:
• Country of origin of dunnage:
• Phytosanitary certificate, if applicable (as a file attachment)

Ensure the above information is accurate to the best of your knowledge.

Appendix 4: Application for the shipborne dunnage program

Printable PDF – 223 kb

Appendix 5: Shipborne dunnage program: elements of a Preventive Control Plan

Whether a designated terminal, a designated transport facility or a designated disposal/processing facility, each facility involved in the shipborne dunnage program must include in its PCP any following elements that are applicable. Annex B of the Integrated Agency Inspection Model has been used to provide this guide and can be consulted for more details.

Element 1: Process control

Import control

The PCP must describe the control measures used by the designated facility to verify that discharged dunnage meets ISPM 15 requirements and CFIA's import requirements.

Product control

Designated terminals, transporters and disposal/processing facilities must describe how the dunnage will be processed to mitigate the risk of the spread of pests.

Element 2: Biosecurity control

Disposal or processing of shipborne dunnage

The PCP must indicate how the discharged shipborne dunnage will be disposed of or processed as per section 6.7. If procedures vary from high to low risk period, the PCP must explain the differences and how the transition is made.

Designated disposal or processing facilities must submit their own PCP describing all aspects of the disposal or processing procedure. All designated port terminals where shipborne dunnage is received from must be listed in the PCP. If procedures vary from 1 terminal of origin to another, the PCP must explain what are the differences and how these differences are operated.

Designated terminals that use another designated facility for the disposal or processing of shipborne dunnage must reference the PCP of the designated facility in the disposal section of their own PCP. How the facilities will communicate with each other must be described in both PCPs.

Element 3: Employee training

All employees who are involved in the shipborne dunnage program must be trained in the delivery of this program and the content of the PCP they must apply to fulfill their respective responsibilities.

The PCP must indicate:

• the training material that is provided to the employees
• how the effectiveness of the training is monitored, verified, and maintained for all employees involved
• record of employees that have received training

Element 4: Equipment design and maintenance

The PCP must detail the type of equipment used to store, move or dispose/process the dunnage. Equipment must be maintained so as to meet requirements outlined in the shipborne dunnage program.

Element 6: Receiving, transportation, and storage

Receipt, inspection and storage of shipborne dunnage

The PCP must indicate how shipborne dunnage will be discharged and visually monitored as per section 6.3, as well as where and how it will be stored and secured as per section 6.5. The use of plans is suggested. Traceability and segregation^{Footnote 3} procedures must be detailed. Where procedures vary from high to low risk period, the PCP must explain the differences and how the transition is managed.

Transport of shipborne dunnage

The PCP must cover the transport of dunnage from the loading of the stored dunnage on the transport vehicle to the unloading of the shipment at destination. The PCP must indicate how this will be done as per section 6.6 and must include a contingency plan to prevent the escape of pests in the event of an accident. If procedures vary from high to low risk period, the PCP must explain the differences and how the transition is operated.

Movement to other countries, to other certified terminals or to disposal/processing facilities must be detailed in separate sections.

Where not covered by a designated terminal, transport companies must submit their own PCP covering all aspects of the transport procedure. If a designated company is transporting shipborne dunnage for more than 1 port terminal, each terminal should be covered in a separate section. Terminals using a designated company for the transport of shipborne dunnage can refer to the PCP of the designated company in the transport section of their own PCP. How the facilities will communicate with each other must be described in both PCPs.

Element 7: Traceability and control

Traceability

The facility has to include how each occurrence of discharge of dunnage is traced at each step of the process in the PCP.

Control

The PCP must describe how the facility will respond to a pest detection as per section 6.3.

Verification procedures

The PCP must detail an internal verification procedure to ensure that the measures included in the PCP are followed. The PCP must identify a responsible person to conduct the verification and verification frequency.

The PCP must also describe what steps will be taken following a deviation from the PCP: correcting the situation, determining the cause, and preventing reoccurrence.

Records

Records are evidence that the facility has implemented the preventive controls and that they are effective to meet the phytosanitary requirements. The facility must make them available for review by the CFIA.

The facility will need to identify records and documents associated with each element, and retain them for a period of 2 years. Some examples may include:

• records of discharged dunnage in port terminals
• records of shipborne dunnage visual monitoring
• transport/shipping records
• receiving records
• records of disposal/processing
• training records
• domestic movement certificates and Permit to Import
• verification of procedures
• deviations and corrective actions taken

Amendment procedure for the PCP

The PCP should be reviewed on an ongoing basis by the facility staff to ensure that it properly details the procedures and processes in place, and that it effectively addresses the risk associated with shipborne dunnage. Minor changes to the PCP may be done at any time, major changes to the PCP that impact the integrity of the program must be submitted to the CFIA for review and approval prior to implementation.

The PCP must have an amendment record.

Appendix 6: Permit to Import conditions for the shipborne dunnage program

Important note: this appendix is provided for informational purposes only. Conditions outlined in the permits to import may differ.

Destinations

(Permits can combine more than 1 terminal of the same port, but cannot combine terminals from different ports.)

Selected conditions

Shipborne dunnage (all species)

• The phytosanitary certificate is not required

Additional conditions

Shipborne dunnage (all species)

• The import permit holder must have a PCP that is approved by the CFIA
• The PCP must be implemented prior to the discharge of shipborne dunnage
• The import permit holder must meet all the requirements as outlined in the D-98-08 and must follow its CFIA-approved PCP at all times
• The import permit holder must verify that all shipborne dunnage discharged at their facility is marked according to ISPM 15 requirements, made of debarked wood, and does not contain any live pests or signs of live pests
• The import permit holder must report incidences of non-compliant shipborne dunnage to the CFIA immediately
• The import permit holder must immediately implement their specified control measures as per its PCP if live pests or signs of live pests are detected
• Shipborne dunnage can only be moved out of the designated terminal as per a written approval issued by an inspector
• Shipborne dunnage must be processed or disposed of as per the PCP

Appendix 7: High and low risk periods impacts on the shipborne dunnage program

Appendix 8: Approved disposal methods

All wood packaging material, including shipborne dunnage

The following methods may be used to dispose or process all WPM and shipborne dunnage:

• Incineration
• Burial to a depth of no less than 2 metres at a landfill and must be covered immediately
• Industrial processing using glue, heat, pressure and any combination thereof that render the end product a negligible risk, such as wood dust, plywood, particle board, oriented strand board or veneer

Wood chipping is not an approved method of disposal due to the risk of pathogens, bacteria, or viruses that could be present. Chipping can be included as a step in the disposal or processing procedure, but must be treated or disposed of as described above.

Other disposal methods may be accepted by the CFIA on a case-by-case basis.

Compliant shipborne dunnage only

Under the written authorization of the CFIA, shipborne dunnage that has been visually monitored as per section 6.3 and found compliant with entry requirements in section 5 may be permitted to be recycled (or remanufactured) in a facility registered under D-13-01. Original certification marks must be completely obliterated and the material treated and re-marked in accordance with ISPM-15 by the facility.

Segregation and identification is required at all times.

Appendix 9: Flowchart on how shipborne dunnage is managed in Canada

This flowchart is a summary of how shipborne dunnage is managed in Canada to help with shipborne dunnage program implementation. If discrepancies between this flowchart and the text of the directive are identified, the text of the directive will prevail.

Long description – How shipborne dunnage is managed in Canada

1. Will the dunnage be reloaded on the same vessel after offloading the cargo?

Yes:

• Dunnage is not considered as being discharged in Canada and cargo can be offloaded in all ports of Canada.

No:

• The ship is considered as discharging shipborne dunnage in Canada
• Ship or ship representatives must notify the CFIA local office 96h (4 days) in advance. Refer to section 5.2.1 and appendix 3
• Continue to question 2

2. Will the dunnage be discharged in a designated terminal?

Yes:

• Dunnage can be discharged
• Discharged dunnage must be visually monitored by the designated terminal
• Continue to question 3

No:

• Dunnage can not be discharged

Refer to appendix 2 for a list of designated terminals in Canada.

3. Is dunnage meeting import entry requirements?

No:

• Continue to question 4

Yes:

• Continue to question 5

Refer to section 6.3.1 for entry requirements

4. Are there any live pests or signs of live pests?

Yes:

• The local CFIA office must be contacted immediately
• The discharge process must be stopped, discharged dunnage should be secured and hold(s) containing undischarged dunnage must be shut
• All dunnage must be fumigated
• The discharge process may continue :
  • Non-compliant dunnage need to be segregated and presented for a CFIA inspection
  • The CFIA will assess the situation and follow up with the violation. Refer to section 8.2.1
  • Traceability of dunnage required at all times, as per the PCP
  • Continue to question 6

No:

• The CFIA local office must be contacted
• Non-compliant dunnage need to be segregated and presented for a CFIA inspection
• The CFIA will assess the situation and follow up with the violation. Refer to section 8.2.1
• Traceability of dunnage required at all times, as per the PCP
• Continue to question 6

5. Will dunnage be reused?

Yes:

• Traceability of compliant dunnage is required at all times
• During the high risk period, reuse of dunnage is not permitted
• During the low risk period, reuse of compliant dunnage is permitted, as per the PCP

No:

• Traceability of dunnage required at all times, as per the PCP
• Continue to question 6

Refer to section 5.2 and section 6.7.3 for more information on dunnage reuse.

6. Is it the high or low risk period?

High risk period:

• Storage restrictions are detailed in section 6.5.2 : shipborne dunnage need to be secured for no longer than 72h.

Low risk period:

• No storage-specific restrictions.
• Continue to question 7

See section 6.4 for the high and low risk period description.

7. Is dunnage moved to another location?

No:

• Dunnage must be disposed of at the designated terminal as per the PCP.

Yes:

• A CFIA-issued written authorization is required.
• During the high risk period :
  • Transport restrictions: measures must be undertaken to prevent pests from escaping
  • Temporary storage is not permitted
  • Storage restrictions at the disposal site: dunnage need to be secured and stored for no longer than 48h
• During the low risk period :
  • Transport restrictions: secure dunnage in a way to avoid loss of material
  • Temporary storage is permitted as per the PCP
  • Storage restrictions at the disposal site : dunnage must be disposed of before the end of the low risk period

In all cases, shipborne dunnage must be disposed of, processed or recycled at the approved facility as per the PCP. Refer to appendix 1.