Fumigation Regulations in the United States: An Overview

Wooden products, including furniture and packaging materials, must undergo fumigation or heat treatment prior to being imported into the United States. In this guide, we explain the basics that American importers must know about fumigation and heat treatment requirements – including APHIS pre-import permits, ISPM 15, and more.

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What is fumigation?

Products that are made from logs or timbers might be infested with parasites, pests, and microorganisms. When these wood products are exported from one country to another, it is possible that pests harbored inside the products come out and become invasive species to the local environment, causing irreversible ecological disasters.

Therefore most of the countries, including the United States, enforce regulations aiming at minimizing such risks.

Nowadays, one of the widest introduced methods to treat wooden materials is fumigation. During the fumigation treatment process, the room or container that contains the wooden products is filled with gaseous pesticides or fumigants to eliminate the parasites and pests inside the woods.

Fumigation treatment can quickly eradicate pesticides and insects hidden inside the wood structures. The chemical gases used during the process can effectively penetrate the cracks, crevices. Proper and good practice of fumigation treatment generally leaves no odors or hazardous residues to the wooden materials.

On the other hand, the chemical gases used during the fumigation treatment can cause adverse effects. For example, the chemicals are highly toxic and can be fatal to most living things, including humans. Improper operation, chemical spills, or equipment failures could lead to serious injury to the users.

In addition, fumigation might negatively impact the environment, if the gases escape the container or tent.

What is heat treatment?

Heat treatment is an alternative measure to fumigation that does not use chemicals to kill the pests and parasites. Instead, heat treatment kills pests and parasites by high temperatures or pressure.

Commonly used heat treatments approved include conventional steam heating, kiln-drying, heat-enabled chemical pressure impregnation, and dielectric heating treatment.

These heat treatment processes differ in terms of heating time, temperature, or other parameters. For example, when conventional steam heating or kiln-drying treatment is used as a pest control method for wood packaging materials, most common standards require a minimum of 56 °C during the heat process, for at least 30 minutes.

In the case of dielectric heating treatment for wood packaging materials, the requirement is to reach 60 °C for 1 continuous minute.

For which products is fumigation or heat treatment required in the US?

According to the United States Department of Agriculture’s Animal and Plant Health Inspection Service (USDA APHIS), several categories of products are subjected to subject to phytosanitary measures such as fumigation or heat treatment, including:

• Wood packaging materials
• Wooden handicrafts imported from China
• Bamboo stakes

In particular, for wood packaging materials that are used during consignment to prevent product damage, the following list of articles are required to conform with the USDA APHIS requirements:

• Dunnage
• Crating
• Pallets
• Packing blocks
• Drums
• Bins
• Cases
• Skids

However, note that composite wood packaging materials are excluded by the regulation, as materials that undergo glue, pressure, or similar processes are deemed to be free of dangerous parasites.

Regulations of the Department of Agriculture on Foreign Quarantine Notices

The USDA APHIS lays down the pest control and importing requirements for plant products imported to the United States in Title 7, Part 319.40 of the Code of Federal Regulations.

Here we list some of the products that follow under the scope of the regulation:

• Wooden packaging materials
• Wooden handicrafts
• Artificial Christmas trees
• Bamboo stakes and poles
• Wheat straw
• Rice straw
• Seeds and plants

However, note that fumigation or heat treatment is not required for all of these products. Other measures might be in place as well. For instance, unprocessed wheat straw can only be imported from Canada, New Zealand, and Norway.

Conversely, wheat straw composite plastic products can be imported from any country without undergoing any further treatment as, after being molded, mixed with plastics such as PP or TPU, and heat pressed, they are deemed free of pests.

Wood Packaging Materials: ISPM 15 Heat Treatment and Fumigation

The United States is a member of the IPPC (International Plant Protection Convention) and adopts the ISPM 15 (International Standards For Phytosanitary Measures 15), which stipulates phytosanitary requirements for wood packaging products.

ISPM 15 aims at decreasing the damage of the pests harbored in wood packaging materials used during international trading activities, and it was adopted by the USDA in 2005.

Wood packaging materials regulated by the ISPM 15 include the following:

• Skids
• Dunnages
• Crating
• Boxes
• Bins
• Reels

Excluded Wood Packaging Materials

ISPM 15 does not regulate all wood packaging materials. For example, some wood packaging materials for special products are pre-treated to expel pests and parasites. Other types of wood packaging materials are processed in a way that makes it harder to harbor pests and parasites.

These products include:

a. Materials processed with adhesives, heat, or pressure (i.e.plywood, particleboard, oriented strand board, and veneer)

b. Alcohol, wine barrels or gift boxes, cigars cases

c. Sawdust, wood shavings, and excelsior

d. Wood products that are thinner than 6 mm

Debarkment

ISPM 15 requires that wood packaging materials must be made of debarked woods, except if each piece of bark measures less than 3 cm in width, or has an area lower than 50 square cm.

Recognized Measures for Wood Packaging Materials

ISPM 15 approves several kinds of phytosanitary methods, including:

1. Methyl bromide treatment (treatment code displayed on the IPPC Mark: MB)

2. Sulfuryl fluoride fumigation (treatment code displayed on the IPPC Mark: SF)

3. Heat treatment (treatment code displayed on the IPPC Mark: HT)

• Conventional steam heating
• Dry kiln heating

4. Dielectric heating treatment (treatment code displayed on the IPPC Mark: DH)

• Microwave treatment
• Radiofrequency treatment

IPPC Mark

ISPM 15 stipulates that an IPPC Mark is compulsory for all regulated wood packaging materials. This mark indicates that such an article is fully compliant with the ISPM 15 phytosanitary requirements and should be printed on the surface of the wood packaging materials in a legible way, and contain the following information:

a. The IPPC certification symbol

b. The ISO country code of the country where the products were treated (e.g. CHN for China, CAN for Canada, MEX for Mexico)

c. A producer/treatment provider code, in order to guarantee traceability

d. The treatment code that we introduced in the previous section of this guide (i.e., HT, DH, MB, or SF)

Finally, ISPM 15 declares that a phytosanitary certificate for regulated wood packaging materials is “unnecessary” since the application of the IPPC Mark on a product demonstrates the phytosanitary compliance according to ISPM 15.

Wooden Handicrafts from China

The USDA APHIS requires that wooden handicrafts that are made from wood, twigs, and vines, bamboo poles, and garden stakes must be treated in accordance with the requirements specified in Part 305 of CFR Chapter 7.

Examples of covered products:

• Carvings
• Baskets
• Boxes
• Birdhouses
• Rustic wooden furniture
• Artificial trees
• Garden fencing and edging

Manufacturers or importers should choose the proper treatment for their products. The options include the following:

• Heat treatment
• Chemical treatment
• Radiation treatment
• Cold treatment

For wooden handicrafts more than 1 centimeter in diameter imported from China, the USDA specifically appoints a list of permitted wooden handicraft manufacturers. This list will be updated annually. Only shortlisted manufacturers are permitted to export wooden handicrafts to the US.

Labeling

Section 319.40-5 of the regulation requires that all the packaging of wooden handicrafts shipped from China to the United States must be labeled with a merchandise tag revealing the identity of the product manufacturer. This tag must be placed before the shipment and only allowed to be removed before being sold.

Bamboo Products

The USDA requires that bamboo poles should undergo phytosanitary treatments before they can be imported to the US.

In particular, the products should comply with the requirements set in Part 305 of CFR Chapter 7, in addition to the documentation and marking requirements specified in §319.40-9 – Inspection and other requirements at the port of the first arrival.

Import Permit

Manufacturers and importers of regulated products should apply for an import permit by filling out the physical or electronic application form.

Here we list some of the information that must be provided during the permit application:

• Company name
• Company address
• Company contact information
• The specific type of regulated article (common and scientific names)
• Country of origin
• Intended use of the regulated article
• Intended port(s) of the first arrival
• Description of the processing, treatment, or handling of the regulated article

Products that require a general import permit

Section 40-3 of CFR Part 319 specifies the list of products that only require a general import permit. These products include:

• Certain regulated wood packaging materials
• Certain wood products from Canada and Mexico
• Loose wood packing materials
• Specific types of bamboo timber
• Regulated articles that have been proved no plant pest risk

Before being permitted to enter the United States without specific permits, these products must also meet certain criteria. For example, wood packaging materials must bear the IPPC Mark.

Products that require a specific import permit

These are examples of products that are required to obtain a specific import permit from the USDA APHIS:

• Certain types of bamboo timber
• Wooden handicrafts with more than 1 centimeter in diameter from China
• Ashwood chips or bark chips
• Firewood of all hardwood
• Christmas trees
• Pine articles

The USDA APHIS will review the application and issue either the general permit or specific permit, based on whether the imported article meets the criteria specified in §319.40-5 for a specific import permit, o rin §319.40-6 for the universal import permit.

What happens if my products are non-compliant?

If the USDA APHIS decides that the information on the importation document is inaccurate, then these articles can be refused entry into the US.

Fumigation Treatment Services

Importers of consignments that contain regulated plant products or wood packaging materials are recommended to arrange phytosanitary assessments before the importing process.

The following agencies are listed on the official website of the US Customs and Border Protection as reference information which offers fumigation treatment or heat treatment services:

• Package Research Laboratory
• Timber Products Inspection
• LEE Inspection and Consulting Services
• Pacific Lumber Inspection Bureau