• Wood & Bamboo Product Regulations in the United States: A Complete Guide

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    Planning or import wooden or bamboo products to the United States? In this guide, we explain what you must know about permits, fumigation, APHIS regulations and markings.

    Covered Products

    • Wooden Handicrafts
    • Wooden Furniture
    • Bamboo Products
    • Wooden Packaging Materials
    • Fumigation and Heat Treatment Requirements
    • Other regulations

    Wooden Handicrafts

    Wood and bamboo regultations

    For the wooden handicrafts products, it is regulated by the animal and plant health inspection service (APHIS) in the united states, and the scope of wooden handicrafts products including the example below:

    • Baskets
    • Birdhouse
    • Boxes
    • Picture frames
    • Pencils
    • Wooden furniture
    • Other items composed of wood

    Approved Ruppliers

    The first step for importing wooden handicraft products from China is to check the APHIS list of approved wooden handicraft manufacturers.

    Note that manufacturers are not considered approved until they have been added to the list. The list is maintained by the government of China as part of an agreement with the U.S.

    • Guangzhou Nanfang furniture Co.,Ltd
    • GL plastic goods MFG Co.Ltd
    • Crownwell (Heyuan) Co.Ltd
    • Gaoyao Lianrun arts & crafts Co.Ltd

    Facility Requirements

    The approved manufacturers produce wooden handicrafts according to specifications which have been agreed by the U.S and China. These products are designed to eliminate the presence of pests in their products. Also, it indicated that the manufacturers have met with the following requirements:

    • Heat treatment to the wooden handicraft product
    • The production area is neat and clean
    • Quarantine treatment to the wooden handicraft product
    • Quality management such as pest control and traceability system

    Pre-Import Approvals

    Once you have confirmed if the supplier is on the APHIS list, you may proceed to the ePermits website and apply for an import permit.

    To access ePermits, you must have a USDA eAuthentication account and it can be registered online. You will also need to provide some general information for the application of the permit.

    • Product category
    • The registered number of the manufacturer
    • Personal contact
    • Quantity of goods

    It takes approximately 30 days to receive the permit and you can keep track of the application status online.

    The permit indicates the type of treatment the wood requires. Also if the wood component comes from either natural or planted forest stands, you will also need to fill out the declarations form for information such as:

    • Tree’s scientific name
    • Country of harvest
    • Value
    • Description

    Wooden Furniture

    Wooden furniture

    Product Scope

    The APHIS regulation (detailed above) for wooden furniture includes the following categories:

    • Children’s furniture
    • Upholstered furniture
    • Bunk beds
    • Toddler Beds

    Notice that it does not apply to mattress or other home furnishings such as carpets and rugs.

    Other Regulations and Agencies

    There are several U.S federal agencies administering regulations associated with the wooden furniture:

    • CPSC (Flammability, lead content)
    • CBP(Country of origin)
    • EPA (Formaldehyde in wood)
    • FTC (Labeling)
    • USDA (Organic claims)
    • CPSIA( certificates and mandatory third-party testing)

    For example, section 102 of the CPSIA requires a general certificate of conformity by the CPSC, and also requires children’s product certificate for children furniture.

    Wooden Furniture Packaging and Labeling

    The Uniform Packaging and Labeling Regulation (URLP) requires furniture packaging includes the following information:

    1. Identity of the commodity

    2.Name and place of business of the manufacturer, packer or distributor

    3.Net quantity of contents in terms of weight or mass measure

    4.Heavy metals(if any) in packagings such as mercury, lead, cadmium, and hexavalent chromium.

    The URLP require a special label for wood furniture, in order to help customers to identify the manufacturer of the product. The labeling must include the following information:

    • Percentage of filling materials by weight
    • The tag must not be removed except by consumer warning
    • The country of origin
    • The uniform registry number of the manufacturer

    Note that the labeling requirements can vary between US states, therefore, you should be aware of the labeling law in which state you are importing to.

    Restricted and Endangered Wood Species

    If the wood used in the furniture you’re importing is listed under regulations pertaining to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), it’s subject to the requirements listed below.

    CITES Requirements

    1. A general permit issued by the USDA

    2. Certificates issued by the representative of CITIES in the country where the wood was harvested

    3. Certificates issued by the representative of CITIES representative in the U.S.

    4. Arrival at a US port equipped to handle shipments of CITES-listed species.

    CITES-listed species for reference

    • Honduran rosewood
    • Red stinkwood
    • Zitan
    • Ramin
    • Japanese Oak

    Bamboo Products

    Products such as bamboo furniture or other manufactured products made of bamboo are regulated under the APHIS as well. For Bamboo products that are “thoroughly dried and split”, it can enter the U.S. without USDA import permit will be released after inspection at the port of entry.

    In addition, mandatory fumigation at the port of arrival is required for garden and nursery stakes made from bamboo. Notice that the mandatory fumigation is not required for other bamboo products.

    Lacey Act

    The lacey act applies to all plants including bamboo. Depending on the specific bamboo products you are importing, it may require importers to fill out a lacey act declaration as known as PPQ form 505.

    Required information

    • Scientific name
    • Country of harvest
    • Value
    • The volume of the wood product

    You may wonder whether you need to fill out the Lacey Act declaration or not since there is no prohibited list of plants under the lacey act. However, you can send an email to APHIS and provide a description of the types of products you are planning to import for assistance.

    Wooden Packaging Materials

    freight pallet

    The APHIS has set standards for wood packaging materials (WPM) imported into the United States. Examples of Wooden packaging materials include but is not limited to the following:

    • Pallets
    • Skids
    • Containers
    • Boxes
    • Dunnage

    Packaging combined with solid wood components must be treated and marked. Further, the importer or exporter must treat and mark all WPM prior to shipping, to ensure your product is in compliance with APHIS regulations.

    Regulations

    The importation of WPM is regulated under 7 CFR § 319.40. First, you will need to apply for a permit from the APHIS depends on the type of WPM. Also, you will need to prepare the importer document including the following information:

    • The genus and species of the tree
    • The country where the tree from
    • The quantity of the regulated material
    • The use of the product
    • Treatments performed prior to arrival at the port

    Marking

    As mentioned above, the marking is required for the WPM. For both heat treatment and methyl bromide fumigation programs, the treatment mark must include the information as below:

    • Identifying symbol, logo or name of the accredited agency
    • The facility identification
    • The county code
    • The IPPC approved international code for compliant WPM
    • DUN when the indication is used for dunnage

    Fumigation and Heat Treatment Requirements

    The APHIS regulates the importation of all wood products, and it requires the regulated product to undergo certain phytosanitary procedures prior to importation. The two main treatment options will be:

    • Heat Treatment such as dry heat and kiln dryer
    • Chemical treatment such as methyl bromide fumigation and surface pesticide

    Fumigation wood types

    • Solid wood
    • Timer
    • Logs

    Heat treatment wood types

    • Plywood
    • Blockboard
    • Hardboard
    • Other man-made boards

    The ultimate goal of heat treatment or fumigation is to kill pests and insects inside or outside the wood material.

    Comparison Table

    ProductFumigation /

    Heat Treatment

    Requirement

    APHIS 

    Restrictions

    Other

    Requirements

    Wooden CraftYesYes1.Approval manufacturer list

    2.Pre-import approval

    3.Import permit

    Wooden FurnitureYesYes1. Labeling

    2. Packaging

    3. Comply with related regulations

    Bamboo ProductsOnly for garden and

    nursery stakes

    Yes1. Lacey act declaration
    Wooden PackagingYesYes1. Marking

    2. Importer documentation

    Other Regulations

    Wood products containing bark

    Wood products from China that contain bark are subject to additional APHIS restrictions.
    If the wood products contain less than 1 centimeter in diameter will be subject to inspection for insects.

    In general, wood products containing bark may not be allowed to import to the U.S in order to prevent the spread of wood-boring insects.

    21 CFR (FDA) Food Contact Materials

    Food Contact Materials (FCM) imported and sold in the United States must not contain certain chemicals and heavy metals, such as lead, that are deemed to be unsafe.

    FCM regulations also cover coatings that may be used in the manufacturing process of wooden food contact materials, such as wooden bowls, bamboo straws, and similar products.

    The only way to ensure that your wood or bamboo FCM product is safe and compliant is by sending a product sample for lab testing.

    California Proposition 65

    If your product passes the CA Prop 65 lab test, you don’t need to bear a label. Otherwise, you will need to bear a warning label to the product, to indicate that chemicals or heavy metals are used in the product that causes cancer or reproductive toxicity. Here are some chemical or substances listed under CA prop 65:

    • Wood dust
    • Thorium dioxide
    • Terbacil
    • Melphalan

    For wood and bamboo product, there is little chance to find those regulated substances of the product itself.

    However, most wood product’s surface is painted or coated for purposes, for example, increase the resistance to moisture. Therefore, it is also important to ensure all substances in your products are in compliance with the regulations.

    CPSIA

    The CPSIA regulates all imported toys and children’s products in the United States, including wooden toys and wooden children’s furniture.

    • Wooden Puzzles
    • Toy wooden blocks
    • Wooden dolls

    CPSIA Requirements

    • Tested by a CPSC accredited laboratory
    • Tracking label
    • Children’s Product Certificate (CPC)

    Failure to comply with the regulations can result in heavy fines and force-recall on the product.

    Country of Origin

    Country of origin is mandatory for all consumer products imported and sold in the US, including wood product. The country of origin should be included in your declaration documents and also the labeling.

    In addition to the FTC labeling requirements, the name of the country of origin must appear in English and it must be accessible and clear to the customers.

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