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Global Phytosanitary Standards Impact Recyclers

As major world markets move toward implementation of new phytosanitary standards for solid wood packaging, especially pallets, dunnage and crates, most of the initial focus has been on new pallet production. But these new laws will certainly impact recycling, which could possibly make a complex situation even more confusing. This may be especially true as phytosanitary laws intersect with widely accepted international quality/size standard pallets, such as the Euro pallet. Not only do shippers have to comply with quality standards, now they also have to consider plant health and treatment requirements.

The new international standard (ISPM-15) gives individual countries some latitude in developing specifics about how to deal with recycled pallets. As a voluntary standard, international governments are not required to enact it. Thus, packaging could be ISPM-15 compliant and still not be in compliance with the entry requirements of the importing country if it has not adopted the international standard or has interpreted certain provisions differently than other nations. You must always check to make sure that the packaging is compliant with the current regulations for the country where the packaging is headed.

One example of something where countries may differ on requirements even for those who are implementing ISPM-15 is the repair standard. It is up to each importing country to decide if it will allow treated components to be added to repair a pallet instead of re-treating the whole thing after repair. The United States requires pallets that are repaired or re-built to be completely re-treated and remarked after the initial mark is removed. The EU does not have an official policy on this issue. It allows each member country to decide. The United Kingdom holds the same position as the U.S. Stan Bowes, president of the European Pallet Association (EPAL), said that he expects most of the other European countries to require the same thing as the U.S and the U.K.

Another question area has been EUR pallets, which are commonly known in North America as Euro pallets. Euro pallets are made, mostly in Europe, according to strict specifications in order to be included in a large, common, global pool. These pallets get shipped to North America and are a popular return choice for loads heading to Europe because they have value in the European market. Currently, there are millions of Euro pallets in distribution throughout the globe. Since Euro pallets tend to come from Europe, many pallet companies in North America want to know if they can freely ship them back to Europe without having them to be ISPM-15 compliant. Stan said, “As with any other solid wood packaging, any “EUR” Euro pallets, whether EPAL or not, must conform to ISPM-15 to be allowed into the European countries.”

He further said, “Prior to the official adoption of ISPM by the EU, if it could be shown that the pallet had originally been made in a member state, then it could be re-imported into the EU without further ceremony. This is no longer the case. There is a small exception, in the case of Switzerland, as it is totally surrounded by member states of the EU.” Based on what Stan said, official EUR pallets that are not marked as being treated and ISPM-15 compliant should be treated and marked in accordance with ISPM-15 before being re-shipped to the EU.

The good news is that some Euro pallets already carry the IPPC mark and have been treated according to ISPM-15. Steve Klinkefus of Compliance Packaging International, the only company certified to repair official Euro pallets in the United States said, “Europeans have been heat treating pallets for a while. Most new Euro pallets that have been exported have been treated and many carry the IPPC mark.”

What if a used Euro pallet needs to be repaired? Well, that’s where things get a little bit complex. Only licensed companies are allowed to make or repair official Euro pallets. And Compliance Packaging is the only company certified to repair Euro pallets in the United States. Phytosanitary treatment is not considered a repair and thus can be done by anyone who is certified under an official government program.

If a non-authorized company makes a repair and tries to pass it off as an official Euro pallet, this amounts to a trademark infringement, which is prohibited by international law. Do some companies do it anyway? Yeah, but it could get you in trouble with the customers that have to pay waste disposal taxes or lose the commercial value of the pallets when returned back to the European market.

The Euro pallet standard is owned and controlled by the International Union of Railways (UIC). EPAL is a regulatory body recognized by the UIC to control the licensing and quality of pallet manufacture and repair. Some countries are still controlled by their own individual railway organizations, and there is another independent body similar to EPAL. However, EPAL is by far the largest. It controls over 80% of all EUR pallets manufactured and repaired. According to Stan, the UIC specifically prohibits fumigation for the manufacture and repair of EUR pallets. Thus, a company could fumigate Euro pallets, mark them according to ISPM-15 and ship them to Europe. The packaging would be in compliance with phytosanitary rules but not the UIC standard for Euro pallets. Stan said, “These pallets would not be refused entry into the EU, as they would comply with the required phytosanitary standard. There is a risk element. It is possible that the recipient could raise an objection, if they knew of the UIC directive…The risk of this is very small, but I would not personally advocate fumigation of second hand EUR pallets.”



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