ISPM 15 stamp no guarantee of compliance

ISPM 15 stamp no guarantee of compliance

Infestations of wood-boring siricidae wasps have been found in wood packaging materials (WPM) with legitimate stamps of treatment from Europe and other regions, according to US Customs and Border Protection (CBP). Photo credit:

The United States Department of Agriculture (USDA) has known for years that untreated or inappropriately treated wood packaging materials (WPM) for imports can be a primary pathway for invasive pests.

“We ask our inspectors to adjust the intensity of inspection,” Osama El-Lissy, deputy administrator of Plant Protection and Quarantine with the USDA’s Animal and Plant Health Inspection Service (APHIS), told “Some cargo commodities that pose lower risk, we may not inspect as intensely as those as that have higher risk. We are not picking on WPM per se, but it depends on risk levels.”  

For reasons not clearly understood, US Customs and Border Protection (CBP) has recently been finding an increased pest presence in properly — as well as improperly — marked WPM, John Sagle, director of Agriculture Safeguarding, Agriculture Programs and trade liaison for CBP, told “Is there an increased pest presence in certain countries? Is it a climate cycle or a pest trend?”

Sagle said infestations of wood-boring siricidae wasps, for example, have been found in WPM with legitimate stamps of treatment from Europe and other regions. The possibility of treated WPM being re-infested has not been ruled out fully, but experts say it’s unlikely. Sagle said it’s more likely that the wood was not effectively treated to begin with.

“It could be execution issues, rather than gross negligence,” he said. “Is it the sawmills? The treatment? Some companies are deploying their own employees to work on this; we are showing them images of what to look for, signs of infestation, and so on.” Some companies have come to CBP for help finding the vulnerabilities in their supply chains. Companies must do their own reinspection of packaging and dunnage, he said.

“We’re seeing a lot of project and out-of-gauge cargo coming in from Europe, where methyl bromide [fumigation] is not allowed,” said Dominic Sun, director of trade development with the Port of Houston. Wood-boring infestations seem to be worse in WPM from the EU, he said. “We need to find a solution, so that the wood is treated differently to knock out the infestations coming in.”

‘Common sense’ approach

El-Lissy said much of CBP’s enforcement effort comes down to a “common sense,” case-by-case approach.

“If you have a large cargo of steel products, and it happens that you only have a piece of [infested] wood, you will not reject the entire shipment due to this piece of wood. [But] if a large shipment has WPM, not just one piece of wood, and you find live insects, larvae and adults, then it is more complicated,” he said. “A ship could have several holds, one with WPM problems and one without. We may allow entry from one hold but reject the cargo in the hold with pest problems. At the bottom of all this, we want to facilitate safe trade. We want a vibrant trade economy, but in doing so we want to make sure we don’t end up with the unintended consequences of invasive pests.” 

When it comes to importing large manufacturing equipment, El-Lissy said cargo owners are typically focused on the product, rather than the material it is packed in. “The last thing they think about is the WPM, and now they learn that the shipment is being rejected due to the WPM. That has started getting a lot of attention,” he said. “We don’t see that big of a jump, but we are observing that many of the shipments we are rejecting are coming from Europe. We have met with the EU and are trying to find the underpinning reason as to why some shipments have WPM pest problems.”

“Pallets are easy,” Sagle added. “But when [a piece is] custom built for specific pieces of machinery, that’s more complex. They are building on site. That’s largely what we are seeing a lot of in Houston — custom-built, encased pieces — so we are making sure that all the components were properly treated. We stress this to companies, to check all of that, that all the crating is treated correctly, along with checking where they are getting their supplies from. Are there gaps in the system? Is there any intermingling?”

WPM is typically supplied by an importer’s manufacturer, often through a subcontractor hired by that manufacturer. Dunnage, a subset of WPM, is loose wood, matting, or similar material used to keep breakbulk or project cargo in position in a ship’s hold and not affixed to cargo. It typically belongs to the ship operator. Similar to all WPM, dunnage requires International Standards For Phytosanitary Measures No. 15 (ISPM 15) treatment for pests, by heat or fumigation.

APHIS and CBP work together at US borders and ports to intercept and keep out any foreign agricultural pests. APHIS’s policy is to re-export WPM infested with any of a list of eight high-risk wood-boring pests. For dunnage, options include re-exporting or incineration, but there is only one APHIS-approved incinerator in the US, on the Delaware River.

ISPM 15 is part of a multilateral International Plant Protection Convention (IPPC) treaty that requires treatment, debarking, and marking of all approved WPM. The mark must include the approved symbol, country of manufacture, identification number of the manufacturer, and the type of treatment used. Marks are registered with the National Plant Protection Organization of the manufacturing country.

Contact Janet Nodar at and follow her on Twitter: @janet_nodar.


Dear Colleagues, The EU ban on methyl bromide has been in place for at least seven years and it is, therefore, strange to see this surge in infestations only now. The most elegant and 100% safe solution is to use non-wood pallets. They are available in a wide range of dimensions and specifications. It is also possible to change the parameters of thermal treatment: increase the temperature and/or the duration of the treatment. Kind regards, Radomir Djuric Trade Facilitation, Customs, Integrated Border Management Consultant