Key takeaways
- Every piece of raw-wood packaging in the container, including dunnage and bracing, needs ISPM 15 treatment and a legible mark.
- The mark has the IPPC symbol, the country code IN, a producer or treatment provider number and a treatment code such as HT.
- Plywood, MDF, particle board and OSB are exempt, which is why many exporters use them for crates.
- The US can order immediate re-export of unmarked wood packaging; the EU and Australia also enforce ISPM 15 at the border.
- Checking marks on every pallet and crate is a standard part of container loading supervision.
What ISPM 15 covers
ISPM 15, Regulation of wood packaging material in international trade, is a standard of the International Plant Protection Convention (IPPC). The current text was adopted in 2018 and published in 2019. It aims to stop pests moving between countries in packaging made from raw wood.
| Covered | Exempt |
|---|---|
| Pallets, crates, boxes, packing cases, dunnage, cable drums, spools and reels made from raw wood, softwood or hardwood | Wood packaging made entirely of thin wood, 6 mm or less in thickness |
| Dunnage and bracing used to secure cargo in a container | Packaging made wholly of processed wood: plywood, particle board, oriented strand board or veneer made with glue, heat or pressure |
| Reused, repaired or remanufactured wood packaging (with specific rules) | Sawdust, wood shavings and wood wool; wood components permanently fixed to vehicles and containers |
The furniture itself is not wood packaging. A sheesham table is regulated as a product, while the pallet it stands on and the battens holding it in place are wood packaging.
Treatment and the mark
Wood packaging must be made from debarked wood and treated by one of the methods in Annex 1. Small pieces of bark may remain if each is less than 3 cm wide, or wider but under 50 cm² in area.
| Code | Treatment | Key requirement |
|---|---|---|
| HT | Heat treatment | At least 56 °C for 30 continuous minutes throughout the profile of the wood, including its core |
| DH | Dielectric heating (microwave or radio frequency) | At least 60 °C for 1 continuous minute throughout the profile, including the surface |
| MB | Methyl bromide fumigation | Schedule in Annex 1; bark removed before treatment |
| SF | Sulphuryl fluoride fumigation | Schedule in Annex 1; bark removed before treatment |
Annex 2 sets the mark. It must contain:
- The IPPC symbol, to the left of the other parts.
- The country code: the ISO two-letter code, IN for India, followed by a hyphen.
- The producer or treatment provider code, a unique code assigned by the national plant protection organization (NPPO).
- The treatment code, such as HT or MB.
The mark sits inside a border with a vertical line separating the symbol from the codes. No other information may appear inside the border. It must be legible, durable and not transferable, placed where it is visible in use, preferably on at least two opposite sides. It must not be hand drawn, and red or orange should be avoided.
India's scheme for treatment providers
India's NPPO is the Directorate of Plant Protection, Quarantine & Storage (DPPQS) under the Ministry of Agriculture & Farmers Welfare. It accredits treatment facilities and publishes National Standards for Phytosanitary Measures (NSPM), including:
- NSPM-9: forced hot-air treatment facilities for wood packaging material.
- NSPM-11: methyl bromide fumigation.
- NSPM-12: accreditation of fumigation agencies for methyl bromide fumigation.
Accredited treatment providers and registered units are listed on the DPPQS Plant Quarantine Management System (PQMS) portal. For an exporter, the practical rule is to buy pallets and crates from a provider on that list and to keep its treatment certificate for each lot.
Typical problems to look for at an export factory are pallets bought without treatment records, marks drawn by hand, extra battens cut from untreated wood during packing, and bark left on low-grade timber.
How destination countries enforce it
| Market | Legal basis | What happens if it fails |
|---|---|---|
| United States | 7 CFR 319.40-3(b): treatment and a legible, permanent IPPC mark on each article, preferably on two opposite sides | An inspector may order immediate re-export of wood packaging without the required mark |
| European Union | Regulation (EU) 2016/2031, Article 43: ISPM 15 treatment and mark required unless an ISPM 15 exemption applies | Under Delegated Regulation (EU) 2019/2125, authorities order the operator to destroy non-compliant wood packaging found at release for free circulation or at destination |
| Australia | Biosecurity Import Conditions (BICON): ISPM 15 compliant timber or an approved alternative treatment; non-commodity timber in containers must be declared with documents | Non-compliant timber packaging is treated, exported or destroyed at the importer's expense |
In each case the importer bears the cost and delay. A single unmarked pallet can hold up a whole container.
What an inspection checks at loading
| An inspector at loading can check | Needs the NPPO, treatment provider or a lab |
|---|---|
| Every pallet, crate and dunnage piece carries a complete mark: symbol, IN, provider number, treatment code, border | Whether the treatment was actually done to schedule |
| Marks are stamped or branded, not hand drawn, and visible on two opposite sides where possible | Whether a provider number is genuine and its accreditation current |
| No bark beyond the tolerance, no live insects, fresh bore holes or frass | Identification of any insect found |
| No untreated battens or repairs added after treatment; plywood crates are used where planned | |
| The treatment certificate covers the quantity of packaging used |
How Clear To Load checks this in India
During container loading supervision in India, the inspector photographs the ISPM 15 mark on pallets and crates, checks dunnage and bracing as they go in, and records any unmarked or damaged wood before the doors close. Unmarked packaging is listed in the report so it can be replaced before sealing.
The report arrives within 24 hours and ends in a verdict: Cleared to load, Hold or Not cleared. To add these checks, book an inspection. For the timber in the furniture itself, see FSC and timber legality in India.
Sources
- ISPM 15, Regulation of wood packaging material in international trade (IPPC)
- 7 CFR 319.40-3, regulated wood packaging material (eCFR)
- Regulation (EU) 2016/2031 on protective measures against plant pests, Article 43 (EUR-Lex)
- Commission Delegated Regulation (EU) 2019/2125 on wood packaging material (EUR-Lex)
- Australian Department of Agriculture, Fisheries and Forestry: ISPM 15
- DPPQS: National Standards and Accredited Agencies
- PQMS portal: National Standards for Phytosanitary Measures