Risk Management Proposal:   
Review and amendment of the 
import health standard : Wood  
Packaging Material from All 
Countries   
 
FOR PUBLIC CONSULTATION  
 
 
  
26 November 2019  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Plant s & Pathways  
Ministry for Primary Industries  
TSB Tower  
147 Lambton Quay  
PO Box 2526  
Wellington 6140  
New Zealand  
 
Tel: +64 4 894 0100  
 
 
Email: plantimports@mpi.govt.nz   Disclaimer  
 
This Risk Management Document does not constitute, and should not be regarded as, legal 
advice from the New Zealand (NZ) Ministry for Primary  Industries (MPI). While every effort 
has been made to ensure the information in this document is accurate, MPI does not accept 
any responsibility or liability whatsoever for any error of fact, omission, interpretation or 
opinion that may be present, howev er it may have occurred.   
 
 Requests for further copies should be directed to:  
 
Plants and Pathways Directorate  
Ministry for Primary Industries  
PO Box 2526 Wellington 6140  
New Zealand  
Email: standards@mpi.govt.nz  
 
© Crown Copyright - Ministry for Pri mary Industries  
Submissions  
The Ministry for Primary Industries (MPI) invites comment from interested parties on the 
proposed amendments to the i mport health standard (IHS) for Wood Packaging Material  from 
All Countries  which is supported by this disc ussion document.  
 
An IHS “specifies requirements to be met for the effective management of risks associated 
with importing risk goods, including risks arising because importing the goods involves or 
might involve an incidentally imported new organism” (se ction 22(1) Biosecurity Act 1993).  
MPI therefore seeks comment on the proposed format and amendments to the requirements in 
the proposed IHS for Wood Packaging Material  from All Countries . Submitters may also like 
to comment separately on other aspects of  the IHS and MPI will respond to these in due 
course.  
 
The following points may be of assistance in preparing comments:  
 Wherever possible, comments should be specific to a particular change in IHS 
requirements or a question asked in  this document (refere ncing Part numbers or 
subjects as applicable).  
 Where possible, reasons, data and supporting published references to support 
comments are requested.  
 The use of examples to illustrate particular points is encouraged.   
 
MPI encourages respondents to forwar d comments electronically. Please include the 
following in your submission:  
 The title of the consultation document in the subject line of your email;  
 Your name and title (if applicable);  
 Your organisation’s name (if applicable); and  
 Your address.  
 
Send  submissions to: plantimports@mpi.govt.nz .  
  Page 4 of 10 However, should you wish to forward submissions in writing, please send them to the 
following address to arrive by close of business on 31 January 2020. 
Plant Import s  
Plants  and Pathways  
Ministry for Primary Industries  
PO Box 2526  
Wellington 6140  
New Zealand  
 
Submissions received by the closure date will be considered during the development of the 
final IHS. Submissions received after the closure date may be held on  file for consideration 
when the issued IHS is next revised/ reviewed.      
 
Official Information Act 1982  
Please note that submitted documents are public information. These documents may be the 
subject of requests for information under the Official Inform ation Act 1982 (OIA). The OIA 
specifies that information is to be made available to requesters unless there are sufficient 
grounds for withholding it, as set out in the OIA. Submitters may wish to indicate grounds for 
withholding specific information conta ined in their submission, such as the information is 
commercially sensitive or they wish personal information to be withheld. Any decision to 
withhold information requested under the OIA is reviewable by the Ombudsman.  
 
© Crown Copyright - Ministry for Pr imary Industries  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  Page 5 of 10 Contents  Page 
 
Submissions  3 
Purpose  1 
Background  1 
Summary of Risk  3 
Risk Mana gement  4 
Practicality of Measures  5 
References  5 
  
Ministry for Primary Industries   Risk Management Prop osal Wood Packaging Material   1 Purpose  
1. The purpose of this document is to:   
a) incorporate by reference ISPM 15 directly into the import health sta ndard;  
b) update the import health standard  format  to an MPI  standard ised format; and  
c) seek stakeholder feedback on the proposed import health standard  amendment .  
 
Background  
2. The Biosecurity Act 1993 (the Act) requires that an import health standard  (IHS) 
specifying the requirements to be met is in place before a risk good can be given 
biosecurity clearance .  
3. MPI has been reviewing the biosecurity requirements of the IHS: Wood Packaging 
Material from All Countries  (MPI 2009)  because of the use of a specific international 
standard for wood packaging material : ISPM 15 Regulation of wood packaging material 
in international trade  (ISPM 15).   
4. The ISPM 15 standard and the “mark” used on wood packaging material has become 
internationally adopted and recognised since introduction in 2002.   
5. Conditions from ISPM 15 were copied into the IHS : Wood Packaging Material from All 
Countries  to give effect under the Act . Changes to the Act in  2012 , where “incorporation 
by reference ” was inserted , allow recognised and consulted material to  be incorporated as 
if it were part of the biosecurity document (s ection 142M(e)) . This effectively allow s the 
IHS to link directly to the ISPM 15 requirements  instead of repeating them .  
6. The International Plant Protection Convention (IPPC) is th e international standard setting 
body and responsible for all changes and updates to ISPM 15. All accepted changes have 
been through extensive consultation at IPPC with all 183 member parties.  
7. By incorporating by reference directly to ISPM 15 the chief te chnical officer believe s will 
provide the most up to date requirements and measures for protecting New Zealand from 
risks associated with wood packing materials.  
Commodity description  
8. ISPM 15 gives examples of wood packaging material as crates , boxes, pack ing cases, 
dunnage , pallets, cable drums and spools/reels .  
9. “Wood packaging material” is defined under Glossary of phytosanitary terms  (ISPM 5) 
as “wood or wood products used in supporting, protecting or carrying a commodity  
(includes dunnage)” .  
10. Following  on from the requirements in ISPM 15 , these articles are of sufficiently low risk 
to be exem pted from the provisions of the amended  standard:  
a) wood packaging material made entirely from thin wood (6 mm or less in 
thickness) ;  
b) wood packaging made wholly of processed wood material, such as plywood, 
particle board, oriented strand board or veneer that has been created using glue, 
heat or pressure, or a combination thereof ;  
c) barrels for wine and spirit that have been heated during manufacture ;   
Ministry for Primary Industries   Risk Management Prop osal Wood Packaging Material   2 d) gift boxes for w ine, cigars and other commodities made from wood that has been 
processed and/or manufactured in a way that renders it free of pests ;  
e) sawdust, wood shavings and wood wool ; and   
f) wood components permanently attached to freight vehicles and containers . 
Trade   
11. Prior to the adoption of ISPM 15 the volume of wood packaging material used in trade 
was substantial.  In the USA alone in 1999 it was estimated that 15.4 million m3 of 
wood was used in the construction of pallets and containers.  
12. It is estimated that in 2018 approximately 523,000 sea containers carrying cargo arrive d 
in New Zealand and from previous surveys 50% of these sea containers have wood 
packaging material.  
13. Wooden pallets provide for quick loading and unloading of cargo by forklifts saving 
handling and labour costs . Alternatives are available (particularly pallets made from 
plywood and reconstituted wood products) but seem unlikely to replace solid wood 
packaging any time soon.   
Current requirements  
14. The current import requirements for wood packaging  material from all countries are 
provided in the import health standard dated 1st November 2009 and can be found using 
this link: Wood  packaging Material from All Countries.  
15. The current requirements repeat the mark information and the approved treatments 
given in ISPM 15.  
International setting  
16. Where possible, phytosanitary measures are aligned with international standards, 
guidelines, and recommendations as per New Zealand’s obligations u nder Article 3.1 of 
the WTO Agreement on the Application of Sanitary and Phytosanitary Measures (SPS 
Agreement), WTO 1995  and section 23(4)(c) of the Biosecurity Act 1993 .  
17. The SPS Agreement states that phytosanitary measures must not discriminate unfairly  
between countries or between imported or domestically produced goods, and where there 
is a choice of phytosanitary measures to reduce risk to an acceptable level, WTO 
members must select the least trade restrictive measure .  
18. International adoption of a st andard implies that countries recognize the need for 
harmoni sed measures and that these countries are not required to individually provide 
technical justification for implementation of the standards  [taken directly from the 
Explanatory document for ISPM 15 , page 8].  
19. If countries require measures beyond those described in ISPM 15, they are obligated to 
provide a technical justification. The technical justification should be based upon pest 
risk analysis with careful consideration of the appropriate level of protection [taken 
directly from the Explanatory document for ISPM 15, page 8].  
20. The international standard ISPM 15 was adopted in March 2002 and has been revised in 
2006, 2009 and 2013 with updated treatments.  The use of the mark has spread globally 
since adoption.   
Ministry for Primary Industries   Risk Management Prop osal Wood Packaging Material   3 21. Example of a mark  from ISPM 15  
 
22. Before the adoption of ISPM 15 in 2002, a number of countries concerned with the 
movement of wood pests recognised that some industrial processes of heating wood for 
commercial purposes was sufficient to kill a ra nge of insects and wood inhabiting 
nematodes such as the pinewood nematode, Bursaphelenchus xylophilus .  
23. Research confirmed that heating the profile of the wood including its core to a minimum 
temperature of 56°C for a period of 30 minutes was effective in  killing these pests. More 
recent work has shown that this heat treatment also kills many fungal organisms 
associated with wood.   
24. To date, there are 4 treatments recognised internationally as being effective in providing 
sufficient protection against quara ntine pests associated with wood packaging material. 
These are 2 x heat treatments (heat treatment and dielectric heating); and 2 x fumigation 
treatments (methyl bromide and sulphuryl fluoride).   
Objective  
25. MPI’s objective is to ensure that the known biosec urity risks associated with wood 
packaging material are managed appropriately and are consistent with New Zealand’s 
domestic legislation and international obligations.  
26. That the IHS is aligned to the international standard ISPM15 and that the treatments 
provided are efficacious and internationally accepted.   
 
Summary of Risk  
27. Wood may be infested by pests present in the area of origin at the time of growing or 
harvesting. Several factors can influence a pest’s ability to infest trees or wood. These 
factors can also affect pest survival on or in the harvested wood, and in turn impact the 
risk of pest association with the wood  packaging .  
28. Several documented studies and pest risk assessments have shown that untreated wood 
packaging material can harbour pests wh ich can be moved to new areas.  
29. In general, the greater the level of processing or treatment of the wood after harvest, the 
greater the reduction in the pest risk.   
Ministry for Primary Industries   Risk Management Prop osal Wood Packaging Material   4 Risk Management  
30. ISPM 15 balances risk reduction to an internationally recognized acceptabl e level with 
least restrictive trade measures. The identified treatments do not provide absolute 
protection against all pests of wood, however, the application of these measures do 
provide a safer worldwide trading environment in which the majority of risk s have been 
mitigated.  
31. ISPM 15 encourages the application of a treatment in conjunction with debarked wood to 
be applied before the initial export of wood packaging material in the country of 
production . The treatments are prescribed in ISPM 15 and are be lieved to be sufficiently 
effective provided th ey are applied using good application services. Treatments and 
conditions of application are set out in Annex 1 of ISPM 15.   
32. The approved treatments prescribed in ISPM 15 have been based upon assessments on a  
range of wood pests that are affected by the treatments; the efficacy of the treatments in 
killing wood pests, and the technical or commercial feasibility of the treatments for use 
on wood packaging material.  
33. ISPM 15 requires the use of debarked wood in the construction of compliant wood 
packaging material . Debarking is an industrial process in which the majority of bark is 
removed from the harvested tree using metal teeth, knives or chains which tear the bark 
from the wood. Debarking is defined as “w ood that has been subjected to any process that 
results in the removal of bark ”.  
34. Debarking does not result in wood which is entirely bark free . To manage the risk of 
insects, ISPM 15 requires that the removal of bark should result in wood that contains no 
more than 3 cm bark in width (regardless of the length) or if the residual bark exceeds 
3cm in width, then any individual piece of bark should not exceed 50 square centimetres.  
These tolerances are also stipulated in ISPM 39 where debarking reduces the risk o f pests 
completing their life cycle in untreated wood especially bark beetles.     
35. Wood packaging material is often transported in moist environments where surface fungi 
may develop (e.g. moulds). Many of these fungi are ubiquitous organisms and do not 
pose a quarantine risk  and do not require treatment upon arrival .    
36. Provided untreated wood is not added during repairs or remanufacturing, wood packaging 
material that has been treated using heat or fumigation is unlikely to be  susceptible to re- 
infestatio n. The remaining bark surface is insufficient to support most insect 
development, and once debarked, the cambium surface of the wood dries and becomes an 
unsuitable host for most pests.   
37. The use of the ISPM 15 mark is an internationally accepted option to  manage the risk of 
wood packaging material. Wood packaging material that is not ISPM 15 marked or is not 
accompanied by a treatment certificate is considered untreated and will require inspection 
upon arrival.   
38. Provision of an off shore treatment certifi cate in lieu of the ISPM 15 mark is still an 
acceptable option under the proposed import health standard. Treatments are linked to the 
ISPM 15 standard .  
39. ISPM 15 encourages compliance inspection of imports of wood packaging material.    
Ministry for Primary Industries   Risk Management Prop osal Wood Packaging Material   5 Practicality of Meas ures  
40. NPPOs are responsible for the implement ation of ISPM 15 and therefore it is expected 
that export ed goods will meet the measures of ISPM 15 .  
41. The obligation to comply with ISPM 15 is already an accepted practise  and th e options of 
heat treatment and fu migations in ISPM 15 are widely used  by industry .  
42. Referring directly to ISPM 15 by incorporation by reference in the import health standard 
enables New Zealand to operate under current internationally approved requirements.   
43. Proposed changes to the impor t health standard do not impose additional costs, resources 
or time  to industry .   
References  
Explanatory document for ISPM 15 (regulation of wood packaging material in international 
trade) Approved 2014, published 2017  
https://www.ippc.int/static/media/files/publication/en/2017/02/ISPM_15_ED_En_2017 -02-
10.pdf  
 
Frequently Asked Questions ISPM15  
https://www.ippc.int/en/faq/?_sm_au_=iHVPn8fvVHn6Njj5#Ispm15  
 
ISPM 39: International Movement of Wood  
https://www.ippc.int/sta tic/media/files/publication/en/2017/05/ISPM_39_2017_En_2017 -05-
15.pdf  
 
ISPM 15 : Wood packaging Material  
https://www.ippc.int/static/media/files/p ublication/en/2016/06/ISPM_15_2013_En_2016 -06-
07.pdf