Phytosanitary requirements for entry into the EU (wooden packaging).

In less than 2 years the UK will be leaving the EU becoming a third country. I am looking in this blog at wooden packing requirements as a third country exporting to the EU. These standards include wooden packing cases and in particular wooden pallets which everyone uses. This is entirely separate from what is in or on that packaging.

The EU requires all imports that have wooden packaging from third countries to conform to ISPM 15 standard http://www.ispm15.com as set out in http://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32004L0102

Currently as the UK is trading within the single market shippers do not have to conform to this standard. If you export to the single market you can use less strict standards as set out by HMRC https://www.gov.uk/wood-packaging-import-export , in reality it means in practice you can use any old pallet that is laying about as there is no control point that checks this requirement.

At 2300 (the UK being an hour behind) on the 29th March 2019 we will have to conform to ISPM15. At that point there will be a control point at the border doing these checks that we are meeting that requirement. A certain amount of trailers will be stopped and checked that the packaging is conforming to the standard. This will cause delays as every wooden pallet will have to be checked for the required marking. In practice this would mean being very careful of how the vehicles are loaded. With a curtain sided vehicle with all the pallet markings on the outside then easier, with a solid sided vehicle everything will be offloaded and checked.

Typically all Customs world wide work via risk profiling. If the ones they do check are fine then they will stick to minimum checks, if (and as I expect) the ones they stop particularly groupage trailers do not conform they will have to check more and more.

This is difficult enough but even then I am assuming there will be a deal on trade and mutual recognition agreements that the notifiable institution (in the UK it is the Forestry Commission) that oversee standards will be recognised by the EU. This isn’t looking currently likely in the event of a hard Brexit, At a stroke we would find that they would not recognise the markings on the wooden packing and would either mean it cannot cross the border or requires fumigation.

My thanks to Dr Richard North of EUreferedum.com for the EU reference.