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Lesson 6 of 8
Plant health, ISPM 15 and the documents that travel with the load
Plant health rules are the third layer, and the one most often confused. There are two separate questions.
Two different questions
The timber may need a phytosanitary certificate issued by the exporting country's plant protection authority, and may have to meet conditions such as bark-free, soil-free or pest-free. Wood packaging (pallets, crates, bearers, dunnage) must separately be treated and marked under ISPM 15, whatever it carries. Mixing these up is a common reason for problems.
New Zealand government pages for New Zealand exporters show the type of requirement: for sawn timber to Saudi Arabia, a phytosanitary certificate with no bark, quarantine-pest freedom and soil freedom; for sawn wood to China, a certificate, verification inspection, and fumigation only if quarantine pests are present. They are examples, not instructions for EU exporters. Ask your own plant protection authority and the importer what applies.
ISPM 15 (2018 edition)
| Item | Content |
|---|---|
| Scope | Wood packaging made from raw wood; processed wood products are outside scope |
| Exemptions | Wood 6 mm or thinner, panel products such as plywood and OSB, sawdust and wood wool |
| HT (heat treatment) | Core temperature at least 56 °C for at least 30 continuous minutes |
| DH (dielectric heating) | At least 60 °C for 1 continuous minute throughout the wood |
| MB (methyl bromide) | Not allowed for pieces over 20 cm in the smallest dimension |
| Mark | IPPC symbol, ISO country code, producer code assigned by the national plant protection organisation, treatment code |
| Legibility | Legible, durable, not hand-drawn, visible, preferably on two opposite sides; avoid red and orange |
| Repair | Up to about one-third of components replaced: new components treated and marked. More than about one-third: obliterate marks, re-treat and re-mark |
Older 2009 brochures list only HT and MB, so they may be out of date.
Worked example: a repaired pallet
A pallet has 12 components. If 3 are replaced (25%), the new parts must be treated and marked. If 6 are replaced (50%), that exceeds about one-third, so the old marks must be obliterated and the whole pallet re-treated and re-marked. Our interpretation: a mark proves treatment by an authorised provider, not that a given pallet is that unit, so buy from producers with a verifiable registration and check marks at loading. Whether spacers and bearers count as packaging at the destination was not verified.
Destination examples
- United Kingdom. GOV.UK says "high-priority" EU timber needs an original phytosanitary certificate presented within three days of arrival; the importer pre-notifies and registers as a professional operator; kiln-dried wood must carry a "KD" or equivalent mark; customs documents quote the certificate reference. The page did not say which products are high-priority. Northern Ireland differs.
- Egypt. A Swiss export-promotion body reports shipment pre-registration (ACI): the exporter registers on CargoX, the importer enters data in Nafeza, and documents must show the ACID number or delivery is rejected. Sea binding applied from 1 October 2021 and air from 1 January 2026. This is a secondary source; confirm with the importer. Our interpretation: ask for the ACID number before issuing documents, because errors cannot be fixed afterwards.
Documents commonly used in timber export (general practice)
| Document | Typical pitfall |
|---|---|
| Commercial invoice | Description or certification claim not matching other documents |
| Packing list | Volume differs from invoice or bill of lading |
| Certificate of origin | Name or address differs from invoice; legalisation needed |
| EUR.1 or origin statement | See below |
| Phytosanitary certificate | Lead time; treatment details wrong |
| Bill of lading, CMR or rail note | Consignee mismatch; missing ACID number for Egypt |
| Certification and CE documents | Claim outside certificate scope; strength class mismatch |
Proof of origin
The Commission's customs page lists the EUR.1 or EUR-MED movement certificate, the statement on origin made by exporters registered in the REX system (with unregistered exporters allowed for consignments up to EUR 6,000 ex-works value, EUR 10,000 for trade with overseas countries and territories), approved exporter declarations, supplier's declarations and importer's knowledge under some agreements. The right proof depends on the destination agreement, the origin of your logs and consignment value. Imported logs can complicate origin, so keep an origin calculation on file.
Key points
- The timber's phytosanitary certificate and the pallet's ISPM 15 mark answer different questions.
- ISPM 15 heat treatment: at least 56 °C core temperature for at least 30 minutes; the mark has four parts.
- Repairing more than about one-third of a pallet means re-treatment and re-marking.
- Destination-specific items, such as Egypt's ACID number, must be on the documents.
- The right origin proof depends on the agreement, log origin and consignment value; ask a customs adviser about REX.