NHLA would like to thank the American Hardwood Export Council (AHEC) for notification of this important Trade Alert. Mike Snow, Executive Director of AHEC, sent this alert out after meeting with the USDA Animal and Plant Health Inspection Service.
The USDA Animal and Plant Health Inspection Service (APHIS) has issued an alert. In view of recent publicity surrounding invasive pests and plant health in Europe, EU customs authorities are looking much more closely at U.S. lumber being imported. There is is increased risk that any shipment of lumber into the EU that fails to meet strict interpretation of EU phyto-sanitary requirements will be refused entry.
Specifically, the EU has emphasized to APHIS that if any more lumber shipments into the EU covered by a phyto certificate with an Additional Declaration (AD) stating that the lumber is stamped "KD" or "HT" arrives without the required marks, the shipment will be refused entry and returned to the U.S. immediately.
Exporters are advised to be extra vigilant to ensure that if the additional declaration referring to Heat Treatment or Kiln Drying is on the Phyto Certificate, the mark must also be clearly visible on every bundle of lumber.
APHIS has also advised all certifying offices to mark "KD" or "HT" in a more conspicuous manner - perhaps by stenciling or painting it on the ends of the bundles. This is not a requirement, but members are advised to encourage this practice so that when a European inspector opens the doors on a container he would immediately see KD/HT and the situation is diffused.
This advice relates to phytosanitary certificates for exports of the following species of US hardwood to the EU: Oak (Quercus L.), Maple (Acer saccharum L.), Plane (Platanus L.), Poplar/Apsen (PopulusL.), and Sweet chestnut (Castanea Mill.)
To issue phyto certificates for export of these species to the EU, APHIS has to put an additional declaration (AD) on the certificate. There are a range of possible ADs (the options varying to some extent by species) which include:
- the lumber is squared so as to remove entirely the rounded surface, or
- the lumber is bark-free with water content less than 20%, or
- the lumber is bark free and has been disinfected by an appropriate hot-air or hot water treatment, or
- the lumber has been kiln dried or heat treated and has a mark (KD or HT as appropriate) signifying this "put on the wood or on any wrapping in accordance with current usage".
In practice, due to the EU's strict interpretation of definitions for "squared" and "bark free" lumber, the fourth declaration is typically used for exports of U.S. lumber to the EU.
EU inspection authorities have in the past allowed a degree of discretion in interpretation of the fourth declaration requirement. However, this discretion now seems to be much more limited, and the EU has made it clear that bundles which are not marked KD or HT in a conspicuous manner will be refused entry and returned to the U.S. immediately.
** Note that the specific issue of KD and HT marks does not relate to ash from the United States which is subject to different phyto certification requirements. Neither kiln drying nor heat treatment is recognized by the EU authorities as effective treatment against Emerald Ash Borer. Ash lumber exports to EU require a phyto certificate stating that the ash lumber either: (a) originates in an area established by the national plant protection organisation in the country of export as being free fromAgrilus planipennis Fairmaire in accordance with the relevant International Standards forPhytosanitary Measures; OR (b) is squared so as to remove entirely the round surface.