The WPM regulations restrict the importation of many types of wood articles, including pallets, crates, boxes, and pieces of wood used to support or brace cargo, unless properly treated or marked. For the purposes of this rule, WPM that are imported as cargo, such as a container or truckload of new or unused pallets, are considered WPM and subject to the rule. The status as merchandise is irrelevant.
Regulated WPM does not include certain manufactured items, such as worked wood items, even if those items are used to contain other non-regulated merchandise. Examples of non-regulated manufactured items might include such things as carved or formed wooden bottle stoppers, wooden boxes built to house fuel gauges or armaments, ammo crates, etc. Wine crates for any vintage year prior to 2006 are also non-regulated; wine crates for vintage year 2006 and beyond are regulated.
Regulated WPM also does not include any manufactured wood, such as fiberboard, plywood, polywood, strand board, whisky and wine barrels, and veneers, nor do they include "loose wood packing materials" as defined in 7CFR § 319.40-1. Examples of such loose wood packing materials include excelsior (wood wool), sawdust, and wood shavings. Dunnage that is not covered by the "loose wood packing materials" definition cited above is WPM regulated, and full CBP enforcement will apply to such dunnage effective July 5, 2006.
Therefore, beginning July 5, 2006, if CBP discovers any WPM not properly marked, immediate exportation will be ordered for the entire shipment, unless the Port Director determines that it is feasible to separate merchandise from the violative WPM. If the importer wishes to request such an arrangement, care must be taken to ensure that noncompliant materials are separately secured to guarantee their proper exportation and verification by CBP. Otherwise separation will not be permitted. All expenses incurred for the services of CBP involved in the separation of cargo will be billed to the importer or other party of interest. For more information on WPM, please contact USDA at 1-866-738-8197 or access www.cbp.gov.