Blog · 3 posts · 2,518 words

Compliance

ISPM-15, export marking, food-safety audits and the documentation that turns a port query into an email.

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3posts in this subject
2,518words written
12 mintotal reading time
5defined terms
Primer

The mark is the claim. The batch record is the evidence.

If wood packaging crosses an international border it has to prove it is not carrying pests, and the standard governing that is ISPM-15. In practice it means heat: 56 °C at the core of the wood, held for thirty continuous minutes, in a chamber with probes driven into the thickest member. Methyl bromide fumigation is technically still an option and is being phased out almost everywhere for ozone reasons.

The mark that goes on afterwards — the IPPC wheat symbol, a country code, a registered facility number and the treatment code HT — is a compact document. It must be legible, permanent and on at least two opposite faces. What it does not tell you is whether the unit is still compliant, which is where almost all real-world failures live: a treated platform repaired on a dock with an untreated board carries a perfectly genuine mark that now misrepresents it.

Food-safety audits ask a different set of questions, mostly about prior use, segregation of chemically treated wood, moisture control and traceability. The answers are documents rather than assurances, which is why we stamp a passport number into every remanufactured platform and keep the pack ready.

If you only remember five things
  • Debarked wood is a precondition, not an extra. Bark insulates, so the layer under it may never reach core temperature.
  • The mark goes on two opposite faces, legibly and permanently. One face is not compliant.
  • Loose dunnage and blocking fall under ISPM-15 independently. This is the most-missed item.
  • Treat after repair, never before. A post-treatment repair with untreated wood voids the mark silently.
  • HT is not KD. Heat treatment kills pests; kiln drying controls moisture. Different objectives, different documents.
Common mistakes in this area
  1. Assuming a heat-treated platform is dry enough not to mould
  2. Repairing a marked platform on a dock with whatever board was to hand
  3. Treating the pallets and forgetting the loose bracing inside the container
  4. Accepting a 'heat treated' claim with no batch record behind it
  5. Leaving a marked platform in a wet yard until the mark weathers illegible
Reference

The tables behind these posts.

The same data we work from in the yard, so you can check the arguments above against the numbers.

Moisture content — states, risk and what to specify
StateMoisture contentMould riskNote
Green, off the saw60–120%+Very highHeavy, moves as it dries, blooms readily. Rarely what you want.
Air dried, yard stored15–22%ModerateTypical of outdoor recycled stock in a humid month.
Kiln dried≤19%LowBelow the biological threshold for mould. The usual specification.
Kiln dried, millwork grade8–12%Very lowFor cladding and interior work, matched to heated-interior equilibrium.
Reclaimed, long service10–16%LowYears of cycling beat any kiln schedule for stability. An under-appreciated advantage.

Moisture content is water weight divided by oven-dry weight, which is why green softwood can exceed 100%. Heat treatment is not kiln drying — see moisture explained.

Documentation we issue
DocumentWhenWhy it matters
Certified weigh ticketEvery inbound and outbound movementThe evidentiary basis of any diversion claim
Count sheet by gradeEvery purchase of your surplusYou get the sheet, not a summary
ISPM-15 batch recordAny heat-treated consignmentTurns a port query into an email
Pallet Passport recordAny remanufactured platformOrigin, repair history, treatment batch, running ledger
Quarterly diversion reportProgramme customersMeasured tonnage for ESG reporting, not an industry average
Feedstock segregation attestationMulch and bedding buyersWritten statement of what the wood was
Certificate of insuranceOn requestNamed-insured endorsements for on-site crews
Grading criteria statementOn requestThe written standard our graders work to

Ask for any of these before an audit rather than during one. Assembling the pack takes us an afternoon and converts verbal questions into documents.

ISPM-15 · eight checks before a container moves
  1. Every component debarked — a single strip on one bottom board voids the unit
  2. Core temperature 56 °C held for 30 continuous minutes, probed in the thickest member
  3. IPPC wheat mark with country code, registered facility number and HT treatment code
  4. Mark applied on at least two opposite faces, legibly and permanently
  5. Loose dunnage, blocking and bracing treated and marked independently
  6. Any post-treatment repair made with treated material, and the unit re-marked
  7. Batch record retained, tied to your shipment reference, issued with the packing list
  8. Methyl bromide (MB) avoided — phased out in most destinations and refused by several
Vocabulary

The terms these posts assume you know.

Vocabulary is the cheapest performance upgrade in this industry — almost every argument we have with a new customer comes down to two people using the same word for different objects.

Full glossary
Core
An unsorted, un-repaired used pallet — raw material for a recycler. Sold by the load.
Dunnage
Loose wood used inside a load for blocking and bracing. Needs its own ISPM-15 treatment for export.
HT
Heat treated: wood core held at 56 °C for 30 continuous minutes to satisfy ISPM-15.
ISPM-15
The international phytosanitary standard governing wood packaging in cross-border trade.
KD
Kiln dried — moisture reduced, usually to ≤19%, to prevent mould and dimensional movement.
Questions

Compliance questions we get.

Can a recycled pallet be ISPM-15 compliant?

Yes, and most of what we treat is recycled. Every component must be debarked and any repair boards must be treated too — which is why treatment happens after repair here, never before. The platform's history is irrelevant to the standard; its current condition and treatment are what matter.

Does the ISPM-15 mark ever expire?

No. Treatment is permanent for as long as the unit is not subsequently modified with untreated material. That single caveat voids more marks than anything else, and it usually happens on a dock, with good intentions, by somebody fixing a pallet.

What do food-safety auditors actually ask about pallets?

Prior use, exclusion of chemically treated wood, mould and moisture control, protruding fasteners, pest management in storage, traceability to a batch, your non-conforming product procedure, and whether the people grading are trained. All of those have documentary answers and we will assemble the pack before an audit rather than during it.

Other subjects

Eleven more areas.

NoteSubject pages are reachable from the blog index and from every post rather than the main menu. The full archive lists all forty posts by year.

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