Memo to clients - visibility of stamp

September 14, 2011

Important note to facilities registered under the Canadian Wood Packaging Certification Program

Please ensure that your ISPM-15 stamp complies with the requirements specified in D-01-05. Recently, CFIA
intercepted a mark that did not comply (there was no vertical line separating the IPPC logo from other information, and IPPC
lettering was slanted rather than upright).

CFIA views the use of a non-conforming mark as a Major Non-Conformance, since it can result in detained or rejected products by foreign authorities who may question the validity of the mark and whether the treatment requirements of ISPM-15 were met.

The interpretation that a non-conforming mark should be taken as a Major N/C is consistent with other regulatory agencies which oversee ISPM-15 compliance in other countries, and many Canadian agencies have similarly viewed infractions of the mark as a Major N/C in the past. It is important to ensure that all agencies are consistent in their application of the standard, and CFIA has circulated a memo on this matter.

ISPM-15 was revised in 2009 with more prescriptive (“must”) requirements for the IPPC mark, including removing extraneous information within the boundaries of the mark (eg ‘DUN’). Since WPM in circulation may include the old version (showing ‘DUN’ inside the box), this non-conformity will be allowing until January 2013; by then, stamps must be revised to exclude the ‘DUN’ in the mark.

There is NO tolerance for irregularities to the format for the mark as it has been presented in ISPM-15 (2009) and in D-01-05 (7th Revision), and this interpretation has remained consistent since the standard was first introduced in 2002.

Some facilities may question the severity of a non-conforming mark being viewed as a Major Non-Conformance but, given the risk of enforcement action by importing countries and potential delays to imports and demurrage costs, a consistent application of the mark by certified WPM facilities is warranted.

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T. 613.521.6468 or 1.877.224.3555 F. 613.521.1835 or 866.375.1835
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