I posted earlier about DEFRA Brexit guidance on importing and exporting plants and plant products after exit day, and this guidance was updated on 21st February – here.
The UK guidance identifies that all Wood Packaging Material (including pallets) – WPM – moving between the UK and the EU would need to meet ISPM15 international standards by undergoing heat treatment and marking. In addition, WPM might be subject to official checks either upon or after entry to the EU.
In practice, not having the ISPM15 stamp on the pallet on checking is a main cause of goods being resealed and sent back.
The National Standards Authority of Ireland (NSAI) includes the pallet aspect in its Brexit Factsheet on Green Procurement Certification – here.
The NSAI Brexit Factsheet confirms the following :
(1) Unless a ratified withdrawal agreement establishes another date or the European Council, in accordance with Article 50(3) of the Treaty on European Union and in agreement with the UK, unanimously decides that the Treaties cease to apply at a later date, all Union primary and secondary law will cease to apply to the UK from 30 March 2019.
(2) The UK will then become a third country (from 30 March 2019) and as such trade in goods and service between the UK and the EU will be affected. It will have an impact not only on the goods exported from Ireland but also imported goods that come into Ireland from the UK.
(3) In the EU procurement market, economic operators from the UK will have “third party” status as all other economic operators based in a third country with which the EU does not have any agreement and will be subject to the same rules as any third country tenderer.
(4) In the event of the UK leaving the EU in March 2019 without a withdrawal agreement all Wood Packaging Material (WPM) being imported from the UK to the EU (including Ireland) will need to be ISPM 15 compliant which is not currently required.
ISPM 15 is an internationally recognised phytosanitary measure that establishes standards for the treatment and marking of WPM (pallets, crates, dunnage etc.) and affects all WPM used in international trade.
The WPM associated with these products may be subject to official checks either upon entry to the EU (including Ireland) or after entry.
The UK may introduce reciprocal arrangements requiring EU (including Ireland) exporters to the UK to ensure WPM arriving in the UK from the EU is ISPM15 compliant.
(5) The Department of Agriculture, Food and the Marine (DAFM) is responsible for implementing the ISPM 15 scheme in Ireland. NSAI carries out audits of companies registered to the ISPM 15 scheme on DAFM’s behalf.