International Standard for Phytosanitary Measures Number 15 (ISPM15) requires wood packaging material in international trade to be heat-treated and marked with a specific certification stamp. The purpose is to prevent the spread of wood-boring insects and plant pathogens that hitchhike in pallets, crates, and dunnage.

Australia enforces ISPM15 strictly. Non-compliant wood packaging is refused entry, destroyed, or required to be re-exported at the importer’s cost. Yet compliance failures remain common. The Department of Agriculture’s 2024-25 biosecurity compliance report shows that wood packaging non-compliance accounted for approximately 18% of all interceptions at Australian ports and airports.

Why does this keep happening? After reviewing audit reports and interviewing compliance officers, several patterns emerge.

Missing or Incorrect Marks

The most common failure is wood packaging that arrives without the required ISPM15 mark or with marks that don’t meet the standard format. The mark must include:

• The two-letter ISO country code where treatment occurred
• A unique producer/treatment facility number
• The treatment method code (HT for heat treatment, MB for methyl bromide where permitted)
• The IPPC logo

Typical failures:

Mark is painted or stencilled instead of being burned, stamped, or branded. Paint and stencils can be removed or transferred to untreated wood, so they’re not acceptable under ISPM15.

Mark is illegible due to damage or weathering. The mark needs to be readable when the shipment arrives, not just when it was created. Damaged packaging sometimes arrives with partially obliterated marks, and if the certification can’t be verified, the package is non-compliant.

Mark is present on only some pieces of a multi-piece packaging unit. All wood components need to be marked. A pallet with marked stringers but unmarked deck boards fails compliance.

Producer code doesn’t match the approved facility database. ISPM15 marks are only valid when issued by approved treatment facilities. Occasionally, marks appear with facility codes that don’t exist in the IPPC registry or that have been deregistered due to non-compliance.

Partial Compliance

Some shipments arrive with a mix of compliant and non-compliant wood packaging. A pallet that’s mostly ISPM15-treated except for a single replacement board that wasn’t treated. A crate with compliant walls but non-compliant blocking inside.

This happens during repairs or modifications after initial treatment. A warehouse replaces a broken pallet board with untreated timber and ships the pallet. The mark is still present, but the packaging is no longer fully compliant.

From a biosecurity perspective, partial compliance is functionally equivalent to full non-compliance. Pests don’t discriminate — if there’s untreated wood in the shipment, it’s a risk.

Treatment Verification Failures

Compliance officers sometimes sample wood packaging for destructive testing to verify that heat treatment actually occurred. Wood that’s been properly heat-treated to 56°C core temperature for 30 minutes undergoes detectable chemical changes in certain wood components.

Laboratory analysis occasionally finds that marked wood hasn’t been treated to the required standard. This can result from treatment facility equipment failure, inadequate treatment duration, or fraudulent marking of untreated wood.

When verification testing fails, the entire shipment is non-compliant, and the treatment facility that issued the mark may face investigation and potential deregistration.

Prohibited Materials Mixed with Compliant Packaging

Occasionally, shipments arrive with compliant ISPM15 packaging but also contain wood materials that aren’t allowed under any circumstances:

• Bark (even on treated wood): Bark can harbour pests that survive heat treatment.
• Green (unseasoned) wood: Even if heat-treated, green wood’s moisture content makes pest survival more likely during storage and transport.
• Solid wood packaging from specific countries under embargo: Australia bans all solid wood packaging from certain high-risk origins regardless of treatment.

These materials trigger interceptions even when the primary packaging is compliant.

Documentation Issues

Sometimes the wood packaging itself is compliant, but documentation problems create compliance failures:

The phytosanitary certificate doesn’t mention wood packaging treatment. Some countries require explicit declaration of ISPM15 treatment on phytosanitary certificates. Missing this creates doubt about treatment verification.

Treatment date significantly predates shipment date. ISPM15 treatment doesn’t expire, but packaging treated years earlier and stored under unknown conditions raises questions about whether the wood has been re-contaminated or whether post-treatment repairs introduced untreated materials.

High-Risk Origins

Certain origin countries have consistently higher non-compliance rates. This isn’t due to lack of ISPM15 adoption — most major trading partners have implemented the standard — but due to inconsistent enforcement, fraudulent treatment claims, or cultural approaches to compliance that don’t align with Australian expectations.

Shipments from countries with high non-compliance histories face higher inspection rates. This doesn’t prevent non-compliant packaging from arriving, but it does mean it’s more likely to be detected.

The Cost of Non-Compliance

For importers, the consequences are direct and expensive:

Destruction or re-export of non-compliant packaging. This delays the shipment and requires repacking with compliant materials before the goods can enter.

Treatment on arrival (where feasible): Some non-compliance can be resolved by treating the packaging on arrival, but this requires approved treatment facilities, delays delivery, and costs hundreds to thousands of dollars.

Biosecurity Direction requiring future shipments from the same exporter to be inspected at 100% rate instead of the normal risk-based sampling. This increases inspection costs and delays for subsequent shipments.

Infringement notices ranging from $500 to $10,000+ depending on the severity and whether it’s a repeat offence.

For exporters, the consequences include:

Loss of customer relationships when non-compliance causes delivery delays and costs for importers.

Treatment facility deregistration if verification testing shows systematic non-compliance or fraud.

How to Avoid Non-Compliance

Use certified suppliers who are on the IPPC-registered treatment facility list and who have a track record of compliance.

Inspect packaging before shipment. Check that marks are present, legible, and on all wood components. If packaging has been repaired, ensure replacement materials are also treated and marked.

Don’t mix compliant and non-compliant materials. If you’re adding dunnage or blocking, use treated and marked wood, or use non-wood alternatives (plastic, cardboard, foam).

Train staff involved in packaging selection and shipment preparation to recognize ISPM15 marks and understand compliance requirements.

Maintain records linking ISPM15 marks to specific treatment facilities and treatment dates. This makes it easier to resolve questions if compliance is challenged.

The standard isn’t ambiguous. Most non-compliance results from inattention, cost-cutting, or lack of awareness. The consequences — for both importers and Australia’s biosecurity — justify the effort to get it right consistently.