Who must comply with ISPM 15? Stakeholders, roles, and responsibilities

Overview

Compliance with International Standards for Phytosanitary Measures No. 15 (ISPM 15) is not the responsibility of a single actor. The standard creates an obligation framework that spans international organizations, national plant protection authorities, private-sector producers and users of wood packaging material (WPM), and frontline enforcement personnel at points of entry. Understanding who must comply and what each stakeholder must do is essential to practical implementation and to maintaining efficient international trade.

International bodies

The International Plant Protection Convention (IPPC), administered by the Food and Agriculture Organization of the United Nations, develops and maintains ISPM 15. The IPPC itself is not an enforcement body; rather, it issues the standard and provides technical guidance. Its contracting parties agree to adopt and implement its standards through their national plant protection organizations.

National Plant Protection Organizations (NPPOs)

NPPOs are the primary implementers and regulators of ISPM 15 at the national level. NPPO responsibilities include authorizing and auditing treatment providers and stamping facilities, issuing producer identification codes, establishing national implementation rules, and conducting inspections at borders. Examples include USDA APHIS in the United States, CFIA in Canada, and the European national plant protection organizations operating under EU legislation. NPPOs also maintain lists of recognized facilities and treatment providers and publish guidance for exporters and importers.

Wood packaging manufacturers and treatment providers

Pallet makers, crate builders, dunnage suppliers, and other manufacturers of non-manufactured wood packaging are subject to ISPM 15 when producing WPM for international shipment. Their responsibilities include ensuring wood is appropriately treated (commonly heat treatment or approved fumigation), applying the official ISPM 15 mark with the correct country and producer codes and treatment code, and maintaining traceability records. Treatment providers and facilities that perform heat treatments or fumigations must be authorized by the NPPO and follow documented procedures, monitor treatment parameters, and retain treatment records for audit.

Exporters and importers

Exporters must ensure that the wood packaging accompanying their shipments complies with ISPM 15 before export. This includes verifying that pallets and crates are marked correctly, that treatment certificates or documentation are in order where needed, and that repackaging or repairs do not breach marking or treatment integrity. Importers are responsible for ensuring incoming consignments meet the importing country’s phytosanitary requirements and for cooperating with inspections, re-treatment, or corrective measures if non-compliance is found. Freight forwarders and customs brokers commonly assist in these verifications.

Carriers, freight forwarders, and warehousing providers

Carriers and logistics service providers frequently handle WPM in transit and storage. Their responsibilities include avoiding unapproved repairs that alter ISPM 15 marks, segregating suspect or damaged WPM for assessment, and notifying shippers or NPPOs of detected issues. Warehouse operators and fulfillment centers that use or re-use pallets for international shipments should ensure that in-house recycled pallets are repaired or re-certified in accordance with NPPO guidance and that records of repairs and treatments are maintained.

Port and customs authorities, quarantine inspectors

Inspectors at ports of entry and customs authorities are empowered to examine shipments and verify ISPM 15 compliance. If WPM is non-compliant or unmarked, inspectors may require treatment, re-export, destruction, or other phytosanitary measures. Quarantine authorities often coordinate with NPPOs to issue detention notices and to apply penalties when appropriate.

Pallet recyclers and secondary markets

Companies that refurbish, repair, or resell used pallets play a pivotal role. When pallets are repaired, the ISPM 15 mark may no longer be valid and re-treatment or re-marking under NPPO authorization may be required. Recyclers must ensure that repaired or repurposed WPM destined for export complies with marking and treatment rules.

Certification bodies and auditors

Where NPPOs delegate auditing or certification functions, accredited third-party auditors may inspect facilities, review records, and verify marking accuracy. These organizations help sustain compliance across large supply chains.

Responsibilities and practical implications

Responsibility is distributed: NPPOs set and enforce rules; manufacturers and treatment providers perform and document treatments and apply marks; exporters verify compliance prior to shipping; importers and inspectors verify at arrival. Failure at any link can trigger quarantine actions, delays, fines, and re-export or destruction costs. To reduce risk, stakeholders should implement documented quality and traceability practices, train staff on ISPM 15 requirements, and adopt supplier verification programs.

Common compliance failures

Typical problems include incorrect or illegible markings, use of unauthorized treatment codes, failure to re-treat or re-mark repaired pallets, reliance on unapproved treatment methods, and lack of records. These issues generally stem from unclear internal controls, lack of awareness of national NPPO rules, or informal pallet reuse practices that fail to consider international destination requirements.

Practical steps for each stakeholder

• NPPOs: Publish clear implementation guidance, maintain authorized provider lists, and run outreach programs.

• Manufacturers: Use only NPPO-authorized treatments, apply proper marks, and keep treatment logs.

• Exporters/importers: Integrate ISPM 15 checks into shipment readiness workflows and document verification steps.

• Carriers and warehouses: Implement handling protocols that avoid unauthorized repairs and keep records of pallet usage for export.

• Pallet recyclers: Verify the export intent of pallets and re-treat/re-mark under NPPO guidance when required.

Conclusion

ISPM 15 compliance is a shared responsibility that reaches across the international trade ecosystem. Understanding the roles and obligations of each stakeholder — from the IPPC and NPPOs to pallet makers, exporters, and port inspectors — is essential to preventing the introduction and spread of wood-borne pests while maintaining efficient global supply chains.