AHEC REPORT AHEC TRADE
AHEC REPORT AHEC TRADE ALERT: CHANGES TO EU PHYTOSANITARY REQUIREMENTS As many of you are aware, there has been considerable confusion surrounding several changes to the EU phytosanitary regulations that were introduced October 1, 2014. These changes are set out in European Commission Implementing Directive 2014/78/EU of June 17, 2014, which amends the Annexes to the European Council Plant Health Directive 2000/29/EC. Some of the new measures are clearly burdensome and, we believe, disproportionate to the risk involved. There are particularly onerous requirements for Ash from EAB affected areas and for all Birch to be bark-free with at least 2.5 cm of outer sapwood removed. (The situation is complicated further by APHIS’ issue of guidance implying that the EU’s 2.5 cm ruling applies not only to Ash and Birch, but also to Maple and Oak. This guidance on Oak and Maple is inaccurate and neither species is subject to the 2.5 cm ruling.) AHEC is now consulting with APHIS to ensure their guidance is clarified. This requirement was introduced by the EU following their internal appraisal of existing phytosanitary measures in North America and an ambiguous summary of scientific evidence compiled by the European Plant Protection Organization (EPPO). The EU appears to have been particularly influenced by Canada’s decision in March 2012 to require the removal of 2.5 cm of sapwood from green Ash lumber imported from EAB controlled areas in the U.S. This is despite the fact that Canada has always recognized kiln drying as an alternative treatment for EAB and also reduced their requirement for removal of sapwood in green lumber from 2.5 cm to 1 cm in March this year. Regrettably the EU did not consult on these measures and provided no advance warning to the industry. AHEC is now taking steps to challenge the new ruling on Ash and Birch. However, given the slow pace of decision-making in the EU, we do not know how long the measures will be in place. The following sets out AHEC’s understanding of the official requirements introduced by the EU from October based on detailed scrutiny of the new legal text and recent correspondence with EU Plant Health authorities. This information will be updated depending on the success of our-ongoing efforts to overturn the most burdensome measures. ASH MUST HAVE 2.5 CM OF SAPWOOD REMOVED Before October 1, 2014, import of Ash of U.S. origin into the EU required a phyto certificate to indicate that the wood either: (a) originates in an area established by APHIS as being free from Emerald Ash Borer (EAB); or (b) is squared so as to remove entirely the round surface. From October 1, 2014, the rule is amended so that the phyto certificate must indicate that the wood either: (a) originates in an area established by APHIS as being free from EAB (i.e. no change for such wood) or (b) the bark and at least 2.5 cm of the outer sapwood are removed in a facility authorized and supervised by the national plant protection organization; or (c) has undergone ionizing irradiation to achieve a minimum absorbed dose of 1 kGy throughout the wood. BIRCH CONTROLLED FOR THE FIRST TIME The new regulation imposes new controls on imports of Birch similar to those applied to Ash, in this case to control spread of the bronze Birch borer (Agrilus anxius Gory). From October 1, 2014, all Birch imported into the EU from the U.S. must be accompanied by a phytosanitary certificate indicating that: (a) its bark and at least 2.5 cm of the outer sapwood have been removed in a facility authorized and supervised by the national plant protection organization; or (b) the wood has undergone ionizing irradiation to achieve a minimum absorbed dose of 1 kGy throughout the wood. NO CHANGE TO EU RULES FOR IMPORTS OF SAWN OAK AND MAPLE In recent weeks, some exporting companies have been under the impression that the new EU regulations will require that all sawn U.S. Oak and Maple must be entirely free from all bark and the sapwood removed to a depth of 2.5 cm. AHEC Members are advised that this rumor is unfounded. The rumor is the result of amendments made on July 10, 2014, to the APHIS (NOT the EU) definition of “bark freedom” in the European Union (EUN) Summary and Additional Declaration Glossary of the Phytosanitary Export Database (PExD) System. PExD is the APHIS system setting out phytosanitary import requirements of U.S.-origin commodities to foreign countries. The APHIS guidance states that “Bark freedom is now defined as the removal of all bark and at least 2.5 cm (1 inch) of the outer sapwood. Wherever bark freedom is required in PExD, it must meet this new definition.” APHIS then provided examples implying that their new definition of “bark free” applied to all wood irrespective of species. The APHIS PExD guidance therefore gives the impression that the 2.5 cm rule is a broadly applicable new definition of “bark free” in the EU regulation, whereas it actually only replaces the reference to “squared so as to remove entirely the rounded surface” specifically in relation to Ash for control of EAB. APHIS’ new PExD definition of “bark-free” is not aligned to the EU definition, which is that contained in the International Plant Protection Conventions (IPPCs) as stated in ISPM5 ‘Glossary of BY MICHAEL S. SNOW, EXECUTIVE DIRECTOR, AMERICAN HARDWOOD EXPORT COUNCIL RESTON, VA 703-435-2900 www.ahec.org Please turn to page 57 12 NOVEMBER 2014 ■ NATIONAL HARDWOOD MAGAZINE
NWFA FLOORING REVIEW HOW LEED’S CHANGES IMPACT OUR INDUSTRY Significant buzz has been generated during the past few years about environmentally friendly building products. One thing environmentalists agree upon, as we’ve learned through the development of our responsible procurement program, is that wood is the most abundantly renewable building material available. All other building materials use more energy to produce than wood through increased energy consumption, greenhouse gas emissions, and waste production. Sustainable forest management makes it possible to harvest wood without any serious environmental impact because trees are a renewable resource that can be replaced time and time again. Fortunately for our industry, one of the most-recognized green building programs, the United States Green Building Council’s Leadership in Energy and Environmental Design (LEED) program, recently made some significant changes to its recognition of wood as a green building product. The program was developed in 1993 to promote green building practices. Established as a green building certification program, LEED is certifying 1.5 million square feet of building space each day in 135 countries. To participate, construction projects earn points toward different levels of certification by adhering to specific green building principles. Recognizing wood is one of the areas where LEED v4 made changes. The most significant credit for wood is “building product disclosure and optimization – sourcing of raw materials,” which is eligible for a possible two points. The intent of this credit is to encourage the use of products and materials for which life cycle information is available and that have environmentally, economically and socially preferable life cycle impacts, and to reward projects that utilize products verified to have been extracted or sourced in a responsible manner. One point can be obtained for meeting each of these two criteria. In conjunction with the U.S. Lacey Act, which was established more than 100 years ago to prohibit the illegal trafficking of wildlife, and amended in 2008 to include wood and wood products, LEED v4 has given domestic wood species a new focus as a sustainable and environmentally friendly building product. Lacey specifically prohibits the import, sale or trade of illegally harvested wood. This has made it more difficult to import wood from other countries into the U.S., which has impacted the sale of domestic wood species with American consumers. In particular, the growth of “domestic exotic” species has risen as cases of Lacey Act violations hit the mainstream media. Domestic exotic wood species are species that are grown in the United States, but traditionally have not been used in con- struction. For example, the majority of homes in the U.S. with wood flooring utilize either Red Oak or White Oak, which accounts for more than 50 percent of current U.S. flooring sales. Maple is another prominent flooring species within the U.S., but rising in popularity are species that provide a completely different look, including Hickory and Walnut. The popularity of Hickory, in particular, has risen dramatically in recent years. Historically, Hickory has been ignored as a flooring or cabinet material. It is a slow-growing species when compared to other domestic trees, the grain pattern is irregular, its color varies dramatically between springwood and summerwood, and it is extremely dense, which makes it difficult to sand. As a comparison, on the Janka scale, which identifies the relative hardness of wood species, Hickory is rated at 1,820, while Red Oak is rated at 1,290, and White Oak is rated at 1,360. These perceived drawbacks from yesteryear, however, are exactly what make Hickory appealing as a flooring material today. Consumers are increasingly looking for wood species that reflect a more rustic decorating style, and that make small imperfections like minor scratches or dents less noticeable. Hickory meets this demand. It contains a wide variety of color, even within the same boards, an abundance of character marks, like knots and mineral streaks, and an inconsistent grain pattern, which is a departure from the straight-grain patterns consistent with Oak and Maple species. Added to this is the fact that Hickory is harder than traditional U.S. species, making it more durable, and it is a natural as a flooring or cabinet material that is suited to a busy family lifestyle. Hickory and other species like it are poised to continue to grow in popularity, both in response to the Lacey Act, and to LEED v4. You can learn more about different wood species used as flooring from the National Wood Flooring Association. Simply visit www.woodfloors.org and click on Species under the About Hardwood Floors link, or contact the NWFA at 800-422-4556. ■ BRETT MILLER, DIRECTOR OF CERTIFICATION & EDUCATION, NATIONAL WOOD FLOORING ASSOCIATION, CHESTERFIELD, MO 800-422-4556 (USA AND CANADA) 636-519-9663 (INTERNATIONAL) www.nwfa.org NOVEMBER 2014 ■ NATIONAL HARDWOOD MAGAZINE 13
