Federal & Regulatory Issue Updates

The NWPCA is the world's largest international organization of wood packaging professionals. The wooden pallet industry is an $11.5 billion American success story, and nearly 3,000 mostly small family businesses operate in all 50 states and almost every Congressional district.

We are integral to the American supply chain and logistics industry, from forest and farm to factory and fork. While the pallet industry contends with the same issues as most American businesses and manufacturers, it has its own specific issues, including those below. If you have any questions about these or other issues, please contact us.

Farm Bill

On May 1, 2024, the Senate Agriculture Committee Democrats released their Farm Bill framework. This marks the first time that NWPCA's proactive policy agenda has been reflected in a Farm Bill. The framework includes priorities, such as strengthening and improving the USDA BioPreferred® Program and promoting wood product research, especially in the carbon emissions space. Importantly, the framework does not include policies that would disrupt critical programs like ISPM-15 and international trade.

• Issue Brief: Farm Bill Update
  

Packaging and Packaging Waste Regulation

In November 2022, the European Commission, the EU’s executive arm, proposed a new piece of legislation called the Packaging and Packaging Waste Regulation (PPWR). The PPWR’s rules apply to all packaging placed on the EU market. NWPCA engaged and strategically advocated for exemptions to certain elements of PPWR using various arguments.

• Issue Brief: PPWR
• FAQ: Implementation of the EU Deforestation Regulation (Note Question 32)   

Lacey Act Declaration for Wood Packaging

Effective October 1, 2021, new declaration requirements exist for US imports of ‘empty’ wood packaging. NWPCA has resources to help members better understand what this means for wooden pallet importers, international manufacturers, recyclers, brokers, and the new responsibilities under the Lacey Act.

• NWPCA Resources & Updates
• Do I need a Lacey Act Declaration? - USDA, APHIS

Invasive Species

As per Executive Order 13112, an "invasive species" is defined as a species that is 1) non-native (or alien) to the ecosystem under consideration and 2) whose introduction causes or is likely to cause economic or environmental harm or harm to human health. Invasive species can be plants, animals, and other organisms.

• Issue Brief: Emerald Ash Borer
• Issue Brief: ISPM 15 & Export Treatment
  
• Link to USDA-APHIS

Labor & the Workforce

The Manufacturing Institute (MI), in partnership with the NWPCA, conducted a study on the workforce challenges facing this industry from March to May 2023. This project aimed to identify the key issues that wooden pallet companies are tackling, solutions that are being tested, recommendations for the industry and ways NWPCA can support its members. The study consisted of an online survey and in-depth interviews with industry leaders.

• Link to Executive Summary
• Link to Full Report (NWPCA Member login)

Corrugated Pallets Fail Oregon State Tests

House Bill 4089 was introduced in the Oregon legislature to give a purchasing preference to corrugated pallets over wood pallets. NWPCA worked closely with organizations in Oregon and the WPA on countering this initiative which was ultimately defeated. The Oregon Dept. of Corrections eventually analyzed and turned down a proposed pilot program due to cost and viability issues.

• Link to Oregon DOC Report
• Issue Brief: Wooden Pallets Compared to Corrugated Cardboard Pallets.

International Code Council Update

A proposal before the International Code Council (ICC) would have eliminated up to 60% of this industry’s outdoor pallet storage space.

• Issue Brief: ICC Outdoor Pallet Storage, Code Proposals
• Link to International Code Council

Food Safety Modernization Act

The FDA Food Safety Modernization Act (FSMA) was signed into law and aimed to ensure the U.S. food supply is safe by shifting the focus of federal regulators from responding to contamination to preventing it.

• Issue Brief: Food & Pharma Sanitary Transport
• Link to FDA's Sanitary Transportation Final Rule: FAQs for Pallets
• Link to Food and Pharma FAQ-Treatment of Pallets and Wood Crates