ISPM 15 pallets and the UK Timber Regulations: what importers must do

Two sets of rules, two different jobs

ISPM 15 is an international standard for wood packaging. It exists because untreated wood packaging is known to carry pests and diseases that harm trees. It applies to the pallets, crates and dunnage holding your goods, whatever the goods are.

The UK Timber Regulations, often shortened to UKTR, are about illegal logging. They apply to the goods themselves when those goods are timber or timber products, such as wooden furniture. The Office for Product Safety and Standards (OPSS) enforces them.

A container of wooden garden furniture on wooden pallets can be caught by both. A container of steel shelving on wooden pallets is caught only by ISPM 15, of these two sets of rules.

ISPM 15: what your packaging must meet

Wood packaging material covers packing cases, boxes, crates, drums, pallets, box pallets, pallet collars, other load boards and dunnage, which is loose wood used to brace or protect goods. Solid wood packaging must meet ISPM 15 when it is imported into Great Britain from any country, and that includes China.

To meet the standard, the wood must be debarked and treated by one of these methods:

• Heat treatment, reaching at least 56°C for 30 continuous minutes throughout the wood, including the core.
• Dielectric heating, such as microwaving, for wood under 20cm across its smallest dimension, holding at least 60°C for one continuous minute throughout.
• Fumigation with methyl bromide or sulphuryl fluoride.

Small pieces of bark can remain if each is under 3cm wide, or if wider pieces have a total surface area under 50 square centimetres.

Treated wood must carry a legible ISPM 15 mark. It shows the IPPC symbol, a two-letter country code, a code for the producer and a code for the treatment, such as HT for heat treatment or MB for methyl bromide. No certificate is needed, and a certificate cannot replace the mark.

These are exempt:

• Processed wood packaging, such as plywood, particle board or oriented strand board made with glue, heat or pressure.
• Raw wood 6mm thick or less.
• Barrels for wine and spirits, and gift boxes made from processed wood.
• Sawdust, shavings and cardboard used as packing.

Checks, and what happens if packaging fails

Any wood packaging can be checked at the border or at inland premises. If it does not comply, it can be rejected or destroyed, and you will need to make other arrangements to move your goods. Plant health inspectors serve notices setting out what must be done, and failing to comply with a notice is an offence.

In practice that means a hold while the problem is sorted out, and a hold at the port uses up free days. Our guide to what can go wrong covers holds and demurrage, and the demurrage calculator shows what a delay could cost. Portside counts down the free days on each container, so a hold does not run on unnoticed.

The UK Timber Regulations in brief

The core rule is that operators must not place illegally harvested timber on the market in Great Britain. The UKTR have applied in Great Britain since 1 January 2021, with the same requirements as the EU Timber Regulation that came before them. Northern Ireland still follows the EU rules.

The regulations split businesses into two roles:

• Operator: anyone who first places timber or timber products on the GB market. If you import wooden goods from China and sell them here, you are normally the operator for those goods.
• Trader: anyone who buys and sells timber or timber products that are already on the GB market. Traders must keep records of who they bought from and who they sold to.

Operators carry the main duty, which is due diligence.

Which goods are in scope

The regulations cover imported and home-grown timber and a wide range of timber products, including composite products such as furniture, and pulp and paper. Where a product mixes recycled and virgin wood, only the virgin timber needs assessing, and each species in a mixed product is considered separately.

Scope is set by commodity code, so not every wooden item is covered. In recent checks OPSS looked at wooden furniture (heading 9403), plywood and laminated panels (4412), fuel wood, chips and waste (4401) and veneer sheets (4408). For other products, such as garden buildings, fencing or wooden homeware, check whether your code is on the list in the regulations, or ask the OPSS enquiries team before you order.

Due diligence in practice

Due diligence has three steps:

1. Gather information: the species, the quantity, the supplier, the country of harvest and evidence that the timber complied with the law there.
2. Assess the risk that the timber was illegally harvested, using the criteria in the regulations.
3. Reduce any risk you find to negligible, by getting more information or having the legality verified.

You can build your own system or use one from a monitoring organisation approved in the UK. Timber with a valid FLEGT licence, which currently means timber from Indonesia, is treated as legal once the licence has been verified.

The country of harvest is not always the country of manufacture. A Chinese furniture factory may use wood grown elsewhere, so ask where the timber was felled, not just where the furniture was made. Questions to put to the factory:

• Which timber species are used in each product.
• Which country, and which region, the timber was harvested in.
• Who supplied the timber to the factory, and what documents show it was legally harvested.
• How much timber goes into each order.
• Whether the supply chain has changed since your last order.

Portside chases factories for paperwork and files documents against each shipment, so your due diligence evidence stays with the container it relates to.

Checks and penalties

OPSS checks are risk-based. Its criteria include the type of product, the country or region of harvest, the species, complex supply chains and high-value timber. Most checks are desk reviews of records and due diligence systems. Between April 2022 and March 2025, OPSS carried out 109 checks and issued 25 notices of remedial action. It brought one prosecution and served one seizure notice covering 26,767 furniture items.

The penalties are serious:

• Placing illegally harvested timber on the market: an unlimited fine, imprisonment, seizure of the timber, or a combination.
• Failing to carry out due diligence, or to maintain and evaluate a due diligence system: an unlimited fine or imprisonment.
• Failing on traceability or record keeping, obstructing an inspector, or ignoring a remedial action notice: an unlimited fine.

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