Case Overview
A company imported a batch of "used integrated circuit imaging scanners" under general trade and declared the goods to Customs. Upon inspection, Customs identified that the shipment contained natural wood packaging bearing IPPC label, which had not been declared for quarantine inspection. The company’s failure to declare the wood packaging of imported goods for inspection constituted a violation of Article 12 of the People's Republic of China on the Entry and Exit Animal and Plant Quarantine, and was treated as a regulatory offense. Accordingly, Customs applied administrative penalties in accordance with the law.
Key Analysis
Why is the IPPC Label Required for Wood Packaging in this Case?
Pursuant to the Administrative measures on quarantine and supervision for importation of wood packaging materials, wood packaging used for imported goods must undergo approved phytosanitary treatment under the supervision of the plant quarantine authority of the exporting country, in accordance with the International Standards for Phytosanitary Measures No. 15 (hereinafter referred to as ISPM 15) - Guidelines for Regulating Wood Packaging Material in International Trade, and thus be marked with the IPPC label. Wood packaging arriving without a valid or compliant IPPC label does not satisfy the statutory entry requirements under Chinese laws and regulations.
IPPC denotes the International Plant Protection Convention. China acceded to the IPPC on October 20, 2005.In line with ISPM15, when goods in international trade are furnished with wood packaging that has been properly treated and bears the IPPC label, no separate phytosanitary certificate is required for such wood packaging, as the label is mutually recognized by all contracting parties. Notably, wood packaging includes wood materials such as wooden boxes, crates, pallets, frames, barrels, spools, wedges, dunnages, sleepers, and lining wood, used for containing, packaging, bracing, supporting, or securing cargo.
The vast majority of wood packaging used in cross-border shipments must carry the IPPC label, with the following cases excluded: IPPC label is not required for wood packaging materials that have undergone sufficient processing such as being artificially synthesized, heated, pressurized, or otherwise deeply processed, to eliminate pest risks, thereby exempting them from specific treatment requirements. This exemption applies to wooden cases, pallets or other items made entirely from reconstituted wood products, such as plywood, particleboard, or fiberboard; items composed entirely of wood pieces less than 6 mm in thickness (including wood shavings and chips); and certain processed wooden articles for packaging (e.g., wine barrels, wooden gift boxes) that have been treated during their manufacturing process.
Customs Quarantine Procedures for Wood Packaging of Imported Goods
Pursuant to the Administrative measures on quarantine and supervision for importation of wood packaging materials, where imported goods involve the use of wood packaging, the owner or their agent shall declare such packaging to Customs for quarantine inspection. For wood packaging bearing the IPPC label, Customs shall conduct sampling inspections in accordance with relevant regulations. Goods shall be released if no live pests are detected, whereas upon the detecting of any live pests, the owner or their agent must ensure that the required phytosanitary treatments conducted to the satisfaction of Customs. For wood packaging without the IPPC label, such packaging shall undergo either phytosanitary treatment or destruction under Customs supervision. In cases where the labeling status of IPPC cannot be determined at the time of declaration, Customs shall conduct sampling inspections as stipulated and handle the packaging pursuant to the aforementioned provisions.
Legal Consequences for Failure to Declare Wood Packaging of Imported Goods for Quarantine
In accordance with item 1, paragraph (1) under Article 39 of the People's Republic of China on the Entry and Exit Animal and Plant Quarantine, item 1, paragraph (1) under Article 59 of the Regulations for the Implementation of the Law of the People's Republic of China on the Entry and Exit Animal and Plant Quarantine, and item 1, paragraph (1) under Article 17 of the Administrative measures on quarantine and supervision for importation of wood packaging materials, Customs shall impose an administrative penalty in the form of a fine of up to 5,000 yuan on the owner or their agent for using undeclared wood packaging for imported goods, with the specific amount determined according to the severity of the case. Where a violation involving wood packaging is deemed serious, the competent Customs authority shall, upon reporting to and obtaining approval from the General Administration of Customs, ensure that the owner or their agent returns the entire shipment, including both the goods and the packaging, to its satisfaction.
It should be noted that, as stipulated in Article 21 and Article 22 of Annex 4 Discretion Benchmark of the Customs for Common Cases under Summary Procedures and Expedited Handling of Administrative Penalties (II) of the Announcement No. 21 [2025] of the General Administration of Customs’ Announcement on Issuing the Discretion Benchmark of the Customs of the People's Republic of China for Administrative Penalties (II), the penalty for using wood packaging of imported goods without an IPPC label and failing to declare it, ranging from a minimum of a warning to a maximum fine of 3,700 yuan based on severity, is significantly heavier than that for failing to declare wood packaging bearing a valid IPPC label, which carries a penalty ranging from a warning to a maximum fine of 1,500 yuan based on severity.
Case Implications and Guidance
Consignees and Customs declarants must fully recognize the importance of accurately declaring information on wood packaging for imported goods. They are required to truthfully provide and submit authentic documentation, with particular attention to verifying whether the wood packaging of imported goods bears the IPPC label. Furthermore, for goods subject to wood packaging quarantine, enterprises are prohibited from unauthorized removal of the goods from the means of transport or the shipment, as well as the dismantling or abandonment of the wood packaging without Customs approval, except under special circumstances.
(by an author from Shenzhen Customs)
