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APHIS Provides Details on Enforcement of ISPM-15 Marking Requirements on Jan. 1, 2026

The USDA Animal and Plant Health Inspection Service (APHIS) continues to remind the trade that the temporary suspension of the hyphen requirement for ISPM‑15 markings on Wood Packaging Material will end on Dec. 31, 2025. 

As you may recall, the ISPM-15 hyphen requirement is a component of the international standard that mandates a hyphen to separate the country code from the facility code in the compliance mark. In March, APHIS temporarily suspended enforcement of the hyphen requirement earlier this year because so many shipments were arriving with no hyphen. 

Beginning Jan. 1, 2026, all Wood Packaging Material (WPM) must fully comply with the ISPM-15 hyphen. There will NOT be a period of soft enforcement.

The NCBFAA Regulatory Agencies Committee (RAC) reached out to APHIS to ask what enforcement of the ISPM-15 hyphen requirement for WPM will look like on Jan. 1. APHIS provided the following guidance:

Message from APHIS to the Trade

APHIS and CBP are working closely together to support a smooth transition and minimize disruptions for stakeholders. Both agencies have made significant efforts to ensure the trade community is well-informed. Initial notifications were issued in March, and since November, we’ve continued outreach through multiple stakeholder announcements, Trade Issue Notices (TINs), and posts on social media platforms including Facebook and X. These communications are part of a coordinated effort to provide clarity and ample time for industry partners to prepare for the enforcement restart.

Once enforcement resumes, the following actions may apply to non-compliant shipments:

• Cargo may be held at the port of arrival. Depending on port operations and capacity, separation of the WPM from the cargo may be offered, allowing the WPM to be exported while the cargo is retained.

• Re-export may be required. If separation is not feasible or corrective action is unavailable, the shipment may be refused entry and require full re-export.

• Penalties may be assessed. CBP may assess penalties under Title 19, depending on the nature of the violation.

• Reconditioning options. If a compliance company becomes operational for Shredder/Hammermiller, that could provide a viable reconditioning pathway. However, at this time, companies are still in the process of sourcing the necessary equipment, and no compliance agreements have been issued.

For shipments currently en-route (with noncompliant WPM), but that will not arrive in the U.S. prior to December 31, importers have two options:

1. Divert the shipment to another country where the WPM can be reconditioned to meet compliance standards.
2. Self-report the noncompliance to APHIS and CBP and initiate the process in advance. This proactive approach may help expedite handling upon arrival.

We understand the challenges this may present and want to emphasize that our goal is to work with stakeholders to ensure compliance while minimizing disruptions. Please don’t hesitate to reach out with any further questions or if we can assist in any way.

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