Compliance

Dunnage: the compliance blind spot

Everybody knows the pallet needs a stamp. Almost nobody thinks about the offcut wedged against the load to stop it sliding.

Banded stacks of pallets in an outdoor yard under a blue sky, strapped and ready for collection.

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In short

Dunnage — the loose timber used to block, brace, chock and separate freight — is solid wood packaging material and falls squarely under ISPM-15 when a shipment crosses a border. It must be debarked, heat treated and marked exactly like the pallet under the load.

It is the single most common source of compliance failure because it is the one piece of wood in the process that nobody procures deliberately.

Two tall stacks of reclaimed wooden pallets in a warehouse, stamped and stencilled from previous owners, with shrink-wrapped freight behind them.
Inbound cores waiting on the grading line. Every stencil on those stringers belonged to somebody else first.

Why dunnage slips through

Pallets are ordered. Crates are ordered. Dunnage is *found*.

It comes off the scrap rack, out of a dismantled crate, from a length of 2×4 left over from a building project. Nobody raises a purchase order for it, so nobody applies a specification to it, so nobody checks whether it is treated.

It is also invisible in the paperwork. A packing list records the goods; it does not usually record the three wedges holding them still.

That combination — unprocured, unspecified, unrecorded — is precisely why it is the failure mode we see most.

What counts as dunnage

Broader than most people assume:

  • Blocking and bracing timber
  • Chocks and wedges
  • Separator boards between layers
  • Load bars and stanchions where made of wood
  • Skid runners under machinery
  • Cross members inside a crate
  • Battens under a coil or a roll

What is exempt: engineered wood such as plywood and OSB, because manufacturing already destroys pests; and anything under 6 mm thick. A plywood separator sheet is fine. The solid batten under it is not.

Fixing it structurally

The organisational fix is more reliable than the vigilance fix, because vigilance fails at four in the afternoon on a Friday.

  • Procure treated dunnage. Order it with the pallets, in the sections you actually use. We cut and treat blocking to spec alongside pallet orders — it is a line item, not a special request.
  • Store it with the export stock. Same bay, same segregation.
  • Remove untreated scrap from the export dock entirely. Not moved to the corner — removed from the area. If it is not there, it cannot be grabbed.
  • Mark it visibly. Treated dunnage carries the stamp; paint or band it so a loader can tell at a glance from ten feet away.
  • Put it on the packing checklist. One line: 'all timber treated and marked'.

The crate version of the same problem

Crating has an internal equivalent. A crate can be built entirely from treated timber and then have untreated internal bracing added when the item is packed, because bracing is fitted to the item rather than built into the crate.

Same rule, same consequence. Every solid wood component of an export crate falls under the standard: base, frame, slats, lid and internal blocking. See crates, boxes and skids.

If you are packing machinery for export, the timber that stops it moving inside the crate deserves the same attention as the crate itself — and more attention than it usually gets, because internal movement causes most transit damage anyway.

Takeaways

  • Dunnage is solid wood packaging and falls under ISPM-15 like anything else.
  • It fails because it is unprocured, unspecified and unrecorded.
  • Plywood and OSB are exempt; the solid battens next to them are not.
  • Removing untreated scrap from the export dock beats relying on vigilance.

Questions

Asked and answered

Does blocking and bracing need to be heat treated?

Yes, if the shipment crosses a border into a country enforcing ISPM-15. It is solid wood packaging material and is assessed as part of the consignment.

Is plywood dunnage exempt?

Yes. Plywood, OSB and other engineered wood are outside the standard because manufacturing destroys pests. Solid timber used alongside them is not exempt.

Written by

Owen Kessler

Custom Build Shop

Prototypes and production runs. Draws the cut lists, tests them against real loads, then argues with the cut lists.

Disagree with something here? That is genuinely useful to us — several of these articles exist because a customer told us we had it wrong. Use the form at the top of the page or write to the yard directly.

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Terms used here

Definitions live in one place so they cannot drift. Full list in the pallet glossary.

Base
The lowest structural layer of a pallet — bottom deck boards or, on a skid, the runners themselves.
Dunnage
Loose timber used to brace, block and protect freight in transit. Falls under ISPM-15 for export.
Frame
A heavily worn pallet retaining structural soundness but minimal deck. Sometimes called Grade 3.
ISPM-15
The international standard governing treatment and marking of wood packaging in international trade.
Runner
A lengthwise support member under a load or a skid deck, providing fork clearance.
Skid
A pallet with a top deck only, sitting on runners. Easier to drag, not compatible with a standard pallet jack.

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