CFIA and IPPC Draft ISPM Consultations: What Importers Should Watch Before September 30

Draft ISPMs Are Open for Comment Until September 30

The International Plant Protection Convention secretariat has opened first and second consultation on a slate of draft International Standards for Phytosanitary Measures (ISPMs), with submissions due September 30, 2026. The drafts include an annex on international movement of citrus fruit and several other specifications. Most Canadian importers will never read them, but if you bring in fresh produce, cut flowers, nursery stock, or containerized freight with wood dunnage, these standards eventually become CFIA inspection protocols and OGD release conditions at the port.

The consultation page is hosted at IPPC’s member consultation portal. Canada participates through the CFIA, and industry comments are usually funneled through sector associations or brokers who deal with phytosanitary certificates daily. If your shipment profile includes regulated commodities, it’s worth knowing what’s in the draft pipeline, because once an ISPM is adopted and Canada signs on, the CFIA updates its import requirements and your broker sees new documentary demands or inspection triggers in the system.

How ISPM Changes Show Up in Your Release Timeline

When a new ISPM is ratified, the CFIA typically amends its Automated Import Reference System (AIRS) decision trees. That means a HS code or country-of-origin combination that used to clear on PARS or RMD may suddenly flag for OGD hold. Your customs broker files the CAD, CBSA releases for examination or direct release, but the CFIA hold sits on top until the inspector reviews the phytosanitary certificate, treatment records, or facility registration.

The delay is usually one to three working days if the paperwork is clean and the inspector is on-site. If the certificate is missing a required declaration box or the treatment code doesn’t match the new ISPM annex, the container sits until the overseas shipper or exporter corrects and reissues. We’ve seen that stretch to two weeks when the exporter is in a different time zone and the CFIA won’t accept email amendments.

For fresh produce, that delay is product loss. For cut flowers, it’s complete write-off. For wood packaging (pallets, crates, dunnage), the shipment may be refused entry or forced to treatment at the importer’s cost. The standard you want to watch is ISPM 15, which governs wood packaging material. Revisions to that annex tend to tighten treatment protocols or add new pest concerns, and enforcement ramps up within months of adoption.

Citrus Annex and Tropical Fruit: Why It Matters

The draft annex on international movement of citrus fruit is part of a broader ISPM series covering commodity-specific pathways. Citrus imports into Canada from the U.S., Mexico, South Africa, and Chile are already subject to phytosanitary certification, and the CFIA maintains a list of approved facilities and treatment protocols by country. Any change to the ISPM annex usually triggers a review of that approved-facility list.

If the new annex adds a cold-treatment requirement, importers may need to provide temperature-monitoring logs for the entire voyage. If it restricts certain pest-prevalent regions, the CFIA may suspend or audit facilities in those areas, and your supplier may lose their certification mid-season. We’ve handled entries where a Peruvian mango packinghouse was delisted two weeks into a contract, and the importer had to switch suppliers or face automatic refusal at the border.

For compliance planning, check the CFIA’s automated import reference system and import requirements database quarterly. The CFIA doesn’t always publish advance notice when an ISPM change is coming, but they do update AIRS within 30 days of adopting a new standard. If you’re locking in a Q4 produce contract now, ask your broker to pull the current AIRS decision tree for your HS code and country pair, and flag any recent changes.

OGD Hold and Dwell Cost at the Port

When a CFIA hold lands, the container is typically delivered to your Montreal sufferance warehouse or direct to a CFIA-approved facility where the inspector can access it. Dwell fees start the day after free time expires, and for perishables that’s often within 24 hours of arrival. At Port of Montreal, container free time is typically two to three working days, but if the CFIA hold extends past that, you’re paying drayage detention, warehouse storage, and reefer monitoring if it’s temperature-controlled.

The cost stack for a four-day CFIA hold on a reefer container can run CAD 800 to CAD 1,200 in combined dwell and power fees, plus the risk of product degradation. If the inspector orders a treatment or fumigation, add another CAD 1,500 to CAD 3,000 depending on the treatment provider and container size. That expense is unrecoverable unless your purchase contract explicitly assigns phytosanitary compliance risk to the seller.

For non-perishable commodities (wood furniture, pottery with wood crating, machinery on wooden skids), the financial hit is smaller but the scheduling impact is the same. If your buyer is expecting a just-in-time delivery and the CFIA holds the container for five days, your downstream customer may cancel or assess late penalties.

What to Do Before September 30

If you import regulated commodities and you’re part of a sector association (Canadian Produce Marketing Association, Canadian Horticultural Council, Canadian Nursery Landscape Association), forward the IPPC consultation link to your technical committee. Industry comments carry more weight when they’re consolidated and submitted through the CFIA’s stakeholder process.

If you’re not part of an association, ask your broker to review the draft ISPMs that touch your product category. Most brokers who handle fresh produce or wood packaging subscribe to CFIA notices and can tell you whether the draft standard will change your documentary requirements or add new inspection triggers. If it does, you have until September 30 to submit a comment through the IPPC portal or through the CFIA’s consultation coordinator.

The other step is to audit your current phytosanitary certificate process with your overseas suppliers. If the exporter is using a generic certificate template that just barely meets today’s requirements, any tightening in the ISPM will push them out of compliance. Ask them to share a sample certificate and check it against the draft annex requirements. If gaps exist, now is the time to fix the template, not three months after the new standard takes effect and your first shipment is sitting in exam.

Filing CADs Against OGD Holds

Once the CFIA releases, your broker completes the CAD and CBSA processes payment or posts to your RPP bond. The OGD hold doesn’t delay the CAD filing itself, but it does hold the cargo from physical release, which means you’re accruing dwell even though the customs side is complete. If you’re new to CARM, that distinction matters: your K84 monthly statement will show the entry as accounted, but your warehouse will still be billing storage until the CFIA inspector signs off.

For routine OGD holds (wood packaging inspection, certificate review), our brokerage team files the CAD as soon as CBSA releases the entry for examination, and we notify the importer that CFIA hold is in place. For high-risk shipments (first-time supplier, pest-intercept history, country under CFIA audit), we recommend pre-clearing the phytosanitary certificate with CFIA’s regional import service centre before the container arrives. That consultation adds two to three business days on the front end but eliminates the risk of a week-long hold at the port.

If your import profile includes regulated plants, seeds, soil, or untreated wood, it’s also worth reviewing CFIA’s compliance and enforcement posture annually. Penalty assessment for phytosanitary violations has increased since CARM went live, and repeat violations can trigger facility audits or importer registration suspension.

Next IPPC Review Cycle

The IPPC runs member consultations twice a year, typically in spring and fall. The September 30 deadline applies to this round of drafts, but new ISPMs and amendments are always in the pipeline. If you want to stay ahead, bookmark the IPPC standards page and check it quarterly. The CFIA doesn’t always publish a domestic notice when an ISPM is under consultation, so you’re relying on either your broker or your own monitoring.

For importers who handle containerized freight with wood packaging but not regulated commodities, the key standard is still ISPM 15. Any revision to heat-treatment or methyl-bromide protocols will hit your supply chain within six months of adoption. If your overseas suppliers are using non-certified pallets or recycled crating, flag that now. CBSA and CFIA have ramped up wood-packaging inspections at Port of Montreal and Vancouver, and refusal rates are climbing.

If the draft ISPM annex is going to change your documentary requirements or add a new treatment protocol, the time to adjust your supplier contracts and certificate templates is before the standard is adopted. After that, you’re reacting to holds at the port instead of preventing them.

We file CADs against CFIA holds weekly, and we track which suppliers and countries are flagged most often. If your phytosanitary compliance process hasn’t been reviewed since before CARM, get in touch.

Source: CSCB