CFIA D-14-02 (9th revision): Heat treatment exemption dropped for EU hardwood exports

What changed

CFIA published the 9th revision of directive D-14-02 (Hardwood Export Program) on April 29, 2026. The update removes a heat treatment exemption that previously applied to certain hardwood shipments destined for the European Union and Norway.

Prior revisions added Norway to the country list (7th) and expanded coverage to chestnut and oak species for EU exports (8th). This version tightens the phytosanitary certificate requirements by eliminating the carve-out that let some consignments skip the heat treatment attestation.

If your business touches Canadian hardwood exports or handles packaging material made from chestnut or oak, the documentation trail just lengthened. More immediately: if you’re bringing back export-rejected loads or coordinating inbound freight on pallets or dunnage made from these species, expect CFIA to ask for proof of treatment at the border.

Why this matters on the import side

Most brokers see D-14-02 as an export directive and tune out. That works until a client’s containerized goods arrive on hardwood pallets or blocking that now require phyto certificates under ISPM 15, and the exporter in Rotterdam assumed the old Canadian exemption still applied.

CBSA doesn’t directly enforce CFIA plant health rules, but the referral happens automatically when the eManifest flags wood packaging material on the cargo description. If the CFIA inspector at the port or sufferance warehouse can’t verify heat treatment (look for the HT stamp and the accredited treatment facility code), the container sits until the importer provides a retroactive certificate or arranges for compliant repackaging.

We’ve seen this twice in the last six weeks at our Montreal sufferance facility: EU-origin machinery arrived on oak blocking, exporter cited the old D-14-02 language, container held four business days while the supplier scrambled to get the treatment facility in Leipzig to issue the cert. Demurrage, storage, and a missed production window.

The compliance gap: export program, import consequence

D-14-02 governs Canadian hardwood exports leaving for the EU and Norway, so the certificate and treatment burden sits with the Canadian exporter. But the mirror image plays out on the import side when EU sellers ship goods to Canada on hardwood packaging and assume reciprocal treatment.

There is no reciprocal exemption. CFIA still requires ISPM 15 compliance for all regulated wood packaging material entering Canada, regardless of what the EU accepts outbound from us. The revision to D-14-02 doesn’t change our import rules, but it does remove a talking point that EU exporters sometimes relied on when they lobbied their own treatment facilities to skip the HT step.

The practical risk: your EU supplier books the container, uses untreated chestnut dunnage because “Canada allows it under D-14-02,” and the load gets refused or held at the port until compliant packaging is sourced. You’re not filing a CAD yet because the goods haven’t released, but you’re paying storage and scrambling to fix someone else’s phyto paperwork.

What to check now

If you’re importing capital equipment, industrial machinery, or bulk raw material from the EU on wooden pallets or blocking, confirm with your supplier that all wood packaging material carries the ISPM 15 HT stamp and that the treatment facility is accredited under their national plant protection organization.

Don’t accept “we ship to Canada all the time” as proof. The exemption language in earlier revisions of D-14-02 created confusion, and some European freight forwarders still cite it when quoting packaging options. The 9th revision removes that ambiguity on the Canadian export side, which means EU sellers have less cover when they try to argue for lighter treatment standards on the return leg.

If your purchase order doesn’t specify ISPM 15 compliance for all wood packaging, add it. If your supplier pushes back or doesn’t know what you’re talking about, that’s a red flag. CFIA will not release the container without the cert or the stamp, and your customs broker can’t force the issue. The compliance gap sits entirely in the phyto space, not the tariff or origin space.

The intersection with drawback and returned goods

One edge case worth noting: Canadian exporters who ship hardwood to the EU under D-14-02 and later face a rejected load or a warranty return now have to document compliance twice. Outbound, they need the updated phyto cert under the 9th revision. Inbound, if the same goods come back to Canada as a returned shipment, CBSA will still ask for proof that the packaging meets ISPM 15, even though it’s Canadian-origin lumber that never left the container.

We filed a duty relief claim last month for a Vancouver exporter whose oak flooring samples were rejected in Oslo and returned to Canada. The outbound phyto cert under D-14-02 was perfect, but the inbound examiner at the port flagged the pallet material because the HT stamp was partially obscured. The client had to provide a letter from the treatment facility confirming the batch number and treatment date. Two-day delay, no duty owing under the returned-goods relief provision, but still a headache.

If you’re handling returned goods or warranty freight that touches hardwood packaging, treat the inbound leg as a fresh import from a phyto perspective. Don’t assume the outbound paperwork will carry you through.

Practical next step

Review your standard purchase order terms for EU and Norway suppliers. Add an explicit ISPM 15 clause that requires HT-stamped packaging and a copy of the treatment facility accreditation cert with every shipment. If your supplier can’t provide it, budget for compliant packaging or plan to rework the load at a Canadian facility before it hits your production line.

CFIA’s revised D-14-02 doesn’t directly change what you owe at the border, but it removes a loophole that European sellers leaned on. That tightening will ripple back into your inbound freight over the next twelve months. Get in touch if you’re seeing phyto holds on EU machinery or raw material and want to audit your supplier’s documentation before the next container ships.

Source: CSCB