
Brassware From India, US Duty and Lead Rules
Which Indian town makes which brass, why one bowl can pay 50% or about 10% at the US border depending on its code, and how lead rules (FDA, Prop 65, CPSIA) reach importers.
10 min read
ISPM 15 is the international rule for raw wood packaging such as pallets, crates and dunnage: it must be debarked, treated and marked, whatever the product inside. This guide explains how to read the mark, what is exempt, what each market does without it, and the purchase order clause to use for Indian shipments.
The goods can be perfect and the paperwork spotless, and your container still sits at the port because of the pallet underneath. In May 2026 an Australian clearance firm put it bluntly: "a missing ISPM 15 stamp on a wooden pallet or an unverified furniture treatment can stop your entire delivery in its tracks" (LinkedIn, Australian clearance firm, May 2026 (opens in a new tab)). That firm sells clearance, so read it as a warning from someone with an interest. But the rule behind it is real, and it applies in every big import market.

This guide follows one shipment through that rule - an Indian container of brass lamps in wooden crates, headed for a Melbourne warehouse. We'll cover what the mark means, what's exempt, what happens at the border without it, and the clause to put in your purchase order. One honest caveat before we start. We read the Australian, US and UK rules at source, but New Zealand's and the EU's official sites blocked our automated reads, so those parts are marked as reported, not verified.
ISPM 15 is an international standard for packaging made from raw wood - pallets, crates, packing cases, cable drums, spools and dunnage, the loose timber that braces cargo inside a container (ISPM 15, section 2 (opens in a new tab)). Raw wood can carry beetles and larvae across borders, so the wood must be debarked, treated by an approved method and marked to show it.
The part first-time importers miss is that it has nothing to do with what you bought. Cotton towels on untreated pallets break the rule as surely as a crate of furniture does. So our brass lamps are a metal product, and the lamps don't matter here at all. The crates and the pallets they sit on do.
And biosecurity is a separate check from customs. The Australian clearance firm above describes an unmarked pallet stopping a delivery after customs had already released it, and a pallet maker says the same thing (two vendors on LinkedIn, 2026, founder-confirmed). Customs clearance tells you the duty is settled. It tells you nothing about the wood.
The mark is a small stamped box with the IPPC symbol on the left and three codes on the right (ISPM 15, Annex 2 (opens in a new tab)). The first is the ISO country code of the country where the wood was treated or the packaging made, which for India is IN. The second is the number the national plant protection body gave the maker or treatment provider, so a bad pallet can be traced back to a firm. The third is the treatment code.
There are four treatment codes you'll see. HT is heat treatment, with the core of the wood held at 56°C for at least 30 continuous minutes. MB is methyl bromide fumigation, DH is dielectric heating and SF is sulphuryl fluoride. Methyl bromide can't be used on wood thicker than 20 cm, and the standard asks countries to move away from it because it damages the ozone layer. We'd ask for HT every time, and there's a second reason for that which we'll get to in section 5.
| Code | Treatment | Note |
|---|---|---|
| HT | Heat treatment, core at 56°C for at least 30 continuous minutes | Our preference |
| MB | Methyl bromide fumigation | Not on wood thicker than 20 cm, countries asked to move away from it |
| DH | Dielectric heating | |
| SF | Sulphuryl fluoride |
The standard is fussy about how the mark is applied too. It must not be hand drawn, it should sit on at least two opposite sides of each unit, and red and orange ink are to be avoided because they flag dangerous goods. A hand-drawn mark on a pallet is a bigger warning sign than no mark at all, because it means someone knew a mark was expected.
Is a stamped pallet compliant forever? Only if nobody alters it. A repaired pallet needs treated wood and its own mark, and a rebuilt one must have the old marks ground or painted out (ISPM 15, section 4.3 (opens in a new tab)). And a pallet that picks up live pests after treatment can still be ordered for treatment, export or destruction, stamp or no stamp (DAFF, ISPM 15 (opens in a new tab)).
The standard exempts packaging that's low risk because of how it's made (ISPM 15, section 2.1 (opens in a new tab)) -
Plastic pallets and metal crates sit outside the rule altogether, which is why some importers simply ask for them.

Here's the catch - "wholly". A plywood crate on solid-timber skids isn't wholly processed wood, and that's exactly how a lot of export crates are built. Australia says it plainly: packaging that combines solid timber with plywood or reconstituted wood must still be treated and declared (DAFF, timber and bamboo packaging (opens in a new tab)). So back to our brass lamps. If the crates are all plywood then only the pallets need the mark. If the crate base is solid timber then the whole crate needs treatment and a mark, and you won't know which one you've got unless you ask for photos.
ISPM 15 lets the importing country detain the goods, then remove, treat, destroy or reship the packaging (ISPM 15, section 4.6 (opens in a new tab)). Each country uses that power in its own way.
Australia treats non-compliant wood on arrival, "or it may be exported or disposed of at the importer's expense" (DAFF, timber and bamboo packaging (opens in a new tab)). In the US an inspector "may order the immediate reexport" of wood packaging that arrives without the mark, which can mean the goods go back with it (7 CFR 319.40-3(b)(3) (opens in a new tab)). Great Britain requires any goods on wood packaging to meet ISPM 15 (GOV.UK (opens in a new tab)). The EU applies ISPM 15 through its plant health rules, and New Zealand through MPI's import health standard for wood packaging (both reported from our desk research, because the official sites blocked automated reads when we checked in September 2026).
For the UAE we couldn't find the rule on an official page. Suppliers in the Gulf say the GCC applies ISPM 15, but they sell pallets, so treat that as unconfirmed and ask your broker before the first shipment.
Notice who pays in every one of those rules. It's you, the importer. The cost stacks up as treatment or disposal, storage and container detention while the box waits, labour to repack onto new pallets, and freight if it goes back. Charges vary by port and provider, so check the current ones with your customs broker rather than guessing.
Australia builds ISPM 15 into its import conditions (BICON) and adds paperwork on top. Whoever packs a container completes a packing declaration, and solid timber packaging goes on it (DAFF, timber and bamboo packaging (opens in a new tab)). The department also runs random checks on cargo, so a clean declaration doesn't mean nobody looks.
Australia also watches who does the treating, and 2026 showed why. Between January and July its industry notices suspended Indian fumigation providers one notice at a time, and on 10 July it said thirteen Indian providers had been suspended from, or had withdrawn from, its offshore fumigation scheme (DAFF notices 2026 (opens in a new tab), notice 118-2026 (opens in a new tab)). Indian press reports put the number far higher, but we'd go with the department's own count.
That notice is about methyl bromide treatment of goods and containers, not pallet stamps. The lesson carries over anyway. An Australian biosecurity consultant summed it up in August: "Having a treatment certificate in the shipping documentation does not automatically mean the biosecurity risk has been adequately managed" (LinkedIn, Australian biosecurity consultant, August 2026 (opens in a new tab)). A certificate is only as good as the provider's standing on the day. This is the second reason we prefer HT for packaging - a kiln-treated pallet doesn't depend on a fumigator staying on anyone's approved list.
None of this is special to India. ISPM 15 is the same wherever the pallet was built. What's specific is the habit on the ground. A UK logistics voice put it frankly in 2026: ISPM 15 pallets "are not standard in India and considered an unnecessary added cost for the shipper" (r/logistics, UK logistics voice, April 2026 (opens in a new tab), via our forum-signal log). The same threads describe Indian containers floor-loaded with no pallets at all, which avoids ISPM 15 but leaves you paying for slow hand unloading at Felixstowe or a US warehouse (three voices, UK and US, 2026, founder-confirmed).

That's not a knock on Indian exporters. A supplier who ships loose cartons to buyers who never asked for pallets is doing what the market paid for. The fix is simply to ask, in writing, before the order is packed.
India does make the check easier than most origins. The plant protection directorate links to its list of accredited treatment providers from its home page, so a supplier who names one can be checked against it (PPQS (opens in a new tab)).
Here's the clause we'd put in the PO for our brass lamps, and it works for any origin -
Three things still slip through, even with a good clause. Dunnage gets cut to length at loading, and a short offcut can lose its mark, which is why the standard says pieces too small to carry the whole mark shouldn't be used. Repaired pallets often carry several marks, which is normal, but a new unmarked board on an old pallet is not. And "fumigated" on the paperwork is a certificate for the goods, not an ISPM 15 mark on the wood. You may need both, and one doesn't stand in for the other.
If you'd rather someone at the Indian end checked the packing and the marks before the container is sealed, SourcingSync (opens in a new tab) does that. For the wider pre-shipment checks, see quality control in India.
We keep this part current and date it. The method above doesn't change when it does.
Australia. ISPM 15 is built into BICON, solid timber goes on the packing declaration, and the fumigation provider's standing matters. Non-compliant wood is treated, exported or destroyed at your expense (Verified).
United States. ISPM 15 applies under 7 CFR 319.40-3, and unmarked wood packaging can be ordered for immediate re-export (Verified).
United Kingdom (Great Britain). Goods on wood packaging must meet ISPM 15 (Verified).
European Union and New Zealand. Both apply ISPM 15, the EU through its plant health rules and New Zealand through MPI's import health standard (Reported, official sites not readable by us). Ask your broker for the current text.
UAE. Not confirmed on an official page (Unknown). Ask your broker.
Wholly plywood packaging is. A plywood box on solid-wood runners isn't.
The standard says the mark makes a certificate unnecessary. Australia still wants the timber listed on the packing declaration.
Both are approved, but we'd ask for HT. The standard discourages methyl bromide, and HT keeps a fumigator's status out of your clearance.
The importer. No rule we read puts it on anyone else, so plan on it being you, and put the cost of a failure back on the supplier in your contract if you can.
So for our Melbourne lamps, the whole fix fits in five lines of a PO and a set of photos before the doors close. That's cheap insurance against a container waiting at the port for a reason that has nothing to do with lamps.
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Which Indian town makes which brass, why one bowl can pay 50% or about 10% at the US border depending on its code, and how lead rules (FDA, Prop 65, CPSIA) reach importers.

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