The Importance of Clarity in Labeling

States should consider requirements for labeling firewood that are consistent, clear, and in plain language. Labels can identify heat treatment standards and certifying authorities to regulators and the public, and help firewood distributors meet requirements from multiple states.

Labeling Requirements

State	Label Language Explicit within Quarantine	Label Requirements
Florida	Allowable firewood in Master Permit System requires a certificate	Certificate indicating compliance with Florida’s Firewood and Unprocessed Wood Products rules, Chapter 5B-65, F.A.C. This shall include: Name of the producer/shipper under compliance Compliance Agreement number issued to them by the state of origin Statement indicating that the product meets the requirements of 5B-65 Florida Administrative Code
New Hampshire	Exempted heat treated firewood requires labeling	Firewood labeled as treated to standards of 60 °C (140 °F) for 60 minutes Display APHIS or State Department of Agriculture authorization and Compliance Agreement number Company name Bulk firewood shipments also have labeling requirements
New York	Exempted heat treated firewood requires labeling	“New York-approved treated firewood/pest-free”, or phytosanitary certificate, or plant health certificate
Oregon	Firewood harvested and sold in the Pacific Northwest does not need to be labeled. There is optional labeling for untreated Pacific Northwest firewood. Treated firewood may be labeled.	“Approved Pacific Northwest Firewood” is sourced wholly within the Pacific Northwest and outside of declared quarantine areas for invasive species. Includes record keeping requirements. “Approved Pest Free” firewood is heat treated to 60 °C (140 °F) for 60 minutes or equivalent treatment approved by Oregon Department of Agriculture.
Pennsylvania	Exempted treated firewood requires labeling	Kiln Dried and/or USDA Certified Producers name and address
Utah	Labeling for all firewood, and advance notification of firewood shipments into the state	Based on weight and measure of firewood Origin of firewood Treatment of firewood Exporter and importer information
Vermont	Label is one options for certification of treatment	Firewood labeled as treated to standards of 71.1 °C (165 °F) for 75 minutes Name and physical address of = heat treatment facility Name of certifying agency

The Complexities of Labeling Firewood

Label requirements by states are mostly associated with information about meeting a heat-treatment certification process, or origin of firewood. Labels can be used to identify compliant firewood. Labels should be easy to read and consistent.

Labels, certificates, and other documents may be subject to fraudulent use and labels listing company, certifying authority, and certification number make it easier to identify legal firewood.

Labels with the USDA shield on heat-treated firewood can be problematic and should not be used. Clear labels with identifying information are preferred.

Benefit

• Ready identification of compliant firewood.

Recommendations

1. Explicitly state treatment requirements in plain language.
2. Get language consistency across states.
3. Regulatory language should be legible.
4. Plain language indicating the requirements should be favored over shields or graphics.

Clear Sample Language

This firewood has been certified heat-treated to a core temperature of 60 ˚C (140 ˚F) for 60 min [or other preferred standard]. Certifying agency: State or Federal Department of__________________. Certification number_____________.

Unclear Sample Language

• “[State]-approved treated firewood/pest-free”
• “Product meets the requirements of [regulation #] [State] Administrative Code”
• “Meets State of [State]standards”