Pallets need a declaration of conformity too
The Commission's FAQ is clear: there is no exemption for transport packaging. Since 12 August 2026, pallets, collars, wrap and straps each need a conformity assessment and an EU declaration. EPAL has published its own.
One question kept coming up before PPWR started to apply: do simple wooden pallets really need the same paperwork as consumer packaging? The Commission's answer, in the second edition of its FAQ (August 2026), is yes. There is no exemption for transport packaging, and pallets, pallet collars, wrap and straps each need their own assessment and declaration (PPWR FAQ, 2nd edition).
What is required
Since 12 August 2026 the manufacturer of packaging must (Regulation (EU) 2025/40, Arts. 15, 38, 39):
carry out the conformity assessment procedure in Annex VII (Module A, internal production control);
draw up the technical documentation;
sign an EU declaration of conformity following Annex VIII;
keep both for 10 years for reusable packaging (5 for single-use);
mark the packaging with an identifier and its name and postal address, or use an accompanying document where the packaging's size or nature makes that impossible.
Importers and distributors must check that this has been done.
Who the "manufacturer" is matters. For custom-made packaging, the company that orders and sets the design may be the manufacturer, and the workshop that builds it a supplier. That is how FEFPEB summarises the FAQ; we haven't seen that exact passage of the FAQ ourselves (FEFPEB news).
EPAL's declarations
EPAL published EU declarations of conformity for EPAL Euro pallets and other EPAL load carriers on 12 August 2026 (the Euro pallet declaration is version 1.2, dated July 2026) (EPAL declaration, Euro pallets). EPAL acts as manufacturer on the basis of its standard and trademark, and says the Commission has not conclusively confirmed that role. The declarations cover new and used pallets and describe several articles as only partly applicable until the Commission's secondary acts arrive.
Packaging placed on the market before 12 August 2026 may stay in use.
For pallet makers and repairers
Check, product by product, whether you are the manufacturer or a supplier to one.
Keep the technical file with the evidence behind each statement: materials, heavy-metal content, the design for reuse.
Keep customer records for reusable pallets for ten years (Art. 22).
Resupply doesn't issue declarations; that stays with the manufacturer. It does keep the delivery-by-delivery record of which counterparties received which pallet types, captured at the dock. Resupply is building more on top of that: a record of each counterparty's PPWR role and a place to keep their declarations.
General information, not legal advice.
Want an overview of what applies to you? Resupply can send a short proposal: resupply.se (in Swedish).