Fact check: were wooden pallets exempted from PPWR?
Headlines in April 2026 said the EU had exempted wooden pallets from reuse requirements. The Commission's guidance says something narrower.
In April 2026 several trade sites ran the headline that the EU had exempted wooden pallets from the reuse requirements of PPWR (for example HortiDaily, 13 April 2026). If you make, repair or use pallets, it is worth knowing what lies behind it.
What the guidance says
The Commission's guidance on PPWR, published in the Official Journal in June 2026, makes two relevant points about Article 29 (Commission Notice C/2026/3084):
Territory. The reuse targets apply only within the EU. For imported goods they apply from the point where the product is placed on the market, usually the first warehouse in the EU. Transport legs outside the EU, and pallets leaving the EU with exports, are outside the targets.
Custom packaging. The existing exemption in Article 29(4)(b), for custom-designed packaging for large machinery, equipment and commodities, stands. The custom design has to be documented in the technical file.
What it does not say
Neither the regulation nor the guidance exempts pallets because they are made of wood. Article 29(1) covers pallets "of any size or material" (Regulation (EU) 2025/40). From 1 January 2030 a wooden pallet used between your own sites, or to deliver to another company in the same Member State, must be reusable within a reuse system. In other flows it counts towards the 40% aggregate.
The real wood-specific points in PPWR are different ones:
repaired wooden packaging can count towards national recycling targets (Art. 54(2));
the bar for "recycled at scale" is 30% for wood against 55% for other materials (Art. 3);
the recycled-content rules apply to plastic only (Art. 7).
Why it matters
A company that read the headline and stopped planning for 2030 may find its domestic one-way pallet flows out of line with the rules. The calculation method arrives by mid-2027, but which flows are domestic, intra-company or cross-border can be mapped now. That is easier when every delivery is already recorded with its counterparty and site, as it is in Resupply.
General information, not legal advice.
Want your flows mapped against Article 29? Ask Resupply for a short proposal: resupply.se (in Swedish).