What PPWR means for wooden pallets

The EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40 or PPWR, replaced the old packaging directive on 12 August 2026. Because it is a regulation, it applies directly in every Member State, with the same text in Stockholm, Helsinki and Copenhagen. Norway will follow once it is taken into the EEA Agreement; it doesn't apply there yet (see [The Nordic picture](/ppwr-nordic-picture-sweden-norway-denmark-finland)).

For the wooden pallet industry the short version is this: pallets are packaging, and nothing in the regulation exempts them for being made of wood. Some rules already apply. The big one, the reuse targets, starts on 1 January 2030. Several of the rules that decide how those targets work in practice have not been written yet.

Pallets are transport packaging

PPWR covers all packaging placed on the EU market, whatever the material, including transport packaging. Pallets are named explicitly. Article 29 lists "pallets" among the formats with reuse targets, and Annex II lists "pallets, boxes, crates" under wooden packaging for the recyclability rules (Regulation (EU) 2025/40, Art. 29 and Annex II).

Trade headlines in spring 2026 said the EU had "exempted wooden pallets" from reuse requirements. The Commission's guidance does not say that. It clarifies that the targets apply only within the EU, so for imports they start at the first EU warehouse, and it confirms an existing exemption for custom-designed packaging for large machinery (Commission Notice C/2026/3084, June 2026). There is no wood-specific exemption from Article 29.

What already applies (since 12 August 2026)

• Conformity assessment and a declaration of conformity. Whoever counts as the manufacturer must assess the packaging against the regulation's requirements, keep technical documentation and sign an EU declaration of conformity (Arts. 15, 38 and 39). The Commission's FAQ says there is no exemption for transport packaging: pallets, pallet collars, wrap and straps each need their own declaration (PPWR FAQ, 2nd edition, August 2026). EPAL published declarations for Euro pallets on 12 August 2026.

• Identification on the packaging. Manufacturers mark a type, batch or serial identifier and their name and postal address on the packaging, or in a QR code or accompanying document where that isn't possible (Art. 15).

• Heavy metals. Lead, cadmium, mercury and hexavalent chromium together must stay at or below 100 mg/kg (Art. 5(4)). For untreated or heat-treated wood this is rarely an issue, but it belongs in the technical file.

• Traceability of reusable packaging. Operators must be able to name their suppliers and customers of reusable packaging for 10 years, and keep the documentation for that long (Arts. 15 and 22).

• Reuse systems. Reusable packaging has to circulate in a reuse system that meets the rules in Annex VI (Arts. 26 and 27).

Packaging placed on the market before 12 August 2026 may stay in use (PPWR FAQ).

What comes on 1 January 2030

• Reuse targets (Art. 29). At least 40% of the pallets, crates, boxes, drums, wrap and straps an operator uses within the EU must be reusable within a reuse system. Between an operator's own sites, and for deliveries to another company in the same country, the figure is 100%. In 2040 operators should "endeavour" to reach 70%. Our explainer [The reuse targets explained](/ppwr-reuse-targets-explained) goes through the cases.

• Minimisation (Art. 10) and a maximum empty space of 50% in transport packaging (Art. 24). Reusable packaging in a reuse system is exempt from the empty-space rule.

• Recyclability (Art. 6). Wooden pallets must be recyclable under design-for-recycling criteria the Commission still has to adopt.

What doesn't apply, or hardly

• Recycled content rules (Art. 7) cover plastic parts only. A wooden pallet has no recycled-content target; plastic wrap does.

• The consumer sorting label (Art. 12(1)) doesn't apply to transport packaging.

• The reusable-packaging label and QR code (Art. 12(2), from February 2029 at the earliest) don't apply in open-loop systems without a system operator. The Commission names the Euro pallet as exactly that kind of system (PPWR FAQ).

• Repair counts. Member States may count wooden packaging repaired for reuse towards their recycling targets (Art. 54(2)), which recognises what pallet repairers already do.

Who is the "producer" of a pallet?

Producer responsibility (EPR) under PPWR attaches to the empty packaging. The Commission's guidance says that for unbranded transport packaging the producer is normally its physical maker. For branded packaging it is the brand owner or filler. When packaging goes to a business in another Member State, the receiving business becomes the producer there (Commission Notice C/2026/3084). FEFPEB, the European federation of wooden pallet and packaging makers, has said it disagrees with putting this on unbranded domestic pallet makers (FEFPEB newsletters, 2026). For now the guidance is what authorities will read.

What is still open

Several acts that decide the details are late or still to come (Commission PPWR page):

• the minimum number of rotations for reusable packaging (Art. 11(2), due February 2027);

• how reuse targets are calculated (Art. 30(3), due June 2027);

• the labels (overdue, now planned for 2027);

• the format of national producer registers (overdue);

• design-for-recycling criteria for wood (due January 2028).

Our piece on [the PPWR timeline](/ppwr-timeline-what-to-do-now) keeps track of them.

Handling it without a spreadsheet war

Almost every one of these obligations comes down to the same thing: being able to show where your pallets went.

• The reuse target is a count of reusable versus single-use units per calendar year.

• Traceability means knowing which counterparties you exchanged reusable packaging with, for ten years.

• A reuse system needs return rates and rejects.

• EPR reporting needs volumes per Member State.

Most companies that exchange pallets today keep this in a mix of ERP notes, paper waybills and spreadsheets per supplier. That works until someone asks for the full year's numbers.

The practical answer is to record each pallet movement once, at the dock, as it happens:

• the delivery, the counterparty and site, and the pallet types and counts;

• deviations;

• returns, sorting and reconditioning.

Balances, claims and, later, PPWR figures then come out of the same records instead of being rebuilt every year.

That is how we work at Resupply:

• Deliveries are registered on a phone at the dock. Photographing the waybill reads the supplier, order numbers, pallet types and counts automatically.

• Balances are kept per counterparty and agreement.

• Deviations become claims.

• Sorting and reconditioning to EUR A or B quality are logged as handlings.

Resupply is building PPWR reporting on top of that data: reuse shares per counterparty and site, and an export for the authorities' reports.

This article explains the regulation in general terms and is not legal advice. Check your own obligations with your national authority or adviser.

Want to see which PPWR requirements apply to your pallet flows? Resupply puts together a short proposal for your company, with no meeting needed: resupply.se (in Swedish).