Knowledge centre
PPWR and wooden pallets
The EU Packaging and Packaging Waste Regulation has changed the questions EU customers ask their UK suppliers. This page separates what the regulation is about from the claims circulating around it.
Two different rulebooks
What PPWR is
Regulation (EU) 2025/40 on packaging and packaging waste replaced the previous packaging directive with a directly applicable regulation. It entered into force in February 2025, with its main provisions applying generally from 12 August 2026, and further requirements phasing in after that. Because it is a regulation rather than a directive, it applies across member states without each one transposing it separately — which is precisely why supplier questionnaires started arriving in UK inboxes.
Pallets are packaging. Transport packaging sits within the scope of the EU packaging regime, so pallets are not outside the conversation. What that means in practice for a particular pallet depends on the role each business plays and on the pallet itself.
Economic operator roles
The regulation allocates obligations by role rather than by object, and this is the part most often misread.
- Manufacturer — the operator that makes the packaging, or has it designed or made and places it on the market under its own name or trade mark. This role carries the conformity obligations.
- Importer — an operator established in the EU that places packaging from outside the EU on the EU market. It has duties of its own, including checking that the required conformity steps have been carried out.
- Distributor — an operator in the supply chain, other than the manufacturer or importer, that makes packaging available. Its duties are lighter but not nil.
A UK company that buys second-hand pallets and resells them did not manufacture them and is generally not the manufacturer of that packaging. That matters, because it means it cannot honestly issue a manufacturer’s declaration for them. Where responsibility sits in your particular chain depends on the arrangement, so this is worth confirming rather than assuming.
Used and reused pallets
Reuse is a policy objective in the EU packaging regime, not a problem to be eliminated. Used pallets crossing into the EU are not categorically prohibited. What has genuinely changed is the volume of documentation questions, and anonymous mixed-origin white-wood stock is difficult to answer those questions about. That is a practical evidence problem, not a legal ban.
Where your customer needs a clean documentation trail, a documented new pallet or a licensed system pallet is usually the easier answer. Where they simply need serviceable pallets for a journey, used stock may be perfectly appropriate.
Common claims, and what is actually the case
| What people say | A more careful answer |
|---|---|
| Used pallets are banned from the EU. | No blanket ban exists. Reuse is actively encouraged in EU packaging policy. The practical difficulty with anonymous used pallets is answering documentation questions about them, not legality. |
| An ISPM15 stamp proves PPWR compliance. | It does not. ISPM15 is plant health; PPWR is packaging law. Different subject matter, different evidence. |
| Every pallet needs its own Declaration of Conformity. | Where a declaration is relevant it is a manufacturer-level obligation tied to a defined economic-operator role — not a certificate that travels with each individual pallet. |
| A UK pallet supplier can certify any pallet as PPWR compliant. | A supplier can only speak to what it actually knows. Nobody can issue a manufacturer's declaration for pallets they did not manufacture. |
What a UK supplier can reasonably tell your EU customer
Useful, honest, verifiable information — and nothing beyond it:
- Pallet dimensions, construction and material.
- Whether the pallet is new or used, and the condition grade applied.
- Which marks are physically present and whether they are legible.
- Whether the pallet came from a licensed system such as EPAL.
- Where new pallets are supplied, who manufactured them.
Be wary of anyone offering a blanket certificate
What to do next
- Ask your EU customer what specifically they need, in writing.
- Establish whether the pallets are new, used or from a controlled system.
- Identify who the manufacturer is, if there is one you can name.
- Decide whether documented new pallets are simply the cheaper route once the admin is counted.
- Take legal or specialist advice where the answer carries real commercial risk.
PPWR questions from UK exporters
- Does PPWR apply to wooden pallets?
- Pallets are packaging, and transport packaging is within scope of the EU packaging regime. What that means for a given pallet depends on the role each business plays in placing the packaging on the EU market, the pallet's origin and whether it is new or reused. It is not a single rule that applies identically to every pallet.
- Who is the manufacturer for PPWR purposes?
- The manufacturer is the operator that makes the packaging, or has it designed or made and places it on the market under its own name or trade mark. A UK supplier of second-hand pallets it did not manufacture is generally not the manufacturer of those pallets, and cannot issue a manufacturer's declaration for them.
- What is the EU importer's role?
- Where packaging is placed on the EU market, the EU-established importer has obligations of its own — including checking that the required conformity steps have been carried out. This is one reason EU customers are sending supplier questionnaires to their UK suppliers.
- What information can a second-hand pallet supplier reasonably provide?
- Practical, honest information: pallet dimensions and construction, material, condition grade, what marks are physically present and legible, and whether the pallet came from a controlled system. What it cannot provide is a manufacturer's declaration for pallets it did not make, or a guarantee about the original production of anonymous white-wood stock.
Had a PPWR questionnaire from your EU customer?
Send it over with details of the pallets involved. We will tell you which parts we can answer as a supplier, which parts belong to the manufacturer or the EU importer, and where you may need specialist advice.