Many people think their export pallet shipments are exempt from the European Union’s Packaging and Packaging Waste Regulation (PPWR) reuse requirements, so they don’t really have to worry about it. The reality is a little more muddled.
Jason Ortega, senior vice president of Woodpack Global, stated, “The most immediate impact is additional reporting requirements.” He added, “Woodpack Global has worked for years to ensure that all wooden pallets can continue to be used to ship products into the EU. We continue to engage the EU Commission and stakeholders to make the requirements workable and limit supply-chain disruptions. Many questions still remain, and we will engage on behalf of the industry to get those resolved.”
Woodpack Global has suggested that the main compliance issue right now for pallet companies is supplying customers with information that can be used for reporting requirements that went into effect on August 12, 2026. Woodpack Global has developed compliance guidance that is free for anyone in the industry to use. The focus of these documents is the presence of certain heavy metals and other substances for packaging with direct food contact, the weight of the packaging, as well as participation in any reuse system. For more information, download the kit at https://woodpackglobal.org/page/ppwr-toolkit.
To avoid disrupting international trade while still supporting the PPWR’s main goals, the EU created two exclusions from the reuse requirements:
- Transit and pre-market goods: Packaging isn’t subject to reuse rules until it’s officially “placed on the EU market.” This also covers goods just passing through Europe on their way to a non-EU destination.
- Custom-designed, specialty pallets, boxes and containers: Packaging that doesn’t fit well with existing reuse systems (like EPAL and EUR pallets) is also excluded.
Woodpack Global recently further clarified its interpretation of the rules. Ortega noted, “The Commission states that for the reuse targets to apply, both companies in the transaction must be within the EU…. Whether the exemption applies depends on the product and where it is in its journey. The exemption expires at the ‘first warehouse’ where goods shipped into the EU are removed from the international pallet for distribution throughout the EU supply chain. Reuse requirements do not apply until the imported product is first de-palletized.”
Ortega also stated, “Lastly, they (EU Commission) make it clear that if at that ‘first warehouse’ the goods are not unpacked but continue to a single destination, they do not need to be unpacked and reloaded onto a different pallet.”
Ortega pointed to the EU’s own statements. The EU Commission declared, “Consignments arriving at the first warehouse and destined for a single final destination shall not be required to be unpacked and repacked into reusable packaging. Distribution centres and logistics hubs shall not be considered as final destination.”
As a result, many pallets shipped into Europe don’t have to meet the reuse requirements. It really depends on the supply chain and where those loads go and how they are unpacked and repacked within the EU. At the same time, most stringer pallets are not likely to be considered reusable as far as PPWR is concerned unless there is a special reusable system established for that pallet.
While the EU does not prohibit stringer pallets, the PPWR does favor reusable pallets, and the most commonly accepted reusable pallet types in the EU are all block pallets. These include EPAL and EUR pallets or the CHEP, IPP and LPR rental pools. So what happens to these stringer pallets, commonly known as GMA pallets, once they reach Europe? Many are used for energy or are shipped under load back to the United States.
The EU Commission recently answered key questions in its FAQ document released in early August. See the full document at https://tinyurl.com/5yabf5sn.
The EU’s FAQ document clarified a number of unknowns about the PPWR process. For example, the real burden for compliance falls to the manufacturer of the packaging. That’s not surprising. What is a bit shocking is how the EU has defined who qualifies as a packaging manufacturer. The EU Commission explained that a packaging manufacturer is the entity that “places the order and sets the design specs.” The EU Commission clarified, “For transport packaging without a brand or trademark, the manufacturer/producer is whoever places the order and sets the design specs — for imported unbranded pallets, this typically shifts responsibility onto the EU company that orders/imports them, not the overseas woodshop.”
This means that in many cases U.S. pallet companies are not on the hook to meet paperwork requirements or face fines for non-compliance. But many U.S. producers will be required by customers to help with their compliance.
If the transport packaging is going to be placed on the EU market, one of the easiest ways to comply with the PPWR is to use a recognized pallet system. EPAL has already clarified its compliance and provided mechanisms to help pallet producers and users comply. To see EPAL’s full compliance process, visit https://tinyurl.com/mry7jckp.
So, what happens if you ship non-compliant packaging? The reality is that the EU has outlined a procedure for non-compliant packaging. The first step is notification of non-compliance to the economic operator behind the shipment. The government will work with the operator to develop a compliance plan. The EU seems to favor an education and awareness-raising approach versus heavy-handed fines and restrictions. Non-compliant loads may be required to be repalletized onto compliant packaging. Some companies could face fines for non-compliance, improper paperwork or violating reuse targets when those are initiated in 2030. Fines are up to the individual countries where any infraction occurs.
The reality behind fines is that a lot of the details have yet to be worked out. There will be test cases and warnings before fines are assessed. Of course, non-reusable pallets will not comply with reuse targets when they are set in 2030. So, stringer and other non-standard types in the EU will negatively affect shippers’ ability to meet reuse targets where applicable.
More than just complying for the moment, PPWR should give both pallet users and providers pause to consider their long-term strategy. If packaging is placed on the EU market, it will need to comply. The import exclusion doesn’t last forever. Some shippers will shift to new platforms. Others will not. The reality is that non-reusable pallets will have little value in Europe, especially once reuse targets go into effect. While EPAL or other recognized platforms are more expensive on the front end, they do provide a sellable asset once delivered to Europe, which can lead to lower total trip costs. In addition, it is difficult to claim that you are using sustainable packaging when your choices don’t support reuse in the destination country. Shipping on a reusable pallet provides more options for the load once it arrives in Europe. Your strategy depends on your supply chain and customers’ needs. Eventually, the PPWR will have a ripple effect globally whether other countries like it or not.
