The European Union\u2019s new Packaging and Packaging Waste Regulation is now applicable across the bloc, bringing immediate compliance requirements for pallet and packaging manufacturers and setting much tougher reuse rules for transport packaging from 2030.<\/p>\n
The Packaging and Packaging Waste Regulation, or PPWR, Regulation (EU) 2025\/40, has applied since August 12, 2026. For the wood industry, the effect is uneven. Pallet producers, companies manufacturing their own wooden crates and businesses already using reusable packaging face obligations now, while many sawmills, furniture manufacturers and other wood processors will feel the largest operational impact from 2030.<\/p>\n
The distinction matters because PPWR does not look only at companies selling packaging as a separate product. A sawmill that manufactures crates for its own lumber shipments can itself be considered a packaging manufacturer. A company ordering packaging carrying its own name or trademark can also assume responsibilities normally associated with the manufacturer, even if another company physically produces the packaging.<\/p>\n
For pallet producers, the August deadline is already relevant. Manufacturers must assess conformity with the regulation, prepare the required technical documentation, issue an EU Declaration of Conformity and comply with the applicable marking rules.<\/p>\n
For companies simply purchasing standard pallets without placing their own brand on them, responsibility for product compliance will normally remain with the pallet manufacturer. The situation changes, however, where packaging is manufactured under the buyer\u2019s name or trademark.<\/p>\n
The same issue can apply to bags, foil, cartons and other packaging used by pellet producers, furniture companies and wood processors. In the case of commercial packaging, the company carrying out the final filling and sealing operation can in some cases be treated as the manufacturer of the packaged product for PPWR purposes.<\/p>\n
| Company \/ situation<\/th>\n | What changes<\/th>\n | When<\/th>\n | Main requirement<\/th>\n<\/tr>\n<\/thead>\n | ||||||||||||||||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Pallet and wooden crate manufacturers<\/strong><\/td>\n| Packaging must comply with PPWR product rules.<\/td>\n | From August 12, 2026<\/strong><\/td>\n | Conformity assessment, technical documentation, EU Declaration of Conformity and marking.<\/td>\n<\/tr>\n | Sawmills making their own pallets or crates<\/strong><\/td>\n | They can be treated as packaging manufacturers even if the packaging is not sold separately.<\/td>\n | From August 12, 2026<\/strong><\/td>\n | Manufacturer compliance obligations apply.<\/td>\n<\/tr>\n | Companies ordering packaging under their own brand<\/strong><\/td>\n | The brand owner may become the manufacturer under PPWR.<\/td>\n | From August 12, 2026<\/strong><\/td>\n | Check responsibility for branded bags, foil, cartons and other packaging.<\/td>\n<\/tr>\n | Companies already using reusable pallets<\/strong><\/td>\n | Reusable packaging must operate within a reuse system.<\/td>\n | From August 12, 2026<\/strong><\/td>\n | Return, collection, repair and reconditioning must be organised. Occasional pallet returns are not sufficient.<\/td>\n<\/tr>\n | Transport between own plants or certain affiliated operations<\/strong><\/td>\n | Covered packaging moves to full reuse.<\/td>\n | From January 1, 2030<\/strong><\/td>\n | The Commission describes the effect as 100% reuse for covered formats.<\/td>\n<\/tr>\n | B2B deliveries within the same EU Member State<\/strong><\/td>\n | Domestic transport is subject to the stricter reuse requirement.<\/td>\n | From January 1, 2030<\/strong><\/td>\n | 100% reuse for the relevant transport packaging formats.<\/td>\n<\/tr>\n | B2B deliveries to another EU country<\/strong><\/td>\n | A lower EU-wide reuse threshold applies.<\/td>\n | From January 1, 2030<\/strong><\/td>\n | At least 40% of covered packaging must be reusable within a reuse system.<\/td>\n<\/tr>\n | Direct exports outside the EU<\/strong><\/td>\n | Article 29 reuse targets do not generally apply to packaging used only for a direct third-country shipment.<\/td>\n | From 2030<\/strong><\/td>\n | Companies need to separate third-country flows from packaging subsequently circulating inside the EU.<\/td>\n<\/tr>\n | Goods imported from outside the EU<\/strong><\/td>\n | Reuse obligations can become relevant once packaging enters circulation within the EU.<\/td>\n | From 2030<\/strong><\/td>\n | The first EU warehouse can become the point from which the subsequent packaging flow must be assessed.<\/td>\n<\/tr>\n | All packaging placed on the EU market<\/strong><\/td>\n | Packaging must meet EU recyclability requirements.<\/td>\n | From 2030<\/strong><\/td>\n | Only packaging meeting the required recyclability performance grades will remain eligible for the market.<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n | Source:<\/strong> Regulation (EU) 2025\/40, European Commission PPWR guidance and EPAL.<\/p>\n EPAL publishes conformity declarations for pallets<\/strong><\/p>\n EPAL moved quickly to address the new compliance requirement. The European Pallet Association published EU Declarations of Conformity under Article 39 for EPAL pallets when the PPWR became applicable on August 12.<\/p>\n The documents are intended to confirm that EPAL pallets comply with the requirements contained in Articles 5-12 of the regulation. For users in manufacturing, trade and logistics, the declarations provide documentation that can be passed through the supply chain instead of every pallet user having to establish compliance independently.<\/p>\n EPAL has also linked the declarations to its digital pallet passport. Companies can include a QR code in delivery documents or send it electronically to customers. The digital record provides access to information on the pallet and its PPWR conformity.<\/p>\n According to EPAL, its conformity assessment confirms that the pallets are recyclable, reusable and comply with the substance requirements contained in Article 5. The association says it can use data already collected through its long-established independent quality-control system to demonstrate continued compliance.<\/p>\n The bigger change comes in 2030<\/strong><\/p>\n The immediate documentation requirements are only one part of the PPWR. The more significant change for many wood companies will come from January 1, 2030, when reuse targets begin applying to transport packaging.<\/p>\n The rules differ according to where the goods are going.<\/p>\n For covered transport between a company\u2019s own facilities, or between certain affiliated or partner operations, packaging will have to be reusable and operate within a reuse system. The Commission describes the practical effect of the relevant provision as a 100% reuse requirement.<\/p>\n The same applies to covered business-to-business deliveries within the same Member State.<\/p>\n A sawmill shipping lumber to another company in Germany, for example, will face a different rule from the same sawmill shipping lumber from Germany to a customer in Austria.<\/p>\n For cross-border deliveries between EU Member States, the general requirement is that at least 40% of the relevant transport packaging must be reusable within a reuse system from 2030.<\/p>\n Direct exports outside the EU are treated differently<\/strong><\/p>\n The Commission\u2019s guidance states that the Article 29 reuse targets concern packaging used within the EU.<\/p>\n A direct shipment from an EU company to a third country, such as the United Kingdom, is therefore not covered by the 40% reuse target simply because the goods leave the EU on a pallet.<\/p>\n Imports work differently.<\/p>\n If goods arrive from a third country and are placed in an EU warehouse before being distributed further inside the Union, the reuse requirement can become relevant from that point. According to the Commission guidance cited in the source material, the first EU warehouse will typically be the point at which the packaging enters the internal distribution chain.<\/p>\n For imported lumber, wood-based panels, furniture and other forest products, that means companies will need to distinguish between packaging used for the international transport leg and packaging that continues circulating within the EU.<\/p>\n Using a pallet twice does not make it a reuse system<\/strong><\/p>\n One of the areas most likely to cause confusion is the definition of reuse.<\/p>\n PPWR does not simply require a pallet to be durable enough to be used again. The packaging must operate within a reuse system.<\/p>\n The regulation defines such a system as an organisational, technical or financial arrangement that enables reuse and ensures that packaging is collected for subsequent use. It can operate as a closed loop between known locations or as an open system with a larger number of participants.<\/p>\n For a sawmill, furniture company or timber merchant, an informal arrangement under which customers sometimes send pallets back will not necessarily be enough.<\/p>\n The company needs to know how pallets are collected, where they return, how damaged units are repaired and when they are ready for another rotation. The regulation defines a rotation as the complete cycle from placing the packaged goods on the market until the packaging is ready to be used again.<\/p>\n This requirement is relevant already in 2026 for companies using reusable packaging.<\/p>\n Businesses using reusable packaging must participate in at least one reuse system and ensure that the packaging is reconditioned before being used again. Closed-loop systems also require packaging to be returned to collection points agreed by the participants and approved by the system operator. These activities may be delegated to a third party operating the common system.<\/p>\n EPAL pool already recognised as a reuse system<\/strong><\/p>\n The European Commission\u2019s August 2026 PPWR FAQ again names the EPAL pallet pool as an example of an open reuse system.<\/p>\n That gives EPAL users an existing structure for meeting the reuse-system requirement rather than having to build a proprietary return system. EPAL says pallets circulating through its open pool can contribute towards the reuse targets that will apply from 2030.<\/p>\n The system is already large. EPAL says more than 1,750 licensed companies manufacture and repair its pallets and other load carriers. More than 670 million EPAL Euro pallets and around 20 million box pallets are currently in circulation.<\/p>\n The regulation could therefore strengthen the commercial position of established pallet pools. For companies facing future reuse targets, using a system that already documents circulation, repair and reuse may be considerably simpler than setting up a new system for individual pallet flows.<\/p>\n Some wooden packaging is exempt from the reuse targets<\/strong><\/p>\n Not every wooden crate or pallet will fall under the 2030 reuse requirements.<\/p>\n The PPWR provides several exemptions that may be relevant to wood packaging producers.<\/p>\n Packaging used for dangerous goods is excluded. Packaging for bulky machinery, equipment and other large goods can also be exempt where it has been individually designed to meet the requirements of a specific customer.<\/p>\n That provision is particularly relevant to companies manufacturing bespoke timber crates for machinery, industrial equipment and oversized loads.<\/p>\n Cardboard and paperboard boxes are also excluded from the reuse targets, but this exemption does not cover wooden crates or pallets. It also does not remove other PPWR obligations applying to cardboard; it concerns the reuse requirements specifically.<\/p>\n Companies still do not know how the 40% target will be calculated<\/strong><\/p>\n A major problem for companies preparing for 2030 is that the final calculation method does not yet exist.<\/p>\n The European Commission has until June 30, 2027 to establish the methodology through an implementing act.<\/p>\n Until then, companies know the broad target but do not know the final accounting rules that will determine whether they have met it.<\/p>\n That complicates decisions over pallet pools, long-term packaging contracts and investments in return logistics.<\/p>\n The regulation states that the formal obligation to demonstrate achievement of the targets will begin on January 1, 2030, or 18 months after the implementing act enters into force, whichever comes later.<\/p>\n Several other technical elements are also unfinished.<\/p>\n The EU has not yet established the detailed criteria for assigning packaging to recyclability performance grades. Minimum rotation requirements for common reusable packaging formats are due by February 12, 2027. There are also unresolved questions over the responsibilities of some suppliers of packaging components, including companies producing parts later incorporated into finished pallets.<\/p>\n PPWR could favour further investment in fibre-based packaging<\/strong><\/p>\n The consequences for the forest products industry extend beyond pallets.<\/p>\n By 2030, packaging placed on the EU market will have to comply with recyclability criteria and performance standards. Packaging classified in recyclability grades A, B or C will initially remain eligible for the market, with the rules tightening further later in the following decade.<\/p>\n Paper and board already have a relatively strong position.<\/p>\n Around 87% of paper and cardboard packaging in Europe is recycled, according to the source material, while the industry is targeting a 90% recycling rate for fibre-based packaging by 2030.<\/p>\n This matters because the European paper industry has been moving investment towards packaging for several years.<\/p>\n European paper and board production fell 1.6% to around 77.4 million tonnes in 2025 and remained weak at the beginning of 2026. Graphic papers continue to lose volumes, making packaging grades increasingly important for mills looking for other markets.<\/p>\n Paper producers are particularly interested in functional and barrier papers that can replace plastic in applications where ordinary paper does not provide enough protection.<\/p>\n These grades can require moisture, grease or oxygen barriers, heat-sealing properties and sufficient mechanical strength for high-speed packaging lines.<\/p>\n The difficulty is making those products perform like plastic packaging without adding coatings or other components that interfere with conventional paper recycling.<\/p>\n PPWR does not automatically give paper an advantage. Fibre-based packaging will still have to meet the same regulatory test: it must comply with the recyclability and other product requirements applicable to the packaging concerned.<\/p>\n For producers of coated and barrier papers, the details of the future EU design-for-recycling criteria will therefore be important.<\/p>\n Higher fibre packaging demand would also reach wood markets<\/strong><\/p>\n Any large-scale shift towards fibre-based packaging would eventually affect raw material demand.<\/p>\n Europe already uses large volumes of recovered paper, but recycled fibre cannot circulate indefinitely without fresh fibre being added.<\/p>\n Fibres deteriorate after repeated recycling, some material is lost during processing and a proportion never returns to the collection system. Virgin fibre therefore remains necessary both to maintain volumes and to provide the technical properties required for many paper and board grades.<\/p>\n If PPWR accelerates the substitution of some plastic packaging with paper-based alternatives, the effect would not stop with packaging converters. It could also affect packaging paper, market pulp and demand for virgin wood fibre.<\/p>\n How large that effect will be is still uncertain. European mills remain under pressure from energy and manufacturing costs, weak demand in several product groups and competition from producers outside Europe.<\/p>\n What wood companies need to do now<\/strong><\/p>\n For most wood companies, the first job is to establish what packaging they actually use and what legal role they have.<\/p>\n A sawmill should check whether it manufactures its own crates or pallets. A pellet producer needs to look at who is legally responsible for its bags. Furniture manufacturers should examine cartons, plastic film and transport packaging ordered under their own branding.<\/p>\n Companies already using returnable pallets need to establish whether their current system meets the PPWR definition of a reuse system.<\/p>\n The next step is to map the physical flow of packaging.<\/p>\n Companies need to know how many pallets move between their own plants, how many are used for domestic business-to-business deliveries, how many cross into another EU Member State and how many leave the EU.<\/p>\n Under PPWR, those routes can produce different reuse obligations from 2030.<\/p>\n The exercise should not stop at pallets. Companies will also need information on crates, foil, strapping, clips, dividers, cartons and other packaging used in their shipments.<\/p>\n Return and repair data are likely to become more important as well. Businesses that currently do not record pallet returns, repairs, damage and repeated rotations may need to start doing so before the 2030 reporting regime begins.<\/p>\n For pallet manufacturers and companies producing their own packaging, PPWR is already a compliance issue in 2026.<\/p>\n For most sawmills, furniture producers and timber traders, the bigger change is still ahead. From 2030, the type of pallet will matter, but so will where it travels, whether it comes back and whether that return is part of a system that can be documented.<\/p>\n That makes PPWR less a question of simply replacing one pallet with another than of reorganising how transport packaging moves through the supply chain.<\/p>","protected":false},"excerpt":{"rendered":" The European Union\u2019s new Packaging and Packaging Waste Regulation is now applicable across the bloc, bringing immediate compliance requirements for pallet and packaging manufacturers and setting much tougher reuse rules for transport packaging from 2030. The Packaging and Packaging Waste … Continue reading |