For two years the timber sector has been focused on EUDR. Meanwhile a second regulation has been moving quietly toward its deadline, and it lands squarely on wood packaging: the Packaging and Packaging Waste Regulation, or PPWR. Its main obligations apply from 12 August 2026.
We already covered what PPWR requires in general. This piece is about the part that catches pallet buyers off guard: under PPWR, the company legally on the hook is often not the pallet supplier. It is the buyer.
The deadline is closer than it looks
PPWR (Regulation (EU) 2025/40) entered into force in February 2025, and its core obligations apply from 12 August 2026. As a regulation rather than a directive, it applies directly in every member state, with no national transposition. The rules are the same across the EU on day one.
The trap: you may be the "manufacturer"
PPWR assigns most obligations to the "manufacturer" of the packaging (Article 3, point 13). The instinct is to assume that means the sawmill or pallet workshop that physically nails the boards together. Often it does not.
If a pallet carries your name or mark, or is built to your design specification, PPWR treats you as the manufacturer, even when a supplier physically builds it.
In other words, a plain, unmarked, standard pallet is the supplier's responsibility. But a custom pallet built to your drawing, or a standard pallet stamped with your company name, flips the liability to you. A quick look at a typical pallet spec sheet makes the point: a bespoke 825x1050 pallet ordered by a named client, built to that client's design, is exactly the case where the client becomes the manufacturer under PPWR. One narrow exception: if the company that orders the pallet is a micro-enterprise (under 10 people and under 2 million euros turnover), the obligation stays with the supplier.
What being the manufacturer makes you responsible for
1. A Declaration of Conformity
Every packaging type placed on the EU market needs a signed EU Declaration of Conformity (Article 39, Annex VIII): a legally binding self-declaration that the pallet meets PPWR requirements. Without one, the packaging cannot legally be placed on the market. The FNB, the French timber federation, publishes a harmonised template for wood packaging.
2. A technical file behind it
The declaration has to be backed by technical documentation (Article 38, Annex VII): a general description of the pallet, its design and materials, the wood volume, and a qualitative assessment of recyclability, minimisation, and reuse. If your supplier built the pallet, you will need them to hand over the technical data so you can compile this file.
3. Records, kept for years
Declarations of Conformity must be retained and produced for authorities on request: five years for single-use packaging, ten years for reusable packaging. Reusable pallets also become subject to identification requirements from 2029, though EPAL pallets are exempt because the EPAL mark already serves that purpose.
The good news: wood is well placed
None of this should read as a reason to move away from wood. The opposite is true. Wood packaging enters PPWR from the strongest position of any material:
- Recycling targets for wood are set at 25% by 2028 and 30% by 2030, far below the 70% to 85% demanded of steel, paper, and glass.
- France was already recycling 37% of wood packaging in 2023, ahead of the 2030 target, according to ADEME.
- EPAL pallets are exempt from the additional reuse labelling; the EPAL logo suffices.
- The sector argues, credibly, that wood needs no eco-design subsidy because it is already a mature, well-recovered material.
For most pallet designs, the design and recyclability obligations are about producing evidence, not re-engineering the product.
A France-only layer: REP for professional packaging
One caution for French operations specifically. Alongside PPWR, France is introducing an Extended Producer Responsibility scheme for professional packaging (REP Emballages Professionnels) from 1 July 2026, with its own obligations: registering for a unique identifier, joining an eco-organisme (Citeo Pro, Twiice, or Léko), and filing an annual declaration. This is a French national scheme, separate from EU-wide PPWR, and it does not apply to pallets exported outside France. If you operate across several EU countries, keep the two frameworks distinct.
What to do now
- Work out your role first: are you the manufacturer for any of your pallets, because they carry your name or are built to your spec?
- Separate in-scope EU pallets from export-only stock, which is treated differently.
- Set up a Declaration of Conformity for each pallet type you place on the market.
- Assemble the technical file behind each one, requesting the data from your supplier where needed.
- Put five and ten year record-keeping in place, and plan reuse labelling ahead of 2029.
Not sure whether you are the party on the hook? Our free PPWR pallet compliance check runs through these six questions in about two minutes and hands you a tailored list of gaps to close.
PPWR paperwork is exactly the kind of documentation our free PPWR tool is built to handle, the same way we run EUDR due diligence. If you want to walk through your specific situation before the August deadline, book a call and we will map it out with you.