PPWR and EUDR for wooden pallets, crates and timber packaging: what applies from 2026
Two EU regulations hit the wooden packaging industry at the same time: the Packaging and Packaging Waste Regulation (PPWR) and the EU Deforestation Regulation (EUDR). Which obligations apply to pallets, export crates and reusable load carriers depends on how the packaging is placed on the market – and who orders it. This guide sorts it out, including the new pallet rule from Delegated Regulation (EU) 2026/2102.
At a glance: which regulation applies when?
What matters is not the material but the role of the packaging: is it sold as a product in its own right, made to a customer's specification, or does it accompany other goods?
| Situation | EUDR | PPWR |
|---|---|---|
| Standard pallets and cratesYou sell new wooden packaging under your own name, e.g. as a pallet manufacturer. | coveredEntry ex 4415 – due diligence statement or reference number required. | coveredYou are the manufacturer: declaration of conformity, technical documentation, marking. |
| Custom-made crate or palletYou build to your customer's specification, e.g. export packaging for a machine. | coveredThe sale to your customer is a product in its own right – pass on reference numbers. | depends on roleThe manufacturer is usually your customer. As a supplier you provide the necessary documents (Art. 16). |
| Single-use packaging for your own goodsThe wooden packaging exclusively supports, protects or carries your goods and is supplied with them. | excludedExcluded – expressly since Delegated Reg. 2026/2102. | coveredThe packaging must be compliant and marked. |
| Reusable and pooled palletsLoad carriers in an exchange or pooling system after their first use. | excludedExcluded from their first use as packaging. | coveredCounts towards the Article 29 reuse targets from 2030. |
| Trading used palletsYou buy used load carriers and resell them. | excludedUsed products are excluded – for repairs, the EUDR applies to the newly added wood. | depends on roleDistributor obligations (Art. 19): due care and checking the marking – no own declaration of conformity. |
The in-depth guides
EUDR for wooden pallets and timber packaging
Roles in the timber chain, the due diligence statement step by step, reference numbers, low risk, special cases and penalties.
PPWR for wooden pallets and export packaging
Manufacturer role for custom work, declaration of conformity, marking, reuse targets and the German VerpackDG.
Key dates
EUDR: the new pallet rule
Wooden packaging is listed in Annex I of the EU Deforestation Regulation under entry 4415. Since Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, the entry expressly excludes:
- used and second-hand products,
- single-use packaging used exclusively to support, protect or carry another product and presented with it,
- packaging clearly suitable for reuse from its first use for that purpose.
Anyone selling or exporting new pallets or crates as products in their own right remains covered. Only whoever first places the wood on the EU market files a due diligence statement; pallet plants using EU sawn timber are usually downstream operators and record suppliers and customers. Important: for timber products the EUDR applies from 30 December 2026 to micro and small companies as well – the postponement to June 2027 does not apply here.
All details: EUDR for wooden pallets and timber packaging.
PPWR: manufacturer role, declaration, reuse
The EU Packaging and Packaging Waste Regulation has applied to wooden pallets and export crates since 12 August 2026. Three points determine the effort:
- Manufacturer role: for custom work to the customer's specification, the customer is usually the manufacturer; the crate builder, as supplier, provides the documents under Art. 16. Exception: if the customer is a micro-enterprise in the same member state, the crate builder is the manufacturer.
- Declaration and marking: one declaration of conformity with technical documentation per packaging type; on the packaging a type, batch or serial number plus the manufacturer's name and address (Art. 15). The Art. 12 material label does not apply to transport packaging.
- Reuse from 2030: 40 % of pallets and crates used must be reusable, 100 % between own sites and within the same member state. Custom crates for large machinery are exempt (Art. 29(4)).
All details: PPWR for wooden pallets and export packaging.
What about ISPM 15?
Heat treatment and marking under ISPM 15 remain plant health law. They replace neither EUDR nor PPWR evidence, but they draw on the same master data: wood species, origin, batch and treatment. If you already document ISPM 15 properly in your ERP, you have a good part of the data in place.
How to handle PPWR and EUDR in Business Central
For wooden packaging manufacturers, both regulations come down to the same data: origin of the wood, bill of materials of the packaging, role in the order and the path of the goods. duveka maps this directly in Microsoft Dynamics 365 Business Central – and shows it live in free webinars on the EUDR and the PPWR.
duveka EUDR
Reference numbers from sawn-timber goods receipt to invoice, due diligence statements and Article 10 risk assessment.
duveka PPWR
Packaging types with ten check modules, traffic-light status, declaration of conformity and Art. 16 supplier declaration.
duveka Packaging
Industry solution for wooden and industrial packaging – from measurement to container.
duveka Pooling
Load carrier pools as objects in their own right in your ERP – so you know where your reusable pallets are.
duveka IPPC
ISPM 15 documentation, integrated with packaging and timber.
Frequently asked questions
Do the EUDR and the PPWR both apply to wooden pallets?
Often, yes. Anyone selling new pallets or crates as products in their own right is affected by both: the EUDR for the origin of the wood, the PPWR for the packaging itself. Packaging accompanying your own goods, by contrast, falls only under the PPWR.
Do I need an EUDR due diligence statement for every pallet I ship goods on?
No. Single-use wooden packaging that exclusively supports, protects or carries your goods and is supplied with them is excluded from entry 4415 – expressly since Delegated Regulation (EU) 2026/2102, and regardless of whether the goods themselves fall under the EUDR.
Who issues the declaration of conformity for a custom export crate?
Usually the customer who specifies dimensions, load capacity and design. The crate builder is a supplier and provides the necessary documents under Art. 16 PPWR – unless the customer is a micro-enterprise in the same member state, in which case the crate builder is the manufacturer.
Does the later EUDR deadline in June 2027 apply to small timber businesses?
No. The postponement for micro and small companies does not apply to products already covered by the EU Timber Regulation (EUTR) – so not to sawn timber and pallets either. The EUDR applies to them from 30 December 2026.
When do the obligations apply?
PPWR since 12 August 2026, reuse targets from 1 January 2030. EUDR from 30 December 2026 – for timber products regardless of company size. The new EUDR pallet entry has applied since 18 September 2026.