PPWR for wooden pallets, crates and export packaging: manufacturer role, declaration of conformity, reuse

• The PPWR has applied since 12 August 2026 directly to all packaging – wooden transport packaging expressly included.
• The manufacturer is whoever the packaging is made under the name of. For custom work to the customer's specification this is usually the customer; the crate builder supplies the documents.
• One declaration of conformity per packaging type with technical documentation, kept for 5 years (single-use) or 10 years (reusable).
• Marking: manufacturer information under Art. 15 is mandatory – the new material label under Art. 12 does not apply to transport packaging.
• From 2030: minimisation, recyclability criteria and reuse targets for pallets and crates.

The PPWR distinguishes roles that often blur in daily business. For wooden packaging two matter most: the manufacturer, who carries the product obligations (conformity, documentation, marking), and the producer, who carries extended producer responsibility (register, take-back) – in each member state where the packaging is first made available. For a pallet plant selling empty pallets in Germany, both usually coincide.

For crate builders this is the key question. Under Art. 3(13) PPWR, the manufacturer is primarily whoever has packaging designed or manufactured under its own name or trademark. The European Commission confirms in its FAQ: for packaging made specifically for one product to the customer's specification – dimensions, load capacity, material, design – the customer is usually the manufacturer. Taking the measurements does not change this: the dimensions come from the goods.

The crate builder is then a supplier and, under Art. 16, must provide its customer with all information and documents needed for the conformity assessment and declaration. The roles follow from the law and cannot be shifted by terms and conditions or contract.

Important exception: if the customer is a micro-enterprise in the same member state, the supplier – i.e. the crate builder – is the manufacturer instead (Art. 3(13)(b), Art. 15(12)). And anyone selling standard pallets or catalogue crates under their own name is the manufacturer anyway.

Conformity is assessed under Module A – internal production control (Art. 38, Annex VII). No notified body is needed; the manufacturer checks and declares itself.

The technical documentation (Annex VII) contains, where relevant, a risk analysis, a description and intended use of the packaging, designs, drawings and materials, the standards and specifications applied, the assessments of recyclability, minimisation and reusability, and test reports.

The EU declaration of conformity (Art. 39, Annex VIII) is issued by the manufacturer for each packaging type – not per batch. It states, among other things, a unique identifier of the packaging, the manufacturer's name and address, the legislation and standards applied, place, date and signature. It must be provided in the language of the member state concerned and kept up to date.

• Retention: 5 years for single-use, 10 years for reusable packaging (Art. 15(3))
• On request of the authority: provide documents within 10 days (Art. 15(10))
• Old stock: according to the Commission FAQ, packaging placed on the market before 12 August 2026 remains marketable – without a declaration of conformity.

• Heavy metals (Art. 5(4)): lead, cadmium, mercury and chromium VI in packaging or packaging components must not exceed 100 mg/kg combined – this includes nails and staples.
• Recyclability (Art. 6): a principle since 2026. Wooden pallets and crates are a separate category in Annex II; the Commission will set the specific design-for-recycling criteria by 2028, binding from 2030 at the earliest.
• Minimisation (Art. 10): from 2030, weight and volume must be limited to the functional minimum and justified in the technical documentation – using criteria such as product protection and logistics, expressly including pallet systems.
• Empty space (Art. 24): the 50 % cap from 2030 applies to whoever fills transport packaging – the packer, not the pallet plant. Wood wool used as filling counts as empty space.
• Not relevant to wood: minimum recycled content and bio-based content (plastic only), PFAS limits (food contact only).

Mandatory since 12 August 2026 (Art. 15(5) and (6)): a type, batch or serial number for identification, plus the manufacturer's name or trademark, postal address and, where applicable, electronic contact details – on the packaging, via QR code or, if size or type do not allow it, in the accompanying documents. According to the Commission FAQ, marking per type or batch is sufficient.

Not for transport packaging: the harmonised material label under Art. 12 does not apply to transport packaging – except in e-commerce.

Reusable packaging (Art. 11, Annex VI) must be designed for as many rotations as possible, be reconditionable and recyclable at the end, and run within a re-use system. The minimum number of rotations will be set by the Commission in a delegated act – which had not yet been adopted at the date of this guide. Open pools such as the EPAL exchange pool regard themselves as a re-use system within the meaning of the PPWR.

The targets (Art. 29) apply to everyone who uses pallets, crates, pallet wrapping and straps as transport packaging in the EU:

• Large machinery, equipment and raw materials (para. 4(b)): packaging designed to the individual requirements of the ordering company is not covered by the targets – the classic export crate in mechanical engineering.
• Dangerous goods and cardboard boxes (para. 4(a), (d)) are exempt as well.
• Pallet wrapping and straps have been exempt from the 100 % obligation since Delegated Decision (EU) 2026/429, but still count towards the 40 % target.
• Micro-enterprises making available no more than 1,000 kg of packaging per year and member state are exempt (para. 13).

The German Packaging Law Implementation Act (VerpackDG) has supplemented the PPWR since 12 August 2026:

• Registration with the Central Agency Packaging Register (ZSVR) – including for transport packaging. Newly obliged companies had to register by 12 September 2026; existing registrations must be updated by 12 November 2026.
• Authorisation (Section 19): producers of packaging not subject to system participation need an authorisation or transfer their obligations to an authorised organisation – transitional period until 31 December 2027.
• Take-back (Section 39): commercial transport and reusable packaging must be taken back; companies may agree otherwise. System participation is generally not required for commercial pallets and crates.
• Fines (Section 66): for PPWR infringements from 12 February 2027 – up to €10,000, €100,000 or €200,000 depending on the infringement.

An up-to-date declaration for every packaging type, the right role for every order, the marking for every pallet: this can only be managed from clean master data. duveka PPWR maps packaging types, checks and declarations directly in Microsoft Dynamics 365 Business Central – with the Packaging Connector straight from the bill of materials. See it live in the free PPWR webinar; wood origin is covered in our guide EUDR for wooden pallets and timber packaging.