The EU Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40, universally shortened to PPWR — entered into force in February 2025 and became generally applicable on 12 August 2026. It replaces the old packaging directive with a directly applicable regulation, which means no national transposition and far less variation between member states.
If you buy wooden pallets or crates, the headline you have probably heard is that transport packaging faces reuse targets. That is true, but the detail matters, and for wooden packaging the detail is unusually favourable.
Wooden pallets are exempt from the reuse targets
The reuse quotas that attracted most attention — including a 40% target for transport packaging moving cross-border between economic operators from 2030 — do not apply to wooden pallets. Guidance issued ahead of the application date confirmed that pallets, along with plastic strapping and stretch film, sit outside the quantitative reuse targets. Custom transport packaging, which is most of what we build, is likewise outside them.
The logic is straightforward once you see it: a pallet is already a reused item. Pooling and exchange systems have existed for decades, wooden pallets are routinely repaired rather than discarded, and imposing a reuse quota on a product with an existing reuse rate near total would achieve nothing.
Exempt from targets is not exempt from the regulation
This is where buyers get caught out. Being outside the reuse quotas does not put wooden packaging outside the PPWR altogether. The obligations that do apply include:
- Substances of concern. Packaging must respect limits on heavy metals — lead, cadmium, mercury and hexavalent chromium. For untreated softwood packaging this is rarely a problem in practice, but it is a declared requirement rather than an assumption.
- Recyclability. Packaging needs a recyclability assessment and self-declaration.
- Technical documentation and a declaration of conformity. This is the practical change: someone in the chain has to hold a file demonstrating the packaging complies, and be able to produce it.
- Extended producer responsibility. Registration and reporting obligations continue and are harmonised.
- Minimising empty space. The much-quoted 40% empty space limit is aimed at e-commerce parcels and grouped packaging rather than a crate built around a machine, but the underlying principle — do not ship air — applies to packaging design generally.
What this means when you place an order
Practically, three things change in the conversation between a buyer and a packaging producer.
First, ask your supplier for the conformity documentation rather than assuming it exists. The obligation attaches to packaging placed on the EU market, and the documentation trail is what an enforcement authority will ask to see.
Second, expect design questions to be asked earlier. "Does this need to be this big?" was always a cost question; now it is also a compliance question. Oversized packaging is more expensive, uses more timber, wastes freight space and is now harder to defend.
Third, treat reuse as an opportunity rather than an obligation. Because wooden packaging is outside the reuse quotas, any returnable system you run is a commercial decision made on its own merits, not a compliance box to tick. In many cases the economics genuinely work — see our article on one-way versus returnable packaging — but you get to make that call on cost and logistics grounds.
Timeline beyond August 2026
PPWR is phased. The obligations that landed in August 2026 are the general applicability, the documentation and substances requirements, and the empty-space rules. Further requirements on design for recycling, recycled content, reuse systems and labelling arrive through implementing and delegated acts, with the substantive milestones falling in 2030, 2035 and 2040.
For a manufacturer buying wooden transport packaging, the realistic reading is that PPWR raises the paperwork bar now and the design bar gradually. It does not force you away from wood. If anything, it does the opposite: a material that is renewable, repairable and already circular is a comfortable place to be under this regulation.
A note of caution
Guidance around PPWR is still developing, and the exemption picture has moved more than once during the run-up to application. If a compliance decision at your company turns on whether a specific item is in or out of scope, verify against the current official guidance rather than an article — including this one. What we can tell you with confidence is what we supply, how it is made, and what documentation comes with it.
