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Regulations for wooden pallets.

Navigating the regulatory landscape is crucial for ensuring compliance and promoting sustainability in the pallet and packaging industry. At the Sustainable Pallet Association, we are committed to keeping our stakeholders informed about the latest EU legislation impacting our sector. Below is a summary of the key regulations and their specific implications for wooden pallet producers.

SPA members are fully compliant with all relevant EU regulations, including the PPWR, WFD, EUDR, and EUTR. With a strong commitment to environmental responsibility, the SPA members consistently adopt practices that surpass the minimum requirements, setting a higher standard for the industry. Our approach to responsible sourcing, recycling, and circular economy principles reflects our dedication to not just meeting legal obligations, but setting the bar for a more sustainable future in the global logistics sector.

EU Deforestation Regulation (EUDR)

The EU Deforestation Regulation (EUDR) is a landmark piece of legislation that replaces the EU Timber Regulation (EUTR). It came into force on June 29, 2023, and its primary goal is to ensure that products sold in the EU market have not been sourced from deforested or degraded land. The EU Timber Regulation will be fully repealed by December 30, 2027, with a transition period for certain products.

Key Implications for Wooden Pallet Producers:

A core requirement of the EUDR is the collection of precise geolocation data for the plot of land where the wood was harvested. This necessitates robust traceability systems throughout the supply chain, from the forest to the final pallet production.

1. Sourcing and Compliance:

  • Wooden pallet manufacturers must ensure that their wood is sourced from legally harvested timber. This may involve working with certified suppliers (e.g., those adhering to FSC or PEFC standards) to provide assurance of legality.


2. Traceability Requirements:

  • Producers must maintain detailed records of their timber supply chains, including geolocation data and documentation proving compliance with EUTR requirements.


3. Increased Administrative Burden:

  • Implementing due diligence systems can increase operational complexity and costs, particularly for small and medium-sized pallet producers.


4. Market Differentiation:

  • Compliance with the EUTR offers an opportunity for producers to market their products as responsibly sourced, appealing to environmentally conscious clients.


5. Impact on Imports:

  • Non-EU suppliers must also adhere to EUTR standards, which may limit access to certain types of imported wood or increase costs due to stricter controls.


6. Penalties for Non-Compliance:

  • Failure to comply with the EUTR can result in significant penalties, including fines, product recalls, or reputational damage, making rigorous due diligence essential.

In summary, while the EUTR imposes strict obligations on wooden pallet producers, it also provides a framework for promoting sustainable and responsible business practices. By adopting robust due diligence systems and partnering with certified suppliers, producers can ensure compliance while enhancing their appeal in a market increasingly focused on sustainability.

While challenging, the EUDR presents an opportunity for our industry. Wooden pallets sourced from sustainably managed local forests can clearly demonstrate compliance, reinforcing their position as a truly green logistics solution. This stands in contrast to materials derived from fossil fuels, which have a different environmental footprint.

In summary, while the EUTR imposes strict obligations on wooden pallet producers, it also provides a framework for promoting sustainable and responsible business practices. By adopting robust due diligence systems and partnering with certified suppliers, producers can ensure compliance while enhancing their appeal in a market increasingly focused on sustainability.

Packaging and Packaging Waste Regulation (PPWR)

The former “Packaging and Packaging Waste Directive” has been updated to the Packaging and Packaging Waste Regulation (PPWR). This change is significant because a regulation is directly applicable in all EU member states without the need for national transposition. The PPWR aims to create a circular economy for packaging by setting ambitious new targets and requirements, which have direct consequences for our industry.

Key Features and Uncertainties for the Wooden Pallet Sector:

  • A central point of uncertainty is the requirement for a minimum number of rotations or trips for a pallet to be officially defined as ‘reusable’. The exact number has not yet been determined, creating significant ambiguity for the market.

  • The European Commission will convene an expert panel to clarify these technical details, but this process has been delayed.

  • The regulation acknowledges that reuse can occur in an “open system” (typical for many wooden pallets), but proving this is more complex than in a “closed system” (often used by poolers).
  • There is a critical debate on whether the ‘producer’ responsible for Extended Producer Responsibility (EPR) reporting is the pallet manufacturer or the end-user (e.g., a retailer).

  • The approach varies between member states. In Belgium, the end-user is considered the ‘producer’, whereas in Italy, it is the manufacturer.

  • The PPWR text currently suggests that for transport packaging, the manufacturer is the ‘producer’. This would place an enormous and potentially unfeasible traceability burden on pallet manufacturers.
  • The regulation aims for 100% of transport packaging used for intra-EU transport of goods to be reusable by 2030. This means pallets must not only be reusable but also be part of a system where they are actually reused. This reinforces the need for effective repair and collection networks, which are hallmarks of the wooden pallet industry

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