Exporting to the EU? What the New Packaging Law Means for Your Pallets
The EU’s new packaging regulation took effect on August 12, and your heat treated pallets clear customs exactly the way they did in July. ISPM-15 is untouched. What changed is what your customer in Rotterdam or Antwerp does with that pallet once it’s off the boat, and who pays for it.
The ISPM-15 part, which didn’t move an inch
Same standard as last year. Wood packaging headed to the EU has to hit 56°C at the core for 30 continuous minutes, and it has to carry the IPPC stamp with the treatment facility’s number on it.
The part that trips up Georgia shippers isn’t the heat. It’s the bark. ISPM-15 has required debarked wood since the 2009 revision, and the tolerance is tighter than most people assume: individual patches have to be under 3 cm wide, or if a patch is wider than that, its total surface area has to stay under 50 cm². That’s roughly a business card. Inspectors at EU entry points check for it.
EU border checks run under the Official Controls Regulation 2017/625 and Regulation 2019/2125, and the outcomes when wood packaging fails aren’t a warning letter. The load gets detained. Depending on the risk assessment, the wood packaging gets re-exported at your cost or destroyed. Your product sits in a bonded yard while somebody figures out which.
Picture a flooring exporter out of Dalton loading 22 pallets for Antwerp. One pallet in that load has a stringer with a strip of bark somebody missed on the line in March. That’s the whole load held, not that one pallet.
The exemption that protects you, and the part it doesn’t cover
PPWR is Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation. It applied from August 12, 2026, and yes, pallets are packaging under it. They’re classed as transport packaging, right alongside crates, trays, and stretch film.
Here’s the good news, and it’s real. The NWPCA fought for and won language limiting the reuse requirements to packaging used “within the territory of the Union.” Pallets entering or leaving the EU under load are exempt from PPWR’s reuse-system tracking obligations at the border. Practically, that means your standard 48x40 stringer still lands. So does an expendable single-use pallet. If it’s heat treated and stamped, customs takes it.
What the exemption doesn’t do is follow the pallet past the gate. Inside the EU, PPWR sets reuse targets for transport packaging: 40% reusable by 2030, rising to 70% by 2040. Your receiver is on the hook for those numbers, not you. But a receiver who has to hit 40% reusable on their own transport packaging is a receiver who has a strong reason to stop accepting your stringer into their internal distribution — and the labeling and digital data carrier requirements, QR or RFID, phase in behind the 2026 date and add to that pressure.
Where this actually shows up on your invoice
Repalletization. That’s the whole answer.
EU receivers in pharma, food ingredients, chemicals, and anything running automated handling have been standardizing on EPAL and CP block pallets for years, and PPWR gave them a regulatory reason to formalize it. A US stringer doesn’t run in EU pallet pooling networks, doesn’t always feed cleanly into their automation, and can’t count toward their reuse targets. So the cross-dock strips your load, puts it on their pallet, and bills you.
I’m not going to quote you a per-pallet repalletization fee, because it varies by country, facility, and contract, and any number I gave you would be a guess dressed up as research. Ask your receiver directly. That question — “are you repalletizing our loads, and what does it cost us” — is worth a phone call this week, because plenty of shippers are finding out about the charge when the debit memo arrives.
If the answer comes back that they need EPAL or CP, be straight with yourself about what that means. Authentic new EPAL pallets require a licensed manufacturer, and there are very few in the United States. That’s a different supply chain and a longer lead time than a heat treated 48x40, and it isn’t something we build. We’ll tell you that on the phone rather than let you find out in November.
What to do before the next EU load leaves your dock
Four things, in order of how much money they save you.
Call the receiver and get the pallet spec in writing. Not the freight forwarder, not the broker. The plant that’s unloading it. If they want EPAL, you want to know now.
Check the boards, not just the stamp. A stamped pallet with bark on a stringer is a non-compliant pallet. Walk a few off the stack before they go on the truck.
Keep your treatment records where you can reach them. When a load gets flagged, the speed at which you produce the heat treatment documentation is the difference between a delay measured in hours and one measured in days.
Order HT stock earlier than you think you need to. Low-grade lumber is up 27% since January and Canadian softwood tariffs are past 40% combined, which has squeezed the #3 and #4 Southern Yellow Pine that pallets get built from. Tight material means lead times move around.
If you’re shipping out of Atlanta, Dalton, Gainesville, or anywhere on the I-75 corridor and you need heat treated pallets with the IPPC stamp, get a quote or call 770-607-0867.
