PPWR reaches its general application date: what UK pallet users should review now

What has actually happened

Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation — entered into force on 11 February 2025 and applies generally from 12 August 2026, with a number of individual provisions phased in on their own timetables set out in the regulation itself.

It is a packaging regulation. It is concerned with packaging placed on the EU market: how it is designed, what it contains, how it is minimised, how it is labelled and how it is recovered. It has nothing to do with the ISPM15 plant-health regime, which governs the treatment and marking of solid wood packaging to control pests. The two regimes are triggered by different things and are evidenced in completely different ways, and confusing them is the single most common mistake we see in enquiries.

Palletmove has not published a position on how any individual obligation applies to any individual business, because that depends on what is being placed on the EU market, by whom, and in what role in the supply chain. Those are questions for the businesses concerned and their professional advisers.

Why this matters

• If your goods reach the EU market, someone in your chain has packaging obligations under this regulation, and pallets and transport packaging are within the scope of the packaging conversation even where the specific duty sits elsewhere.
• Because the general application date has now passed, procurement and packaging specifications written before it should be reread rather than assumed to be current.
• Treating PPWR as though it were an export/plant-health matter leads teams to look for the wrong evidence — an IPPC mark answers nothing here, and a packaging declaration answers nothing about ISPM15.

What UK pallet users should review

None of the following is a legal conclusion, and none of it tells you whether a particular duty falls on you. It is the review we would run before answering a customer questionnaire about EU packaging.

• Identify which of your goods reach the EU market, and in what role you sit — the regulation allocates duties by role, not by industry.
• Separate your plant-health evidence from your packaging evidence. ISPM15 treatment and IPPC marking answer a pest-control question and nothing else.
• Reread packaging and pallet specifications written before August 2026 rather than assuming they remain appropriate.
• Agree with your customers which party is being asked for what, in writing, before the questionnaire arrives.
• Where a specific obligation is genuinely arguable, take professional advice. Implementation detail is exactly where generic guidance fails.

PPWR is not ISPM15. PPWR is EU packaging regulation; ISPM15 is an international plant-health measure for solid wood packaging. Meeting one says nothing about the other. Palletmove does not give legal advice and makes no statement about how any provision applies to any individual business.