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Knowledge Centre — export & packaging compliance

PPWR explained, and why it is not ISPM15

The EU Packaging and Packaging Waste Regulation governs packaging and packaging waste. Plant-health marking of timber is a different regime with different obligations. Conflating the two produces confident answers that are wrong.

Published by Palletmove. Last reviewed: 3 September 2026. Operational guidance for logistics and procurement teams. It is not legal advice, customs advice, certification, or a guarantee that a given consignment will be accepted.

What PPWR is

PPWR — Regulation (EU) 2025/40 — is the European Union's regulation on packaging and packaging waste. The European Commission's overview confirms that it applies to packaging and packaging waste and that it begins to apply from mid-2026.

It is separate from ISPM15. ISPM15 concerns the plant-health treatment and marking of solid wood packaging moved across borders. PPWR concerns packaging placed on the EU market and what happens to it as waste. A pallet can be relevant to both, to one, or to neither, depending on what you are doing with it and where.

What PPWR means for your business

There's no single table of obligations we can give you here. PPWR's application depends on your role in the supply chain, the market you place packaging on, the packaging format, and how your customers and distributors are structured. Those are questions for your own compliance function or a competent adviser working from the legal text.

What we can do is keep the three regimes separate in your thinking, and help you gather the operational facts any adviser will ask for first.

UK packaging EPR is a third thing

UK extended producer responsibility for packaging is a domestic producer-responsibility and reporting regime. It is not PPWR, and PPWR compliance activity does not discharge it. If your business handles or supplies packaging in the UK, treat UK EPR as its own workstream with its own owner, and do not assume that a single "packaging compliance" project covers both.

Keeping them apart

Three regimes, three questions

How ISPM15, PPWR and UK packaging EPR differ
ISPM15 / WPMEU PPWRUK packaging EPR
Core questionIs this timber packaging treated and legibly marked?Does this packaging meet EU packaging and packaging waste requirements?Have UK packaging obligations been reported and paid?
Applies toSolid wood packaging moved between GB and other countries, EU included.Packaging and packaging waste in the EU context.Packaging handled or supplied in the UK.
TimingIn force; GOV.UK guidance last updated 22 April 2026.Begins to apply from mid-2026.Ongoing domestic reporting cycles.
EvidenceA legible physical mark on the item.Documentation determined by your role and the legal text.Reported data under the domestic regime.

Establish before you scope any PPWR work

  • Which of your packaging formats actually reach the EU market, and in whose name.
  • Your role for each format: producer, importer, distributor or end user.
  • Whether the pallets involved are owned, purchased used, or pooled operator stock.
  • Which internal owner holds UK packaging EPR, so the two are not merged.
  • Whether any of your assumptions come from a supplier's summary instead of the legal text.

Where Palletmove can help operationally

  • Establishing what pallet types and volumes actually move through your sites.
  • Separating pooled operator stock, which is never yours to reclassify or dispose of.
  • Recording reuse, recovery and recycling activity we carry out for you, factually and without invented figures.
  • Structuring collection and supply so evidence is easier to produce later.
  • Flagging where a question needs a competent adviser, not a service provider.

Packaging review under way?

We can supply the operational pallet facts your compliance team needs, without guessing at the legal conclusions.

Talk to Palletmove