The Packaging and Packaging Waste Regulation (PPWR) introduces new requirements for transport packaging, including wooden pallets. While some obligations already apply, others will come into force over the coming years. Here's how Rotom helps customers meet current PPWR requirements and prepare for future obligations.
PPWR Requirements for Wooden Pallets
The PPWR contains several requirements that are relevant for wooden pallets as transport packaging. As the regulation is being implemented in phases, Reusable Packaging (Article 11), Substances of Concern (Article 5) and the first phase of Recyclable Packaging (Article 6) already apply, while additional obligations will follow between 2028 and 2030.
| PPWR Article | Topic | Applicable from | Definition |
|---|---|---|---|
| Article 11 | Reusable Packaging | 11 February 2025 | The PPWR sets specific criteria for reusable packaging. Packaging must be designed to withstand multiple use cycles, maintain health, safety and hygiene standards, allow reconditioning where appropriate, continue performing its intended function, be safely handled during use, and be recyclable at the end of its life cycle.More |
| Article 5 | Substances of Concern | 12 August 2026 | The PPWR requires that the presence and concentration of substances of concern in packaging materials and components are minimised. This applies to substances that may pose a risk to human health or negatively affect recycling processes and material cycles. Key requirements include limiting the combined concentration of heavy metals such as lead, cadmium, mercury and hexavalent chromium to a maximum of 100 mg/kg, while restricting per- and polyfluoroalkyl substances (PFAS) in food-contact packaging.More |
| Article 6 | Recyclable Packaging |
12 August 2026 (phased implementation until 2030) |
From 12 August 2026, packaging must be recyclable and enable material recovery. From 2030, packaging must be designed for material recycling, enabling the substitution of primary raw materials with secondary raw materials of similar quality. From 2035, packaging waste must also be capable of being collected, sorted into dedicated waste streams, and recycled at scale. Packaging must also comply with future Design for Recycling (DfR) criteria to be established by the European Commission.More |
| Article 12 | Packaging Labelling | 12 February 2029 | Reusable transport packaging operating in a closed-loop reuse system must carry a label informing users that the packaging is reusable. The label must also provide information on applicable recovery systems and collection points.More |
| Article 10 | Packaging Minimisation | 1 January 2030 | Packaging manufacturers and importers must demonstrate that the weight and volume of packaging are limited to the minimum necessary. This requirement applies while maintaining functionality, safety, product protection and durability.More |
Current PPWR Requirements: How Rotom Complies Today
Rotom already complies with the PPWR requirements that currently apply to wooden pallets:
- Article 11: Reusable Packaging (from 11 February 2025)
Rotom pallets are designed for multiple use cycles and conform to EN 13429:2004, the European standard for reusable packaging. Through both open-loop and closed-loop systems, pallets can be reused multiple times while maintaining their functionality and safety. In addition, Rotom's Pallet Recovery Service helps customers retain and extend the value of their own pallet pool, supporting circular logistics and helping maximise pallet reuse. - Article 5: Substances of Concern (from 12 August 2026)
All Rotom pallets are backed by supplier declarations demonstrating compliance with PPWR requirements. Our suppliers comply with REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) and RoHS (Restriction of Hazardous Substances) regulations, ensuring that materials and components used in our pallets meet existing EU restrictions on hazardous substances. - Article 6: Recyclable Packaging: Material Recovery (from 12 August 2026)
Rotom pallets are recyclable and conform to EN 13430:2004, the European standard for recyclable packaging through material recovery. Both wood and metal components can be recovered and recycled through established waste streams.
Future PPWR Requirements: How Rotom Is Preparing
Rotom is already preparing for the next phases of the PPWR implementation:
- Article 6: Recyclable Packaging: Design for Recycling (from 1 January 2030)
Rotom is closely following the development of the European Commission's Design for Recycling (DfR) criteria and the methodology for recyclability performance assessment, which are expected to be established by 2028. Together, they will provide a harmonised framework for assessing packaging recyclability from 2030 onwards. As Rotom wooden pallets are 100% recyclable, Rotom is confident in its ability to formally demonstrate compliance with Article 6 once the delegated acts are adopted. - Article 12: Packaging Labelling (from 12 February 2028)
Rotom is monitoring the development of labelling requirements for reusable transport packaging, especially those in a closed-loop reuse system, and is preparing its processes and documentation accordingly. - Article 10: Packaging Minimisation (from 1 January 2030)
Rotom pallets are designed to balance material efficiency, durability, product protection and operational safety. By optimising pallet designs according to customer requirements and industry standards, we ensure efficient use of materials without compromising performance or reusability.
The Rotom Guarantee
All Rotom pallets are backed by an EU Declaration of Conformity in accordance with Article 39 and Annex VIII of the PPWR. These declarations are supported by supplier documentation and supply chain due diligence processes, ensuring that Rotom is prepared for both current and future PPWR requirements.
Through its Circular Pallet Solutions, including Buy Back, Pallet Recovery and Rental, alongside reusable and recyclable wooden pallets, Rotom supports customers in building more circular supply chains while meeting the requirements of the PPWR. Want to learn how Rotom can support your PPWR compliance and sustainability goals? Reach out to our logistics specialists using the contact form below. We are happy to discuss the right solution for your business.