The EUDR does not cover plastic pallets; therefore, for buyers and logistics managers, they are the simplest way to avoid the new, stringent due diligence obligations and the legal risks associated with the origin of timber.
What is the EUDR and what is its purpose?
The EUDR is European Union Regulation 2023/1115 on goods and products associated with deforestation and forest degradation. In practice, these regulations are intended to drastically restrict the import and placing on the European market of timber products (and other raw materials, such as rubber, soya or cocoa) if the supplier is unable to unequivocally demonstrate that they originate from legal, ‘deforestation-free’ sources.
Of course, the new EU legislation does not completely block the timber trade – but it does require the entire supply chain to be fully documented. For companies that manufacture, import or place timber products on the EU market for the first time (including manufacturers of wooden pallets), this means significant new administrative procedures, increased operating costs and the risk of financial penalties.
Which pallets does the EUDR cover? Who is responsible, and what are their obligations?
The EUDR covers, among other things, wooden packaging in all forms, including new wooden pallets placed on the EU market.
The key term here is ‘placing on the market’. Crucial responsibilities rest with manufacturers, importers and first sellers. These companies must:
For end users of pallets and logistics operators, this means that packaging suppliers must be thoroughly vetted. If your wooden pallet supplier fails to comply with the formalities, you risk having your deliveries held up or facing penalties.
Timeline: When did the EUDR come into force?
In accordance with the latest decisions by the EU authorities, the timetable for the implementation of the EUDR provisions is as follows:
Although these dates may seem a long way off, the years 2026–2027 will be a period of significant upheaval for the wooden pallet market. Timber suppliers and packaging manufacturers must completely overhaul their IT systems and compliance procedures. For the end customer purchasing wooden pallets, this means one thing: the risk of sudden price volatility, periodic shortages in the availability of pallets, and a significant amount of extra work verifying suppliers’ documents.
Why are plastic pallets completely outside the scope of the EUDR?
Plastic pallets, including the flagship recycled HDPE models manufactured by Libra Partners, are not timber products. As such, they are in no way subject to the EUDR.
When choosing plastic containers:
From the perspective of a purchasing manager or logistics manager, switching to plastic pallets represents a significant reduction in regulatory risk and the red tape that the compliance department would otherwise have to deal with.
An alternative ready to meet the challenges of PPWR and EUDR
For companies involved in large-scale logistics, the EUDR imposes a significant legal liability for every tonne of new timber. HDPE plastic pallets are completely unaffected by these regulations.
What’s more, by investing in reusable plastic pallets from Libra Partners, you’ll kill two birds with one stone: you’ll eliminate EUDR risks whilst also fully complying with the upcoming EU requirements on packaging waste reduction (the PPWR Regulation).
FAQ – Frequently Asked Questions
I’ve heard that EPAL lobbyists have negotiated an exemption for pallets from the EUDR. Is that true?
No, that’s a myth. Organisations representing wooden pallet manufacturers (including the EPAL committees and the European federation FEFPEB) lobbied very hard in Brussels, but they did not succeed in securing an exemption for new wooden pallets from the EUDR. All newly manufactured wooden pallets (both domestic and imported) are 100% subject to the regulation. The only success achieved by the lobbyists was a clarification of the regulations concerning used pallets (in the secondary market), meaning that logistics companies do not have to report GPS coordinates every time goods are transported on an old pallet. The market for the purchase of new wooden pallets remains fully subject to the bureaucracy of the EUDR.
Why is buying new wooden pallets in Ukraine now such a risky business?
Under EU law, Ukraine is treated as a ‘third country’. This means that any Polish company importing new pallets from there is, under the regulations, the importer responsible for the EUDR. It is the Polish buyer who must obtain accurate geolocation data (GPS) for the Ukrainian forests from which the raw material was sourced. Given the geopolitical situation, the difficulty of conducting on-site audits and the risk of corruption associated with illegal logging, reliably verifying this data is virtually impossible. If an EU inspection reveals discrepancies in the documentation of a Ukrainian sawmill, the Polish importer will face huge financial penalties and the goods will be seized.
Does the EUDR apply to users of pallets in day-to-day logistics?
As a general rule, the regulation applies to entities placing timber products on the market for the first time. Ordinary secondary trade and the reuse of older pallets on the domestic market do not give rise to any new reporting obligations. However, be mindful of importing goods: if your company imports finished goods from outside the EU (e.g. from Asia) on wooden pallets, you become, in the eyes of the law, the importer of that wooden packaging, and it is your responsibility to demonstrate its full compliance with the EUDR and to obtain the forest’s GPS coordinates. Choosing plastic pallets for international transport completely eliminates this risk.
Are all new wooden pallets subject to the EUDR?
Yes. If the pallet enters the European Union market as a new timber product (CN code 4415), its manufacturer or importer must, without exception, carry out due diligence procedures and register the pallet in the EU system.
What documents must a supplier of wooden pallets have?
Such a supplier must have a complete due diligence audit trail, an official declaration of due diligence submitted to the EU system, documentation proving that the raw material was sourced from a legal source, and precise geolocation data (GPS) for the forest plots from which the timber used to produce the batch of pallets in question was harvested.
Does choosing plastic pallets exempt you from EUDR obligations?
Yes. Plastic pallets do not contain a single gram of wood-based material (they are classified under a completely different customs code – CN 3923), and are therefore entirely excluded from this regulation. The buyer does not assume any legal or administrative risk associated with deforestation.
From an ESG perspective, isn’t plastic worse than wood?
From an ESG perspective, isn’t plastic worse than wood? Absolutely not. A modern approach to ESG involves not only analysing the material itself, but also regulatory stability and supply chain transparency. Libra Partners’ plastic pallets are made from 100% recycled material, operate in closed-loop systems for many years, hold an official LCA certificate confirming a 55% reduction in carbon footprint, and completely eliminate the risk of deforestation (EUDR).
Summary: Between 2026 and 2027, price will no longer be the sole criterion for selecting pallets – legal certainty and a lack of red tape will take its place. If you wish to protect your logistics operations from the effects of the EU Deforestation Regulation and the risks associated with importing pallets from abroad, please contact the Libra Partners team. We will provide free samples of recycled plastic pallets for testing in your warehouse.
Rafał Szarzała Centrum Produkcyjno-Handlowe “Szarpol”
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98-200 Sieradz
