European Pallet Association e.V.
EPAL
Organisation der Wiederverwendung von Holzpaletten (EPAL-Paletten) in einem offenen Tauschpool (open loop-System).
ID: 182920592207-72
Lobbying Activity
Response to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)
13 May 2025
EPAL welcomes and supports the clarification in Annex I No. 4415 that used and second-hand wooden packaging such as pallets will be excluded from the application of the EUDR. This is the urgently needed consequence of the correct regulation that wooden pallets loaded with goods are not relevant products. Since the EUDR information chain is therefore interrupted with the transport of goods, no reference number can be passed on when the empty and used pallets are subsequently collected and delivered again. However, we strongly recommend that the exemption for used wooden pallets and wooden packaging also applies if they are repaired with new wood components and not exclusively with reclaimed (recycled) wood components, contrary to what is explained in the FAQ (version April 2025, no. 2.6). Despite the repair with new wood components, it is still a used wooden pallet and wooden packaging and the main commodity is used wood. In the case of the application of the EUDR to repaired wooden pallets and other wooden packaging, it is to be expected that the repair rate of wooden packaging and thus also the duration of use will decrease significantly, because the effort for preparing a new DDS for the new components alone is disproportionately high compared to the prices for the repair or for repaired wooden pallets and wooden packaging. Any reduction of the repair rate of wooden packaging would run counter to the objectives of the PPWR, which is intended to promote repair in order to extend the service life of packaging and thus reduce the consumption of resources. When repairing used wooden pallets and wooden packaging, reclaimed wood components are often used. However, if new or as good as new wooden pallets and wooden packaging are being repaired, new wood components are also used in order to maintain the quality and value and not shorten the period of use of the wooden packaging or limit the possible use cases. Paasing on a new DDS for wooden pallets and wooden packaging repaired with new wood components is likely to cause confusion in the market, as the trade in used wooden pallets and wooden packaging often does not distinguish between repaired and unrepaired use wooden pallets and wooden packaging, in particular between wooden pallets and wooden packaging that have been repaired with new or reclaimed components. If this were necessary, the effort for sorting and storing used wooden pallets and wooden packaging would increase significantly, which would further impair reuse. In practice it will hardly be possible to distinguish between new and as-new but reclaimed wood components. The companies that repair used wooden pallets and wooden packaging are predominantly SME or micro-enterprises, many of which would be overstrained with the preparation of DDS and will look for avoidance strategies for this reason alone. It can be assumed that compliance would depend to a large extent on the frequency and effectiveness of national controls, so that considerable distortions of competition would have to be expected. It is therefore strongly recommended by EPAL that the exemption of used wooden pallets and wooden packaging from the application of the EUDR should also be extended to used wooden pallets and wooden packaging that have been repaired with new wood components. Since the wood material volume of the new wood components used for the repair of wooden pallets and wooden packaging is relatively low, a waiver of DDS for repaired wooden pallets and wooden packaging is justifiable without jeopardizing the achievement of the right objectives of the EUDR. It is sufficient if the repairers collect the reference numbers for the purchased new wood components and thus ensure the EUDR compliance of wooden pallets and wooden packaging that are repaired with new wooden components. It is not necessary to prepare and pass on a new DDS.
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