Féderation Europeènne des Fabricants de Palettes et Emballage en Bois
FEFPEB
• The European Federation of Wooden Pallet & Packaging Manufacturers (Fédération Européenee des Fabricants de Palettes and Emballages en Bois – FEFPEB) represents European national timber packaging associations, including the pallet, lightweight packaging and industrial packaging sectors.
ID: 924074750032-19
Lobbying Activity
Response to Circular Economy Act
6 Nov 2025
Position paper on the Circular Economy Act The European Federation of Wooden Pallet and Packaging Manufacturers (FEFPEB) welcomes the opportunity to contribute to the consultation on the forthcoming Circular Economy Act (CE Act). Wooden pallets and packaging are the backbone of European logistics, representing one of the most established models of circularity in practice. They are made from renewable raw materials, designed to be reused and repaired many times, and recycled into valuable secondary raw materials at the end of life. In some countries, wood is the only critical raw material. The scale of the sector illustrates its importance: in 2022, European manufacturers produced 521 million new pallets and repaired 220 million. Together, this represents nearly three quarters of a billion pallet units returned to circulation in one year alone. Pallets in circulation within the EU are estimated at 2.6 Billion units. The industry generates annual turnover in excess of 7 billion, supports over 100,000 jobs in Europe, and plays a critical role in enabling the Single Market to function by facilitating the cross-border movement of goods. Wooden pallets account for more than 90 percent of the European pallet pool, far outweighing plastic or other alternatives. This dominant position reflects woods unique combination of sustainability, performance, and cost efficiency. To achieve this, the CE Act must not only set guiding principles but also provide robust enforcement tools and practical mechanisms that allow businesses to comply efficiently. Our key recommendations for the CE Act include: 1. Harmonised rules on the entity responsible for EPR fee payment FEFPEB calls for the CE Act to bring clarity and harmonize who is the entity responsible for paying EPR fees for packaging put on the market. Divergent definitions across Member States create confusion and risk double charging leading to unnecessary administrative and financial burden. FEFPEB recommends that the producer who first places packaging on the market should be responsible for paying EPR fees. The definition of first placing on the market should clearly exempt packaging of producers to be exported outside the European Market since some European Countries like Italy or Germany have a high worldwide export rates of e.g. machinery. This approach eliminates uncertainty and administrative disputes among manufacturers, fillers, distributors, and importers. Since manufacturers of wooden pallets and packaging often cannot trace the end use or country of final disposal, the reponsibility should rest with the initial producer (such as the brand owner or first distributor), consistent with established practices in Spain, Belgium, and France. Pallet producers who already manage large, complex flows of packaging across borders have administrative clarity to maintain efficiency of EPR systems. Best practice from Spain provides a supporting precedent, requiring first placers, including importers and distance sellers, to register and assume EPR obligations. This model demonstrates that traceability is possible, and free riding can be prevented without creating additional burdens. 2. Eco-modulation of EPR fees for wooden packaging FEFPEB calls for the CE Act to mandate that EPR fees should be modulated to reward circular and sustainable materials such as wood. Current weight-based criteria unfairly penalise wood compared with lighter, less sustainable alternatives. A wooden pallet can circulate between 7 and 10 times in typical supply chains, and many remain in use for decades thanks to repair systems. In 2022, 220 million pallets were repaired and recirculated, extending lifetimes and reducing demand for virgin raw material. At end of life, recovery rates exceed 90% in leading Member States, feeding established secondary markets such as panel board or pallet block manufacturing. In Belgium, more than 83% of C&I packaging is reusable, with wooden pallets forming the backbone
Read full responseResponse to Towards a Circular, Regenerative and Competitive Bioeconomy
23 Jun 2025
The European Federation of Wooden Pallet and Packaging Manufacturers (FEFPEB), welcomes the opportunity to provide input to the EUs Bioeconomy Strategy consultation, and urges policymakers to recognize the essential role of wooden pallets and packaging in achieving Europes circular and climate objectives. As the voice of the European wooden pallet and packaging industry, we call for a Bioeconomy Strategy that fully acknowledges the environmental benefits, circularity, and functional value of wood-based packaging, and supports its continued use and development. Wooden packaging is a proven model of circularity. It is durable, designed for repeated use, easy to repair, and recyclable into high-value products or biomass. It stores carbon throughout its lifecycle, contributes to climate mitigation, and is made primarily from sustainably managed forests. Unlike fossil-based materials, wood is biodegradable and naturally antimicrobial, making it ideal for logistics, food transport, and industrial use. Its unique sustainability profile must be reflected in EU legislation. We urge the EU to adopt a regulatory approach that is fit for purpose. Applying rules designed for fossil-based packaging to wood risks undermining its environmental benefits, particularly through unnecessary treatments that compromise biodegradability and carbon storage. Legislation must recognize woods low impact and high value. Incentives should be introduced to support reuse and return systems, and sustainability criteria such as reuse potential should be prioritized in public procurement. The upcoming revision of the Food Contact Materials Regulation must also reflect the antimicrobial properties of wooden packaging. We strongly support a cascading use model for wood, where material is first used for high-value applications, then reused or recycled, and only finally used for energy. This model maximizes resource efficiency and extends carbon storage. However, it must remain flexible, driven by market conditions and regional realities. Wooden packaging should only be classified as waste at the end of its cascading lifecycle, and policies must recognize it as a valuable secondary raw material until that point. A harmonized collection and recycling infrastructure is needed across Member States, supported by dedicated funding. We also call for the alignment of the Bioeconomy Strategy with the Green VAT Initiative. Current VAT rules discourage reuse of wooden pallets by applying tax on second-hand products. This disincentivizes circularity. Exempting reused pallets from VAT would directly support the EUs climate and resource-efficiency goals. On reusability labelling, we emphasize that existing branding and marking systems used by pallet poolers already function as effective reuse indicators in B2B logistics. These systems are well-established, widely recognized, and do not require redundant labelling. The Bioeconomy Strategy should explicitly recognize such branding as valid proof of reusability, particularly in the context of the Packaging and Packaging Waste Regulation. To ensure the success of the EU Bioeconomy Strategy, we call for a legislative and policy framework that reflects the specific strengths of wooden packaging. This includes tailored regulation, tax alignment for reused products, recognition of established reuse systems, and support for cascading use. Wood packaging is a cornerstone of the circular economy and climate strategy, and must be treated as such in EU policy.
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