EUDR wooden pallets 2026/2027 – CN ex 4415, packaging exemption and return evidence | Word/PDF/Excel

Is a wooden pallet sold empty exempt from EUDR simply because the same pallet type is used as transport packaging? No. A new wooden load pallet or pallet collar imported or sold as a separate product may be covered by the EU Deforestation Regulation under CN ex 4415. The same wooden pallet may, however, be covered by an explicit exemption when it exclusively carries, protects or supports another product and is presented together with it.

A third situation is reusable pallets: the updated Annex I to delegated regulation (EU) 2026/2102 specifies an exemption from the time the packaging is actually used for that purpose and thereafter. This means that an unused new EPAL or return system pallet is not automatically exempt solely by virtue of its design or marking. The actual use must be verifiable.

This special package is designed for Swedish pallet factories, wood packaging wholesalers, importers, reusers, exporters and logistics companies that need to document new pallets, loaded pallets and used return packaging separately. The work templates are based on EUDR Regulation (EU) 2023/1115, the simplified role allocation in (EU) 2025/2650, the new Annex I (EU) 2026/2102 and the Commission guidance 2026.

Which wooden pallets may be covered by EUDR 2026/2027?

New empty wooden pallets sold separately: New load pallets, pallet collars, pallet boxes and wooden packaging placed on the EU market or exported as separate products may potentially be covered by CN ex 4415. For an applicable product, the operator responsible needs to assess the EUDR requirements for deforestation-free status, legality, wood raw material origin, operator role and any due diligence statement (DDS).

Loaded pallets: A pallet used exclusively as packaging to support, protect or carry another product that is supplied on the market or exported, and which is presented together with this product, may be covered by the exemption under Annex I. Document the actual goods transport with a shipping document, packing list or other reliable link. The product being transported may have its own EUDR requirements.

Reusable pallets and return packaging: When a reusable pallet is clearly suitable for repeated use and has actually been used to carry/protect other goods, there is a special exemption from the time of use and onwards. Used or second-hand goods also have explicit exemptions under the amended Annex. However, a stamp, a purchase agreement or a future intention to use the pallet is not the same as documented first use. Pallets that are repaired or rebuilt with new components may require additional manual borderline assessment.

Important Dates and Business Roles

EUDR generally starts to apply on 30 December 2026. For certain specially qualified micro and small primary operators, 30 June 2027 is specified, but this date does not automatically apply to all smaller businesses. Special conditions apply, among other things, to goods that were already covered by the older timber regulation. The Swedish Forest Agency guidance distinguishes between importers, primary operators, downstream operators and traders.

For new separately sold pallets that are covered, the operator responsible may need to establish an actual due diligence process and, where applicable, a DDS in the EU information system. Subsequent operators may be covered by other traceability and retention requirements. This package can document supporting information and actual reference numbers, but does not create an official DDS, geolocation or customs classification.

File List – What Do You Get?

Excel: Nine Tabs and Eight Approved Scenario Tests

The workbook contains Overview, Pallet Batches, Evidence of Use, Suppliers, Wood Origin, DDS & References, Risk & Exemptions, Decisions & Follow-up and Read Me & Sources. Common pallet batch ID links a business case to shipping documents, actual evidence of use, supplier supporting information and any deviations. The formulas report only administrative signals.

Eight scenario tests are approved: (1) new separate pallet with documented supporting information leads to manual EUDR assessment, (2) new separate pallet without wood origin evidence is blocked, (3) loaded pallet with actual shipping evidence goes to manual exemption assessment, (4) loaded pallet without evidence is blocked, (5) documented used return pallet goes to manual exemption assessment, (6) unused “return pallet” without first use is blocked, (7) open deviation blocks and (8) incorrect/unclear CN code is blocked. No fictitious test entries remain in the customer file.

Practical Workflow for Purchase, Import and Pallet Pool

1. Identify the actual pallet: item, wood type, CN ex 4415, manufacturing, supplier and the actual business transaction.
2. Distinguish the business case: is the pallet sold as a new separate product, as loaded packaging pallet or as used return packaging?
3. Verify potential exemption: link the shipping document to the other product, document first use and retain reliable return/pallet pool information.
4. Request evidence of origin where EUDR applies: sawmill lots, raw material, actual geodata, legality supporting information, deforestation evidence and any issued DDS/DI references.
5. Record deficiencies: unknown first use, seemingly “used” new pallet, changed wood material or an incomplete supplier chain.
6. Perform separate manual assessment: authorized person decides on applicable exemption, EUIS requirements, import/export and sufficiency of documentation.

Who Benefits Most from the Package?

Suitable for: pallet manufacturers, importers of new Europallets, pallet collar wholesalers, pallet pools, rental and return logistics companies, reusers and purchasing/compliance officers who need to trace the difference between new and used pallet products.

Not intended for: issuing an official decision, an EUIS-DDS, CITES/FLEGT certificate, binding customs ruling, legality guarantee for wood, actual GPS or satellite control or full timber regulation compliance for all goods. For other product groups, Mallbutiken offers its general EUDR package and EUDR wooden furniture – CN 9403.

Frequently Asked Questions about EUDR and Load Pallets

Are new empty Europallets covered by EUDR?

A new wooden pallet sold or imported as a separate product may be covered by CN ex 4415. It cannot automatically be treated as exempt transport packaging simply because it is designed for goods delivery.

Is a wooden pallet carrying other goods exempt?

The exemption may apply when the packaging is exclusively used to support, protect or carry another product and is presented together with it. Actual business and use must be assessed.

Does the same apply when an empty return pallet is sent back?

Packaging clearly suitable for repeated use has a special exemption from the time it has actually been used to carry/protect other goods and thereafter. Document the previous use. Also assess exemptions for used goods.

Is the EPAL stamp sufficient for exemption?

No. A standard or quality marking does not in itself provide evidence of when the pallet was first used and in which actual business flow.

Must a small importer start on 30 June 2027?

Not always. The later date only applies to qualified categories. Wood products covered by the timber regulation may fall under the earlier date. Check the business and the legal status of the goods.

Can Excel decide that my pallet is exempt?

No. Excel provides administrative signals and barriers; a final EUDR decision requires checking the legal text, actual documentation and an authorized person.

Are the PDF files fillable and is the entire package available in English?

The PDF versions are searchable and printable but not interactively fillable. The five work templates and Excel are in Swedish. A Swedish guide and a separate English User Guide are included.

Official Legal Sources

EU 2023/1115 – Deforestation Regulation · EU 2026/2102 – Annex I and new ex 4415 exemption · EU 2025/2650 – Application dates and operator roles · EU Commission guidance on packaging, load pallets and reuse 2026 · Swedish Forest Agency – Products and exemptions · Swedish Forest Agency – Application dates and responsibility.

Product version 1.0 · AI-assisted legal primary source check 11 November 2026 · No external independent legal review, certification, official decision, actual customer testing or EUIS submission has been carried out. Check changes and specific exemptions before actual import/export.