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Explainer 7 min read

Wood Packaging EPR Regulations: UK Compliance Guide

EPR Compliance Team

Table of Contents


Key Takeaways

  • Wood packaging attracts an EPR fee of approximately £215 per tonne — one of the lower rates.
  • Pallets are the dominant wood packaging item and can represent the largest single packaging category by weight for many businesses.
  • Returnable pallets may be excluded from EPR obligations if they are part of a managed return and reuse system.
  • One-trip pallets (supplied with goods and not returned) are definitively packaging and must be reported.
  • Wooden crates, boxes, and dunnage are all in-scope packaging items.

Wood Packaging Under EPR

Wood is one of the most significant packaging materials by weight, primarily due to pallets. Almost every business in the UK supply chain uses wooden pallets for transit, and for many businesses, pallets represent the single largest packaging item by tonnage.

Under EPR, wood packaging is relatively straightforward in terms of fee rates but complicated by the question of returnable versus one-trip packaging. Understanding when a pallet counts as your EPR obligation and when it does not is essential for accurate reporting.

For EPR background, see what packaging EPR is.

Common Wood Packaging Types

FormatTypical WeightCommon Use
Euro pallet (1200x800mm)20-25 kgStandard transit
UK standard pallet (1200x1000mm)25-30 kgUK transit
Half pallet (800x600mm)10-15 kgRetail display
Wooden crate10-50 kgHeavy/fragile items
Wooden box5-20 kgPremium goods, export
Dunnage (timber supports)VariableLoad separation/support
Plywood sheets5-15 kgPallet tops, protection

EPR Fee Rates for Wood

Wood FormatFee per tonne (approx.)
Wood (general)£215
Wooden pallets£215
Wooden crates£215
Plywood packaging£215

Wood has a flat fee rate. At £215/tonne, it is one of the lower-cost materials under EPR.

For all material rates, see the EPR fees by material type guide.

Cost Example

A business using 5,000 one-trip pallets per year at 25 kg each:

  • Total tonnage: 125 tonnes
  • EPR fee: 125 x £215 = £26,875

This is a significant cost that can be avoided by switching to returnable pallets.

Returnable Pallets and Crates

The key question for wood packaging is: when is a pallet returnable (and therefore potentially excluded from EPR)?

Excluded from EPR

Pallets may be excluded if:

  • They are part of a managed pool system (e.g., CHEP, LPR)
  • There is a documented return process with records showing pallets are actually returned
  • They are reused multiple times in a closed-loop supply chain

Included in EPR (Your Obligation)

Pallets count as packaging when:

  • They are one-trip pallets — supplied with goods and not returned
  • The customer keeps or disposes of the pallet
  • There is no return system in place

Documentation Required

If you claim that pallets are returnable and excluded from EPR, you should maintain:

  • Records of pallet movements (sent and returned)
  • Agreements with customers regarding pallet returns
  • Data on actual return rates

Regulators can challenge returnable claims, so documentation is essential.

Reporting Wood Packaging

What to Report

  1. One-trip pallets supplied with your products
  2. Wooden crates and boxes shipped to customers
  3. Dunnage and supports — timber used to separate or support loads
  4. Plywood sheets — used as pallet tops or load separators

What to Exclude

  1. Pool pallets with documented return systems
  2. Pallets you receive from suppliers (their obligation, not yours)
  3. Timber that is part of the product (e.g., a wooden shelf sold as furniture is not packaging)

ISPM 15 Treatment

Wood packaging used in international trade must be treated to ISPM 15 standards (heat treatment or fumigation). This does not affect the EPR classification — treated and untreated wood are both classified as wood packaging.

For reporting guidance, see how to report packaging data to DEFRA.

Reducing Wood EPR Costs

1. Switch to Pool Pallet Systems

The most impactful change is moving from one-trip pallets to a managed pool system (CHEP, LPR, or your own return scheme). This can eliminate hundreds of tonnes from your EPR obligation.

Cost comparison:

  • One-trip pallets: £5-8 per pallet purchase + £215/tonne EPR
  • Pool pallets: £5-10 per pallet per trip + £0 EPR

2. Use Lighter Pallets

If one-trip pallets are unavoidable, specify lighter-weight options:

  • Press-wood pallets — lighter than solid timber
  • Plywood-top pallets — lighter deck boards
  • Smaller pallets — half pallets where full pallets are not needed

3. Replace Wood with Plastic Pallets

Plastic pallets are lighter than wooden ones and can be more easily returned. However, they would be classified as plastic packaging (£360/tonne) if not returned, so the benefit only applies if they ARE returned.

4. Eliminate Dunnage

Timber dunnage used to separate loads can sometimes be replaced with cardboard or corrugated spacers.

5. Maximise Pallet Loads

Shipping full pallets rather than partial ones reduces the per-unit pallet weight allocation.

Getting Started

  1. Audit your pallet usage — count one-trip vs returnable
  2. Weigh your pallets — they vary significantly
  3. Document returnable systems — keep records of returns
  4. Register with a compliance scheme
  5. Submit data to DEFRA

Use the EPR fee calculator and visit our pricing page.

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