PPWR pallet marking: what Article 15 asks for
A type, batch or serial number. The manufacturer's name and address. That is the mark. Not a unique identity on every pallet, and not an RFID tag by default.
A PPWR pallet mark is a batch-level identifier plus a manufacturer address. Article 15(5) of Regulation (EU) 2025/40 asks for a type, batch or serial number, or another element that identifies the packaging. Article 15(6) asks for the manufacturer's name, registered trade name and postal address. Both may sit on the pallet or behind a QR code. An accompanying document is allowed only where size or nature makes on-product marking impractical.
What the regulation does not require
The Commission's PPWR FAQ, updated in August 2026, states that the identification number does not have to be unique to each unit. A type, model or production batch is enough, because the mark exists to link the pallet to its technical file and its declaration of conformity. A written answer published on 2 November went further: reusable packaging already in circulation can keep moving without redesign, and reuse rotations can be proven with statistical and operational records rather than item-level tracking.
Two retention rules follow from Article 15(3). The declaration and technical file stay available for five years on single-use packaging, and for ten years on reusable packaging, counted from the date the pallet is placed on the market.
Where the mark should physically sit
Moulded recycled pallets are hostile to labels. Contamination bloom from mixed polyolefin feed leaves a textured skin. Hot wash at 60–80 °C lifts adhesive within months. Ink at the fork entry wears off first, because that is where the truck touches. Engraving the cavity avoids all three.
Mark zones on a nine-foot moulded pallet. The centre foot carries both marks; neither sits in a fork path.
Three rules that decide whether the mark survives
Text depth of at least 0.8 mm, so it does not polish out over 300,000 cycles. A pin pocket clear of the wear zone. A defined orientation, so the mark lands in the same place on every shot and can be photographed for the first-article report.
What to write into a mould RFQ
| Line item | Ask for | Why |
|---|---|---|
| Type code | Model, footprint and material class, e.g. "ZK-1210 rHDPE 80" | Answers a procurement question without a phone call |
| Date insert | Monthly pin in a protected pocket, owner named | Gives batch-level traceability without per-unit tags |
| Position | Marked on the drawing, 30 mm clear of fork openings | Survives handling; stays photographable |
| Evidence | First-article photo with the mark legible, before shipment | Cheapest compliance evidence you will buy |
Three questions buyers ask
Do I need a unique number on every pallet?
No. The Commission's FAQ confirms that a type, model or batch reference is sufficient. Uniqueness at unit level is a commercial choice, usually driven by a pooling contract or a high-value fleet.
Does an RFID tag satisfy the marking requirement?
It can carry the identity, but it is not required by Article 15, and on-metal read rates fall below 50% on steel-faced pallets. A moulded batch code plus a maintenance log is the cheaper route to the same evidence.
What happens if the pallet was moulded before 12 August 2026?
Packaging already placed on the market can stay there without redesign or relabelling. For stock still on your floor, an accompanying document carrying the identification number and manufacturer details is acceptable, provided the substance limits are met.
Put the mark in the tool, not in the warehouse
Send 50–100 kg of your own flake. We will press a first article on the ZK-P1800 and photograph the mark before you commit to a cavity.
Request a trial press See mould specifications