Rotogal
Knowledge for hygiene-critical logistics
Guide · Export & regulation
9 min read

Food export compliance: a plastic-pallet and container guide for EU, US and UK shipments

EU 10/2011, FDA 21 CFR, FSMA, ISPM-15 and the split second between loading dock and harbour — what's actually required of hygienic pallets and transport boxes.

Key points
  • Plastic pallets are ISPM-15-exempt — no fumigation or IPPC stamp required for overseas shipment.

  • For US food imports FSMA additionally demands preventive-controls documentation; the 21 CFR 177 material certificate is mandatory.

  • On request we ship a combined export pack: EU 10/2011 DoC + FDA 21 CFR + BfR + traceability — all documents in a single PDF.

In detail

EU side: the baseline

Anyone producing food inside the EU needs a DoC under EU 1935/2004 and EU 10/2011 for every contact material. Our hygienic pallets and boxes ship by default with a product- and batch-specific DoC.

German authorities additionally expect the BfR reference (notably BfR III for polyethylene). France accepts the EU DoC as-is; for Italy we add the D.M. 21-3-1973 reference on request.

USA: FDA + FSMA + certificates

For US imports the 21 CFR 177 material certificate is central (177.1520 for PE or 177.1520(c) for PP, depending on the base resin). We provide this alongside the DoC and the approved-additive list.

Since FSMA (Food Safety Modernization Act) US authorities also require a preventive-controls documentation layer. The pallets and boxes themselves are not directly subject — but the importer must show their supply-chain programme covers contact materials. Our compliance pack slots into that evidence trail.

UK: Retained EU Law + FSA

Post-Brexit the UK operates the Retained EU Food Contact Materials Regulation, which reproduces EU 1935/2004 and EU 10/2011 verbatim. The Food Standards Agency (FSA) accepts EU DoCs in practice.

Add-on for Northern Ireland: under the Northern Ireland Protocol the EU framework applies in parallel — the standard EU DoC is sufficient.

ISPM-15 and why plastic wins

ISPM-15 (wooden packaging in international freight) requires heat treatment or fumigation of wooden pallets — with an IPPC stamp. Plastic pallets are explicitly exempt, which is a substantial total-cost-of-ownership advantage as export volumes grow.

Worked example: fumigating 5,000 wooden euro pallets per year typically costs €15,000–25,000 just for ISPM-15 compliance. With Rotogal hygienic plastic pallets that spend disappears.

Recommendation

EU export

Our DoC covers EU 1935/2004, EU 10/2011, BfR and migration results in one document.

US export

Plus FDA 21 CFR 177 with additive list — drops straight into any FSMA supplier programme.

Overseas freight

Plastic = no ISPM-15 fumigation, no IPPC stamp, no certificate chaos.

Frequently asked questions

Do plastic pallets need an IPPC stamp?

No. ISPM-15 applies exclusively to wooden packaging. Plastic pallets are exempt from fumigation and the IPPC stamp requirement.

Does FSMA apply to the importer as well as the manufacturer?

FSMA's Foreign Supplier Verification Program requires the US importer to document every supplier and every contact material. Our compliance documents satisfy FSVP evidence requirements.

Can we get the export proof in English?

Yes. All DoC and FDA documents are issued on request in English, French, Spanish or Chinese.

Does the export pack cover heavy-metal testing?

Yes. Our material testing covers lead, cadmium, chromium(VI) and mercury — all values sit well below EU and US limits.

Got a project?

Tell us about your requirement — we typically come back with a first assessment within 24 hours.

Request a quote

Please note: All information on this page – in particular dimensions, technical data, material properties and application recommendations – is provided for general guidance only and is non-binding. The exact specifications tailored to your specific application are agreed on a binding basis as part of the quotation and order process.

Project enquiry

Got a project?

Tell us about your requirement — we typically come back with a first assessment within 24 hours.