Hygienic and food-grade pallets: what the regulations say

In briefA food-grade pallet must be washable and, if it may touch the product, comply with Regulation (EC) 1935/2004 and Regulation (EU) 10/2011, backed by the supplier's declaration of compliance. For direct contact you need suitable virgin plastic, or recycled plastic from a process authorised under Regulation (EU) 2022/1616.

A hygienic pallet for food must be washable and easy to disinfect. If it may touch the product, it also needs the supplier's declaration of compliance. This page covers the regulations, the choice between virgin and recycled plastic, and what to ask for.

The regulations at a glance

When a pallet counts as a food contact material

Regulation (EC) 1935/2004 is not just about plates and trays. Article 1(2) extends it to materials that can reasonably be expected to come into contact with food ^[1].

A pallet carrying whole cheeses, fruit in open crates, meat in bins or big bags of flour falls into this category. A pallet with goods sealed in cartons usually does not: the company's HACCP lead makes that assessment.

If the pallet is in scope, three articles of the regulation apply ^[1]:

• Article 3: the material must not release substances in harmful quantities or change the composition, taste or smell of the food;
• Article 16: the supplier issues a written declaration of compliance;
• Article 17: the material must be traceable along the supply chain.

Plastics: migration limits and the declaration

For plastics, Regulation (EU) 10/2011 sets the migration limits. Article 12 sets the overall migration limit: the material must not transfer more than 10 mg of constituents per dm² of contact surface into food simulants ^[2].

Article 15 and Annex IV define what the declaration of compliance must contain ^[2]. The manufacturer must also work to the good manufacturing practice of Regulation (EC) 2023/2006 ^[3].

What to ask your supplier for:

• a declaration of compliance with 1935/2004 and 10/2011, referring to the pallet code;
• the material (HDPE or PP), virgin or recycled;
• the intended conditions of use: type of food, temperature, contact time;
• batch or production date, for traceability.

How to write these requirements into a specification and check them on delivery is explained in plastic pallet specification and testing.

Virgin or recycled

Virgin plastic suitable for food contact is the straightforward choice: the manufacturer declares it compliant and the paperwork is simple.

With recycled plastic the issue is a different one: where it comes from. Regulation (EU) 2022/1616 governs recycled plastic intended for food contact and ties its use to compliant recycling processes ^[4]. A pallet in mixed post-consumer recyclate, without this guarantee, should be kept for goods that are already packaged. How 2022/1616 applies to an article such as a pallet still needs checking case by case with your supplier.

What a hygienic pallet looks like

Annex II, Chapter IV of Regulation (EC) 852/2004 requires containers and equipment used for food to be kept clean and designed so that they can be cleaned and disinfected ^[5]. In design terms, that means:

The two materials behave differently with temperature. HDPE works down to about −45 °C and suits blast freezers; PP handles the heat peaks of washing better, up to about 127 °C against 110 °C for HDPE, according to one manufacturer's data sheets ^[8]. The full comparison is in plastic pallet materials; condensation, ice and washing before the cold store are covered in the guide to pallets for cold stores and frozen goods.

Pharma and cleanrooms

In pharmaceuticals, many companies generally keep wooden pallets out of controlled-contamination areas, because wood sheds fibres and is hard to sanitise. They use closed-deck plastic pallets, often in dedicated colours to separate areas, and in some cases PP pallets that can withstand sterilisation. The exact requirements are set by the site's quality system.

The ROLL hygienic pallet: what it is for and what it is not

ROLL does not sell food pallets in general. Among its flat pallets it offers a single hygienic model, the PPH1: H1 type, 800×1200, closed runners, no reinforcing bars, washable, 19 kg ^[9].

The PPH1 is made from recycled material. It is designed for clean environments, pharmaceutical logistics and sealed goods, not for direct contact with food. Among ROLL products, the ones in virgin PE, such as the RM01, LO01 and SO01 cradle pallets and the CV01 insert, are the candidates for any food contact use. Suitability only holds, however, with a declaration of compliance with Regulation (EC) 1935/2004 and Regulation (EU) 10/2011 referring to the product code: ask ROLL for it before use. The models are in the guide to reel pallets.

The 2020 German study on wood hygiene

A 2020 study that comes out in favour of wood is widely quoted in Germany. Here is who paid for it, who carried it out and what it measured.

• Commissioned by: a national association that promotes wooden pallets ^[7].
• Carried out by: the Institute of Wood Technology in Dresden, with tests from February 2018 to December 2019 ^[7].
• Method: wooden euro pallets of all quality grades and H1-type plastic pallets, bought used and not cleaned, contaminated with Escherichia coli and Staphylococcus aureus ^[7].
• Result: under the test conditions, wood showed antibacterial activity more than 13 times higher than the H1 pallet ^[7].

The study also says two things that are quoted less often. Damaged areas on used plastic pallets hold bacteria, so a damaged plastic pallet should be replaced. And with proper cleaning, bacteria and fungi can be removed from wood too ^[7].

Our reading: the study compares used, uncleaned pallets. In a food business pallets get washed, and plastic goes through a tunnel washer, does not absorb water and does not splinter. We have found no independent studies either way on regularly washed pallets. Methods, machines and washing temperatures are in plastic pallet washing.

Exporting to the United States

In the USA the reference is the FDA. 21 CFR 177.1520 allows polyethylene and polypropylene in contact with food if the polymer meets the specifications in that section ^[6]. For a pallet going to that market, ask for a declaration of compliance with 21 CFR 177.1520 in addition to the European ones.

Loads of film and paper reels for food packaging follow the same rules on hygiene; the right format is in reel pallets. The general comparison with wood is in plastic or wooden pallets.

The three flat pallets offered by ROLL

ROLL does not sell generic plastic pallets. Among flat pallets it offers only these three, each for a specific use.

For pallet racking ROLL PP69 1200×800 with 3 steel bars, 16 kg; 1,200 kg racking load according to the manufacturer’s datasheet. Designed for rack storage, with the pallet spanning two beams.

For hygienic environments ROLL PPH1 H1 type with closed runners, no steel bars, washable. Made from recycled material: not for direct food contact.

For floor handling ROLL PP08 Closed flat deck, 4-way entry, 9 feet: for moving pallets on the floor with a pallet truck. Not designed for racking.

Found a mistake or an outdated figure? Write to us at info@roll-packaging.com