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Export Wooden Pallet Requirements: Regulations and Policies (Updated 2026)

19/10/2026 - Lê Văn Thăng

Export wooden pallet rules explained: ISPM 15 heat treatment, HS code 4415.2000, customs documents, and market-specific standards for EU, US and Australia.

Export Wooden Pallet Requirements: Regulations and Policies (Updated 2026)

Reviewed and updated by ICD - Week 43/2026

Wooden pallets used for export cargo must be debarked, treated under ISPM 15 (most commonly by heating the wood core to 56 °C for 30 minutes) and marked with the IPPC stamp. If the pallet itself is the export product, the exporter also needs legal timber documents under Circular 26/2025/TT-BNNMT (amended by Circular 84/2025/TT-BNNMT) and must declare HS code 4415.20. Markets such as the US and the EU check the IPPC mark right at the port of arrival.

56 °C / 30 minutes
Minimum HT core temperature under ISPM 15
4415.20
HS subheading for pallets, box pallets and load boards made of wood
22%
Maximum wood moisture for an EPAL Euro pallet 800 x 1200 x 144 mm

Pallet as packaging or pallet as the product

Wooden pallets are the most common load-carrying packaging in exports. Before preparing paperwork, work out which situation the shipment falls into, because the requirements differ quite a lot.

The most common situation is a pallet that is only packaging travelling with the goods: furniture, electronic components or farm produce loaded on pallets and then into a container. In that case the pallet only needs to be treated and marked with the IPPC stamp under ISPM 15. The second situation is a company selling wooden pallets themselves overseas. Here the pallet is the product, so besides ISPM 15 it needs legal timber documents, the correct HS code 4415.20 and a full set of commercial documents.

Summary by situation
Packaging travelling with goods: needs a valid IPPC mark. Pallet as the export product: add timber documents and HS code 4415.20. EPAL pallet: 800 x 1200 x 144 mm, maximum moisture 22%.

If you need the opposite direction, importing wooden pallets into Vietnam, see our guide to the procedures for importing wooden pallets.

Technical Requirements for Export Wooden Pallets

Under ISPM 15, a wooden pallet travelling internationally must meet 3 conditions. First, the wood must be debarked: only bark remnants narrower than 3 cm are allowed, or wider ones with an area under 50 cm² each; the standard does not require the surface to be planed smooth. Second, the wood must be treated against pests by one of the 4 recognised methods. Third, the pallet must carry the IPPC mark, made up of the wheat-ear symbol, country code, treatment facility code and method code, on at least 2 opposite sides, never hand-drawn.

How to read the ISPM 15 mark (fumigation mark) on a palletIPPCVN - xxxHTIPPC symbolon the left, separated by a vertical lineCountry codeVN = Vietnam (2-letter ISO code)Facility codeissued by the quarantine authorityTreatment codeHT, DH, MB or SFThe mark must be legible, durable, never hand-drawn, and applied on at least 2 opposite sides; no other information inside the border.ISPM 15 advises avoiding red and orange ink because these are the colours used on dangerous goods labels.
Diagram of a heat treatment mark: IPPC symbol, country code VN, facility code (xxx is an illustrative placeholder), code HT.
IPPC mark with code MB on stacked wooden pallets
IPPC mark with code AU (Australia) and code MB on a methyl bromide fumigated pallet, applied on a visible side face.

Besides ISPM 15, the wood must be free of weevils, mould and live insects at delivery, so pallets should be kept somewhere dry after treatment. Processed wood such as plywood, particle board and OSB falls outside the scope of ISPM 15, so a pallet made entirely of these materials does not need the IPPC mark. The four recognised treatments are:

Code on the mark Method Minimum conditions Notes
HT Heat treatment (steam or drying kiln) Core at 56 °C for 30 continuous minutes Most common, no chemicals, no limit on wood size
DH Dielectric heating (microwave, radio waves) 60 °C for 1 continuous minute across the whole cross-section Few facilities in Vietnam use it
MB Methyl bromide fumigation Wood and air at 10 °C or above, at least 24 hours Must be debarked before fumigation and aired afterwards; the IPPC recommends reducing use because it depletes the ozone layer
SF Sulfuryl fluoride fumigation Per the ISPM 15 dosage table Wood with moisture above 75% cannot be treated

Do Reused or Repaired Pallets Need Re-treatment?

We hear this often when customers want to reuse old pallets for a new shipment. ISPM 15 divides it into three cases. A pallet that has been treated, is marked and has not been repaired or had any component replaced can be reused and does not need re-treatment during its whole life. A repaired pallet, meaning one with up to about a third of its components replaced, may only use treated wood, and each new board must carry its own mark; the plant protection authority may require the old mark to be removed and the whole pallet re-treated.

Stack of used wooden pallets beside a container at the yard
Used wooden pallets stacked next to a container. Reused, repaired and remanufactured pallets each have their own rules in ISPM 15.

A pallet with more than about a third of its components replaced is treated as remanufactured. The old marks must then be removed entirely, the whole pallet re-treated and a new mark applied. So for cargo going to markets that inspect closely, the safe choice is a new treated pallet, or an old pallet that is intact with a clear IPPC mark.

Legal Documents When Exporting Wooden Pallets as Goods

When the pallet is the product, the authorities care about 3 things: the wood has a legal origin, the HS code is declared correctly, and the wood is not on the export ban list.

On timber origin, the exporter needs a harvest permit, a purchase contract or valid import documents for the wood; for processed forest products such as pallets, a forest product list is prepared stating the wood species, volume and origin. The current text is Circular 26/2025/TT-BNNMT, effective 1 July 2025 and amended and supplemented by Circular 84/2025/TT-BNNMT from 1 January 2026.

Sawn timber stored in bundles awaiting processing
Sawn timber bundled and waiting for processing. When exporting the pallets themselves, the company must prove the legal origin of this wood.

On the HS code, wooden pallets fall under subheading 4415.20, covering pallets, box pallets, other load boards and pallet collars; wooden cases, boxes, crates and cable drums fall under subheading 4415.10. The current table of HS codes for agricultural goods is Circular 01/2024/TT-BNNPTNT (effective 20 March 2024), replacing Circular 11/2021/TT-BNNPTNT. On the ban list, Item 20 of Appendix I of this circular prohibits exporting round logs and sawn timber of all kinds from domestic natural forests. Pallets built from plantation wood such as acacia, pine and rubber wood can still be exported, but must have documents proving their origin.

Many online sources still cite old documents. The table below shows the status of each one so that you do not prepare files under rules that have expired:

Document Content Status (October 2026)
Document 07/VBHN-BNNPTNT (2016) Consolidation of Circulars 01/2012 and 40/2015 on legal forest product documents The original circulars expired on 1 January 2019
Circular 24/2017/TT-BNNPTNT Table of HS codes for agricultural goods Replaced several times; the current HS table is Circular 01/2024/TT-BNNPTNT (effective 20 March 2024)
Circular 27/2018/TT-BNNPTNT Forest product management and traceability Expired on 15 February 2023
Circular 26/2022/TT-BNNPTNT Forest product management and traceability Expired on 1 July 2025
Circular 26/2025/TT-BNNMT Forest product management In force, amended by Circular 84/2025/TT-BNNMT from 1 January 2026

Export Wooden Pallet Sizes

There is no single mandatory size; the pallet size is chosen to fit the warehouse and forklift systems in the importing country. ISO 6780 recognises 6 sizes used in international transport: 1200 x 800 mm (Euro pallet, widely used in Europe), 1200 x 1000 mm (Europe, Asia), 1219 x 1016 mm (48 x 40 inch, North America), 1140 x 1140 mm (Australia), 1100 x 1100 mm (Asia) and 1067 x 1067 mm (North America, Europe, Asia).

ICD Vietnam’s wooden pallet range includes 800 x 1200 x 144 mm (static load 4,000 kg, dynamic load 1,500 kg), 800 x 600 x 144 mm (2,000 kg and 500 kg), 1200 x 1000 x 162 mm (4,250 kg and 1,250 kg) and 1200 x 1000 x 156 mm (6,000 kg and 1,500 kg), per the product pages as of October 2026. There are also sizes 1000 x 1200 x 144, 1000 x 1200 x 138, 800 x 1200 x 138, 1140 x 1140 x 138 and 1100 x 1300 x 138 mm; for these we quote load ratings order by order. All models are single-face pallets with 4-way forklift entry.

ICD Vietnam wooden pallet, 800 x 1200 x 144 mm
ICD Vietnam wooden pallet, 800 x 1200 x 144 mm, the same footprint as the Euro pallet widely used for cargo to Europe.

EU and US Requirements

Demanding markets check wooden pallets in 2 layers: the quarantine layer (the ISPM 15 mark, which applies to every wooden pallet) and the pallet technical standard layer such as EPAL, which applies only when the customer requires it.

Market Basis Main requirement for wooden pallets
European Union Implementing Regulation (EU) 2019/2072 Treatment and marking under ISPM 15; EPAL pallets per EPAL rules if the customer requires them
United States 7 CFR 319.40-3 (APHIS) Treatment and IPPC marking with code HT or MB in a visible position, ideally on 2 opposite sides; an unmarked pallet may be ordered re-exported at the port of arrival
Other IPPC member countries (Japan, Australia and others) ISPM 15 and the importing country’s own rules Valid IPPC mark; ask the buyer about additional requirements before choosing the treatment method

An EPAL Euro pallet under the European Pallet Association’s quality classification measures 800 x 1200 x 144 mm, with a rated load of 1,500 kg, ISPM 15 treated, chamber dried, with a maximum residual moisture of 22%. A pallet bearing the EPAL brand can only be made by a facility licensed by EPAL, so if the buyer states that a branded EPAL pallet is required, confirm this before ordering. For the US, a valid mark is itself the proof of treatment; the regulation does not require a treatment certificate to accompany it, although the commercial document set may still ask for one.

Documents and Process

The document set consists of the usual commercial documents plus 2 groups specific to the timber sector:

  • Commercial documents: commercial invoice, packing list, sales contract, bill of lading.
  • Forest product documents when the pallet is the product: timber origin papers, forest product list.
  • ISPM 15 treatment certificate if the contract, letter of credit (L/C) or shipping line requires it.

Under section 3.1 of ISPM 15, a valid IPPC mark makes a phytosanitary certificate for wood packaging unnecessary. Even so, we still advise confirming with the buyer before packing, because if the L/C asks for a treatment certificate and the document set lacks one, the bank may treat the documents as non-compliant.

STEP 1
ISPM 15 treatment
Choose HT or MB and apply the IPPC mark. MB needs at least 24 hours of fumigation plus airing time, so book early.
STEP 2
Forest product documents
Timber origin and the product list, when exporting the pallets themselves.
STEP 3
Commercial documents
Invoice, packing list, contract; treatment certificate if the buyer requires it.
STEP 4
Customs and container loading
Electronic declaration; check the IPPC mark on each pallet before sealing.

Treated wooden pallets still release moisture inside a sealed container. For long sea voyages, ICD supplies container desiccant beads and in-box desiccant packs from the same source as the pallets.

Frequently Asked Questions

Which legal documents apply to exporting wooden pallets?

The current ones are ISPM 15 on treating wood packaging, Circular 26/2025/TT-BNNMT on forest product management (effective 1 July 2025, amended by Circular 84/2025/TT-BNNMT from 1 January 2026) and Circular 01/2024/TT-BNNPTNT on the HS code table. Document 07/VBHN-BNNPTNT (2016) is for reference only because the circulars it consolidated expired on 1 January 2019.

What do legal forest product documents for export wooden pallets include?

A harvest permit, sales contract or valid import documents proving the origin of the wood; processed goods need a forest product list.

Which markets are strictest on export wooden pallets?

Europe, the US, Japan and Australia check the IPPC mark closely under ISPM 15; Europe also has EPAL pallets under their own rules when the customer requires them.

ICD Vietnam team advising on wooden pallets at the VIIF 2026 exhibition
The ICD Vietnam team talking with visitors beside a stack of 800 x 1200 mm wooden pallets at booth D05-D06, VIIF 2026 exhibition.

What is the HS code for wooden pallets?

Wooden pallets fall under HS subheading 4415.20, covering pallets, box pallets, other wooden load boards and pallet collars. Wooden cases, boxes and crates fall under subheading 4415.10.

Does a wooden pallet with an ISPM 15 mark need a fumigation certificate?

Under section 3.1 of ISPM 15, a valid IPPC mark makes a phytosanitary certificate for wood packaging unnecessary. Some contracts, letters of credit or shipping lines may still ask for a treatment certificate, so check with the buyer first.

Can an old wooden pallet with an IPPC mark be reused for export cargo?

Yes, if the pallet has not been repaired or had components replaced. A pallet repaired up to about a third of its components may only use treated wood for replacement boards; replacing more than that means removing the old mark, re-treating and applying a new mark.

What is the maximum moisture for an export wooden pallet?

ISPM 15 sets no moisture limit for heat treatment. An EPAL Euro pallet, per the European Pallet Association’s requirements, has a maximum wood moisture of 22%. For sulfuryl fluoride fumigation, ISPM 15 does not allow treating wood with moisture above 75%.

What does a wooden pallet exported to the US need?

Under 7 CFR 319.40-3, the wooden pallet must be treated and marked with the IPPC mark, made up of the symbol, country code, facility code and code HT or MB, in a visible position, ideally on at least 2 opposite sides. A pallet without the mark may be ordered re-exported right at the port of arrival.

Contact ICD Vietnam

ICD Vietnam supplies wooden pallets in standard sizes or to drawing; pallets for export cargo are treated and marked with the IPPC stamp under ISPM 15. Prices are quoted by quantity and specification.

References


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