FSMA Sanitary Transportation rule: what it means for pallets
The FDA Sanitary Transportation rule (21 CFR Part 1, Subpart O, published 2016) lists pallets as transportation equipment. Food pallets must be suitable, cleanable, sanitary and stored to prevent contamination. It does not ban wood or require plastic, a set material or "FDA-approved" pallets.
Food buyers often hear that "FSMA requires plastic pallets". It does not. The FDA's Sanitary Transportation of Human and Animal Food rule, one of the rules implementing the Food Safety Modernization Act (FSMA), treats pallets as transportation equipment and sets sanitary outcomes for them. It does not specify a pallet material, design or certification. The rule is codified at 21 CFR Part 1, Subpart O (sections 1.900 to 1.934). The final rule was published on 6 April 2016, and compliance dates for all business sizes have passed.
What does the rule say about pallets?
The rule's definitions section (21 CFR 1.904) defines transportation equipment as equipment used in food transportation operations, and names pallets explicitly alongside containers, bins, totes, hoses and loading systems. So every requirement for "vehicles and transportation equipment" applies to pallets.
21 CFR 1.906 sets those requirements. In summary:
| Requirement | What it means for pallets |
|---|---|
| Design, material and workmanship suitable and adequately cleanable for the intended use | The pallet must not make the food unsafe, and must be cleanable to the degree the food requires |
| Maintained in sanitary condition for the intended use | Pallets are clean, free of contamination and in repair when used |
| Temperature control where needed | Relevant to the vehicle more than the pallet; pallets must not block required airflow in reefers |
| Stored to prevent pest harborage and contamination when not in use | Idle pallets kept off the ground, dry, away from pests |
What the rule does not say
| Common belief | What the rule actually does |
|---|---|
| Wood pallets are banned for food | No ban. Material is not specified |
| Pallets must be plastic | No material requirement |
| Pallets must be "FDA approved" | FDA does not approve pallets under this rule |
| Pallets must be heat treated | Not required by this rule; ISPM 15 is a separate export rule |
| Pallets must be new | No. Used pallets are fine if suitable and sanitary |
| A set cleaning frequency | None. The standard is outcome-based |
This is the point of an outcome-based rule. The duty is on the business to judge what "suitable" and "sanitary" mean for its food.
Who is covered?
The rule applies to shippers, loaders, carriers (motor and rail) and receivers of human and animal food in the United States, including foreign shippers arranging transport onto US motor or rail vehicles.
FDA lists these exemptions, among others:
- businesses with less than $500,000 in average annual revenue,
- transportation activities performed by a farm,
- food completely enclosed by a container, unless it requires temperature control for safety,
- live food animals (except molluscan shellfish),
- food transshipped through the US to another country, or imported for future export,
- compressed food gases and food-contact substances,
- human food byproducts for animal food without further processing.
The fully enclosed exemption matters for pallets: much palletized food moves in sealed cases and is exempt from the rule itself. Exposed product (produce in open field bins, bulk ingredients, meat in trays) and temperature-controlled food are where pallet sanitation is directly in scope.
Written specifications and procedures
Under 21 CFR 1.908, shippers must give carriers written sanitary specifications for vehicles and transportation equipment, and develop written procedures to make sure they are in appropriate sanitary condition. Loaders must check that equipment is in appropriate sanitary condition before loading food that is not fully enclosed. Carriers that supply equipment must have written procedures for cleaning, sanitizing and inspection. Records such as procedures, agreements and training records must be kept for set periods (up to 12 months, per FDA's summary).
If you supply pallets to a shipper, expect to see pallet cleanliness and condition in their written specs.
How it relates to other requirements
| Requirement | Relationship |
|---|---|
| FSMA Preventive Controls and Produce Safety rules | Separate FSMA rules that can pull pallet sanitation into a facility's food safety plan |
| FDA food-contact regulations (21 CFR, food-contact substances) | Govern resins for plastic pallets used in direct food contact; basis of "FDA-compliant" plastic claims |
| GFSI audit schemes and customer programs | Often more specific than FSMA on pallet condition, material and storage |
| ISPM 15 | Export phytosanitary rule, unrelated to food safety |
| UL 2335 | Fire listing for plastic pallets |
How to write pallet requirements for food
- "Pallets clean, dry, free of mold, odor, pests, chemical contamination, protruding nails and loose boards at time of loading."
- "Wood pallets: kiln dried to [value]% moisture maximum" (dry wood resists mold; see pallet mold).
- "Plastic pallets for direct food contact: virgin resin with a food-contact letter of compliance."
- "Idle pallets stored indoors or covered, off the ground."
- "Pallet condition inspected at loading and recorded."
See food-grade pallets for material choices and hygienic plastic pallets for washdown environments.
Frequently asked questions
Does FSMA require plastic pallets?
No. The Sanitary Transportation rule sets outcome-based requirements for transportation equipment, including pallets. Wood pallets can comply if they are suitable for the food, clean and kept in sanitary condition.
Is there such a thing as an FDA-approved pallet?
Not under this rule. FDA does not approve pallets. Plastic pallet makers who say "FDA approved" usually mean the resin complies with FDA food-contact regulations; ask for a letter of compliance that names the regulation.
Who is responsible for pallet condition under the rule?
The rule assigns duties to shippers, loaders, carriers and receivers. The shipper must give carriers written sanitary specifications for vehicles and transportation equipment, and whoever supplies the pallets is responsible for their condition in practice. Write it into your contracts.
Does the rule apply to food in sealed cases?
Food completely enclosed by a container is exempt unless it needs temperature control for safety. Most shelf-stable cased goods on pallets fall under that exemption, but customers' own programs may still set pallet requirements.
Sources and references
Related
- GlossaryFSMA (Food Safety Modernization Act)FSMA is the US Food Safety Modernization Act of 2011. Under its Sanitary Transportation of Human and Animal Food rule (21 CFR Part 1, Subpart O), pallets are transportation equipment and must be designed and maintained so they are suitable and adequately cleanable, and do not make food unsafe.
- GuidesFood-grade pallets: what the term means and how to specify oneThere is no FDA certification for a food-grade pallet. The term means a clean, dry, uncontaminated pallet: new or top-grade wood, kiln-dried and heat-treated (never methyl bromide), or virgin food-contact plastic. FSMA requires transport equipment that will not make food unsafe.
- TypesHygienic plastic pallet: closed decks for food and pharmaA hygienic plastic pallet has a closed, smooth top deck and a closed bottom, with no hollow cavities where dirt, water or bacteria can collect. It is made from virgin HDPE or PP, designed to be washed, and used in food processing, meat, dairy, bakery and pharmaceutical plants.
- GuidesPallet mold: causes, prevention and what to do with moldy palletsPallet mold grows when wood stays above about 20% moisture in warm, still air: green pallets in containers, wrapped loads or covered yards. The fix is dry wood: specify kiln-dried pallets (19% or less), store them dry and ventilated, and check moisture before loading. HT alone does not prevent mold.
- IndustriesPallets for food and beverage manufacturingFood companies run two pallet systems: hygienic plastic or aluminum inside wet and open-product areas, and 48 × 40 in wood or pooled pallets for cased goods. The FDA Sanitary Transportation rule requires suitable, cleanable, sanitary pallets but does not mandate a material.
- ComparisonsPlastic vs wood pallets: cost, strength and when to use eachChoose wood when you need the lowest price, a custom size, easy repair or one-way shipping. Choose plastic when pallets run in a closed loop for many trips, when hygiene and washability matter, when you need consistent dimensions for automation, or to avoid ISPM 15 treatment on exports.
- GuidesPallet inspection: an incoming inspection checklist for new and used palletsInspect incoming pallets against a written spec. Check a sample from every delivery for size, board count and thickness, broken boards or stringers, protruding nails, moisture, mold, stains and the ISPM 15 stamp. Reject failures, record why, and share the results with the supplier.
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Last reviewed 2026-09-24. 839 words.