PPWR packaging minimisation and the empty-space rule
PPWR Article 10 requires packaging to be minimised in weight and volume to what is needed for function and safety, and — from 1 January 2030 — caps the empty-space ratio at 50% for grouped, transport and e-commerce packaging. The general duty to minimise, and to hold documentation showing you have done so, is a day-one obligation from 12 August 2026.
This is general information about Regulation (EU) 2025/40, not legal advice. Confirm anything you act on with qualified counsel or an accredited body.
The minimisation duty
Regulation (EU) 2025/40, Art. 10, requires that packaging be designed so its weight and volume are reduced to the minimum needed to ensure functionality — protecting the product, meeting safety and hygiene requirements, and being acceptable to the consumer. Oversized packaging with no functional justification is not permitted. You must hold technical documentation demonstrating the packaging meets the minimisation requirements, as part of the evidence behind your Declaration of Conformity.
The empty-space ratio
For grouped (secondary), transport (tertiary) and e-commerce packaging, Art. 10 sets a maximum empty-space ratio of 50% from 1 January 2030. In plain terms, empty space — voids, excessive fillers, oversized boxes around small products — must not exceed half the packaging volume for those formats. This targets the classic "big box, small product" problem in e-commerce and grouped shipping.
| Packaging level | Empty-space cap | From |
|---|---|---|
| Grouped (secondary) | ≤ 50% | 1 Jan 2030 |
| Transport (tertiary) | ≤ 50% | 1 Jan 2030 |
| E-commerce | ≤ 50% | 1 Jan 2030 |
| Primary (sales) | Minimisation duty applies; the 50% empty-space cap is specified for the grouped/transport/e-commerce levels | 12 Aug 2026 (minimisation duty) |
Empty space is assessed against the methodology set out in the regulation and its annexes. How the ratio is measured for specific formats is an area the standards and any implementing measures firm up — confirm the measurement method for your format before relying on a calculation.
What this means in practice
- Right-size your outer and shipping boxes to the product; reduce void fill.
- Justify every layer. If a grouped or transport pack has more than 50% empty space, it needs redesign before 2030.
- Document the design rationale — the minimisation technical documentation is part of what an authority can ask to see.
Minimisation also intersects with the single-use restrictions in Annex V (for example, restrictions on certain grouped plastic packaging) — reducing unnecessary layers helps on both fronts.
What is still being specified
The regulation fixes the minimisation duty and the 50% empty-space cap, but the detailed assessment methodology and any harmonised standards for measuring minimisation and empty space are still being developed as of 9 July 2026. Treat the cap as firm and the exact measurement procedure as something to confirm against the Commission's guidance and standards as they are published.
Get this mapped to your own packaging
The report screens your packaging profile against Regulation (EU) 2025/40 and returns only the obligations that apply to you — each with its threshold, deadline and article, plus supplier letters ready to send.
Get my PPWR obligations report →Frequently asked questions
What is the PPWR empty-space rule?
Article 10 of Regulation (EU) 2025/40 caps the empty-space ratio at 50% for grouped, transport and e-commerce packaging from 1 January 2030 — empty space must not exceed half the packaging volume for those formats.
Does the empty-space cap apply to primary sales packaging?
The 50% empty-space cap is specified for grouped, transport and e-commerce packaging. Primary (sales) packaging is still subject to the general minimisation duty under Article 10, which requires weight and volume to be reduced to the functional minimum.
When does the minimisation duty start?
The general duty to minimise packaging and to hold technical documentation showing it starts when the regulation applies, on 12 August 2026. The specific 50% empty-space cap for grouped, transport and e-commerce packaging applies from 1 January 2030.
What documentation do I need for minimisation?
Technical documentation demonstrating the packaging meets the minimisation requirements, held as part of the evidence behind your Declaration of Conformity and producible to authorities on request.
Sources
- Regulation (EU) 2025/40 (PPWR) — Art. 10 packaging minimisation and the 50% empty-space ratio for grouped/transport/e-commerce packaging (from 2030) — https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng
- European Commission — minimisation assessment methodology and harmonised standards (in development as of 9 July 2026) — https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en