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, from 1 January 2030; a separate rule, Article 24, caps the empty-space ratio at 50% for grouped, transport and e-commerce packaging from the same date (or three years after the Article 24(2) calculation-methodology implementing act, whichever is later). Until the end of 2029 the existing EU packaging (PPWD) minimisation requirements carry over under Article 70(1)(b), so the new PPWR minimisation standard applies from 2030 rather than on the 12 August 2026 application date, but you should hold documentation, from the outset, showing your packaging meets the minimisation requirements in force.
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. 24 sets a maximum empty-space ratio of 50%, from 1 January 2030, or three years after the Commission's empty-space calculation-methodology implementing act (due by 12 February 2028) enters into force, whichever is later. 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 10 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
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Get my PPWR obligations report →Frequently asked questions
What is the PPWR empty-space rule?
Article 24 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 new PPWR packaging-minimisation duty (Article 10) applies from 1 January 2030. Until the end of 2029 the existing EU packaging (PPWD) minimisation requirements carry over under Article 70(1)(b), so you should hold documentation throughout showing your packaging meets the minimisation requirements in force. The 50% empty-space cap for grouped, transport and e-commerce packaging (Article 24) also applies from 1 January 2030, or three years after its calculation-methodology implementing act, whichever is later.
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 (from 1 January 2030), Art. 24 the 50% empty-space ratio for grouped/transport/e-commerce packaging (from 2030, or 3 years after the Art. 24(2) implementing act, whichever is later), and Art. 70(1)(b) carry-over of the old PPWD minimisation requirements to 31 December 2029, https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng
- European Commission, minimisation assessment methodology and harmonised standards (in development as of 10 July 2026), https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en