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Packaging rule · European Union · Design rule

PPWR: maximum 50% empty space in grouped, transport and e-commerce packaging

Design rule rule covering all packaging in the European Union, set by European Parliament and Council of the EU. Adopted; applies from 1 January 2030.

By the SPI teamRule ID PR-EU-009Source consulted 13 October 2026Verified 13 October 2026
Sourced facts

The rule

Recorded from the official source named below. Rates and dates are as the source states them on the date it was consulted.

Jurisdiction
European Union
Authority
European Parliament and Council of the EU
Rule type
Design rule
Materials
All packaging
Status
Adopted, not yet applying Enacted
Rate or target
50%Maximum empty space ratio.
Adopted or published
19 December 2024
Applies from
1 January 2030
From the source

“maximum empty space ratio, expressed as a percentage, does not exceed 50%”

Official source European Parliament Legislative Observatory: Regulation (EU) 2025/40 summaryOfficial (government or regulator) · consulted 13 October 2026

Deadlines

Key dates

  1. Adopted or published 1 year and 9 months ago

  2. Source consulted by the SPI team 2 days ago

  3. Re-checked by a second SPI team member 2 days ago

  4. Today

  5. Applies from in 3 years and 2 months

SPI analysis

What it means

SPI analysis Our reading of the official source above. Not legal advice; always rely on the official text.

SPI summary

From 2030, economic operators filling grouped, transport or e-commerce packaging must keep the empty space ratio at or below 50%.

In practice

By 1 January 2030, economic operators that fill grouped, transport or e-commerce packaging must keep the empty space ratio at or below 50%. This hits e-commerce fulfilment, contract packers and brand owners shipping in outer cases more than converters directly, though box ranges and void-fill products are likely to change. How the ratio is measured depends on a Commission implementing act due by 12 February 2028.

Where the record is unclear

  • The methodology for calculating the empty space ratio is an implementing act due by 12 February 2028 (Article 24(2)); until then, how void-fill and product shape are counted is not fixed.
  • The Commission timeline lists a review of the empty space ratio by 12 February 2032 (Article 24(6)).
  • The conditions for the e-commerce sales packaging exemption are described here from recital 84 only; SPI has not yet checked Article 24 for this note.

Where it sits in the tracker

  • One of 18 packaging rules we track in the European Union, of which 4 are design rule rules.
  • In all, 6 design rule rules are tracked across 2 jurisdictions. Compare them below

Company profiles that map to this rule

Companies whose SPI profile lists this rule in its regulatory exposure, based on where they report selling. Not company-reported.

SPI analysis

Overview

Article 24(1) of Regulation (EU) 2025/40 caps the empty space in packaging used to ship goods. Economic operators that fill grouped, transport or e-commerce packaging must ensure that the "maximum empty space ratio, expressed as a percentage, does not exceed 50%"4. The start date is conditional: the cap applies from 1 January 2030 or three years after the implementing acts under Article 24(2) enter into force, whichever is later1. Those acts set the calculation method and are due before 12 February 20283.

Article 24 is the numeric end of a wider minimisation duty. Article 10(1) requires packaging to be designed by 1 January 2030 so that weight and volume are cut to the minimum needed for its function, and Article 10(2) bars features meant only to increase perceived volume, such as double walls and false bottoms1. The Regulation also drops marketing and consumer acceptance as reasons for extra weight or volume5. Sales packaging gets no fixed ratio: it is judged against EN 13428:2004 until 1 January 2030 and then against an updated standard1.

The Commission's public explanation is practical: online shops will have to cut empty space in delivery boxes, which means smaller boxes and fewer half-empty parcels while products stay protected6.

Duties

Who must do what

Operators that fill grouped, transport or e-commerce packaging

  • Keep the empty space ratio of each filled grouped, transport or e-commerce pack at or below 50% from the later of 1 January 2030 or three years after the Article 24(2) acts enter into force (Article 24(1)).
  • Apply the calculation method set by the Article 24(2) implementing act once it is adopted3.
  • SPI reading: the duty follows the act of filling, so retailers packing their own web orders, marketplaces running fulfilment and third-party logistics firms are each in scope when they pack the parcel.

Manufacturers of packaging, including sales packaging

  • Design packaging so weight and volume are at the minimum needed for function, taking shape and material into account, by 1 January 2030 (Article 10(1)).
  • Drop double walls, false bottoms and unnecessary layers aimed only at perceived volume; protected designs and trademarks registered before 11 February 2025, and products under protected geographical indications, are exempt (Article 10(2)).
  • For sales packaging, carry out the conformity assessment, draw up technical documentation and issue the EU declaration of conformity (guidance section 11).

Importers and distributors selling under their own name

  • Take on the manufacturer's obligations when packaging is placed on the market under their own name or trademark, or modified in a way that affects compliance (recital 82).
  • Keep transaction records for the set period so authorities can trace non-compliant packaging (recital 83).

European Commission

  • Adopt the empty space ratio methodology before 12 February 2028 (Article 24(2)) and review the ratio by 12 February 2032 (Article 24(6)).
  • Request harmonised minimisation standards, including maximum empty space where relevant, by 12 February 2027 (Article 10(3)).
Scope

Are you in scope?

Work through each question. The answers are the SPI team's reading of the sources cited.

  1. Do you fill grouped, transport or e-commerce packaging with products?

    If yes
    The 50% cap in Article 24(1) applies to the packs you fill.
    If no
    Article 24(1) does not apply to you, though Article 10 minimisation still applies to the manufacturer of the packaging.

  2. Is the pack reusable packaging?

    If yes
    Recital 84 excludes reusable packaging from the 50% cap.
    If no
    The cap applies.

  3. Do you ship a product in its own sales packaging, without an outer box?

    If yes
    Recital 84 says operators using sales packaging as e-commerce packaging may be exempted from the empty space obligation.
    If no
    An outer e-commerce pack counts toward the ratio.

  4. Is it sales packaging only, never used as the shipping unit?

    If yes
    No fixed percentage applies; compliance is judged under EN 13428:2004 until 2030 and the updated standard afterwards.
    If no
    Check the shipping unit against the 50% cap.

  5. Does the design rely on double walls, false bottoms or extra layers to look bigger?

    If yes
    Article 10(2) bars it from 2030 unless a design or trademark protected before 11 February 2025, or a geographical indication, covers it.
    If no
    Article 10(2) raises no issue on this point.
Checklist

Compliance checklist

  1. Baseline empty space in outbound parcels

    By Now

    SPI analysis of the official text. Not legal advice; confirm with the text or counsel. Sample real orders across box sizes and product mixes and record a provisional ratio, knowing the final formula comes only with the Article 24(2) act.

    Evidence to keep Sample log with order mix, box size, product volume and provisional ratio.

  2. Separate reusable and sales-packaging shipments

    By Now

    Tag flows shipped in reusable totes and products sent in their own sales packaging, since recital 84 treats both differently from single-use outer boxes.

    Evidence to keep Flow map by packaging type and share of volume shipped.

  3. Follow the minimisation standard request

    By 2027-02-12

    The Commission is to request harmonised minimisation standards under Article 10(3) by this date; standards will set weight and volume limits and, where relevant, maximum empty space.

    Evidence to keep Note of the standard request and the CEN work item it creates.

  4. Re-measure under the official method

    By 2028-02-12

    Once the empty space methodology act is adopted, redo the baseline with its formula and check how void fill and irregular product shapes are counted.

    Evidence to keep Second sample log using the published method, with the act's reference.

  5. Fix the application date

    By On entry into force of the Article 24(2) act

    Work out the later of 1 January 2030 and three years after that act enters into force; that is the real start of the 50% cap.

    Evidence to keep Dated planning note with both dates and the one that governs.

  6. Redesign the box range and packing lines

    By 2030-01-01

    Plan box sizes, right-size packing equipment and void-fill choices so that every pack can meet 50%, and remove any perceived-volume features from sales packaging for Article 10.

    Evidence to keep Box range specification and line change plan with dates.

Enforcement

Enforcement and penalties

Who enforces
National market surveillance authorities, applying the PPWR together with Regulation (EU) 2019/1020 (guidance section 5).
Powers
For sales packaging, authorities check the manufacturer's technical documentation and EU declaration of conformity; for filled shipping packs they check the operator that filled them. Transaction records kept under recital 83 let them trace packaging back through the chain.
Enforcement so far
The 50% cap has no application date before 2030, so no enforcement decision exists yet.

Regulation (EU) 2025/40 does not set fine amounts for exceeding the empty space ratio; Member States set penalties in national law, and as of 14 October 2026 SPI has not yet confirmed the wording of the Regulation's own article on penalties against the official text. Until 1 January 2030 the existing minimisation requirement stays in force through Article 70(1)(b), with EN 13428:2004 as the standard1.

Connections

How it fits with other rules

  • Regulation (EU) 2025/40, Article 10 (packaging minimisation)
    Article 10 binds the manufacturer to minimise every pack, while Article 24 binds whoever fills shipping packs to a hard 50% limit. A parcel can therefore fail Article 24 even when the box itself was designed to Article 10, if the wrong size is chosen at packing.
  • PPWR: 2030 reuse targets for transport and grouped packaging PR-EU-006
    Recital 84 removes reusable packaging from the empty space cap. Operators moving transport and e-commerce flows into reusable formats under the 2030 reuse targets therefore also step outside Article 24.
  • PPWR: packaging waste reduction targets per capita PR-EU-011
    Smaller boxes and less void fill reduce packaging weight per person, which counts toward the national prevention targets of 5% by 2030 against 2018. Member States may lean on this rule when planning to meet them.
  • Administrative Measures for Postal and Express Packaging PR-CN-002
    China's postal and express packaging measures target the same over-packaging problem in parcels. The EU ratio will be calculated with its own implementing act, so a parcel tested under Chinese rules needs a separate EU test.
Timeline

History of the rule

  1. Commission proposal COM(2022) 677 published.

  2. European Parliament votes its first-reading position and sends the file back for negotiations.

  3. Parliament approves the negotiated text.

  4. Regulation (EU) 2025/40 published; in force from 11 February 2025, which is also the cut-off for protected designs under Article 10(2).

  5. Commission Notice C/2026/3084 explains how Article 10 and Article 24 fit together.

  6. Today

  7. Standardisation request on packaging minimisation due (Article 10(3)).

  8. Empty space ratio methodology act due (Article 24(2)).

  9. Earliest date for the 50% cap; Article 10(1) and (2) apply.

  10. Commission review of the empty space ratio (Article 24(6)).

Questions

Questions

When exactly does the 50% empty space limit start?

Article 24(1) applies from 1 January 2030 or three years after the methodology act under Article 24(2) enters into force, whichever is later. That act is due before 12 February 2028, so a late act would push the start into 2031.

Does the 50% rule apply to a product's own retail box?

No fixed percentage applies to sales packaging. It must be minimised under Article 10 and is judged against EN 13428:2004 until 1 January 2030 and then against an updated harmonised standard.

Are reusable shipping totes covered by the empty space cap?

Recital 84 of Regulation (EU) 2025/40 excludes reusable packaging from the 50% ratio. Single-use outer cases and mailers remain covered from 2030.

Can a brand keep a bigger box for marketing reasons?

The Regulation removed marketing and consumer acceptance as reasons for extra weight or volume. Article 10(2) bars false bottoms and double walls from 2030 unless a design or trademark protected before 11 February 2025, or a geographical indication, covers the pack.

How is void fill counted in the ratio?

The counting method will be set by an implementing act due before 12 February 2028. Until it is adopted, how paper, air pillows and product shape enter the ratio is not fixed, so early measurements are provisional.

Glossary

Definitions

Placing on the market
Defined in EU Packaging and Packaging Waste Regulation (PPWR) applies PR-EU-001
Sources

Sources for this analysis

  1. EUR-Lex: Commission Notice C/2026/3084, Guidance document for Regulation (EU) 2025/40, sections 5, 10 and 11 Official · Consulted 14 October 2026
  2. EUR-Lex: Regulation (EU) 2025/40, OJ L 22.1.2025, recitals 82 to 84 and 119 to 121 Official · Consulted 14 October 2026
  3. European Commission Green Forum: PPWR implementation timeline Official · Consulted 14 October 2026
  4. European Parliament Legislative Observatory: Regulation (EU) 2025/40 summary Official · Consulted 14 October 2026
  5. EUR-Lex: Summaries of EU legislation, Packaging and packaging waste (from 2026), last updated 26.9.2025 Official · Consulted 14 October 2026
  6. European Commission (DG ENV): Facts about the new EU rules on packaging and packaging waste Official · Consulted 14 October 2026
  7. European Parliament Legislative Observatory: procedure file 2022/0396(COD) Official · Consulted 14 October 2026

Written by the SPI team on 14 October 2026. Sources checked as of 14 October 2026. SPI analysis, not legal advice; always rely on the official text.

Audit trail

Change history

Verified: a second SPI team member re-checked every fact above against the source on 13 October 2026. Any later change to the facts sends the rule back to Sourced and is logged here.

  1. Verified by a second SPI team member

  2. Added to the tracker

Spotted an error? Write to sales@strategicpackaginginsights.com quoting PR-EU-009 and the source. Corrections are logged in this history.

Other jurisdictions

Design rule rules elsewhere

The same type of rule for the same materials in other jurisdictions, by the date it applies.

RuleWhereTypeMaterialsStatusApplies from
Administrative Measures for Postal and Express PackagingPR-CN-002ChinaDesign ruleAll packagingIn force12 March 2021
GB 23350-2021 restriction of excessive packaging (food and cosmetics)PR-CN-003ChinaDesign ruleAll packagingIn force1 September 2023

Every design rule rule in the tracker

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