# A shipper case that is 68% empty fails the PPWR’s 50% cap at every counting basis, while a standard box that passes at case level can sit at 47% once the whole pallet is measured

> From 1 January 2030, Article 10 of Regulation (EU) 2025/40 requires every pack, including shipper cases, trays, shrink packs and pallet wrap, to be cut to the minimum weight and volume its function needs under the Annex IV performance criteria, and Article 24 caps the empty space in grouped and transport packaging at 50%, from 2030 or three years after a counting method due by 12 February 2028, whichever is later, while the standards that will turn both duties into numbers are still to be requested from CEN by 12 February 2027.

Publisher: Strategic Packaging Insights  
Published: 2026-11-01  
Last updated: 2026-11-01  
Page: https://www.strategicpackaginginsights.com/insights/ppwr-minimisation-weight-volume-empty-space-grouped-transport/

**From 1 January 2030, Article 10 of Regulation (EU) 2025/40 requires every pack, including shipper cases, trays, shrink packs and pallet wrap, to be cut to the minimum weight and volume its function needs under the Annex IV performance criteria, and Article 24 caps the empty space in grouped and transport packaging at 50%, from 2030 or three years after a counting method due by 12 February 2028, whichever is later, while the standards that will turn both duties into numbers are still to be requested from CEN by 12 February 2027.**

Strategic Packaging Insights (SPI) read Articles 10 and 24, the Commission's June 2026 guidance and its August 2026 FAQ, and set them against SPI's tracker entries [PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/) and [PR-EU-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-009/). The result is a pack level screen and three worked examples that show why the measuring rule, not the box alone, will decide whether a grouped or transport pack passes.

## Executive summary

Most discussion of the PPWR's empty space rule has been about e-commerce parcels. SPI's [e-commerce piece](https://www.strategicpackaginginsights.com/insights/ecommerce-packaging-amazon-alibaba-ppwr/) covers that case. Yet Article 24(1) names three formats, not one: grouped packaging, transport packaging and e-commerce packaging. Every operator that fills a shipper case, a shrink-wrapped tray or a pallet load is in scope from 2030 (Commission Notice C/2026/3084, section 11; DG ENV FAQ, August 2026).

Two duties apply to the same pack. Article 10 binds the manufacturer or importer of the packaging to design it to the minimum weight and volume needed for its function, judged against the performance criteria in Annex IV, by 1 January 2030. Article 24 binds whoever fills grouped or transport packaging to a 50% maximum empty space ratio. A case can be well designed under Article 10 and still fail Article 24 if it is filled with the wrong product mix.

Neither duty has a final measuring rule yet. The Commission must ask the European standardisation organisations by 12 February 2027 to update EN 13428:2004 with calculation methods and, for the most common formats, maximum weight and volume limits and, where appropriate, wall thickness and maximum empty space. The empty space method itself comes in an implementing act due by 12 February 2028 (Notice, sections 10 and 11). SPI has not yet confirmed that the standardisation request has been issued.

On SPI's calculation the measuring rule matters as much as the box. A standard range case that is 38.6% empty on its internal volume is 45.9% empty on its external volume and 47.4% at pallet level when the pallet base and unused footprint count (Exhibit 8). Right-sizing the same 100,000 cases a year cuts board by 51.1% and pallets by 52.4% against an oversized case, but saves only EUR 3,795.07 in Austrian commercial EPR fees (Exhibit 9). The case for acting rests on the regulation and on transport, not on fees.

Leaders should baseline grouped and transport packs on all three counting bases now, build Annex IV evidence files during 2027 and fix box ranges before the 2028 method act.

## Key findings

1. From 1 January 2030, the manufacturer or importer must ensure packaging is designed so that its weight and volume are reduced to the minimum necessary for its functionality, taking account of shape and material (Article 10(1), quoted in Commission Notice C/2026/3084, section 10).
2. Operators that fill grouped, transport or e-commerce packaging must keep the maximum empty space ratio at 50% from 1 January 2030 or three years after the Article 24(2) implementing act enters into force, whichever is later (Notice, section 11).
3. The German text of Article 24(3), as reproduced by LX Gesetze, counts paper, air cushions, foam, wood wool and polystyrene chips as empty space, and defines empty space as the total volume of the grouped, transport or e-commerce pack less the volume of the sales packaging inside.
4. By 12 February 2027 the Commission must request harmonised standards that, for the most common packaging types and formats, specify maximum adequate weight and volume limits and, where appropriate, wall thickness and maximum empty space (Article 10(3)); until the end of 2029 EN 13428:2004 remains the compliance standard (Notice, section 10).
5. Recital 60 states that marketing and consumer acceptance should not on their own justify extra packaging weight and volume, and Article 24 has no design or trademark exemption, unlike Article 10 (Notice, section 10; DG ENV FAQ, section XI).
6. **SPI calculation:**  a 500 x 300 x 250 mm case holding 12 units is 38.6% empty on internal volume, 45.9% on external volume and 47.4% on the pallet bounding box including the pallet base (Exhibit 8).
7. **SPI calculation:**  at ARA's 2026 commercial rates, 100,000 oversized cases a year carry EUR 7,412.90 in paper and film fees, against EUR 3,617.83 for right-sized cases (Exhibit 9).

## Two duties, two addressees

The PPWR has applied since 12 August 2026, but its minimisation articles bite from 2030. Until then, the Commission says, the existing minimisation requirement of the old Packaging Directive and its standard EN 13428:2004 stay in effect through Article 70(1)(b) until the end of 2029 (Notice, section 10). Exhibit 2 sets the two articles side by side.

**Article 10.**  The Notice quotes paragraph 1 in full: by 1 January 2030 the manufacturer or importer must ensure that packaging placed on the market is designed so that its weight and volume are reduced to the minimum necessary to ensure its functionality, taking account of shape and material. Paragraph 2 adds two bans: packaging that does not meet the Annex IV performance criteria, and packaging with features that aim only to increase perceived volume, including double walls, false bottoms and unnecessary layers (Notice, sections 10 and 11).

**Article 24.**  Paragraph 1 is the numeric rule. The Notice reads it as applying to grouped, transport and e-commerce packaging, to be complied with by the natural or legal person using or filling it (Notice, section 11). The DG ENV FAQ confirms that the 50% threshold applies only to those three formats, and that sales packaging has no maximum: the filler must minimise empty space and show it in the technical documentation (DG ENV FAQ, section XI).

**The definitions that matter.**  The FAQ describes grouped packaging, Article 3(1) point (6), as packaging that bundles several sales units, and transport packaging, point (7), as the outer layer used to move packaged products (DG ENV FAQ, section II.4). Recital 10 maps the two terms onto the older vocabulary: grouped packaging is secondary packaging and transport packaging is tertiary packaging (Regulation (EU) 2025/40, recital 10). The FAQ also says stretch wrap used to stabilise packaged products on pallets should be considered packaging (section II.5). A wrapped pallet of shipper cases is therefore transport packaging around grouped packaging around sales packaging, and both Article 10 and Article 24 reach the outer two layers.

## Annex IV: the criteria that justify weight and volume

Article 10(2) makes the Annex IV performance criteria the test of whether a pack is heavier or larger than it needs to be. The Notice quotes point 4 of Part A, packaging functionality, which allows for the purpose of the product and particularities of its sale, such as gifts or seasonal events (Notice, section 10). The full list is not quoted in the Notice, and SPI has not yet confirmed it against the Official Journal; Exhibit 3 follows the eight headings as a compliance provider reproduced them in July 2026 (Complydex, 17 July 2026).

What is missing from the list matters as much. The Notice quotes recital 60: marketing and consumer acceptance remain relevant to design, but they should not be part of the performance criteria that justify extra weight and volume on their own (Notice, section 10). For transport packaging this changes little, since few pallet loads are designed to sell. For grouped packaging that doubles as a display unit, such as a shelf ready tray with a printed header, the functionality point becomes the only route for extra board, and the evidence must show it.

SPI analysis

For grouped and transport packs the logistics criterion is the likeliest justification for volume. A case sized to fit a 1,200 x 800 mm pallet pattern, rather than to fit its contents, can be defended only if the evidence shows that the pallet fit, not habit, set the size. That evidence is what Article 10(4) asks for.

## The evidence file

Article 10(4), in the German text as reproduced by LX Gesetze, requires compliance with paragraphs 1 and 2 to be shown in the technical documentation under Annex VII. The documentation must name the specifications and standards used to assess the pack against Annex IV, list for each criterion the design requirement that prevents further reduction of weight or volume, and attach evidence such as test results, studies, modelling or simulations. For reusable packaging, the assessment must take account of its reusable characteristics, mainly the requirements in Article 11 (Article 10, German text as reproduced). Exhibit 4 turns that into an evidence file for a shipper case.

The Notice is clear on who signs: for minimisation, the obligated party is the manufacturer, who carries out the conformity assessment and drafts the technical documentation and the EU declaration of conformity (Notice, section 11). For a corrugated case that is usually the converter or, where a brand places it on the market under its own name, the brand. For the filled pallet load the Article 24 duty sits with the filler, which may be a contract packer or a logistics provider rather than the brand.

ECOS, the Environmental Coalition on Standards, describes the current method as a weak spot. Its March 2026 paper notes that EN 13428 asks suppliers to identify a critical area for source reduction, the performance criterion considered to prevent further reduction without compromising function, safety or acceptability, and argues that this leaves the choice mostly with the supplier (ECOS, March 2026). It proposes a closed list of criteria, documented evidence, checks of alternative designs and a harmonised structure for the file to help market surveillance.

## From EN 13428 to numbers: the standards path

The standard is where weight and volume limits will come from. Article 10(3), as quoted in the Notice, asks the Commission to request harmonised standards on calculation and measurement of compliance by 12 February 2027, and adds that for the most common packaging types and formats such standards should specify maximum adequate weight and volume limits and, where appropriate, wall thickness and maximum empty space (Notice, section 10). Exhibit 5 sets out the path.

Two consequences follow. First, the Commission says compliance with a harmonised standard creates a presumption of compliance, and that Member States will have to accept compliant packaging without setting different or additional national requirements (Notice, section 10). Second, from 1 January 2030 EN 13428:2004 can still be used as guidance, but only until a new or updated standard is available (Notice, section 10). An operator that relies on the old method after 2030 relies on guidance, not on a presumption.

The DG ENV FAQ adds that the request will account for the changed Annex IV criteria and that the Commission will identify the most common packaging types and formats itself (DG ENV FAQ, section VII). Which grouped and transport formats make that list will decide whether a shipper case or a pallet wrap gets a numeric weight limit. ECOS's March 2026 factsheet calls the period from the February 2027 request to the January 2030 application date a tight three-year window, shorter than the usual standards cycle (ECOS factsheet, March 2026).

## A framework: the pack level stack

SPI's organising device for this piece is a stack of four pack levels. Each level meets a different mix of minimisation, empty space, reuse and format rules, and the duties land on different operators. Exhibit 6 sets it out.

**Level 2**  is where most of the volume decisions sit. A shipper case is chosen once from a box range and then filled many times with different product counts. **Level 3**  is where most of the weight decisions sit: film gauge, wraps per pallet, corner boards and straps. **Level 1**  carries the Article 10 duty only, with no fixed ratio, and Article 24(6) asks the Commission to consider by 12 February 2032 whether ratios should be set for sales packaging of products such as toys, cosmetics, DIY kits and electronics (Article 24, German text as reproduced).

SPI analysis

The levels compound. The empty space of a pallet load is the volume of the whole transport pack less the sales packaging inside, so empty space left in the shipper cases is carried up into the pallet ratio. A pallet can only be as full as the cases on it. SPI's [reuse piece](https://www.strategicpackaginginsights.com/insights/ppwr-reuse-targets-transport-grouped-packaging-pallets-crates/) covers the reuse lanes for levels 2 and 3, and the [format restrictions piece](https://www.strategicpackaginginsights.com/insights/ppwr-2030-format-restrictions/) the Annex V entries; this piece does not repeat them.

## Worked example: three shipper cases for one product

To make the rules concrete, SPI built one product flow. A brand ships a cosmetic in a sales carton of 120 x 80 x 200 mm, or 1.92 litres, in cases of 12 cartons, 23.04 litres of sales packaging per case, on 1,200 x 800 mm pallets with a load height of up to 1.50 m. It has three case options. Exhibit 7 sets out the cases.

**SPI calculation.**  Case A holds 23.04 litres of cartons in 72.00 litres, so its empty space is 48.96 litres, or 68.0%. Case C holds the same in 37.50 litres, 38.6% empty. Case B, sized to the 4 by 3 carton pattern with 10 mm of clearance, is 25.73 litres and 10.4% empty. Board area is 1.42, 0.90 and 0.69 square metres, which at 700 g per square metre gives 0.99, 0.63 and 0.49 kg.

Case A is the format the PPWR targets: a case chosen because it was in stock, not because it fits. Article 24(3), in the German text as reproduced, counts filler such as paper, air cushions and foam as empty space, so packing case A with paper to stop the cartons moving does not lower its ratio. Case C is the common middle: a standard size in a short box range that serves several products. Case B is what a bespoke size or a box range built around the product mix delivers.

## Scenarios: the counting basis decides the result

The Article 24(2) act will set the method. Until it does, SPI tested three plausible bases: the case's internal volume, its external volume and the pallet bounding box including the pallet base. Article 24(2), in the German text as reproduced, already lists features the method must handle: irregular shapes, multi-item packs, liquids, fragile contents, small items at risk from larger ones, and a minimum free area on transport packaging for shipping labels. Exhibit 8 shows the results.

**SPI calculation, high case for option C.**  Thirty-six cases hold 829.44 litres of cartons. The bounding box is 1.2 x 0.8 m by 1.50 m of load plus 0.144 m of pallet, or 1,578.24 litres. Empty space is 748.80 litres, or 47.4%. On the same basis, option B's 42 cases hold 967.68 litres in 1,549.44 litres, 37.5% empty, because six cases of 490 x 250 mm cover only 735,000 of the pallet's 960,000 square millimetres.

Three points follow. First, option A fails on every basis, so the rule is already clear for oversized cases. Second, option C moves from an 11.4 point margin under the cap to a 2.6 point margin as the basis widens, which is the zone where the method act will decide. Third, the right-sized case is not the best pallet case: its footprint leaves 23.4% of the pallet deck empty, so at pallet level a case size that tiles the pallet can matter more than a case that hugs the product.

SPI analysis

Box ranges should be designed on two tests at once, product fit and pallet fit. SPI has not yet confirmed whether the Article 24(2) act will measure pallet loads as a unit, case by case, or both, and the Commission's August 2026 FAQ gives no example for pallet loads.

## The weight side: what right-sizing saves

Article 10 is about weight as well as volume, and grouped and transport packs carry most of their weight in board and film. Exhibit 9 puts the three options on a year of 100,000 cases and prices the result at ARA's 2026 commercial rates in Austria. SPI's [commercial and industrial fees piece](https://www.strategicpackaginginsights.com/insights/commercial-industrial-packaging-epr-fees-austria-portugal-spain/) explains how Austria splits household and commercial packaging; this example assumes all cases and film are commercial.

**SPI calculation.**  Board for option A is 0.9947 kg x 100,000 = 99.47 tonnes; at EUR 0.070 per kg that is EUR 6,962.90. Pallets are 100,000 / 20 = 5,000, film 5,000 x 0.50 kg = 2.50 tonnes, and at EUR 0.180 per kg EUR 450.00. Option B gives 48.62 tonnes of board, EUR 3,403.54, and 2,380.95 pallet loads with 1.19 tonnes of film, EUR 214.29. The total saving from A to B is EUR 3,795.07, or 51.2% of the fee bill; board falls 51.1% and pallet loads 52.4%.

The fee line is the smallest part of the gain. On the same assumptions, option B needs 79 fewer trailer loads a year than option A, and the 50.85 tonnes of board saved is board not bought. The fee numbers are low because ARA's commercial rates are low: Exhibit 10 shows the gap with household rates.

SPI analysis

For transport packaging the fee signal for minimisation is weak in Austria: a tonne of film saved is EUR 180 and a tonne of board EUR 70. Grouped packaging that reaches households is different. A shrink pack or tray declared as household plastic pays EUR 1,040 a tonne, so the weight side of Article 10 and the fee bill point the same way there. SPI's [paper and board piece](https://www.strategicpackaginginsights.com/insights/paper-board-epr-fees-euro-schemes/) sets out board rates in other euro schemes.

## Grouped packs in practice

Grouped packaging covers more than cases. Shrink-wrapped trays, multipack sleeves, clips and glued packs all bundle sales units, and each must meet Article 10 and, as grouped packaging, the 50% cap. For film-only packs the cap is rarely the binding test, since film follows the products. The binding test is weight under Article 10.

In practice: Carlsberg Group.

Carlsberg's Snap Pack holds cans together with glue in place of shrink wrap or plastic rings. The company says it uses up to 76% less plastic than its previous multipacks and that 1,200 tonnes a year will be saved when all its 4, 6 and 8 packs are converted (Carlsberg Group, Snap Pack page). Its FAQ says its tests show the glue does not affect can recycling, and that full removal of plastic is not yet possible because a handle is still used (Carlsberg Group, Snap Pack FAQ). The pages give no launch date or market count, and they do not discuss the PPWR, so SPI does not link the design to the regulation. The example shows what Article 10's weight test rewards in grouped packs: removing a layer, not thinning it.

In practice: ARA.

Austria's ARA prices commercial packaging on separate lines, including foils at EUR 0.180 per kg, paper at EUR 0.070 and wood at EUR 0.020 in its 2026 list, and household plastic at EUR 1.040 (ARA List of Tariff Rates 2026). Its list has no separate commercial line for corrugated board or rigid plastic; the closest are paper and moulded containers. For a producer working through Article 10, those lines are where a lighter shipper case or a thinner stretch wrap shows up in the Austrian bill, and Exhibit 9 shows the scale.

**Perceived volume and grouped packs.**  Article 10(2) bans double walls, false bottoms and unnecessary layers aimed only at perceived volume, with exemptions for designs and trademarks protected before 11 February 2025 and for products under geographical indications or EU quality schemes (Notice, section 10). The DG ENV FAQ adds that Article 24 has no equivalent exemption (section XI). A gift box protected as a design can therefore keep its shape under Article 10, but if it is shipped in an outer grouped case, that case must still meet 50%.

## What the method act must settle for pallets

The Article 24(2) act is due by 12 February 2028 and follows the examination procedure (Article 24, German text as reproduced). For grouped and transport packaging, the open questions are practical. Exhibit 11 lists them.

**Start date.**  The cap applies from 1 January 2030 or three years after the act enters into force, whichever is later (Notice, section 11). If the act enters into force on 12 February 2028, its deadline, the later date is 12 February 2031; SPI's [PPWR timeline piece](https://www.strategicpackaginginsights.com/insights/ppwr-after-august-2026/) sets out the late act scenarios and does not need repeating. Article 10 has no such link: it applies from 1 January 2030 whatever happens to the standard (DG ENV FAQ, section VII).

**Sales packaging filled as part of a grouped pack.**  The German text of Article 24(4), as reproduced, asks operators that fill sales packaging to keep empty space to the minimum needed for its functions, with rules for products that settle in transit and headspace for food, and dates that duty to 12 February 2028. SPI has not yet confirmed that date against the English Official Journal text.

**Penalties.**  SPI's tracker entry [PR-EU-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-009/) records that the Regulation sets no fine for exceeding the ratio; Member States set penalties in national law. An operator loading pallets in several Member States therefore faces several penalty regimes for one box range.

## Industry reaction

> "Standardisation will help industry prove compliance with the minimisation requirements, given that compliance with a harmonised standard creates a presumption of compliance with the sustainability requirement."

***European Commission** , Commission Notice C/2026/3084, section 10, [EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084), 10 June 2026*

The Notice adds that Member States will have to accept packaging that meets the standard without setting different or additional national requirements.

> "These considerations go beyond the functional performance criteria set out in Annex IV of the PPWR and allow non-essential factors to be treated as limiting constraints in packaging minimisation assessments."

***ECOS** , Environmental Coalition on Standards, [PPWR standardisation request recommendations on packaging minimisation](https://ecostandard.org/wp-content/uploads/2026/03/2026-02-26_ECOS-PPWR-SReq-recommendations-packaging-minimisation.pdf), March 2026*

The considerations ECOS refers to are marketing, product presentation and consumer acceptance, which it wants the standardisation request to remove from the assessment.

> "Die bestehende allgemeine Minimierungspflicht in Art. 10 Abs. 1 PPWR, ergänzt durch die leistungsbezogenen Kriterien in Anhang IV, ist ausreichend geeignet, um unnötige Verpackungen zu vermeiden."

***IKW** , German cosmetic, toiletry, perfumery and detergent association, [Positionspapier PPWR](https://www.ikw.org/fileadmin/IKW_Dateien/downloads/Positionspapiere/IKW_Positionspapier_PPWR_0426.pdf), April 2026*

In English, IKW says the existing general duty in Article 10(1), with the Annex IV performance criteria, is enough to avoid unnecessary packaging. The association, which says it represents more than 465 companies, opposes fixed maximum values for weight, volume, wall thickness or empty space and asks that Article 10(3) drop the reference to the most common packaging types and formats (IKW, April 2026).

The two positions frame the 2027 request. ECOS wants numeric limits and a closed list of justifications; IKW wants methods without binding design values. The Regulation's text already asks for limits for the most common formats, so the debate is over which formats and how tight.

## What leaders should do now

1. **Packaging engineers, by 30 June 2027:**  measure every grouped and transport pack in the range on the three bases in Exhibit 8, internal, external and pallet level, with filler counted as empty space, so the gap to 50% is known on any method.
2. **Box range owners, during 2027:**  redesign the case range on product fit and pallet fit together, and retire sizes that exceed 50% on the internal basis, since those fail on every basis.
3. **Converters and brands placing cases under their own name, by end 2028:**  build the Article 10(4) evidence file per case and wrap specification, with one limiting requirement per Annex IV criterion and the test behind it.
4. **Contract packers and logistics providers, before signing contracts that run past 2030:**  agree who measures and records the empty space of filled cases and pallets, because the duty sits with the filler.
5. **Standards and public affairs teams, by 12 February 2027:**  follow the standardisation request and the CEN work it creates, and state which grouped and transport formats you see as most common.
6. **Procurement teams, in the 2027 budget round:**  test thinner stretch film and fewer wraps per load against load stability trials, and record the results as Article 10 evidence.
7. **Finance teams, now:**  cost right-sizing on board, film and trailer loads, not on EPR fees alone; in Austria the commercial fee saving in Exhibit 9 is EUR 3,795.07 on 100,000 cases. This is business advice, not legal advice; check with counsel where it applies.

## Questions for your board

- What share of our shipper cases would exceed 50% empty space today on the strictest of the three counting bases?
- Who in our chain fills grouped and transport packs, and does each of them know the Article 24 duty is theirs?
- Do our box ranges serve product fit, pallet fit or neither?
- Is there an Article 10 evidence file for each case and wrap specification we place on the market?
- Which of our grouped packs rely on marketing or display features that recital 60 no longer accepts as a reason for extra weight or volume?
- Are we following the 2027 standardisation request closely enough to see weight limits before they are set?

## What to watch

- **12 Feb 2027:**  Commission request to the European standardisation organisations on minimisation methods and limits is due (Article 10(3)).
- **12 Feb 2028:**  implementing act on the empty space ratio method is due (Article 24(2)).
- **31 Dec 2029:**  last day on which EN 13428:2004 is the compliance standard under Article 70(1)(b).
- **1 Jan 2030:**  Article 10(1) and (2) apply; earliest date for the 50% cap.
- **12 Feb 2031:**  start of the 50% cap if the method act enters into force on its deadline.
- **12 Feb 2032:**  Commission review of the 50% ratio and its exemptions (Article 24(6)).

## Methodology

- **Data used:**  Commission Notice C/2026/3084, sections 10 and 11, and its March 2026 draft; the DG ENV PPWR FAQ, second edition updated August 2026; recitals of Regulation (EU) 2025/40 in the English Official Journal text; Articles 10 and 24 in the German text as reproduced by LX Gesetze, an unofficial reproduction, summarised by SPI; Annex IV Part A and Part B as reproduced by Complydex, a secondary source; ARA's 2026 tariff list; Carlsberg Group's Snap Pack pages; ECOS and IKW position papers; SPI tracker entries [PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/) and [PR-EU-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-009/).
- **Confirmed and not confirmed:**  Article 10(1) to (3), Article 24(1), Annex IV point 4 and recital 60 are quoted in the Commission Notice. Article 10(4), Article 24(2) to (6) and the other Annex IV criteria rest on unofficial or secondary texts, and SPI has not yet confirmed them against the article text in the Official Journal.
- **Worked examples:**  the carton size, case sizes, board grammage of 700 g per square metre, 7 mm board thickness, pallet patterns, 1.50 m load height, 144 mm pallet base, 0.50 kg of film per load, 33 pallet places per trailer and 100,000 cases a year are SPI assumptions. Ratios follow the Article 24(3) definition on each counting basis. Fees use ARA's published 2026 rates per kg x1,000, in EUR only.
- **Cut-off:**  30 October 2026.
- **Limitations:**  the empty space method act, the standardisation request and the updated standard are not yet published; the counting bases in Exhibit 8 are SPI's tests, not the Commission's. This is not legal advice; check with counsel where it applies.

**Related:**  [GB 23350-2021: China's excessive packaging standard](https://www.strategicpackaginginsights.com/insights/gb-23350-2021-china-excessive-packaging-food-cosmetics/)

## Sources

1. EUR-Lex, Commission Notice C/2026/3084, guidance document for Regulation (EU) 2025/40, sections 10 and 11, OJ C 10.6.2026, [https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084), consulted 2026-10-30.
2. European Commission, Draft Commission Notice, annex to C(2026) 2151 final, 30 March 2026, [https://environment.ec.europa.eu/document/download/3d59ca88-539c-4b6b-a623-0f61068e853e_en?filename=Annex+to+the+Communication+to+the+Commission.pdf](https://environment.ec.europa.eu/document/download/3d59ca88-539c-4b6b-a623-0f61068e853e_en?filename=Annex+to+the+Communication+to+the+Commission.pdf), consulted 2026-10-30.
3. European Commission, DG ENV, PPWR Frequently Asked Questions, second edition, updated August 2026, [https://op.europa.eu/o/opportal-service/download-handler?amp=&amp](https://op.europa.eu/o/opportal-service/download-handler?amp=&amp);amp=&amp=&amp=&format=pdf&identifier=ad14cb8f-8d4f-11f1-9262-01aa75ed71a1&language=en&part=&productionSystem=cellar, consulted 2026-10-30.
4. EUR-Lex, Regulation (EU) 2025/40 on packaging and packaging waste, OJ L 22.1.2025, recitals, [https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202500040](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202500040), consulted 2026-10-30.
5. LX Gesetze, Art. 24 PPWR, German text of Regulation (EU) 2025/40 as reproduced, [https://lxgesetze.de/ppwr/24](https://lxgesetze.de/ppwr/24), consulted 2026-10-30.
6. LX Gesetze, Art. 10 PPWR, German text as reproduced, [https://lxgesetze.de/ppwr/10](https://lxgesetze.de/ppwr/10), consulted 2026-10-30.
7. ECOS, PPWR standardisation request recommendations on packaging minimisation, March 2026, [https://ecostandard.org/wp-content/uploads/2026/03/2026-02-26_ECOS-PPWR-SReq-recommendations-packaging-minimisation.pdf](https://ecostandard.org/wp-content/uploads/2026/03/2026-02-26_ECOS-PPWR-SReq-recommendations-packaging-minimisation.pdf), consulted 2026-10-30.
8. ECOS, How the European packaging minimisation standard can fit EU regulation, 25 March 2026, [https://ecostandard.org/publications/european-standard-packaging-minimisation/](https://ecostandard.org/publications/european-standard-packaging-minimisation/), consulted 2026-10-30.
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