The EU Packaging and Packaging Waste Regulation (PPWR) will begin applying from 12 August 2026, introducing new requirements aimed at reducing unnecessary packaging and packaging waste across the supply chain.
One area receiving particular attention is excessive empty space within grouped, transport and e-commerce packaging, reflecting growing concern around over-packaging linked to the continued expansion of online retail.
Under Article 24 of the PPWR, businesses using grouped, transport and e-commerce packaging will face a new maximum empty space ratio of 50%, fundamentally increasing pressure on packaging efficiency and right-sizing practices.
What are Empty Space Rules?
Under Article 24 ‘Obligation related to excessive packaging’ of the PPWR, the regulation states:
“By 1 January 2030 or 3 years from the entry into force of the implementing acts adopted pursuant to paragraph 2, whichever is the latest, economic operators who fill grouped packaging, transport packaging or e-commerce packaging shall ensure that the maximum empty space ratio, expressed as a percentage, is 50 %.”
Earlier discussions on the PPWR referred to a stricter 40% threshold, which is still frequently cited in industry debate. The final framework, however, is based on a 50% cap.
The PPWR empty space restrictions are primarily targeted at single-use grouped, transport and e-commerce packaging. Reusable packaging systems are generally treated separately under the Regulation and are not expected to be subject to the empty space ratio requirements in the same way, although broader minimisation obligations still apply.
Reusable packaging is treated differently throughout PPWR because the regulation recognises that:
- reusable systems may require more robust packaging formats,
- protective space may be operationally necessary,
- packaging has to withstand multiple rotations and logistics cycles.
Empty Space Requirements Explained
Although the headline rule is a 50% cap on empty space, the regulation acknowledges that some flexibility will be needed in practice.
Paragraph 2 of Article 24 states that:
“By 12 February 2028, the Commission shall adopt implementing acts to establish the methodology for the calculation of the empty space ratio referred to in paragraph 1.”
The future methodology is expected to account for situations where additional extra empty space may be operationally necessary, including factors such as:
- Irregular shaped products.
- Multi-product packs or grouped items.
- Liquid products.
- Fragile items or easily damaged goods.
- Small products transported alongside larger items.
- The minimum space required for shipping and transport labels
Definition of Empty Space
The definition of empty space is set out in Article 24(3) of the Regulations:
“For the purpose of the calculation of the ratio referred to in paragraph 1:
(a) empty space shall mean the difference between the total volume of grouped packaging, transport packaging or e-commerce packaging and the volume of sales packaging contained therein;
(b) empty space ratio shall mean the ratio of the empty space as defined in point (a) and the total volume of the grouped packaging, transport packaging or e-commerce packaging.
Space filled by filling materials, such as paper cuttings, air cushions, bubble wraps, sponge fillers, foam fillers, wood wool, polystyrene or Styrofoam chips, shall be considered as empty space.”
The Regulation therefore treats common void-fill materials as part of the empty space calculation, increasing pressure on businesses to reduce unnecessary padding and improve packaging efficiency.
Separately, the PPWR’s packaging minimisation requirements also place restrictions on packaging features designed to create a misleading impression of product volume, including false bottoms, double walls and unnecessary layers of packaging.
Key Deadlines
- 12 February 2027: The European Commission shall request the European standardisation organisations to prepare or update harmonised standards setting out the methodology for calculating and measuring compliance with the packaging minimisation requirements.
- 12 February 2028: The Commission shall adopt implementing acts to establish the methodology for calculating the empty space ratio.
- January 2030 (or 3 years from the entry into force of the implementing acts, whichever is latest): Full implementation of the 50% empty space limit on e-commerce packaging.
Prepare for PPWR
The Article 24 requirements form part of a wider regulatory push to reduce unnecessary packaging and improve resource efficiency across the supply chain.
For many businesses, compliance is likely to accelerate the move towards right-sized packaging solutions and more precise fulfilment operations. Technologies such as automated box-making systems, dimension-scanning equipment and intelligent packing software are expected to become increasingly important in helping businesses reduce unnecessary void space.
Although this may involve upfront operational investment, right-sizing packaging can also deliver commercial benefits. Reducing package volume may help lower transport and dimensional weight costs, while simultaneously reducing packaging material usage and supporting wider sustainability objectives.
