From 1 January 2030 grouped, transport and e-commerce packaging may contain at most 50% empty space. It is one of the most concrete requirements in the PPWR — and one of the few you can check with a calculator.
The surprise is not in the percentage. It is in what counts as empty space.
What empty space exactly is
The empty space is the difference between the total volume of the grouped, transport or e-commerce packaging and the volume of the sales packaging or packagings inside it.
And then the provision that tips the story: void fill counts as empty space. Paper, air pillows, foam chips, cardboard inserts — it fills space, but it does not make the space filled within the meaning of the regulation.
So anyone filling their boxes to the brim with kraft paper does not reach 0% empty space. They reach exactly the same ratio as when the box was empty. The only solution is a smaller box.
Who it applies to
The ratio applies to:
- grouped packaging — the multipack, the outer box around several sales units
- transport packaging — the box, the crate, the pallet
- e-commerce packaging — the shipping box or bag
Not for primary packaging. The jar itself may keep its headspace.
If you sell online, this is the PPWR requirement that most directly affects your operations. See PPWR for e-commerce.
Not sure whether this applies to your packaging? The PPWR Check walks through your role, market and material in eight questions and shows per pillar what applies to you. Take the PPWR Check →
Do not confuse it with the minimisation obligation
These are two different obligations with two different dates, and they are constantly confused.
Article 10 — packaging minimisation. Applies from 12 August 2026. The packaging must be designed for the minimum weight and volume its function allows, tested against the performance criteria in Annex IV. Misleading features — double walls, false bottoms, filling that suggests volume — are banned. You substantiate this in the technical file; until 2030 this may be based on the standard EN 13428.
Article 24 — empty-space ratio. Applies from 1 January 2030. A hard numerical limit of 50%, only for grouped, transport and e-commerce packaging.
Article 10 is a principle you must already comply with and substantiate in your declaration of conformity. Article 24 is a number that is added in 2030. You can meet Article 10 and still fail Article 24 in 2030.
The methodology does not exist yet
Exactly how you measure the volume — outer dimension or inner dimension, how you handle irregularly shaped products, how you calculate a pallet with a mixed load — will be set in an implementing act. It must be in place by 12 February 2028 at the latest.
That means two things. From that moment you still have almost two years to adjust your box range. And until then you cannot make a definitive calculation. What you can do: measure now how much air is in your shipments on average. If that is structurally above 50%, you know enough — whatever measurement method arrives.
The exemptions
Article 24, paragraph 3, names cases in which the ratio does not apply:
- Gift packaging, provided it was not chosen to suggest volume
- Reusable packaging within a working reuse system
- Cases in which functionality blocks minimisation: fragile products, liquids, irregularly shaped articles
That last category is deliberately broadly worded and at the same time narrowly intended. The exact wording of these exemptions is moreover hard to check without the official PDF of the regulation to hand, and they have not yet been tested in practice. Do not assume that “our product is fragile” suffices: count on having to demonstrate that a smaller box does not protect the product.
What you can do now
Most webshops run on three or four box sizes because it keeps purchasing simple. That is exactly the problem: the fewer sizes, the more air.
- Measure your current ratio. Take your twenty most-shipped orders, calculate the box volume minus the product volume. You will know within an hour where you stand.
- Expand your box range rather than shrinking it. More sizes mean less air, and you often recoup that through shipping costs.
- Consider cartonisation software that picks the optimal box size per order, or a made-to-measure machine that folds the box around the product.
- Scrap void fill as a strategy. It does not solve the problem — it only conceals it, and soon not even that.
- Revise your primary packaging. A product packed more compactly fits in a smaller box. The gains stack.
Anyone who has this in order before 2030 has not incurred a compliance cost but lowered their shipping costs. Of all the PPWR obligations, this is the only one that pays for itself.