Regulation
PPWR and the 50% Empty Space Rule
What Article 24 actually requires, when it actually bites, and why 2030 is closer than it looks.
By Dennis Mosch · · 7 min read
In short
- The cap is 50%, not 40%, and it applies from 1 January 2030, not August 2026.
- PPWR itself has been generally applicable since 12 August 2026; the Article 10 minimisation duty and its Annex VII documentation are the parts already in play.
- Filler counts as empty space. You comply by having less void, not by packing the void better.
- The fix is usually a box assortment change, which has a multi-year lead time. Working backwards, the decision point is around 2027.
The Timeline, Straight
| Date | What happens |
|---|---|
| 11 Feb 2025 | Regulation (EU) 2025/40 enters into force, repealing Directive 94/62/EC. |
| 12 Aug 2026 | General date of application. PPWR is now live — this date has already passed. |
| 12 Feb 2028 | Deadline for the Commission's implementing acts defining the empty space calculation methodology. |
| 1 Jan 2030 | The 50% empty space cap under Article 24 applies (or three years after those implementing acts, whichever is later). |
So the honest summary is: the cap is 50%, not 40%, and it bites in 2030, not now. Anyone telling you that you are already in breach of a hard numeric limit is selling something.
That said, the broader minimisation duty in Article 10 — packaging must be reduced to the minimum volume and weight necessary for functionality, with the reasoning documented in the Annex VII technical documentation — is part of the framework that is already applicable. The 50% figure is a backstop with a date on it. The obligation to be able to justify your packaging size is the part that is live.
What Counts as Empty Space
Article 24 applies to grouped packaging, transport packaging and e-commerce packaging. The empty space ratio is the difference between the total internal volume of the packaging and the volume of the goods inside it, expressed as a percentage.
The detail that catches people out: filler counts as empty space. Paper, air cushions, bubble wrap and foam do not reduce your ratio — they are what the ratio is measuring. You cannot comply by packing the void more thoroughly. You comply by having less void.
Two exemptions in Article 24(5) are worth knowing: sales packaging that also serves as the e-commerce packaging, and reusable packaging operating within a re-use system. Transport packaging for palletised goods, such as stretch film, sits outside the cap as well.
The ratio you already have
If you run any packing calculation, you are computing this number already under a different name. Volume utilisation and empty space ratio are the same measurement from opposite ends:
empty space ratio ≈ 100% − volume utilisation
Subject to whatever the 2028 implementing acts settle on for the precise definition of "internal volume" — but close enough to find out where you stand.
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Why 2030 Is Not Far Away
Four years sounds comfortable. It is not, because the fix is almost never "use a smaller box for this order". The fix is changing your box assortment, and that has a lead time measured in years rather than weeks:
- Deciding which sizes to add or drop requires historical order data you may not be analysing yet.
- New carton sizes mean new tooling, new supplier agreements and new minimum order quantities.
- Warehouse systems, pack stations and pick logic all have to learn the new sizes.
- Then you need a full seasonal cycle to confirm the new assortment behaves under peak.
Work backwards from January 2030 with those lead times and the decision point is roughly 2027. The measurement that informs that decision needs to happen well before it.
A Practical Four-Step Approach
1. Measure your baseline distribution
Not your average — your distribution. An average empty space ratio of 38% can easily conceal a quarter of shipments sitting above 50%. Run a representative month of historical orders through a packing calculation and plot the histogram. That single chart tells you whether this is a project or a footnote.
2. Find the offenders
Failures cluster. In our experience they concentrate in a handful of SKUs with awkward dimensions, single-item orders that go into a box sized for three, and one or two box sizes that are used as a default because nothing better exists. Ranking shipments by empty space ratio usually makes the pattern obvious within an hour.
3. Right-size the assortment
This is the actual intervention, and it is an optimization problem in its own right: which set of n box sizes minimises empty space across your real order mix, given that every additional size costs money in the warehouse? Our Select Bin endpoint answers the per-order half of this; running it across your history answers the assortment half.
4. Measure continuously, not once
Assortments drift as product ranges change. A compliance position established in 2028 and never re-checked will not survive to 2030. If the ratio comes out of the same API call that chooses the box, it stays current for free.
The Part Nobody Says Out Loud
Empty space is expensive regardless of the regulation. You pay for it in freight, in warehouse volume, in corrugated, and in the damage that filler is supposed to prevent and often does not. A shipment that fails the 50% test is a shipment where you are shipping more air than product.
PPWR has not created that cost. It has just attached a date to it. Companies that treat this as a compliance exercise will spend money on documentation; companies that treat it as an efficiency exercise will find the compliance falls out of work they wanted to do anyway.
Find out where you stand.
Every packing response we return includes volume utilisation per bin and across the shipment — which is your empty space baseline, per order, with no separate reporting project.
Sources
- Regulation (EU) 2025/40 (PPWR) — EUR-Lex
- European Packaging and Packaging Waste Regulation: Summary of Provisions and New Guidance
- New EU packaging and packaging waste rules: 10 key things every global business should know
Frequently Asked Questions
Is the PPWR empty space limit 40% or 50%?
50%. Article 24 of Regulation (EU) 2025/40 sets a maximum empty space ratio of 50% for grouped packaging, transport packaging and e-commerce packaging. The 40% figure circulating online appears to come from earlier drafts and from commentary that conflates PPWR with other packaging rules.
When does the 50% empty space rule apply?
From 1 January 2030, or three years after the implementing acts that define the calculation methodology, whichever is later. Those implementing acts are due by 12 February 2028. PPWR as a whole has applied since 12 August 2026, which is the source of most of the date confusion.
How is the empty space ratio calculated?
As the difference between the total internal volume of the packaging and the volume of the goods inside it, expressed as a percentage. The precise methodology is what the 2028 implementing acts will settle. In the meantime, empty space ratio ≈ 100% − volume utilisation, which is a figure any packing calculation already produces — close enough to find out where you stand.
Does void fill count towards the empty space ratio?
Yes. Paper, air cushions, bubble wrap and foam are what the ratio measures, not a way to reduce it. This is the detail that catches most teams out, because "fill the void properly" is the intuitive response and it does nothing for compliance.
What is exempt from the PPWR empty space cap?
Article 24(5) exempts sales packaging that is also used as the e-commerce packaging, and reusable packaging operating within a system for re-use. Transport packaging for palletised goods, such as stretch film, also sits outside the cap. Confirm the specifics for your own packaging with your compliance team.
What should we be doing now if the deadline is 2030?
Measure. Run a representative month of historical orders through a packing calculation and plot the distribution of empty space ratios, then rank the worst shipments. That analysis is what tells you whether this is a footnote or a box-assortment project — and an assortment change needs tooling, supplier agreements, warehouse changes and a peak season to validate.
Have any questions?
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