If your warehouse ships goods in boxes that are half-full of air cushions, bubble wrap, or crinkle paper, you have a compliance problem - not just a cost problem. Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR), sets binding rules on how much empty space your shipping and e-commerce packaging may contain. The minimization obligation is already in force. The hard numeric cap follows in 2030. And the documentation burden starts now.
This article explains what the regulation actually says, corrects a widely circulated figure, and gives operations and compliance managers a practical roadmap.
Article 10: The Minimization Obligation - In Force from 12 August 2026
Article 10 of the PPWR requires that packaging be minimised. The principle is straightforward: packaging should only be as large and heavy as is absolutely necessary for its function. A balance must be found between product protection and environmental protection.
From 12 August 2026, this is a legal requirement, not a guideline. The Commission is to request the European standardisation organisations to specify maximum adequate limits for weight, volume, wall thickness, and empty space for the most common packaging types and formats. Until those harmonised standards are published, companies must self-assess and document their justification.
Regulation (EU) 2025/40 (PPWR) entered into force on 11 February 2025 and applies from 12 August 2026.
What "minimized" means in practice
The PPWR requires that packaging be reduced to the minimum necessary for ensuring its functionality. Packaging not necessary to satisfy certain performance criteria, and packaging only intended to increase the perceived volume of the packaging, will be banned.
That last clause is the one most e-commerce operations underestimate. A box chosen because it was "close enough" from a standard carton range - not because it was the right size - is exactly the kind of decision Article 10 targets.
Article 24: The 50% Empty-Space Cap - Effective 1 January 2030
Here is where the most confusion in the market exists. Several industry sources have cited a 40% threshold applying from August 2026. That figure is incorrect.
Article 24 'Obligation related to excessive packaging' of the PPWR 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%." The final framework is based on a 50% cap.
Under Article 24 of Regulation (EU) 2025/40, the maximum empty-space ratio for grouped, transport, and e-commerce packaging is 50%, applying from 1 January 2030.
The phasing matters: implementing acts are required to be adopted by 12 February 2028 to establish the methodology for calculating this empty space ratio. If those acts are adopted after that date, the 50% cap applies 36 months from their entry into force - meaning the effective date could slip beyond 2030.
Two separate obligations, two separate dates. Article 10 (minimization of weight and volume) applies from 12 August 2026. Article 24 (the 50% empty-space ratio cap) applies from 1 January 2030 at the earliest. Both require documentation. Neither is optional.
How the ratio is measured
Under Article 24, economic operators filling grouped, transport, or e-commerce packaging must keep the empty space ratio below 50% from 1 January 2030. The empty space is the difference between the inner volume of the packaging and the volume of the products it contains.
Critically, void fill is not a workaround - it counts as empty space. The regulation is explicit: space filled by filler materials such as paper cuttings, air cushions, bubble wrap, sponge fillers, foam wool, wood wool, or polystyrene is considered empty space.
PPWR measures volume, not material. Paper void fill and mushroom foam count toward the empty-space ratio exactly the same as plastic air pillows. Switching to a more sustainable filler material does not solve the right-sizing problem.
The ratio is expressed as:
Empty-space ratio (%) = (Inner box volume - Product volume) ÷ Inner box volume × 100
A 30 cm × 20 cm × 15 cm box (9,000 cm³) shipping a product that occupies 4,000 cm³ has an empty-space ratio of 55.6% - non-compliant under the 2030 rule, regardless of what fills the remaining space.
Prohibited Practices: Double Walls, False Bottoms, Oversized Boxes
Article 10 goes beyond the numeric ratio. Packaging that aims to increase the perceived size of the product with double walls, false bottoms, or unnecessary layers should not be circulated. Packaging minimization rules apply: packaging weight and volume must be reduced to the minimum necessary, and double walls, false bottoms, and superfluous layers are prohibited (with limited exceptions for protected geographical indications).
For e-commerce operations, this means:
- Standard carton cascades - using a fixed set of 3-5 box sizes regardless of product dimensions - are a compliance risk if they routinely produce oversized shipments.
- Decorative inner packaging that adds perceived volume without functional justification is prohibited.
- Nested void fill (e.g., a product in a retail box, inside a shipping box, surrounded by air cushions) must be assessed holistically against the ratio.
If you ship a product in its original retail box without an outer shipping box, the 50% rule does not apply to that configuration - though Article 10 minimisation still does.
Calculate Your Current Void Ratio
Use the calculator below to check whether your current shipping configuration would be compliant under the Article 24 cap.
A Practical Right-Sizing Roadmap
Pull 60–90 days of shipping data. For each order, calculate the empty-space ratio using actual box dimensions and product dimensions. Identify which SKU/carton combinations exceed 50% — and by how much. Prioritize high-volume, high-overage combinations first.
Use cartonization logic (algorithmic box selection) to identify the smallest standard carton that fits each product or order combination with adequate protection clearance. Eliminate box sizes from your range that exist only to fill gaps in your cascade.
Right-sizing the box is the primary lever. Void fill should only compensate for unavoidable dimensional mismatch or fragility requirements — not for an oversized box. Document the functional justification for any remaining void fill in your technical file.
For each packaging type, prepare a written report explaining why the current weight and volume cannot be reduced further without compromising product protection, hygiene, or transport integrity. This is the Article 10 evidence pack (TF-03 in your Annex VII technical file).
From 2026, maintain records of box selection decisions at the order level. When the Commission publishes the Article 24 calculation methodology (due by 12 February 2028), you will need this data to demonstrate compliance retroactively and prospectively.
Documentation: What Your Technical File and DoC Must Contain
The Declaration of Conformity is a legally binding self-declaration in which the manufacturer confirms that a specific packaging meets the sustainability requirements of the PPWR. It is defined in Article 39, with the model structure detailed in Annex VIII. The scope covers compliance with Articles 5 through 12: minimisation, recyclability, recycled content, reuse, substance restrictions, and innovative packaging.
Behind the declaration sits the technical documentation - the evidence file that backs up every claim. Both are mandatory and both must be available to market surveillance authorities on request. It applies per packaging type: each format, each material, each configuration needs its own declaration.
For the minimization obligation specifically, your technical file must include:
- Packaging BOM and specification - component hierarchy, materials, weights, dimensions, suppliers (TF-01)
- Minimization evidence pack - design constraints, reduction rationale, tests or studies where relevant (TF-03, per Article 10)
- A written report explaining why weight/volume cannot be reduced further without compromising function or hygiene
- Empty-space ratio calculations - per carton/SKU combination, with methodology notes (ready for the Article 24 implementing act methodology when published)
- Results of design verification, calculations, simulations, and any third-party tests used as evidence
On retention: for single-use packaging, manufacturers must keep the DoC and technical file for at least five years after the last unit is placed on the market.
The PPWR DoC must follow the model structure in Annex VIII of Regulation (EU) 2025/40, and the supporting technical file must be made available to market surveillance authorities within 10 days of a request.
A common failure point: packaging data spread across suppliers, emails, and spreadsheets, with no single dossier pulling the legal references, market rules, and evidence together. That is not an audit-ready technical file.
What E-Commerce Operations Need to Do Right Now
The 2030 hard cap gives operations teams time to redesign carton ranges and implement cartonization. But the Article 10 minimization obligation is live from August 2026 - and the DoC must be ready on day one.
That means:
- Classify all your shipping and e-commerce packaging as grouped, transport, or e-commerce packaging under the PPWR definitions.
- Calculate current empty-space ratios across your carton mix and identify non-compliant configurations.
- Build the minimization justification for each packaging type and integrate it into your Annex VII technical file.
- Issue a DoC per packaging type per the Annex VIII template before 12 August 2026.
- Set a 2028 review trigger to update your methodology when the Commission publishes the Article 24 implementing acts.
Packa's compliance module handles the technical file structure, DoC generation, and per-SKU evidence management - built from 850+ real packaging projects with 300+ enterprise customers across FMCG, e-commerce, and manufacturing.
Walk through your e-commerce packaging portfolio with a Packa expert — identify void-ratio risks, documentation gaps, and a clear path to PPWR compliance. Free of charge, no commitment.
Talk to a Packaging ExpertIs the PPWR empty-space limit 40% or 50%?
The official text of Regulation (EU) 2025/40 sets the limit at 50% for grouped, transport, and e-commerce packaging (Article 24). The 40% figure circulating in some industry sources refers to an earlier draft of the regulation and is not in the final text. The 50% cap applies from 1 January 2030, or 36 months after the Commission publishes the calculation methodology implementing acts, whichever is later.
Does void fill (bubble wrap, air cushions, paper) count as empty space?
Yes. The regulation is explicit: space filled by filler materials — including paper cuttings, air cushions, bubble wrap, sponge fillers, foam wool, wood wool, and polystyrene — counts as empty space. Switching to a 'sustainable' filler material does not reduce your empty-space ratio.
When does the Article 10 minimization obligation apply?
From 12 August 2026. This is the general obligation to reduce packaging weight and volume to the minimum necessary for functionality. It applies to all packaging types, not just e-commerce or transport packaging. The 50% numeric cap under Article 24 is a separate, later obligation.
Does the 50% rule apply if I ship a product in its original retail box with no outer shipping box?
No. If sales packaging is used directly as e-commerce packaging without an additional outer box, the Article 24 empty-space ratio does not apply to that configuration. However, the Article 10 minimization principle still applies.
What documentation do I need to prove minimization compliance?
Your Annex VII technical file must include: packaging specifications and BOM, a written minimization justification explaining why dimensions cannot be reduced further without compromising function, empty-space ratio calculations per packaging type, and any design verification or test results. This file backs your Annex VIII Declaration of Conformity and must be available to market surveillance authorities within 10 days of a request.
