PPWR Articles 10 & 24: Packaging Minimisation & Empty Space
Top line summary
Under the PPWR, rules apply from 12 Aug 2026, with sales-packaging empty-space minimisationdue by 12 Feb 2028 and Article 10 plus the 50 % empty-space cap effective from 1 Jan 2030 (or later if implementing acts delay it). Article 10 requires packaging to be only as light and small as necessary for its function, banning design features that merely increase perceived volume. Article 24(1)-(3) limits grouped, transport, and e-commerce packaging to a 50 % empty-space ratio, including fillers. Article 24(4) adds that sales packaging must keep empty space to the minimum needed for protection, with no fixed percentage.
Summary
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🗓️ Legal timing (what applies when)
🔴 Entry into force: 20th day after publication in the OJ (OJ L, 22.1.2025 → 11 Feb 2025)
🟡 PPWR applies from: 12 Aug 2026
🔴 Art. 24(4) Sales packaging (minimise empty space): by 12 Feb 2028
🔴 Art. 10 Packaging minimisation: by 1 Jan 2030
🔴 Art. 24(1) 50% empty space cap (grouped/transport/e-commerce): by 1 Jan 2030 OR 3 years from entry into force of the Art. 24(2) implementing acts (whichever is later)
What’s the difference
Article 10 – Packaging minimisation | Article 24 – Empty space / excessive packaging | |
Regulates | Design of the packaging placed on the market (weight/volume + “perceived volume” features) | How packaging is filled (empty space) |
Packaging types | All packaging | (1) Grouped / transport / e-commerce (50% cap) (2) Sales packaging (minimise empty space) |
Who is on the hook | Manufacturer or importer | Economic operators who fill the relevant packaging |
Hard metric | No % in Art. 10 (“minimum necessary”) | 50% max for grouped/transport/e-commerce; no % capfor sales packaging (minimise to minimum necessary) |
📦 Article 10 – Packaging minimisation (by 1 Jan 2030)
(Legal basis: PPWR Article 10; references to Annex IV + Annex VII)
Reduce weight + volume to the minimum necessary for functionality (shape + material considered).
Do not place on the market packaging that:
does not comply with Annex IV performance criteria, or
has features aiming only to increase perceived volume (e.g., double walls, false bottoms, unnecessary layers),
unless an Article 10(2) derogation applies.
Derogations (Art. 10(2)(a)-(b)):
IP/design/trade mark protected before 11 Feb 2025 + Art. 10 would undermine novelty/individual character or trade mark distinctiveness; or
product covered by the referenced GI / quality scheme frameworks.
Evidence: demonstrate compliance in Annex VII technical documentation (elements listed in Art. 10(4)).
🔵 Standards: by 12 Feb 2027, Commission requests harmonised standards for minimisation methodology.
📐 Article 24 – Empty space / excessive packaging
(Legal basis: PPWR Article 24)
A) Grouped / transport / e-commerce (Art. 24(1)-(3))
🔴 50% maximum empty space ratio (economic operators who fill). “Empty space” is defined; filling materials count as empty space (paper cuttings, air cushions, bubble wrap, foam/sponge fillers, wood wool, polystyrene/Styrofoam chips, etc.).
🔵 Methodology: Commission implementing acts due by 12 Feb 2028; deadline for the 50% cap is 1 Jan 2030 or 3 years after those acts enter into force (whichever later).
B) Sales packaging (Art. 24(4))
🔴 By 12 Feb 2028, fillers of sales packaging must reduce empty space to the minimum necessary for functionality (incl. protection).
Definition for sales-packaging empty space ratio is given; fillers count as empty space.
Settlement/headspace cases: assess pack-fill at time of filling; air/protective gases in/around packed foodstuff not treated as empty space for that assessment.
🟢 Exemption from the 50% cap only (Art. 24(5))
Using sales packaging as e-commerce packaging, or using reusable packaging within a system of re-use, is exempt from Art. 24(1) – but that sales packaging must still comply with Article 10.
🔵 Review: by 12 Feb 2032, Commission reviews the 50% ratio + exemptions and assesses possible sales-packaging ratios for certain product groups.
✅ Compliance Checklists
Article 10 – Packaging minimisation
(Legal basis: Art. 10(1)-(4))
☐ Audit packaging designs for weight + volume optimisation (“minimum necessary”)
☐ Identify designs with double walls / false bottoms / unnecessary layers (perceived-volume features)
☐ Verify compliance with Annex IV performance criteria
☐ Document technical justification + what prevents further reduction (incl. tests/studies/modelling)
☐ If claiming IP/design/trade mark derogation: confirm protection before 11 Feb 2025 + impact on novelty/distinctiveness
☐ If claiming GI/quality derogation: confirm product status under the referenced EU frameworks
☐ Prepare Annex VII technical documentation elements listed in Art. 10(4)
Article 24 – Empty space
(Legal basis: Art. 24(1)-(6))
☐ Identify all grouped / transport / e-commerce packaging operations you fill (Art. 24(1))
☐ Identify all sales packaging you fill (Art. 24(4))
☐ For grouped/transport/e-commerce: measure empty space using the legal definitions (outer volume vs sales packs)
☐ For sales packaging: evidence that empty space is minimum necessary for function/protection
☐ Audit filling materials (they count as empty space)
☐ Flag any grouped/transport/e-commerce packs likely above 50% empty space ratio
☐ Implement right-sizing / pack-design changes to reduce empty space
☐ Track the Commission’s Art. 24(2) implementing acts (methodology due by 12 Feb 2028)
☐ Check whether you qualify for the Art. 24(5) exemption (only from the 50% cap) and still ensure Art. 10 compliance
Legal text - Law EU 40/2025
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Article 10
Packaging minimisation
- By 1 January 2030, the manufacturer or importer shall ensure that the packaging placed on the market is designed so that its weight and volume is reduced to the minimum necessary to ensure its functionality, taking account of the shape and material from which the packaging is made.
- The manufacturer or importer shall ensure that packaging which does not comply with the performance criteria set out in Annex IV of this Regulation and packaging with characteristics that aim only to increase the perceived volume of the product, including double walls, false bottoms and unnecessary layers, is not placed on the market, unless:
(a) the packaging design is protected by a Community design pursuant to Council Regulation (EC) No 6/2002 (64) or by design rights falling within the scope of Directive 98/71/EC of the European Parliament and of the Council (65), including international agreements having effect in one of the Member States, or its shape is a trademark falling within the scope of Regulation (EU) 2017/1001 of the European Parliament and of the Council (66) or Directive (EU) 2015/2436 of the European Parliament and of the Council (67), including trademarks registered under international agreements having effect in one of the Member States, the design rights and trademarks are protected before 11 February 2025, and the application of the requirements under this Article would affect the packaging design in a way that it would alter its novelty or its individual character, or would affect the trademark in a way that the trademark is no longer capable of distinguishing the marked product from those of other undertakings; or
(b) the packaged product or beverage benefits from a geographical indication protected under Union law, such as under Regulation (EU) No 1308/2013 for wine, Regulation (EU) 2019/787 for spirit drinks or Regulation (EU) 2023/2411 for craft and industrial products, or is covered by a quality scheme as referred to in Regulation (EU) 2024/1143.
- By 12 February 2027, the Commission shall request the European standardisation organisations to prepare or update, as appropriate, harmonised standards laying down the methodology for the calculation and measurement of compliance with the requirements concerning packaging minimisation under this Regulation. For 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.
- Compliance with the requirements set out in paragraphs 1 and 2 of this Article shall be demonstrated in the technical documentation referred to in Annex VII, which shall contain the following elements:
(a) an explanation of the technical specifications, standards and conditions used to assess the packaging against the performance criteria and methodology set out in Annex IV;
(b) for each of those performance criteria, the identification of the design requirements which prevent further reduction of the packaging weight or volume;
(c) any test results, studies or other relevant sources, such as modelling and simulations, used to assess the minimum necessary volume or weight of the packaging.
For reusable packaging, the assessment of compliance with the requirements set out in paragraph 1 of this Article shall take into account the characteristics of reusable packaging, and in the first place the requirements set out in Article 11.
Article 24
Obligation related to excessive packaging
- 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 %.
- 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. That methodology shall take into account the special characteristics of packaging which needs to be placed in an empty space that is large enough to comply with applicable legal requirements or to protect the product, such as, in particular, packaged products of irregular shape, packaging containing more than one sales packaging or product, packaging containing liquid products, packaged products the content of which can easily be damaged and packaged products that can be damaged by larger products due to their small dimensions, and the minimum space on the transport packaging to enable shipment labels to be affixed. Those implementing acts shall be adopted in accordance with the examination procedure referred to in Article 65(2).
- 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.
- By 12 February 2028, the economic operators who fill sales packaging shall ensure that empty space is reduced to the minimum necessary for ensuring the packaging functionality, including product protection.
The empty space ratio for sales packaging shall mean the difference between the total internal volume of the sales packaging and the volume of the packaged product.
For the purpose of assessing compliance with this paragraph, 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.
For sales packaging for products that are subject to settlement during transportation or where headspace is required to protect the food product, or other products that present these characteristics:
(a) compliance with this paragraph shall be assessed as the pack-fill level at the time of filling;
(b) air between or within packed foodstuff or protective gases shall not be considered as empty space.
- Economic operators using sales packaging as e-commerce packaging or using reusable packaging within a system of re-use shall be exempt from the obligation laid down in paragraph 1 of this Article. They shall nevertheless ensure that such sales packaging complies with the requirements set out in Article 10.
- By 12 February 2032, the Commission shall review the empty space ratio referred to in paragraph 1 as well as the exemptions in paragraph 5, and assess the possibility of establishing empty space ratios for sales packaging, particularly for toys, cosmetics, do-it-yourself kits and electronic products.
Source: Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, OJ L, 2025/40, 22.1.2025
