Design & circularity
PPWR empty space ratio
Last regulatory verification: 12 August 2026 · 3 official sources
PPWR caps empty space in grouped, transport and e-commerce packaging at 50%. How the ratio works, a worked calculation, and the methodology still pending.
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Article 24 of Regulation (EU) 2025/40 caps the empty space ratio in grouped packaging, transport packaging and e-commerce packaging at 50%, from 1 January 2030. In plain terms: at least half the volume of the shipper has to be doing something. The detailed measurement methodology is still to be fixed by secondary legislation.
Regulatory status
Phases in- Legal basis
- Article 24, Regulation (EU) 2025/40
- Applies from
- 1 January 2030
- Binds
- Manufacturers, final distributors and online sellers using grouped, transport or e-commerce packaging
The 50% cap is in the Regulation. A harmonised calculation methodology is expected through secondary legislation, which is why the worked example below records its inputs explicitly.
How the ratio works
The empty space ratio is the share of the outer packaging's volume that is not occupied by the goods and their sales packaging. Void fill — paper, air pillows, foam — is part of the empty space, not part of the filled volume. That single point overturns how many fulfilment operations currently think about packing quality.
A worked calculation
Take a shipping box of 400 × 300 × 200 mm. Its internal volume is 24,000,000 mm³, or 24 litres. Inside it are two sales units, each 200 × 150 × 100 mm, so 3,000,000 mm³ each and 6 litres in total.
- Outer packaging internal volume
- 24.0 litres
- Volume occupied by goods and their sales packaging
- 6.0 litres
- Empty space
- 18.0 litres
- Empty space ratio
- 18.0 ÷ 24.0 = 75%
- Result against the 50% cap
- Fails — by a wide margin
To pass, the same two units need an outer packaging internal volume of no more than 12 litres — for example 300 × 200 × 200 mm. The fix here is a box size, not a redesign.
Record your inputs, not just your answer
What usually causes a failure
Too few box sizes in the range, so most orders ship in a box a size too big. Inserts and trays that hold a small item in a large format. Fixed-size subscription boxes shipped part-filled. And multi-item orders picked into a single large carton rather than a right-sized one. In practice, adding two intermediate box sizes fixes more of the portfolio than any packaging redesign.
Exemptions and adjacent rules
Where the goods genuinely require protective space, or where the packaging is reusable within a system, the position differs — but the reason has to be documented against the criteria in the Regulation, not asserted. Read this alongside packaging minimisation, which governs the design of the packaging itself, and transport packaging.
Official sources for this page
Every statement above is written against these sources. Where a Commission document and the Regulation differ, the Regulation controls.
- Regulation (EU) 2025/40 — EUR-LexBinding law
- PPWR Implementation HubCommission guidance
- Commission PPWR GuidanceCommission guidance
- Sources last verified
- 12 August 2026
- Content last updated
- 12 August 2026
- First published
- 12 August 2026
Written and maintained by the PPWRDeclaration.com editorial team. General information about Regulation (EU) 2025/40 — not legal advice.
Why this matters
What happens if the documentation isn't there
The packaging can be restricted
Packaging without valid technical documentation is treated as non-compliant. Market surveillance authorities can require corrective action, restrict sale, or withdraw it from the market.
Penalties apply per Member State
Each Member State sets its own penalties for non-compliance, and they apply where the packaging is placed on the market — not where your business sits.
Buyers block you first
Retailers, distributors and importers increasingly ask for the Declaration and supporting evidence before onboarding. No file usually means no listing.
Late evidence costs more
Supplier declarations and lab testing have long lead times. Discovering a gap close to a deadline forces rushed testing or packaging redesign.