Design & circularity
PPWR packaging minimisation
Last regulatory verification: 12 August 2026 · 4 official sources
Packaging must be reduced to the minimum weight and volume needed for functionality. The criteria, the documentation expected, and what is pending.
Free PPWR Check60 seconds. Find out whether this packaging should be reviewed.Short answer
Article 10 of Regulation (EU) 2025/40 requires packaging to be reduced to the minimum weight and volume necessary to ensure its functionality, with additional weight or volume only where a listed performance criterion justifies it. It applies from 12 August 2026 and the justification belongs in the Annex VII technical documentation.
Regulatory status
In force- Legal basis
- Article 10, Regulation (EU) 2025/40
- Applies from
- 12 August 2026
- Binds
- Manufacturers placing packaging on the EU market
A common assessment methodology and supporting standardisation are still being developed. The obligation to minimise and to be able to justify the design is not waiting for them.
Minimisation is a documentation duty as much as a design duty
Two companies can ship identical packaging and be in different positions under Article 10: one has a dated assessment showing the design is the minimum that works, the other has an opinion. Market surveillance authorities cannot judge whether packaging is excessive without seeing the functional constraints — so the absence of a justification is itself the finding.
A justification template that survives scrutiny
Use the same six-part structure for every configuration. It maps to how the criteria in the Regulation are written, and it keeps the assessment short enough to actually be completed across a portfolio.
1. Define the packaging configuration
Product, primary packaging, any grouped and transport packaging, and every component with its weight and material. Minimisation is assessed against a defined configuration, not a product line.
2. State the functional requirements it must meet
Protection, hygiene and safety, product integrity through the distribution channel, consumer acceptance where legally relevant, and any legal information that must appear on the pack.
3. Record which performance criteria constrain the design
The Regulation lists the criteria that can justify additional weight or volume. Name the ones that actually apply here and say why — a generic 'product protection' claim is not a justification.
4. Show the reduction assessment
What was tested or considered: thinner substrate, smaller format, removed layer, removed component, alternative closure. Include the options rejected and the reason.
5. Evidence the constraint
Transit trial results, drop-test data, shelf-life data, a regulatory labelling requirement. This is what converts an assertion into a defensible position.
6. Date it and set a review trigger
Minimisation is judged against the state of the design. A change of substrate, supplier or distribution channel should re-open the assessment.
Marketing is not a performance criterion
Where minimisation and empty space meet
Article 10 governs the packaging design itself. The separate empty space ratio rule caps unused volume in grouped, transport and e-commerce packaging from 2030. A pack can be individually well minimised and still fail the empty space test inside its shipper — they are different assessments and both need to be documented.
Who this hits hardest
E-commerce operations that ship a wide range of item sizes through a small number of box sizes, cosmetics and supplement categories where secondary cartons are a brand device, and anyone using rigid inserts to hold a small product in a large format. See PPWR for e-commerce 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
- European Commission Harmonised StandardsTechnical standard
- 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.