Industries Retail & Distribution
The empty-space rule: PPWR caps the void in e-commerce parcels at 50%, filler included
The PPWR caps empty space in e-commerce parcels at 50%, and filler counts as void. Who is covered, how the ratio is measured, and what to redesign first.
On this page
An air cushion counts as void. Regulation (EU) 2025/40 on packaging and packaging waste, known as the PPWR (Packaging and Packaging Waste Regulation), says so in plain terms: crumpled paper, air cushions, bubble wrap, foam, and polystyrene chips are all empty space in the meaning of the text. And that empty space will be capped at 50% of the volume of e-commerce parcels, grouped packaging, and transport packaging.
The regulation entered into force on February 11, 2025 and applies from August 12, 2026, less than two months from now. The 50% cap arrives on January 1, 2030 at the earliest. That leaves four holiday peaks to redesign a carton fleet, and for a retailer shipping thousands of parcels a day, four peaks go by fast.
The 50% cap targets whoever fills the parcel, from 2030
Article 24 of the PPWR requires the economic operators who fill grouped, transport, or e-commerce packaging to keep the empty-space ratio at 50% or below. E-commerce packaging is defined as transport packaging used to deliver products to the end user in an online or other distance sale. If you pick and pack the order, the obligation is yours, not your carton supplier's and not the brand's.
The deadline is January 1, 2030, or three years after the entry into force of the implementing acts that set the calculation method, whichever comes later. The European Commission must adopt those acts by February 12, 2028. Reusable packaging operating within a reuse system is outside the ratio entirely.
The void is measured against the product boxes, not the products
Article 24 fixes the arithmetic. Empty space is the difference between the total volume of the parcel and the volume of the sales packaging it contains. The ratio is that empty space divided by the parcel's total volume. A 20-liter shipping carton holding 12 liters of product boxes runs at 40% void and passes. The same carton holding 8 liters of boxes runs at 60% and fails.
Space filled with filler materials counts as empty. The regulation names them: paper cuttings, air cushions, bubble wrap, sponge and foam fillers, wood wool, polystyrene, and Styrofoam chips.
Good to know: the reference point is the sales packaging, not the bare product. In practice, the first blocker is data: if your item master does not carry the dimensions of each product box, you cannot compute a single ratio. Completing those fields is where the work starts.
The detailed measurement method does not exist yet. The implementing acts due by February 2028 must handle the awkward cases: irregularly shaped products, liquids, fragile items, small products traveling with large ones, and the space a shipping label needs.
Shipping in the original box exempts you from the ratio, not from minimization
Article 24 carves out one exemption that matters to retailers: operators using sales packaging as e-commerce packaging, what logisticians call shipping in own container (SIOC), are exempt from the 50% ratio. No shipping carton, no ratio to compute.
The exemption has a floor. Those parcels must still meet Article 10, the general minimization duty: by January 1, 2030, packaging placed on the market must be designed so that its weight and volume are reduced to the minimum necessary for its function. Designs whose only purpose is to inflate perceived volume, double walls, false bottoms, and unnecessary layers, are banned outright, with narrow exceptions for designs and trademarks protected before February 11, 2025 and for products under a geographical indication.
Annex IV sets the test. Eight performance criteria (product protection, manufacturing processes, logistics, packaging functionality, information requirements, hygiene and safety, legal requirements, and recyclability, reuse, and recycled content) against which you must justify, criterion by criterion and in the technical documentation, what prevents further reduction. And one date lands earlier than the ratio: by February 12, 2028, operators who fill sales packaging must already have cut its empty space to the minimum necessary.
| Deadline | Obligation |
|---|---|
| August 12, 2026 | The PPWR applies |
| February 12, 2028 | Empty space in sales packaging cut to the minimum; deadline for the Commission's calculation-method acts |
| January 1, 2030 at the earliest | Empty-space ratio of 50% or below; Article 10 minimization |
| February 12, 2032 | Commission reviews the ratio and exemptions, and considers extending it to sales packaging, notably toys, cosmetics, and electronics |
Four design responses, in order of payoff
- Measure your real ratio on the flows that count. Take your most-shipped references, the carton formats they leave in, and compute the ratio parcel by parcel. Wherever product-box volumes are missing from the item master, that data gap is the first project.
- Rework the carton range. A handful of carton sizes chosen years ago rarely matches what actually ships. Align the range on shipped volumes, and consider variable-height cartons or scored boxes that fold down to the load.
- Test shipping in the original box where the product box can take the journey. The gain is double: exemption from the ratio and one carton removed per parcel.
- Push the question upstream to purchasing. An oversized product box flatters your parcel ratio, since the ratio measures against sales packaging, but it fails Article 24's own requirement on sales packaging and Article 10 behind it. Shrinking the product box is the honest fix, and it compounds through every carton decision downstream.
The official calculation method is still two years away, and there is no need to wait for it. Measure the ratio on your twenty most-shipped references this quarter, complete the volume data where it is missing, and put the carton range on the redesign list for the next peak. The definition of the void is already written.
FAQ
When does the 50% empty-space cap apply?
From January 1, 2030, or three years after the entry into force of the implementing acts setting the calculation method, whichever is later. The European Commission must adopt those acts by February 12, 2028. The cap is set by Article 24 of Regulation (EU) 2025/40.
Do air cushions and other filler materials count as empty space?
Yes. Regulation (EU) 2025/40 states that space filled by filling materials such as paper cuttings, air cushions, bubble wrap, sponge fillers, foam fillers, wood wool, polystyrene, or Styrofoam chips counts as empty space when calculating the ratio.
Are we exempt if we ship products in their original sales packaging?
Exempt from the 50% ratio, yes. Operators using sales packaging as e-commerce packaging do not have to compute the empty-space ratio, but that packaging must still comply with Article 10 of the PPWR, which requires weight and volume to be reduced to the minimum necessary for the packaging's function.
What counts as e-commerce packaging under the PPWR?
Transport packaging used to deliver products to the end user in the context of an online sale or another form of distance selling. In practice, the shipping carton, mailer, or envelope a distance-sold order travels in.
