PPWR Packaging Minimization and Empty Space Rules

Packaging minimization is becoming one of the most practical and visible compliance requirements under the EU Packaging and Packaging Waste Regulation, known as the PPWR.

For companies placing packaged products on the EU market, this means packaging can no longer be designed only around branding, shelf presence, shipping convenience, or standard box availability. Packaging must be right-sized, justified, documented, and free from unnecessary volume or avoidable empty space.

Regulation (EU) 2025/40 on packaging and packaging waste entered into force on 11 February 2025 and will generally apply from 12 August 2026. The European Commission explains that the PPWR is intended to address growing packaging waste, improve recyclability, harmonize packaging standards, and reduce unnecessary packaging across the EU market.

The European Commission also describes the new rules as targeting “common-sense packaging,” including small, light packaging without empty space and no unnecessary layers or pellets in deliveries.

Packaging minimization is a dedicated PPWR compliance area. Packaging must be designed to use the fewest materials, weight, and volume needed to protect and contain the product; unnecessary features such as double walls, false bottoms, or extra layers should not be used to make products look bigger; grouped, transport, and e-commerce packaging must respect empty space limits; and technical documentation should show how packaging has been minimized.

For manufacturers, importers, retailers, e-commerce businesses, distributors, packaging suppliers, logistics teams, and compliance managers, the message is clear: packaging minimization is not only a sustainability improvement. It is a compliance requirement that affects design, shipping, documentation, product launch, EPR costs, customer experience, and market access.

Unnecessary Packaging Features Are Restricted

Packaging minimization is not only about box size. It also covers features that artificially increase packaging volume.

The following are not allowed where they only make the product look bigger:

• Double walls
• False bottoms
• Extra layers
• Other design elements that inflate packaging volume without a real need

These features may create a misleading impression of product size, increase material use, and contribute to unnecessary packaging waste.

Examples of potentially excessive features

Exceptions may exist where the packaging design is legally required, such as for protected geographical indications.

This means companies should document the reason for any feature that increases packaging volume or weight.

Sales Packaging vs E-Commerce Packaging

One of the most important practical distinctions is the difference between sales packaging and e-commerce packaging.

Sales packaging is the packaging presented to the end user as part of the product unit. E-commerce packaging is packaging used to ship products ordered online.

If the sales packaging itself is used to ship products without an extra outer box, the 50% empty space rule does not need to be followed in the same way. However, the sales packaging must still follow packaging minimization rules to ensure it is not excessive.

Practical interpretation

This distinction matters for e-commerce sellers. A company may reduce compliance risk by designing sales packaging that can safely serve as shipping packaging, but it must still avoid excessive size, unnecessary layers, and unjustified material use.

What Fillers Count as Empty Space?

A common misunderstanding is that filling material solves empty space. Under PPWR, fillers can count as empty space when assessing compliance.

Filling materials include:

• Paper cuttings
• Air cushions
• Bubble wrap
• Sponge fillers
• Foam fillers
• Wood wool
• Polystyrene
• Styrofoam chips
• Similar filling materials

These materials are counted as empty space because they occupy void areas created by oversized packaging.

Practical impact for e-commerce and logistics

Companies should review carton libraries, warehouse packing instructions, automated box selection systems, and third-party logistics practices.

Packaging Minimization Must Not Compromise Protection

PPWR minimization does not mean packaging should be too weak, unsafe, or unsuitable. Packaging still needs to protect the product and support safety, hygiene, transport, legal, and functional requirements.

The objective is to avoid wasted material without compromising safety, hygiene, or other essential functions.

Legitimate reasons for additional packaging

The key is evidence. If extra material, empty space, or protective structure is needed, the company should document why it is necessary and what testing or assessment supports the decision.

Technical Documentation for Packaging Minimization

Packaging minimization must be supported by technical documentation.

Companies must include technical documentation showing how packaging has been minimized. This includes the standards or methods used to prove performance, the reasons why weight or volume could not be reduced further, and any test results or studies justifying the design as the minimum necessary.

What to include in minimization documentation

Technical documentation should be prepared before packaging is placed on the market and updated when the packaging design changes.

Reusable Packaging and Minimization

Reusable packaging must also be assessed for minimization, but the assessment should consider the function of reuse.

When checking whether reusable packaging meets minimization rules, companies should also consider the function of reusable packaging, including multiple trips and rotations.

This is important because reusable packaging may be heavier or more durable than single-use packaging. That does not automatically mean it is excessive. The design may be justified if the packaging is intended to survive repeated filling, transport, cleaning, reconditioning, and reuse.

Reusable packaging minimization questions

For reusable packaging, minimization should balance material reduction with durability and system performance.

E-Commerce Packaging: A High-Risk Area

E-commerce packaging is one of the areas most affected by empty space rules. Customers often receive small items in large boxes with excessive filler, making packaging waste highly visible.

The European Commission’s PPWR page refers directly to deliveries and the need to remove unnecessary layers or pellets, supporting small, light packaging without empty space.

Why e-commerce is high risk

E-commerce businesses should work with fulfilment providers to review packing algorithms, box libraries, protective materials, and empty space calculations.

Grouped and Transport Packaging

Grouped and transport packaging can also create empty space risk, especially in B2B supply chains, retail distribution, and warehouse operations.

Grouped packaging is often used to combine several products into a stock-keeping unit. Transport packaging is used to protect and move products through the supply chain.

Practical risks in grouped and transport packaging

The EUR-Lex summary specifically identifies grouped, transport, and e-commerce packaging as subject to the 50% empty space limit by 2030.

Companies should treat B2B and transport packaging as part of packaging compliance, not only logistics.

Packaging Minimization and EPR Costs

Packaging minimization can directly affect Extended Producer Responsibility costs. EPR fees are often linked to packaging material type and weight, and future fee modulation can consider sustainability performance.

Reducing unnecessary packaging weight and volume can help lower the amount of packaging placed on the market. This may reduce reporting quantities and potentially reduce EPR-related costs, depending on the national system.

Cost areas affected by minimization

Packaging minimization should therefore be built into compliance, procurement, logistics, and sustainability business cases.

Packaging Minimization and Environmental Claims

Companies should be careful when making claims about reduced packaging or right-sized packaging.

Claims such as “less packaging,” “reduced material,” “right-sized packaging,” “eco-friendly packaging,” or “waste-free packaging” must be specific and supported by evidence.

Claims that require evidence

The safest approach is to make claims that are precise, measurable, and linked to documented packaging changes.

Practical Packaging Minimization Roadmap

Companies can use the following roadmap to prepare for PPWR packaging minimization and empty space rules.

Step 1: Build a packaging inventory

List all sales, grouped, transport, e-commerce, reusable, refill, and service packaging used across the business.

Step 2: Map packaging to products and markets

Connect each packaging item to SKUs, product families, suppliers, fulfilment sites, and EU markets.

Step 3: Collect dimensions and weights

Gather outer dimensions, internal dimensions, product dimensions, sales packaging dimensions, component weights, and filler information.

Step 4: Identify high-risk packaging

Prioritize packaging with high empty space, high filler use, high material weight, high volume, high shipping cost, or high customer visibility.

Step 5: Calculate empty space ratio

For grouped, transport, and e-commerce packaging, calculate empty space using the outer packaging volume and the volume of the sales packaging or products inside.

Step 6: Review filler use

Identify paper cuttings, air cushions, bubble wrap, foam fillers, wood wool, polystyrene, and similar materials that count as empty space.

Step 7: Review unnecessary features

Check whether double walls, false bottoms, extra layers, oversized inserts, or decorative elements increase packaging volume without functional need.

Step 8: Test alternative designs

Assess smaller, lighter, or better-fitted packaging options while maintaining product protection, safety, hygiene, and legal requirements.

Step 9: Prepare technical documentation

Document the standards, methods, tests, and justifications used to prove that packaging has been minimized.

Step 10: Control changes

Update the documentation when packaging dimensions, suppliers, materials, fulfilment rules, product sizes, or shipping methods change.

Packaging Minimization Compliance Checklist

This checklist can support packaging redesign, supplier onboarding, e-commerce fulfilment reviews, logistics optimization, product launch approvals, and internal audits.

Common Mistakes Companies Should Avoid

Packaging minimization risks often happen because companies treat packaging size as a logistics or branding choice only.

Common mistakes

A strong packaging minimization program should combine product protection, right-sizing, evidence, and ongoing monitoring.

How ComplyMarket Supports Packaging Minimization Compliance

Packaging minimization and empty space compliance require accurate packaging data, supplier evidence, product mapping, technical documentation, and market-specific visibility. For companies with large product portfolios, multiple packaging suppliers, e-commerce channels, and international logistics providers, this can be difficult to manage manually.

ComplyMarket’s packaging compliance services describe packaging compliance as a controlled process covering regulations, documentation, supplier compliance, Digital Product Passport requirements, material composition, recycling obligations, registration, reporting, recordkeeping, and EPR obligations.

ComplyMarket can help companies prepare for packaging minimization and empty space requirements by supporting:

• Packaging inventory and packaging BoM management
• Product-to-packaging mapping
• Packaging material, weight, and dimension data collection
• Supplier declaration and packaging specification management
• Empty space and packaging right-sizing evidence tracking
• Technical documentation and Declaration of Conformity support
• Version control for packaging design, material, supplier, or fulfilment changes
• EPR data preparation by packaging material and weight
• Packaging artwork, label, and claim evidence control
• Country-specific packaging requirement tracking
• Audit-ready records for internal and external compliance reviews
• Digital Product Passport and circular economy data readiness

ComplyMarket capabilities include product compliance management software, sustainability reporting software, material compliance software, packaging compliance, Extended Producer Responsibility services, Digital Product Passport, and global market access.

For companies preparing for PPWR minimization and empty space rules, the challenge is not only calculating a ratio. The bigger challenge is building a repeatable process that connects packaging design, logistics, supplier data, fulfilment operations, technical evidence, and compliance ownership.

ComplyMarket helps companies move from scattered spreadsheets, supplier emails, packaging drawings, and logistics assumptions to a structured, traceable, and audit-ready packaging compliance process.

What Is Packaging Minimization Under PPWR?

Packaging minimization means designing packaging so it uses only the amount of material, weight, and volume necessary to protect, contain, handle, transport, store, and present the product.

The objective is not to remove packaging that is genuinely needed. Products still need protection, hygiene, safety, durability, shelf-life preservation, tamper resistance, legal information, and transport stability. The objective is to remove avoidable excess.

In practical terms, packaging minimization asks companies to prove that packaging is not larger, heavier, more complex, or more material-intensive than necessary.

Packaging minimization can affect:

The rule is simple: packaging must be designed to use the fewest materials by weight and volume needed to protect and contain the product, without compromising safety, hygiene, or other essential functions.

Why Packaging Minimization Matters for Businesses

Packaging minimization matters because excessive packaging creates waste, increases costs, harms consumer trust, and creates compliance risk.

Oversized packaging can lead to:

• Higher material costs
• Higher transport and storage costs
• Higher EPR fees where fees are weight-based
• More packaging waste
• More customer complaints
• Poor sustainability performance
• Inefficient warehouse operations
• More filler material
• More regulatory scrutiny
• More difficulty proving compliance

The PPWR is designed to reduce packaging waste and improve circularity. The European Commission states that packaging waste is growing faster than economies and population, and that packaging uses too many resources while being inefficient and expensive for businesses and consumers.

For companies, packaging minimization should therefore be viewed as a combined compliance, cost, and sustainability opportunity.

A packaging design that uses less material, fits the product better, reduces empty space, and maintains protection can improve compliance while also lowering operational costs.

Which Packaging Types Are Affected?

Packaging minimization applies broadly, but the empty space rule is especially important for grouped packaging, transport packaging, and e-commerce packaging.

Main packaging types to assess

The EUR-Lex summary explains that by 2030, economic operators must ensure that grouped, transport, and e-commerce packaging they fill does not exceed 50% empty space, while sales packaging must minimize empty space while maintaining functionality.

Sales packaging should leave minimal empty space based on product size and characteristics, while grouped, transport, and e-commerce packaging should leave minimal empty space based on the total volume of the grouped or shipped products plus their sales packaging.

The 50% Empty Space Rule Explained

One of the most important PPWR minimization rules is the maximum empty space ratio for grouped packaging, transport packaging, and e-commerce packaging.

When companies supply products in grouped packaging, transport packaging, or e-commerce packaging, they cannot have more than 50% empty space inside the packaging.

The EUR-Lex summary confirms that by 2030, grouped, transport, and e-commerce packaging filled by economic operators must not exceed 50% empty space.

What counts as empty space?

Empty space is not only air. Filling materials count as empty space. This includes paper cuttings, air cushions, bubble wrap, sponge fillers, foam fillers, wood wool, polystyrene, Styrofoam chips, and similar materials.

Empty space examples

The purpose of the rule is not to ban protective packaging. The purpose is to make sure that protection is achieved with the minimum reasonable packaging volume and material use.

How to Calculate Empty Space Ratio

A practical formula can be used to calculate the empty space ratio.

Empty space ratio formula

Formula

Empty space ratio = Empty space / Total volume of the outer packaging

Empty space = Total volume of the outer packaging minus volume of the sales packaging inside it

Fillers count as empty space when checking compliance.

Example calculation

In this example, the empty space ratio is 40%, which is below the 50% threshold.

High-risk example

In this example, the empty space ratio is 70%, which would exceed the 50% threshold for grouped, transport, and e-commerce packaging.

Companies should build empty space calculations into packaging development, warehouse carton selection, logistics specifications, and e-commerce fulfilment workflows.