The Packaging and Packaging Waste Regulation (EU) 2025/40 caps empty space in e-commerce, transport and grouped packaging at a maximum 50% ratio from 1 January 2030. The minimisation principle behind it applies from 12 August 2026, meaning enforcement of right-sizing starts well before the hard cap. For online sellers shipping into the EU, the rule rewrites carton selection, dunnage strategy, and warehouse pick-pack workflows. This guide breaks down how the empty-space ratio is measured, what counts as void fill, and how to bring catalogues into compliance.
What is the PPWR Empty Space Rule?
Under Article 24 of Regulation (EU) 2025/40, economic operators filling grouped, transport, or e-commerce packaging must keep the empty space ratio below 50% from 1 January 2030. The empty space is the difference between the inner volume of the packaging and the volume of the products it contains. Void-fill materials (paper, air pillows, bubble wrap, foam, peanuts) count as empty space, not as product volume. The general minimisation duty applies from 12 August 2026.
How the Empty Space Ratio is Calculated
The calculation is volumetric, not weight-based. The formula:
| Variable | Definition |
|---|---|
| V_pack | Inner volume of the packaging (length × width × height of the inside cavity) |
| V_prod | Sum of the volumes of all products contained, calculated from their bounding boxes |
| Empty space ratio | (V_pack − V_prod) / V_pack, expressed as a percentage |
| Compliance threshold (2030) | Ratio ≤ 50% |
If a 30 × 20 × 15 cm box (9,000 cm³ inner volume) contains products totalling 3,600 cm³ of bounding-box volume, the empty space ratio is 60%, which fails the 2030 threshold. The fix is either a smaller box or product consolidation.
What the Rule Does Not Apply To
Empty space inside the product itself does not count. A bottle of perfume in a custom-fit gift box uses the product's outer dimensions, not the volume of liquid inside. Primary packaging design choices (display value, brand-required cushioning for fragile goods) are also excluded from the ratio calculation in some interpretations, though Commission guidance is still firming up on this. Reusable transport packaging in B2B settings has its own reuse targets and a slightly different compliance path.
The 12 August 2026 Trigger: Minimisation Principle
The hard 50% cap is a 2030 obligation, but Article 10 minimisation duty applies from August 2026. This means operators must demonstrate that their packaging volume and weight are reduced to the minimum needed for functionality, safety, hygiene and consumer acceptance. Market surveillance authorities will use the 2030 ratio as a forward-looking benchmark when assessing minimisation compliance in 2026 and 2027. A catalogue with 70% empty space across e-commerce shipments is unlikely to satisfy the minimisation test even before the hard cap bites.
Implementation Steps for Online Sellers
Bringing an e-commerce operation into compliance takes a structured workflow. The five-step path most fulfilment teams follow:
- Audit current carton mix. Pull 30 to 90 days of shipping data, calculate the empty-space ratio per order, and bucket orders by failure margin. Single-SKU orders fail more often than multi-SKU baskets.
- Expand the carton portfolio. Most operators ship from 5 to 10 carton sizes. PPWR-compliant fulfilment typically needs 15 to 25 sizes, or on-demand carton creation systems that cut to product dimensions.
- Update the WMS carton selection algorithm. Move from weight-bucket logic to dimensional packing, ideally with a 3D bin-packing solver running at the time of pack.
- Reduce dunnage. Once cartons are right-sized, the need for void fill drops. Paper, air pillows and bubble wrap volumes can fall 60 to 80% in well-tuned operations.
- Document and version the policy. Empty-space compliance lives in the Annex VII technical file backing the Declaration of Conformity. Operators need to show their methodology, not just sampled compliant shipments.
On-Demand vs. Pre-Cut Cartons
The carton question splits into two camps. Pre-cut cartons in many sizes are cheaper per unit but require warehouse space, SKU complexity, and accurate WMS selection. On-demand systems (Packsize, CMC Pack, Sparck, Ranpak Cut'it) cut and fold each carton to the order at pack time, hitting near-zero empty space but with a higher capex (EUR 150,000 to EUR 500,000 per line) and consumable cost. The break-even depends on throughput, SKU dimensional variance, and labour costs.
| Approach | Capex | Empty space achievable | Best fit |
|---|---|---|---|
| Expanded pre-cut carton portfolio (20+ sizes) | Low | 30 to 45% | Small to mid throughput, stable SKU mix |
| On-demand carton cutting | High | 5 to 15% | High throughput, high SKU variance |
| Polybag / mailer for non-fragile items | Low | Near zero | Apparel, soft goods, small electronics |
| Hybrid: pre-cut for fast movers, on-demand for tail | Medium | 15 to 25% | Mid to large operations |
Multi-Item Orders and the Consolidation Trap
Multi-item orders look easier on paper because adding products fills the box. The trap is over-boxing: shipping a single multi-item order in two cartons when one tighter carton would do. PPWR enforcement reads at the shipment level, so a multi-package order multiplies compliance risk. WMS rules need to favour single-carton consolidation where dimensions allow, even if it means a non-standard carton or longer pack time.
Marketplaces and Fulfilment Service Providers
Article 21 of PPWR makes fulfilment service providers (Amazon FBA, Cdiscount Fulfilment, Zalando ZFS and equivalents) responsible for verifying that products they ship into the EU come with compliant packaging. Sellers using these services do not escape the empty-space rule by outsourcing logistics. Marketplaces are signalling compliance-driven listing penalties, restricted carton selection, and seller fees for non-compliant shipments. Some have already restricted oversized boxes for small items under their own ESG programmes.
Labelling Implications from 2028
From 12 August 2028, harmonised labelling applies to all packaging including e-commerce mailers and cartons. Material identification pictograms, sorting instructions and the data carrier (QR code) need to appear consistently across the EU. For e-commerce operators that print custom branded cartons, this is a design and procurement project that runs in parallel with the empty-space work. Sellers extending their DPP architecture to packaging can host material composition and sorting data behind the QR code, satisfying both the label and the digital information duty in one go.
Frequently Asked Questions
Does the 50% empty space rule apply to gift packaging?
Decorative or display packaging where the design itself serves a marketing function may benefit from a narrow exemption, but the Commission's guidance treats this strictly. Default assumption: gift cartons count toward the empty-space ratio. Brands relying on the exemption need to document the marketing rationale in the technical file.
What is the penalty for shipping non-compliant packaging?
Penalty regimes are set by Member States. Expected enforcement includes administrative fines proportional to shipment volume, mandatory withdrawal of non-compliant practices, and in repeat cases, marketing restrictions. Marketplaces are layering their own commercial penalties on top.
How is the inner volume of the packaging measured?
Inner length × inner width × inner height in the assembled, closed state. For non-rectangular packaging (jiffy bags, polybags), the closed-state bounding box is used. The measurement excludes the thickness of the packaging walls.
Are sustainable void fillers (paper, mushroom foam) treated differently?
No. PPWR measures volume, not material. Paper void fill and mushroom foam count toward the empty-space ratio exactly the same as plastic air pillows. Switching to a more sustainable filler material does not solve the right-sizing problem.