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.

The attached packaging compliance workshop identifies packaging minimization as a dedicated PPWR compliance area. It explains that packaging must be designed to use the fewest materials, weight, and volume needed to protect and contain the product; that unnecessary features such as double walls, false bottoms, or extra layers should not be used to make products look bigger; that grouped, transport, and e-commerce packaging must respect empty space limits; and that 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.

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:

Area	Practical Impact
Product design	Packaging dimensions may need to be reviewed during development
Packaging engineering	Material thickness, structure, strength, and protection must be justified
Procurement	Suppliers may need to provide lighter or better-sized packaging options
Logistics	Shipping cartons and fillers may need to be optimized
E-commerce	Oversized parcels and unnecessary void fill may create compliance risk
Retail	Packaging should not artificially increase product size
Sustainability	Reduced material use supports waste prevention and circular economy goals
Compliance	Technical documentation must prove the packaging has been minimized
Finance	Smaller and lighter packaging can reduce material, shipping, and EPR costs

The workshop defines the rule simply: 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

Packaging Type	Practical Meaning	Minimization Relevance
Sales packaging	Packaging presented to the end user with the product	Must minimize empty space while maintaining functionality
Grouped packaging	Packaging used to group products together	Must avoid excessive empty space
Transport packaging	Packaging used to transport products through the supply chain	Must avoid excessive empty space and unnecessary fillers
E-commerce packaging	Packaging used to ship products ordered online	High-risk area for oversized boxes and void fill
Service packaging	Packaging filled at the point of sale or used for service delivery	Should be assessed for necessity and material efficiency
Reusable packaging	Packaging designed for multiple trips or rotations	Minimization should consider reuse function and durability

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.

The workshop also confirms that 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.

The workshop states that 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. The workshop explains that 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

Packaging Situation	Compliance Concern
Small product shipped in a large box	Empty space may exceed the allowed ratio
Large amount of paper filler used to stabilize product	Filler counts as empty space
Air pillows used because carton is oversized	Air pillows count as empty space
Multiple sales packages placed in a large transport carton	Outer packaging must be assessed against product volume
Product shipped in right-sized mailer	Lower empty space risk
Sales packaging used directly for shipping	50% outer packaging rule may not apply, but minimization still applies

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

The workshop provides a practical formula for calculating empty space ratio.

Empty space ratio formula

Element	Meaning
Total volume of outer packaging	The volume of grouped, transport, or e-commerce packaging
Volume of the sales packaging inside it	The volume occupied by the packaged product or sales packaging
Empty space	Total outer packaging volume minus volume of the sales packaging inside
Empty space ratio	Empty space divided by total volume of the outer packaging

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

The workshop also emphasizes that fillers count as empty space when checking compliance.

Example calculation

Item	Value
Total volume of e-commerce box	10 liters
Volume of sales packaging inside	6 liters
Empty space	4 liters
Empty space ratio	40%

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

High-risk example

Item	Value
Total volume of e-commerce box	10 liters
Volume of sales packaging inside	3 liters
Empty space	7 liters
Empty space ratio	70%

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.

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.

The workshop explains that 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

Scenario	What to Assess
Product sold in retail box	Sales packaging must be minimized
Retail box placed inside shipping box	Shipping box must respect empty space rules
Sales packaging used directly for shipping	50% outer box rule may not apply, but sales packaging must not be excessive
Product shipped in mailer instead of box	Mailer still needs minimization assessment
Multiple sales units shipped together	Grouped or transport packaging must be assessed

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.

Unnecessary Packaging Features Are Restricted

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

The workshop identifies the following as 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

Feature	Why It May Be a Problem
False bottom in cosmetics box	Makes the product appear larger than it is
Oversized luxury carton	May increase volume without functional need
Decorative inner platform	May be unnecessary if it only creates visual size
Double-wall structure	May be excessive if not needed for protection
Thick molded insert	May increase material use without clear function
Large air gap around small product	May create avoidable empty space
Extra outer sleeve	May be unnecessary if it only adds presentation value

The workshop notes that 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.

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.

The workshop specifically lists filling materials such as:

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

Packaging Practice	Risk
Using one standard box size for many small products	Creates high empty space and filler use
Relying on air cushions to stabilize products	Fillers count as empty space
Using oversized cartons to simplify warehouse operations	May create compliance risk
Overusing protective filler without testing	May be difficult to justify
Not documenting product fragility	Protection need may not be defensible
Failing to update box library	Fulfilment system may keep selecting oversized packaging

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 workshop explains that the objective is to avoid wasted material without compromising safety, hygiene, or other essential functions.

Legitimate reasons for additional packaging

Reason	Example
Product fragility	Glass, electronics, medical devices, precision parts
Hygiene	Food, cosmetics, healthcare products
Safety	Hazardous goods, sharp products, heavy items
Legal information	Required labelling, warnings, instructions
Product stability	Liquids, powders, temperature-sensitive products
Theft prevention	Certain retail formats
Tamper evidence	Consumer safety and quality assurance
Transport conditions	Long-distance shipping, pallet stability, vibration risk
Reusable packaging function	Extra durability for multiple trips

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.

The workshop states that 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

Documentation Item	What It Should Show
Packaging description	What the packaging is and how it is used
Product dimensions	The size and shape of the product or sales packaging
Packaging dimensions	Outer and inner dimensions of packaging
Packaging weight	Material weight by component where possible
Material specification	Material type, thickness, grade, structure
Empty space calculation	Ratio for grouped, transport, and e-commerce packaging
Filler assessment	Type and volume of filler materials used
Protection justification	Why packaging is needed for safety, hygiene, or transport
Performance testing	Drop tests, compression tests, vibration tests, shelf-life studies, or other relevant tests
Design alternatives reviewed	Evidence that lighter or smaller options were considered
Legal justification	Where specific packaging features are legally required
Version control	Updates when dimensions, materials, suppliers, or fulfilment rules change

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.

The workshop states that 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

Question	Why It Matters
How many trips or rotations is the packaging designed for?	Durability may justify additional material
Is the packaging reconditionable?	Reconditioning may require stronger design
Does it protect products through repeated use?	Protection function may differ from single-use packaging
Is it recyclable at end of life?	Reusable packaging still needs end-of-life planning
Is the design heavier than necessary?	Reuse does not justify avoidable excess
Is a reuse system in place?	Reuse claim should be operationally supported

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

Risk Factor	Explanation
Large product variety	One fulfilment site may pack thousands of product sizes
Standardized box libraries	Limited box sizes can lead to oversized packaging
Third-party logistics	Sellers may not control final packing decisions
Protective fillers	Fillers can be overused when boxes are too large
Returns	Packaging must handle both delivery and possible return
Customer visibility	Excessive packaging can damage brand trust
Marketplace pressure	Sellers may need to prove packaging compliance
Cross-border sales	EU-wide obligations may affect non-EU sellers

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

Packaging Situation	Risk
Using one carton size for multiple product combinations	Empty space may be excessive
Grouping products with large voids between units	Inefficient packaging volume
Overusing pallet boxes	Increased transport volume and material use
Using fillers instead of right-sized dividers	Fillers count as empty space
Not tracking product-to-packaging ratio	Compliance evidence may be weak
Ignoring packaging used by distributors	Responsibility may be unclear
Not documenting logistics needs	Protective packaging may be difficult to justify

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

Cost Area	Possible Impact
Packaging material cost	Less material can reduce purchasing costs
Shipping cost	Smaller packaging can reduce dimensional weight and freight cost
Storage cost	Smaller packaging can reduce warehouse space
EPR fees	Lower packaging weight may reduce fee exposure
Waste handling cost	Less packaging can reduce downstream waste burden
Returns cost	Right-sized packaging can improve protection and reduce damage
Customer service cost	Less excessive packaging can reduce complaints

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

Claim	Evidence Needed
“Reduced packaging”	Baseline comparison and reduction data
“30% less material”	Weight comparison and calculation method
“Right-sized packaging”	Product-to-packaging ratio and empty space calculation
“Less plastic”	Material composition and before/after evidence
“Eco-friendly packaging”	Specific environmental basis, not vague wording
“Minimal packaging”	Technical assessment and justification
“No unnecessary packaging”	Design review and documentation
“Lower transport impact”	Shipping volume or lifecycle data where claimed

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

Question	Status
Have all packaging formats been identified?	To be checked
Is each packaging item mapped to products and markets?	To be checked
Are dimensions and weights recorded?	To be checked
Is sales packaging minimized while maintaining function?	To be checked
Are grouped packaging empty space ratios calculated?	To be checked
Are transport packaging empty space ratios calculated?	To be checked
Are e-commerce packaging empty space ratios calculated?	To be checked
Are fillers counted as empty space?	To be checked
Are double walls, false bottoms, or unnecessary layers removed?	To be checked
Are product protection requirements documented?	To be checked
Are performance tests available where needed?	To be checked
Are alternative packaging designs assessed?	To be checked
Is reusable packaging assessed based on multiple rotations?	To be checked
Is technical documentation complete?	To be checked
Is there version control for packaging changes?	To be checked

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

Mistake	Why It Creates Risk
Using oversized standard boxes	Empty space may exceed the 50% threshold
Treating fillers as protection only	Fillers count as empty space
Ignoring e-commerce packaging	E-commerce packaging is directly affected
Keeping decorative volume without justification	False bottoms or extra layers may be restricted
Not documenting fragility	Extra protection may be difficult to justify
Not testing smaller packaging options	Technical file may not prove minimization
Forgetting grouped and transport packaging	B2B packaging can also be in scope
Treating reusable packaging as automatically compliant	Reuse function must be documented
Managing data only in spreadsheets	Version control and evidence may be weak
Not involving logistics providers	Third-party fulfilment may create compliance risk

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

The attached workshop also identifies ComplyMarket capabilities across 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.