From 1 January 2030, Regulation (EU) 2025/40 on packaging sets a maximum empty space ratio of 50% for grouped packaging, transport packaging and e-commerce packaging: the volume inside a box that is filled by neither the product nor the sales packaging protecting it cannot exceed half the box's internal volume. It is the numerical form of the general packaging minimization duty in Article 10, which already requires packaging weight and volume to be reduced to the minimum necessary to fulfill its function.
Two distinct obligations worth telling apart
The PPWR (Regulation (EU) 2025/40, applicable since 12 August 2026) regulates packaging minimization on two levels that kick in at different times:
- General minimization (Article 10). A design principle, enforceable from the regulation's general application date: packaging weight and volume must be reduced to the minimum necessary to guarantee its function, including protecting the product. It sets no single percentage; it relies on performance criteria and on harmonized standards the Commission has tasked standardization bodies with developing for the most common packaging formats.
- Maximum empty space ratio (Article 24). A quantitative obligation that applies later, from 1 January 2030, specifically for grouped, transport and e-commerce packaging: empty space cannot exceed 50% of the packaging's volume.
The distinction matters because Article 10 already shapes the design of any new packaging from 2026 onward, while the numerical 50% cap, for those three packaging types, is only enforceable starting in 2030.
How the empty space ratio is calculated
The empty space ratio is calculated as the difference between the packaging's total volume and the volume of the sales packaging (or packagings) it contains, divided by the packaging's total volume:
- Empty space ratio = (total box volume − volume of the packaged product) ÷ total box volume × 100.
For example, an e-commerce box with an internal volume of 20 liters holding a packaged product of 12 liters has 8 liters of empty space, a 40% ratio: it would meet the 50% limit. If the same product shipped in a 30-liter box, empty space would rise to 18 liters, a 60% ratio, above the limit.
The regulation counts as empty space any volume filled by materials such as paper cuttings, air cushions, bubble wrap, sponge, foam or wood wool: padding the box with these materials does not lower the ratio, because they still count as space not occupied by the product. Excluded from the calculation are space needed for protective gases in food packaging, the air gap that protects the product from damage in transit, space the product needs to settle or expand, and space reserved for labels or other elements required by other legislation.
What counts as filler and what doesn't
| Counts as empty space | Does not count as empty space |
|---|---|
| Paper or cardboard cuttings used as padding | Protective atmosphere in food packaging |
| Air cushions, bubble wrap | Air gap protecting the product from impact |
| Foam, sponge or polystyrene filler | Space needed for the product to settle during transport |
| Wood wool | Space reserved for safety or legal labeling requirements |
The underlying principle is simple to explain to a logistics team: you cannot meet the limit by stuffing an oversized box with filler, because filler counts as empty space just like air does. The only way to bring the ratio down is to shrink the box to fit the product, which in practice usually means keeping several box sizes on hand instead of a single one for every order.
What documentation to keep
Article 10 requires the manufacturer or whoever places the packaging on the market to be able to demonstrate, with technical documentation, that the packaging meets the minimization performance criteria: minimum weight and volume necessary for functionality, including product protection, the manufacturing process, logistics, presentation, and accessibility and information requirements. For the Article 24 empty space ratio, it is worth keeping, per packaging format, the calculation of total volume, the volume of the packaged product, and the resulting ratio, along with the date that format was introduced, so compliance can be shown format by format rather than only in aggregate. The Commission must adopt implementing acts setting out the detailed calculation methodology by 12 February 2028, so it is worth reviewing the applied calculation criterion once those acts are published. Keeping this evidence organized by format, rather than buried in individual packing-line specifications, is what makes it possible to answer a spot check quickly instead of reconstructing the calculation from scratch under time pressure.
How it fits with Spain's packaging declaration rules
In Spain, the obligation to declare packaging placed on the market and to contribute to a collective extended producer responsibility scheme is still governed by RD 1055/2022, which regulates packaging and packaging waste at national level. The PPWR does not replace this declaration and registration duty: it adds design requirements (minimization, recyclability, recycled content) that apply before the packaging reaches the market, while RD 1055/2022 governs what happens to that packaging once it is in circulation and at end of life. A company that redesigns its packaging to meet the Article 24 empty space ratio will also need to update the data it declares to the producer registry under the extended responsibility scheme, a process we cover in the guide to packaging declaration and producer registration.
Why it pays to get ahead of 2030
Even though the Article 24 limit is not enforceable until 2030, redesigning transport and e-commerce packaging ahead of that date has a payoff that does not depend on the rule at all: a box sized to fit the product weighs less, takes up less volume in the truck or delivery van, and cuts freight cost and the number of shipments needed to move the same volume of goods. It is the same principle behind ecodesign for packaging: minimizing transport packaging does not only cut waste, it also cuts the logistics share of a product's carbon footprint, and it usually pays for itself in freight savings well before the regulatory limit even takes effect. For anyone already calculating the carbon footprint of their packaging, resizing transport packaging is one of the most direct and easiest reduction levers to quantify.
It is also worth distinguishing this obligation from the restrictions on certain superfluous packaging formats and single-use plastics the regulation already imposes since its general application date of 12 August 2026, covered in more detail in our guide on what the PPWR already requires and in the summary of Regulation (EU) 2025/40: the empty space ratio is an additional, later obligation, not the entry point into the regulation. Treating the two on the same timeline, with the same evidence file, avoids the common mistake of scrambling to fix void space only once 2030 is already close, after years of otherwise being compliant with the rest of the regulation.
Frequently asked questions
Is the 50% empty space limit already mandatory?
Not yet. It is enforceable from 1 January 2030 for grouped, transport and e-commerce packaging. The general minimization duty in Article 10 has applied since 12 August 2026.
Does the 50% limit also apply to consumer sales packaging?
No. Article 24's maximum empty space ratio targets grouped, transport and e-commerce packaging, not primary sales packaging, which is governed by the general minimization principle in Article 10 without a fixed percentage.
Can I meet the limit by adding more filler to a large box?
No. Filler (paper, bubble wrap, foam, wood wool) counts as empty space in the calculation, so it does not lower the ratio. The only way to comply is to size the packaging to fit the product.
What if different orders use different box sizes?
The calculation is done per packaging format, so it is worth documenting the ratio for each box size used, not a single average across all shipments.
Do I still need to declare packaging under RD 1055/2022 if I comply with the PPWR?
Yes. These are two distinct, complementary obligations: the PPWR regulates packaging design, and RD 1055/2022 regulates its declaration and management as waste in Spain.
Who has to prove compliance, the brand owner or the packaging manufacturer?
The obligation under Article 10 falls on the manufacturer or whoever places the packaging on the market, which in most supply chains means the brand owner selling the packaged product needs to hold or be able to request the technical documentation from its packaging supplier, not assume it exists somewhere upstream.
Adapting packaging design to these limits, with the documentation trail the regulation requires, connects directly with our product carbon footprint solution.
