Have you ever received a delivery where the product was lost in a sea of crumpled paper, with half the shipping carton gaping empty? This kind of situation — on the surface a mundane logistical routine — has now come under the scrutiny of European legislation. The PPWR regulation introduces concrete and directly enforceable rules on how much “air” your packaging may contain. And the deadlines are closing in fast.
One Photo Worth a Thousand Words
Recently, an acquaintance sent us a photo that speaks for itself. He had ordered a bamboo over-door towel holder — a product packaged in a fairly slim product box. He placed it next to the shipping carton in which the order had arrived. The result needed no commentary. The rest of the carton was filled with heaps of crumpled paper.
To be fair to the retailer, one thing deserves credit: all the tertiary packaging was paper-based. A cardboard carton sealed with paper tape, paper void fill inside. Not a trace of plastic bubble wrap. Full marks for material choice.
But the choice of carton size? That’s a different matter. From the retailer’s perspective it makes logistical sense — keeping a small number of standard box sizes simplifies warehousing and fulfilment processes. The problem is that this is precisely the kind of practice that PPWR now sets out to regulate.
What is PPWR and who does it affect?
Regulation (EU) 2025/40 — known as the PPWR (Packaging and Packaging Waste Regulation) — is an EU regulation that, from August 2026, establishes binding rules for packaging across the entire value chain: from manufacturers and importers through to e-commerce operators and distributors. A detailed breakdown of what PPWR entails and who it applies to can be found in our glossary. In this article, we focus on one of its most practical provisions: Article 24, on empty space in packaging.
What does article 24 actually say?
Article 24, which addresses excessive packaging, introduces two distinct obligations depending on the type of packaging involved.
Primary packaging: only the minimum necessary
For primary packaging — the sales packaging a customer holds in their hands or sees on a shop shelf — the proportion of empty space must be kept to the absolute minimum required for the packaging to function and protect the product. The regulation does not set a specific percentage limit; it simply requires the smallest practicable volume of unused space.
We would argue that the regulation can afford to be this broad when it comes to primary packaging, because in practice it is rare for product manufacturers to over-package. The logic is straightforward — manufacturers need to fit as many units as possible into their warehouse space, and excessive packaging would eat into that space while needlessly inflating the cost of the finished product.
This obligation applies to all businesses that fill sales packaging. Probable deadline: 12 February 2028.
Tertiary and grouped packaging: 50% maximum
For tertiary packaging (shipping cartons), grouped packaging (secondary packaging), and e-commerce packaging, a specific numerical limit applies: the proportion of empty space must not exceed 50% of the total packaging volume.
One critical detail: void fill materials also count as empty space. Air pillows, bubble wrap, paper fill — all of these are considered “unused volume” under the regulation. Filling a carton with paper and claiming it is full simply will not wash. The only exception applies to food products — air between food items, or protective gases in food packaging, are not counted as empty space.
This obligation takes effect from 1 January 2030, or 36 months after the publication of the relevant implementing act by the European Commission.
Why do businesses still use oversized packaging?
The reason is straightforward: convenience and logistical savings. Maintaining a warehouse stocked with dozens of different box sizes is costly and complicated. It is far simpler to have five standard sizes and always reach for the next size up — whatever space remains gets filled with paper or air pillows.
But this approach carries a hidden cost. A larger box means higher material consumption, a heavier shipment, and greater volume — all of which feed directly into shipping costs. A study by the Bundesvereinigung Logistik (German Logistics Association) measured the average proportion of empty space in e-commerce parcels at 30–40%, depending on product category. These are direct losses on both materials and logistics — costs that the customer ultimately pays, even if they never realise it.
PPWR is driving change here not merely through legal obligation. Proper optimisation of transport packaging is a genuine commercial opportunity — and it is rare for regulation and business logic to align quite so neatly.
How to meet the requirements in practice
The good news: meeting PPWR requirements does not demand a revolution. It does, however, require a systematic and proactive approach.
Start with an audit
The first step is to establish what proportion of empty space your packaging actually contains. For most e-commerce businesses, the result will be surprising — and sometimes uncomfortable. Only with concrete data can you meaningfully plan changes, prioritise actions, and build a realistic timeline.
Design the Packaging Around the Product, Not Vice Versa
The key is to reverse the established logic: the packaging adapts to the product, not the other way round. Modern packaging design works from precise 3D data of the product, making it possible to design a box or insert so that empty space is genuinely minimised. The result is packaging that protects, avoids unnecessary material and shipping costs, and passes the legislative test.
Void fill that really protects
If a product does require void fill — to protect against impacts or vibrations — choose materials that provide protection with the smallest possible volume. Moulded inserts in foam, textile, or plastic are significantly more effective than loose paper fill, which simply occupies space without providing proportionate protection. The packaging then not only meets regulatory requirements but better fulfils its primary purpose: protecting the product.
February 2028: closer than it looks
The date of 12 February 2028 may seem a long way off. In reality, it is less than two years away. And overhauling a packaging process — selecting new materials, redesigning box dimensions, setting new standards in the packing hall or warehouse — always takes longer in practice than it appears on paper.
Companies that begin optimising their packaging sooner will not only meet the regulatory requirements, but also gain a competitive advantage through lower logistics costs. In this sense, PPWR is not merely a regulatory burden — it is an impetus towards an approach that pays for itself commercially.
If you are not sure where to begin, or would like to assess how your existing tertiary and primary packaging measures up against the empty space requirements, we would be happy to help. Do not hesitate to contact us.
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