Article 24 of the
official PPWR text on EUR-Lex requires economic operators that fill grouped, transport, or ecommerce packaging to ensure a maximum empty-space ratio of 50% by January 1, 2030. The percentage is based on the difference between the total volume of the packaging and the volume of the products it contains.
The PPWR empty space rule is broader than a visual judgment about whether a box “looks half full.” The regulation treats space occupied by filling materials—such as paper cuttings, air cushions, bubble wrap, foam fillers, wood wool, and similar materials—as empty space for this calculation. Adding more cushioning does not automatically improve the ratio.
Product protection still matters. Packaging must remain functional and safe for the goods, and the Commission is developing calculation methodology for cases such as irregularly shaped products. Teams should avoid using a simple length × width × height formula as if it were the final legal method for every shipment before the relevant implementing rules are confirmed.
There are also specific exemptions and distinctions. For example, reusable packaging within a system for re-use is exempt from the Article 24(1) ratio. An economic operator that uses sales packaging as ecommerce packaging is also exempt from the Article 24(1) ratio requirement. Legal classification should be verified before an exemption is built into fulfillment logic.
For most stores, the useful action in 2026 is to collect representative packed-order data, find the combinations with excessive void, and test smaller approved packages. This creates a baseline for the 2030 obligation without pretending that a draft methodology is final.