PPWR Empty Space Ratio: The 50 % Rule for Grouped, Transport and E-commerce Packaging

Article 24(1) of the PPWR (Regulation (EU) 2025/40) caps the empty space ratio of grouped, transport and e-commerce packaging at 50 %, from 1 January 2030 or 3 years after the Commission's implementing acts on the calculation method enter into force, whichever is later. The ratio compares the space left in a filled outer package with its total volume, and space taken up by filling material counts as empty space, so paper cuttings or air cushions do not help a box pass.

Article 24 is titled "Obligation related to excessive packaging" and sits in Chapter V of the EU Packaging and Packaging Waste Regulation (PPWR), among the obligations of economic operators to reduce packaging and packaging waste. Sales packaging gets no number: by 12 February 2028 its empty space must only be reduced to the minimum necessary.

This page covers the formula, why 40 % is wrong, scope, the "whichever is later" date, the sales packaging rule, the exemptions and enforcement.

Compiled by the PackagingRegulation.org Editorial Team from the Regulation's text on EUR-Lex and the cited official sources; every value on this page is checked against EUR-Lex and Commission guidance, see our methodology and fact-checking.

The key facts of the PPWR empty space rule are summarised in the table below.

What Is the PPWR Empty Space Ratio?

The PPWR empty space ratio is the share of a grouped, transport or e-commerce package that is not taken up by the sales packaging inside it, expressed as a percentage of the package's total volume. Art. 24(3) PPWR builds it from two definitions. Empty space, sometimes called void space, is the total volume of the outer package minus the volume of the sales packaging it contains. The empty space ratio is that empty space divided by the total volume of the outer package.

The ratio is therefore set per package as filled, not per packaging design. Art. 24(1) places the duty on the economic operator that fills the outer package. The exact wording of both definitions is in Article 24 in the PPWR legal text.

How is the empty space ratio calculated?

The empty space ratio is calculated by subtracting the volume of the sales packaging inside from the total volume of the grouped, transport or e-commerce packaging, then dividing that empty space by the total volume (Art. 24(3) PPWR). The ratio passes at exactly 50 %, because Art. 24(1) states that the maximum empty space ratio is 50 %.

Empty space ratio (%) = (total volume of the package - volume of the sales packaging inside) / total volume of the package x 100

The worked example below applies the formula to one box with two different fillings.

The example is illustrative arithmetic under Art. 24(3): the binding calculation method is set by the Art. 24(2) implementing acts, which do not yet exist. The same arithmetic gives a rule of thumb, since an outer package complies only if its total volume is no more than twice the combined volume of the sales packaging inside. To test your own box sizes, use the empty space ratio calculator.

Does filling material count as empty space?

Yes: Art. 24(3) PPWR counts space filled with filling material as empty space, so paper cuttings, air cushions, bubble wraps, sponge fillers, foam fillers, wood wool and polystyrene or Styrofoam chips do not reduce the ratio. A box padded out with fillers keeps the same ratio as the same box left half empty, and only a smaller outer package or more sales packaging inside lowers it.

Is the PPWR Empty Space Limit 40 % or 50 %?

50 %: Art. 24(1) PPWR sets a maximum empty space ratio of 50 %, and the 40 % figure is the value of the 2022 Commission proposal, not the law. The 50 % value applies to grouped, transport and e-commerce packaging under Regulation (EU) 2025/40 as adopted.

The 40 % figure comes from Art. 21(1) of the Commission proposal COM(2022) 677 of 30 November 2022, which the adopted text replaced with 50 % in Art. 24(1). Texts that still give 40 %, or that date the ratio from 12 August 2026, describe the proposal or confuse two dates.

Which Packaging Must Meet the 50 % Empty Space Ratio?

The 50 % ratio covers three of the four packaging functions defined in Art. 3(1) PPWR: grouped packaging, transport packaging and e-commerce packaging, which is transport packaging used to deliver goods sold online or at a distance to the end user. One physical box can change category with its use, so a corrugated case is transport packaging in a warehouse and e-commerce packaging when it carries an online order to the end user. The full wording is in the PPWR definitions of grouped, transport and e-commerce packaging.

The table below sets out the four packaging types and whether the 50 % ratio applies to each.

Does the 50 % ratio apply to sales packaging?

No: sales packaging has no numeric empty space limit; Art. 24(4) PPWR only requires its empty space to be reduced to the minimum necessary by 12 February 2028.

When Does the 50 % Empty Space Ratio Apply?

Art. 24(1) PPWR applies from 1 January 2030 or 3 years after the entry into force of the Art. 24(2) implementing acts, whichever is the later, so the 50 % ratio cannot bind before 2030 and starts later if the Commission's method arrives late. The Regulation itself has been in force since 11 February 2025 and has applied generally since 12 August 2026, but neither date starts the ratio.

The implementing acts on the calculation method are due by 12 February 2028 under Art. 24(2), and none has been adopted as of 24 October 2026. The Commission states that the method will be adopted before 12 February 2028, in the Commission's PPWR FAQ (non-binding), section XI, and in Commission Notice C/2026/3084 (OJ C, 10.6.2026), section 11, which is also non-binding. Until the acts enter into force, the 3-year clock has not started, so 1 January 2030 is the earliest date and not a fixed one. The other dates are on the PPWR application dates page.

What will the Article 24(2) implementing act on the calculation method cover?

Art. 24(2) PPWR requires the Commission to set the calculation method by implementing act, taking account of six situations in which more space may be needed. The acts follow the Art. 65(2) examination procedure. The Commission adds, in the same FAQ section XI and Notice section 11, that the method will rest on a wide range of examples, including irregular shapes. The six situations are listed below.

• Products with an irregular shape.
• Packages holding more than one sales packaging or product.
• Liquids.
• Contents that are easily damaged.
• Small products that larger products in the same package could damage.
• The minimum space needed for shipment labels.

The status of this and the other PPWR implementing acts is tracked under PPWR implementing acts.

What Does Article 24(4) Require for Sales Packaging from 12 February 2028?

By 12 February 2028, the empty space of sales packaging must be reduced to the minimum necessary to ensure packaging functionality, including product protection (Art. 24(4) PPWR). The rule sets no percentage. Empty space in sales packaging means the difference between the total internal volume of the sales packaging and the volume of the packaged product. Filling material counts as empty space here too, with the same list of fillers as in Art. 24(3).

Commission Notice C/2026/3084, section 11, reads the Art. 24(4) assessment as based on the European standard EN 13428:2004 on packaging prevention by source reduction. The Notice names the manufacturer as the party obligated for the conformity assessment of sales packaging under Art. 24(4). That reading is guidance, not law, and the Regulation's text prevails where the two differ.

How are headspace and settling products treated?

Art. 24(4) PPWR assesses the empty space of products that settle or need headspace as the pack-fill level at the time of filling, and air between or within packed food or protective gases is not empty space. The fill level is measured when the product goes in, not after contents have settled in transport.

Which Packaging Is Exempt from the PPWR Empty Space Ratio?

Art. 24(5) PPWR exempts two cases from the 50 % ratio: economic operators that use sales packaging as e-commerce packaging, and economic operators that use reusable packaging within a system for re-use. The two cases are listed below.

• Sales packaging used as e-commerce packaging: the product ships in its own sales packaging, without a separate outer e-commerce package.
• Reusable packaging used within a system for re-use.

Both exempt cases still have to meet the Art. 10 minimisation requirements, which require weight and volume to be reduced to the minimum necessary from 1 January 2030. What qualifies as reusable packaging, and what a re-use system is, is explained under reusable packaging under the PPWR.

Is there an exemption for protected designs or trademarks?

No: Art. 24 PPWR has no exemption for design rights or trademarks, according to the Commission's PPWR FAQ (non-binding), section XI, unlike Art. 10(2)(a), which spares designs and shape trademarks protected before 11 February 2025 from the minimisation rule. A protected box shape can therefore escape Art. 10 under that condition but still has to respect the 50 % ratio when used as grouped, transport or e-commerce packaging.

Who Must Comply with the Empty Space Ratio, and How Is It Enforced?

The 50 % ratio binds the economic operator that fills the grouped, transport or e-commerce packaging (Art. 24(1) PPWR), and the Commission's PPWR FAQ (non-binding), section XI, adds that this may be the manufacturer or another economic operator making packaged products available. Economic operators under Art. 3(1)(12) PPWR are the manufacturer, the supplier, the importer, the distributor, the authorised representative, the final distributor and the fulfilment service provider. Filling within the ratio is one duty among many; the PPWR compliance plan lists every economic operator's obligations.

Harmonised standards and common specifications can give a presumption of conformity for Art. 24, as for Articles 5 to 12 and 26 (Art. 36(3) and Art. 37(1) PPWR).

Non-compliance with Art. 24 is formal non-compliance under Art. 62(1)(g) PPWR, a point that also covers Art. 25. If the formal non-compliance persists, the penalties under Art. 68 apply (Art. 62(3) PPWR). Member States must lay down penalty rules and notify them by 12 February 2027, administrative fines are mandatory for infringements of Art. 24 to 29, and the PPWR itself sets no fine amount. Details are under PPWR penalties and market surveillance.

How Does the Empty Space Ratio Fit with Packaging Minimisation and Other PPWR Requirements?

The empty space ratio is one of two Chapter V rules on excessive packaging and formats in the PPWR, while the design rules on weight, volume, recyclability and recycled content sit in Chapter II. Chapter V (Art. 24 to 33) groups the obligations of economic operators to reduce packaging and packaging waste, with Art. 24 next to the Annex V format restrictions of Art. 25. The other design and format rules are explained under PPWR requirements for packaging.

This page covers the EU rule under Regulation (EU) 2025/40 only.

How does Article 24 differ from Article 10 minimisation?

Art. 10 PPWR governs how packaging is designed, while Art. 24 governs how much space is left when it is filled. Under Art. 10(1), the manufacturer or importer ensures that packaging weight and volume are reduced to the minimum necessary, and Art. 10(2) bars features that only increase perceived volume, such as double walls, false bottoms and unnecessary layers, both by 1 January 2030. Art. 24 measures the package as filled and binds the operator that fills it.

Until 31 December 2029, the minimisation essential requirement of Directive 94/62/EC and the standard EN 13428:2004 remain the compliance reference (Art. 70(1)(b) PPWR). The Art. 10(3) standardisation request, due by 12 February 2027, is to cover maximum empty space, among other values, for the most common packaging formats. The design side is explained under PPWR packaging minimisation.

How does the reusable packaging exemption relate to the PPWR reuse targets?

Reusable packaging used within a re-use system is exempt from the 50 % ratio, and from 1 January 2030 the PPWR reuse targets require at least 40 % of transport packaging (Art. 29(1)) and 10 % of grouped packaging in the form of boxes, excluding cardboard boxes (Art. 29(5)), to be reusable. An operator that moves transport packaging into a re-use system to meet those targets also takes that packaging out of the 50 % ratio, while Art. 10 still applies. Which operators must meet the PPWR reuse targets, and the exemptions, are set out there.

Will the Commission review the 50 % ratio?

Yes: by 12 February 2032 the Commission must review the 50 % ratio and the Art. 24(5) exemptions, and assess empty space ratios for sales packaging, particularly for toys, cosmetics, do-it-yourself kits and electronic products (Art. 24(6) PPWR). Until then, sales packaging remains under the "minimum necessary" rule of Art. 24(4).