PPWR empty space rules cap the empty-space ratio of grouped, transport and e-commerce packaging at a maximum of 50 percent from 1 January 2030, while the separate general minimisation duty under Article 10, applying from 12 August 2026, requires packaging designed to reduce weight and volume without unjustified marketing additions.
Two separate duties, one purpose
The PPWR draws a firm line between two duties. Article 10 sets a general minimisation obligation: packaging must be designed to minimise its weight and volume while maintaining functionality, and marketing or consumer acceptance cannot justify additional weight or volume. This duty applies from 12 August 2026 and, until 1 January 2030, is assessed against standard EN 13428:2004 through the criteria in Annex IV Part A. A separate rule, the empty-space ratio cap under Article 24, targets oversized outer packaging. Businesses mapping both duties across an export range can start with dedicated PPWR consulting support.
The empty-space ratio explained
The empty-space ratio is the ratio of empty volume to total packaging volume. Empty space is the volume filled by fillers rather than product, including:
- paper
- air cushions
- bubble wrap
- foam
From 1 January 2030 (or 36 months after the Commission adopts the calculation-methodology implementing act, whichever is later) that ratio is capped at a maximum of 50 percent for grouped, transport and e-commerce packaging. Sales packaging and reusable packaging follow different rules.
| Packaging type | Empty-space rule |
|---|---|
| Grouped, transport, e-commerce packaging | Empty-space ratio capped at 50 percent maximum from 1 January 2030 |
| Sales (primary consumer) packaging | Not subject to the 50 percent cap; Article 10 minimisation still applies |
| Reusable packaging in a reuse system | Exempt from the 50 percent empty-space cap |
What Gulf and Indian exporters prepare
The empty-space cap falls on the producer, which for a business-to-business sale to an EU importer is the importer itself. The practical task for a supplier is designing outer packaging that already sits within the limit and recording the calculation. The EU PPWR guide sets out the wider readiness steps. Across GreenSutra’s PPWR work, exporters most often conflate the general minimisation duty with the empty-space cap and treat both as a single deadline. Independent conformity or laboratory testing, where required, sits with accredited third parties, since GreenSutra acts as a consultant and does not verify or certify packaging.
Sources: Regulation (EU) 2025/40 · European Commission, Packaging waste · EUR-Lex summary