The 50% empty-space rule, explained
For grouped packaging, transport packaging and e-commerce packaging, the empty-space ratio must not exceed 50%. Empty space is the volume of the packaging minus the volume of the products inside (including protective fillers that aren't strictly necessary). In practice: if your parcels ship a lot of air, they will fail.
How to estimate it: empty-space ratio = 1 − (volume of goods + necessary protection) ÷ internal packaging volume. Aim below 0.50.
When it bites. Article 24(1) applies “by 1 January 2030 or 3 years from the entry into force of the implementing acts adopted pursuant to paragraph 2, whichever is the latest”. That act — the one fixing how the ratio is measured — is due from the Commission by 12 February 2028 under Article 24(2). Until it exists there is no official measurement method, and every month it slips pushes the 2030 date back with it. Plan against the principle, not the date.
Article 10 minimisation — what assessors look at
Packaging must be designed to the minimum adequate weight and volume, removing: double-walls, false bottoms, unnecessary layers, decorative or marketing-only additions that increase weight, and features that hinder recyclability.
The split matters when an assessor calls. What is already enforceable is Article 10(2): the Annex IV criteria, and the ban on features whose only purpose is to inflate perceived volume — and since the Commission guidance, marketing or consumer acceptability no longer justifies oversizing. What arrives in 2030 is Article 10(1), the reduction to minimum weight and volume. No harmonised PPWR standard has been published for it; until then the guidance keeps EN 13428:2004 as the designated yardstick for sales packaging. Article 10(4) carries the supporting technical documentation for both, through Annex VII.
Who must comply
Manufacturers, brand owners (fillers), importers and e-commerce sellers placing packaging on the EU market — including non-EU sellers shipping to EU consumers. There is no general size exemption.
What happens if you don't
Packaging that fails the Annex IV criteria, or that carries a double wall or false bottom to look bigger, can be refused market access today — Article 10(2) has applied since 12 August 2026. Failing the weight-and-volume reduction of Article 10(1) or the empty-space ratio of Article 24 does not bite yet, but both are design decisions with multi-year lead times: a pack redesigned in 2029 was specified in 2027. And excess weight already increases your EPR fees (contributions are weight-based and modulated), so minimisation is a cost lever well before it is a ban.
Assess your packaging
Run the free PPWR readiness assessment to see which of your SKUs are at risk on minimisation and empty space — no account needed, results the same day.