If you ship into the EU, a new packaging law is about to change how you box orders. The Packaging and Packaging Waste Regulation (PPWR) — Regulation (EU) 2025/40 — puts a hard numeric limit on how much empty air you’re allowed to ship inside a parcel, and it treats void fill very differently than most sellers assume.
This guide walks through exactly what the empty space rule says, which article of the regulation it comes from, when it actually bites, and the practical steps you can take now — audits, box-sizing, and fulfilment provider checks — so you’re not scrambling as the deadline approaches.
Quick Answer
Under Article 24 of the PPWR, businesses that fill grouped, transport, or e-commerce packaging must keep the empty space ratio below 50%. This applies by 1 January 2030, or three years after the Commission’s implementing act on the calculation methodology enters into force — whichever comes later. Empty space is calculated as the packaging’s total volume minus the volume of the products (and their sales packaging) inside it, and void fill materials like air pillows, bubble wrap, and packing paper still count as empty space, not as product volume. Adding more filler doesn’t help you comply; only using a smaller, better-matched box does.
What the PPWR Actually Requires
The PPWR is a regulation, not a directive, meaning it applies directly and uniformly across all 27 EU member states rather than needing separate national laws. It entered into force in February 2025 and generally applies from 12 August 2026, when a broader packaging minimisation duty (Article 10) kicks in: businesses must be able to show that packaging weight and volume have been reduced to what’s genuinely necessary for protecting and presenting the product.
The specific numeric empty-space cap lives in Article 24, and it targets three categories: grouped packaging, transport packaging, and e-commerce packaging. The formula is straightforward — empty space equals the total internal volume of the shipping package minus the volume of the sales packaging it contains, and the empty space ratio is that empty space divided by the total volume. The regulation explicitly lists filler materials that count toward empty space: paper cuttings, air cushions, bubble wrap, sponge and foam fillers, wood wool, and polystyrene or Styrofoam chips. None of these are treated as ‘product’ for the purposes of the calculation.
Timing is where the regulation gets a bit conditional. Article 24 states the 50% cap applies ‘by 1 January 2030 or three years from the entry into force of the implementing acts… whichever is the latest.’ The Commission is separately required to adopt that implementing act — spelling out the precise calculation methodology — by 12 February 2028. If the Commission hits that deadline on time, three years later would fall before 2030, so 1 January 2030 would govern. But if the implementing act is delayed, the compliance deadline slides out with it. Practically: plan for 2030 as your target, but watch for confirmation of the implementing act’s adoption date, since that’s what ultimately fixes the real deadline.
How to Cut Empty Space Before the Deadline
Start with a packaging audit: pull a sample of recent orders and compare each shipped box’s internal dimensions against the actual product footprint. Most sellers find a handful of box sizes account for the bulk of their empty-space problem — usually because one or two ‘catch-all’ box sizes get used for orders that don’t need them.
Move toward right-sizing rather than better filling. That means stocking a wider range of carton sizes matched to your best-selling SKUs and SKU combinations, or investing in on-demand box-making equipment that cuts corrugate to the exact dimensions of each order at pack time. Because filler material doesn’t count toward your product volume under Article 24, the only way to actually lower your ratio is to shrink the box, not pad it differently.
If you use a third-party fulfilment provider (including marketplace fulfilment programs), check their packaging practices now. The PPWR places compliance duties on fulfilment service providers too, and they’re expected to verify that the packaging used for goods they store, pack, and dispatch meets the regulation’s requirements — sellers can’t outsource their way out of the empty-space obligation. Ask your 3PL what box-sizing technology or cartonization software they’re rolling out ahead of the deadline, and get it in writing.
Multi-item orders deserve special attention. Each shipped parcel is assessed on its own volume versus its own contents, so an order that ships two small items in one oversized box will fail the ratio even if each item individually would have fit a small mailer. Cartonization logic in your warehouse management or order management system — picking the smallest viable box per order — is one of the more direct ways to bring your fleet of parcel sizes into line.
Tips / Common Mistakes
Don’t assume switching to paper-based or ‘sustainable’ void fill solves the problem — the regulation counts filler by volume, not by material, so eco-friendly air pillows still count as empty space just like plastic ones do.
Don’t treat 1 January 2030 as a fixed, guaranteed date. Because the deadline is tied to whichever is later between that date and three years after the implementing act on calculation methodology takes effect, a delayed implementing act could push the real compliance date beyond 2030. Watch for the Commission’s guidance and the implementing act’s adoption date.
Don’t overlook B2B and transport packaging in your audit — Article 24 covers grouped and transport packaging alongside e-commerce packaging, so pallet and case-level shipments are in scope too, not just direct-to-consumer parcels.
Don’t forget decorative or gift packaging. There’s no general exemption for presentation-driven packaging choices, so oversized gift boxes or inserts should go through the same right-sizing review as standard shipping cartons.
Explore more: More EU packaging compliance guides.
EU PPWR empty space rule FAQs
When does the PPWR empty space rule take effect?
The 50% empty space ratio cap for grouped, transport, and e-commerce packaging, set out in Article 24 of the PPWR (Regulation (EU) 2025/40), applies by 1 January 2030 or three years after the Commission’s implementing act on the calculation methodology enters into force, whichever is later. A broader packaging minimisation duty under Article 10 applies earlier, from 12 August 2026, when most of the regulation starts applying across the EU.
Does using void fill like bubble wrap or paper help me comply?
No. Under Article 24, filler materials — including air cushions, bubble wrap, packing paper, foam, and polystyrene chips — are explicitly counted as empty space, not as product volume. The only way to reduce your empty space ratio is to reduce the size of the packaging relative to the product, not to change what you fill the gap with.
What is the PPWR?
The Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40, is the EU’s new packaging law. It entered into force in February 2025, applies directly in all EU member states without needing national transposition, and generally takes effect from 12 August 2026, replacing the older Packaging and Packaging Waste Directive.
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Photo: brownpau / CC BY 2.0, via Wikimedia Commons.