PPWR Empty Space Rules for E-commerce Packaging: 50% Limit, Right-Sizing and Buyer Checklist
PPWR empty space rules are often reduced to a simple “50% rule,” but Article 24 of Regulation (EU) 2025/40 is more specific. The future 50% maximum empty-space ratio applies to operators filling grouped packaging, transport packaging and e-commerce packaging, and it starts on the later of 1 January 2030 or three years after the Article 24(2) implementing acts enter into force. Ordinary sales packaging follows a separate minimisation rule and does not have a predefined 50% cap under Article 24(4).
This guide focuses on Article 24, right-sizing and buyer-side evidence preparation. It does not replace the broader EU PPWR paper packaging buyer guide, and it is not legal advice, a PPWR certification, an EU approval or an official compliance calculator.
Quick Answer: Does PPWR Set a 50% Empty-Space Limit?
Yes, but not for every package and not as a universal rule that applies today. Article 24(1) sets a future maximum empty-space ratio of 50% for grouped, transport and e-commerce packaging. The application date is the later of 1 January 2030 or three years after the Article 24(2) implementing acts enter into force.
- Grouped packaging: falls within the future Article 24(1) 50% route.
- Transport packaging: falls within the future Article 24(1) 50% route.
- E-commerce packaging: falls within the future Article 24(1) 50% route when it is used to deliver products sold online or through other distance sales to an end user.
- Sales packaging: has no predefined 50% cap under Article 24(4); by 12 February 2028 its empty space must be reduced to the minimum necessary for packaging functionality, including product protection.
- Void fill does not solve the ratio: listed fillers such as paper cuttings, air cushions, bubble wrap, sponge, foam, wood wool and polystyrene count as empty space under Article 24(3).
- No official universal calculator is available in the current official search: the Commission must establish the Article 24(2) calculation methodology through implementing acts.
Buyers can prepare now by classifying the packaging function, recording product and package dimensions, documenting insert and filler use, validating functional clearance, and retaining sample and pack-out evidence. These engineering inputs support preparation; they do not automatically prove legal compliance.
Article 24 Scope: Grouped, Transport and E-commerce Packaging
Article 24 is based on packaging function rather than the commercial name of a box. A corrugated mailer may function as e-commerce packaging, a regular slotted carton may function as transport packaging, and a paperboard carton sold with the product may function as sales packaging. The same material family can therefore follow different Article 24 routes depending on how the package is used.
Regulation (EU) 2025/40 defines grouped packaging as packaging that groups a number of sales units, transport packaging as packaging that facilitates handling and transport of sales units or grouped packaging, and e-commerce packaging as transport packaging used to deliver products sold online or through other distance sales to an end user. Classification should be confirmed against the actual supply chain and the responsible economic operator's role.
| Packaging function | Typical HSPACK format | 50% cap? | Current / future | Later-of condition | Buyer action |
|---|---|---|---|---|---|
| Grouped packaging | Corrugated or paperboard pack grouping multiple sales units. | Yes, Article 24(1) route. | Future requirement. | Later of 1 Jan 2030 or 3 years after Article 24(2) implementing acts enter into force. | Record grouped units, package dimensions, filler and functional clearance. |
| Transport packaging | RSC/master carton, shipping carton or other transport box. | Yes, Article 24(1) route. | Future requirement. | Same later-of condition. | Document pack count, contained sales packaging, internal dimensions and protection needs. |
| E-commerce packaging | Corrugated mailer or shipping box delivering a distance-sale order to the end user. | Yes, Article 24(1) route. | Future requirement. | Same later-of condition. | Record final pack-out, insert, filler, label area and damage-risk evidence. |
| Ordinary sales packaging | Retail folding carton, product box or sales unit packaging. | No predefined 50% cap under Article 24(4). | Separate minimisation milestone by 12 Feb 2028. | Not the Article 24(1) 50% later-of route. | Reduce empty space to the minimum necessary for functionality and document product protection. |
| Sales packaging used as e-commerce packaging | A sales package that itself performs the e-commerce delivery function. | Article 24(5) provides an Article 24(1) exemption. | Classification-specific. | Article 10 minimisation still needs to be considered. | Confirm classification and do not treat the exemption as a blanket exemption from minimisation. |
| Reusable packaging in a reuse system | Project-specific reusable transport or grouped packaging. | Article 24(5) can exempt it from Article 24(1). | System- and classification-specific. | Other PPWR requirements, including Article 10, can still apply. | Confirm the reuse system and applicable legal route before relying on the exemption. |
If the project is still deciding whether the outer package is a standard shipping carton or a die-cut mailer, use the shipping boxes vs mailer boxes guide for the structural decision. N06 only owns the Article 24 empty-space layer.
When the 50% Empty-Space Limit Applies
Article 24(1) is directed at economic operators who fill grouped packaging, transport packaging or e-commerce packaging. For those packaging functions, the future maximum empty-space ratio is 50%. The rule is not a current universal threshold for every paper box and it does not convert ordinary sales packaging into a fixed-percentage route.
Before applying the 50% figure, identify what the package actually does: whether it groups sales units, facilitates handling and transport, or delivers a distance-sale order to the end user. Then identify who fills the package and retain the dimensions, contained sales-packaging data, insert, filler and protection evidence used for the final pack-out.
The Later-of Date: Why 1 January 2030 Is Not the Whole Rule
Operators within the Article 24(1) scope must ensure the 50% maximum empty-space ratio by 1 January 2030 or three years from the entry into force of the implementing acts adopted under Article 24(2), whichever is later.
This “whichever is later” wording matters. A buyer should not convert the rule into a simple statement such as “all e-commerce boxes must meet 50% from 1 January 2030.” The actual application date depends on the Article 24(2) implementing acts and their entry into force.
The Commission is required to adopt implementing acts establishing the calculation methodology by 12 February 2028. In the current official search reviewed on 15 August 2026, an adopted Article 24(2) universal calculation methodology was not identified. Buyers should therefore prepare robust inputs now while keeping the final legal calculation open for the adopted method.
What Counts as Empty Space — Including Void Fill
Article 24(3) provides the statutory concept for grouped, transport and e-commerce packaging. Empty space is the difference between the total volume of that packaging and the volume of the sales packaging contained inside it. The empty-space ratio is that empty space divided by the total volume of the grouped, transport or e-commerce packaging.
The Regulation also prevents a common workaround: filler counts as empty space. It specifically lists paper cuttings, air cushions, bubble wrap, sponge, foam, wood wool, polystyrene and similar filling materials. Replacing air with more filler does not automatically improve the Article 24 empty-space result.
This does not mean all clearance or protective material is unnecessary. Product fragility, irregular shapes, liquid packaging, multi-product orders, small items and the minimum space needed for shipping labels are among the issues the future Article 24(2) methodology must address. Buyers should document the functional reason for space rather than removing protection blindly.
Sales Packaging Is Different: No Predefined 50% Cap
Ordinary sales packaging is not governed by the Article 24(1) 50% cap. Article 24(4) requires economic operators filling sales packaging to ensure that, by 12 February 2028, empty space is reduced to the minimum necessary for packaging functionality, including product protection.
This distinction matters for paperboard retail cartons, rigid sales boxes and other packages sold as the product's sales unit. Buyers should not take the grouped/transport/e-commerce percentage and apply it mechanically to a premium sales box. The correct question is whether the remaining space is necessary for the package's legitimate function, with the applicable Article 10 and Article 24 requirements assessed separately.
Filling materials are not a way to hide unnecessary sales-packaging space: the listed filling materials are also treated as empty space for the Article 24(4) minimisation assessment. Settlement, required headspace and protective-gas conditions have specific treatment under Article 24(4). Where those issues are relevant, the responsible EU economic operator should confirm the exact legal application for the product and packaging system.
Why There Is No Official Universal PPWR Empty-Space Calculator Yet
Search results already contain third-party PPWR calculators, but a third-party tool is not the same as the Commission's adopted Article 24(2) methodology. The Regulation requires the Commission to establish the calculation method through implementing acts, and the method must address practical cases such as irregular products, multi-product packs, liquids, damage risk, small items and minimum shipping-label space.
Until that official method is adopted and applicable, this page does not publish a “compliance calculator.” Instead, buyers can prepare a controlled measurement input sheet. The purpose is to capture the data likely to be needed for later calculation, engineering review and evidence retention without pretending that a planning worksheet is the final EU formula.
| Product dimensions | Packaging internal dimensions | Insert | Void fill | Functional clearance | Packaging function | Evidence source | Sample result |
|---|---|---|---|---|---|---|---|
| Record final packed product L × W × H; include accessories that ship in the unit. | Record the approved internal L × W × H of the grouped, transport or e-commerce package. | Material, cavity layout, thickness and product-retention function. | Type, location and controlled amount; do not subtract filler as if it were product volume. | Loading tolerance, protection, removal, irregular geometry and required label area. | Grouped / transport / e-commerce / sales. | Approved dieline, specification, product drawing, sample photos and pack-out record. | Pass / revise, with measured dimensions and dated approval. |
| For multi-item orders, record the final packed dimensions of each contained sales unit. | Record final internal dimensions after board, folds and inserts are approved. | Document separators, dividers or die-cut supports. | Record paper, air cushion, foam or other filler used in the actual pack-out. | Explain damage-risk or handling reason for retained space. | Confirm the function for the actual sales and delivery channel. | Pack-out trial, handling test or project-specific evidence. | Retain the approved sample ID or revision. |
Important: This table is a buyer data-collection sheet, not the official Article 24(2) calculation methodology and not proof of compliance.
Right-Sizing Without Sacrificing Product Protection
PPWR preparation and packaging engineering overlap at the point where buyers need to explain why a package has its current dimensions. Right-sizing does not mean forcing every product into the smallest possible box. The objective is to remove avoidable volume while keeping the protection, handling, loading, closure and logistics functions required by the real product and route.
Start with the packed product, not the empty box. Measure the product and accessories, define the insert, identify functional clearance, confirm how the package closes, and validate the shipping route. Then review whether the internal dimensions can be reduced without increasing damage risk or creating difficult assembly.
Our corrugated mailer structural optimization guide explains the engineering side of dimensions, flute, dielines and shipping volume. The volumetric-weight packaging redesign case study shows how one project used a tighter pack-out and master-carton plan to reduce freight cost. Those engineering results are project-specific and should not be presented as an Article 24 compliance calculation.
If the project requires a new e-commerce mailer rather than a compliance interpretation, use the custom mailer boxes for e-commerce guide or review custom corrugated boxes for commercial structure options.
Packaging Function Examples: Mailer, Shipping Carton, Grouped Pack and Sales Box
The examples below are classification and preparation examples only. Final Article 24 applicability depends on the actual packaging function and supply chain.
- DTC corrugated mailer: when used to deliver an online order to the end user, it can be e-commerce packaging. Record the packed product, insert, void fill, internal dimensions, label area and protection requirements.
- Master shipping carton: when it transports multiple sales units or grouped packaging, it can be transport packaging. Record the contained sales packs, case count, internal dimensions, filler and logistics constraints.
- Grouped promotional pack: when it groups a number of sales units, it can fall within the grouped-packaging route. Record which sales units are grouped and why the outer dimensions are needed.
- Retail folding carton: when it is the sales unit presented to the end user, it normally follows the sales-packaging Article 24(4) route rather than a predefined 50% cap.
- Sales package used as the e-commerce delivery package: Article 24(5) can change the Article 24(1) route, but this should not be treated as a general exemption from PPWR minimisation.
Right-Sizing Buyer Checklist
Use the following checklist to create a repeatable evidence trail from RFQ through sample approval. The “owner” column is a practical project role, not a statement of the final PPWR legal obligation.
| Input | Owner | Why needed | Evidence | Approval stage |
|---|---|---|---|---|
| Final packed-product dimensions | Brand / packer | Establish the real packed geometry rather than bare-product size. | Product drawing, measurement sheet, photos. | Before dieline freeze. |
| Contained sales-packaging dimensions | Brand / packer | Needed to distinguish the sales packaging contained inside grouped, transport or e-commerce packaging. | Approved sales-pack specification. | Before pack-out approval. |
| Transport/e-commerce packaging internal dimensions | Packaging supplier | Defines the actual internal space after structure is approved. | Dieline, sample measurement. | Structural sample. |
| Insert layout | Packaging supplier + brand | Shows product retention, separation and occupied space. | Insert drawing, sample, photos. | Structural sample. |
| Filler type and amount | Packer / fulfillment team | Listed filler counts as empty space under Article 24(3). | Pack-out SOP, photos, material record. | Pack-out trial. |
| Functional clearance | Engineering + brand | Explains space needed for loading, closure, protection or removal. | Engineering note, sample observations. | Sample approval. |
| Shipping-label area | Logistics / fulfillment | The future methodology must consider minimum shipping-label space for relevant cases. | Label template, carrier requirement. | Artwork / pack-out approval. |
| Damage and fragility evidence | Quality / engineering | Prevents right-sizing from creating an unacceptable protection risk. | Drop, transit, handling or internal test evidence as specified. | Before mass production. |
| Sample / pack-out trial | Brand + supplier + packer | Confirms actual product fit, filler, closure and dimensions. | Approved physical sample, dated photos. | Pre-production approval. |
| Master-carton plan | Logistics + supplier | Connects unit-package design to transport efficiency. | Pack count, carton dimensions, pallet plan. | Shipping approval. |
| Final approval responsibility | Responsible EU economic operator | Separates supplier inputs from the final legal decision. | Internal compliance record / responsible-party approval. | Before EU market placement as applicable. |
RFQ and Sample Evidence to Prepare
A PPWR-aware right-sizing RFQ should ask for measurable project inputs rather than a yes/no “PPWR compliant” promise. Send enough information for the packaging supplier to review structure and for the responsible EU party to maintain an evidence trail.
- Product: final packed dimensions, weight, fragility and orientation.
- Current packaging: internal and external dimensions, photos or existing dieline.
- Packaging function: grouped, transport, e-commerce or sales packaging.
- Contained sales packaging: dimensions and quantity when the outer package contains sales units.
- Insert: material, layout, thickness, cavities and product-retention function.
- Void fill: type, amount, placement and reason for use.
- Functional clearance: loading, closure, protection, removal, headspace or irregular-shape needs where relevant.
- Shipping channel: parcel, fulfillment center, wholesale, pallet or other route.
- Destination: EU market and target launch timing.
- Evidence: current sample, pack-out photos, test requirements and document needs.
Use the custom packaging RFQ checklist for general commercial fields such as quantity, materials, artwork, packing and delivery terms, then add the Article 24-specific evidence inputs above.
Common Buyer Misconceptions About PPWR Empty Space
- “Every box must already be under 50% empty space.” Incorrect. Article 24(1) is limited to grouped, transport and e-commerce packaging and uses a future later-of application date.
- “Adding paper filler reduces the empty-space ratio.” Incorrect. Paper cuttings and other listed fillers count as empty space under Article 24(3).
- “Sales packaging also has a 50% cap.” Incorrect. Article 24(4) requires minimisation to what is necessary for functionality; it does not set one predefined 50% percentage for ordinary sales packaging.
- “1 January 2030 is the only date that matters.” Incorrect. Article 24(1) uses the later of that date or three years after the Article 24(2) implementing acts enter into force.
- “A third-party PPWR calculator is the official EU methodology.” Incorrect. The official Article 24(2) calculation methodology must be established through implementing acts.
- “Right-sizing means removing all protective space.” Incorrect. The Regulation and future methodology recognise packaging functionality and damage-risk considerations. Protection still needs project-specific verification.
- “A packaging supplier can guarantee the final EU legal result.” Incorrect. Supplier specifications, dielines, samples and pack-out evidence can support the process, while final applicability and obligations should be confirmed by the responsible EU economic operator.
Official EU Sources
Regulatory status for this page was reviewed on 15 August 2026. PPWR implementation remains dependent on secondary legislation in several areas, including the Article 24(2) methodology. Recheck official sources before relying on this guide for a later packaging release.
PPWR Empty Space FAQ
Does PPWR require every box to stay below 50% empty space?
No. Article 24(1) sets the future 50% maximum empty-space ratio for grouped, transport and e-commerce packaging. Ordinary sales packaging follows a separate Article 24(4) minimisation rule and does not have a predefined 50% cap.
When does the PPWR 50% empty-space rule apply?
The Article 24(1) rule applies from the later of 1 January 2030 or three years after the implementing acts adopted under Article 24(2) enter into force. Buyers should not reduce this to a simple “from 2030” statement.
Which packaging types are covered by the Article 24 50% cap?
The 50% route applies to grouped packaging, transport packaging and e-commerce packaging. Packaging classification should be based on the actual function in the supply chain rather than the commercial name of the box.
Does void fill count as empty space under PPWR?
Yes. Article 24(3) states that listed filling materials such as paper cuttings, air cushions, bubble wrap, sponge, foam, wood wool, polystyrene and similar fillers are considered empty space for the grouped, transport and e-commerce packaging calculation.
Is there an official PPWR empty-space calculator?
The Commission must establish the Article 24(2) calculation methodology through implementing acts. In the official-source review completed on 15 August 2026, an adopted universal Article 24(2) methodology was not identified. Third-party calculators should not be treated as the official EU method.
Are sales packaging and e-commerce packaging treated the same?
No. E-commerce packaging is within the Article 24(1) grouped/transport/e-commerce 50% route, while ordinary sales packaging has a separate Article 24(4) requirement to reduce empty space to the minimum necessary for functionality by 12 February 2028.
What information should buyers collect for PPWR empty-space preparation?
Collect final packed-product dimensions, contained sales-packaging dimensions, outer package internal dimensions, insert layout, filler type and amount, functional clearance, shipping-label needs, damage-risk evidence, sample or pack-out records and the responsible approval role.
Can a packaging supplier confirm final PPWR legal compliance?
A packaging supplier can support a project with specifications, dielines, dimensions, samples, pack-out information, supplier documents, testing coordination and project-specific RFQ support where applicable. Final PPWR applicability and compliance obligations should be confirmed by the responsible EU economic operator for the actual project.
Request a Right-Sizing and Pack-Out Review
Send your product dimensions and weight, current packaging dimensions, insert and filler details, order quantity, shipping channel, destination, current dieline or sample, and protection requirements. HS PACKFACTORY can review the package structure, dimensions, insert layout and pack-out inputs that may support your EU buyer or compliance team.
Support is subject to the applicable PPWR article, packaging function, economic-operator role, adopted secondary legislation and project-specific verification. HS PACKFACTORY does not provide PPWR certification, EU legal approval, guaranteed compliance or a universal Article 24 calculation.