Empty Space in Shipping and Transport Packaging: What Art. 24 PPWR Requires and How to Adapt Your Formats

Under Art. 24 of the PPWR, grouped, transport and e-commerce packaging may have no more than 50 % empty space, from 1 January 2030 or three years after the implementing acts on the calculation method, whichever is later. Filling material such as air cushions, paper or foam counts as empty space. Anyone who fills oversized cartons today should therefore review their range of formats early.

Which packaging is affected (Art. 3)

The empty-space limit applies to three types of packaging, which Regulation (EU) 2025/40 defines in Art. 3:

• Transport packaging: packaging intended to facilitate the handling and transport of one or more sales units or grouped packaging and to prevent damage during handling and transport. Road, rail, ship and air transport containers are not included.
• E-commerce packaging: transport packaging used to deliver products sold online or by other distance sales to the end user.
• Grouped packaging: packaging that groups a number of sales units at the point of sale or forms a storage or distribution unit.

The obligation falls on economic operators who fill this packaging, that is, the company that actually packs. For manufacturers in Bosnia and Herzegovina and Serbia, it becomes relevant when their shipments reach the EU market. How the obligation is then distributed depends on roles and contracts. In Croatia the regulation applies directly.

The 50 % limit and its timing

Art. 24(1) requires an empty-space ratio of no more than 50 %. The date is conditional: 1 January 2030 or three years after the implementing acts on the calculation method, whichever is later.

The Commission must adopt the method by 12 February 2028 (Art. 24(2)). Among other things, it is meant to take into account:

• products with irregular shapes
• packaging that contains more than one product
• space needed to protect the product or to meet legal requirements

For planning, it is advisable to count on 2030. An overview of all dates is given in the guide PPWR deadlines 2025 to 2040.

How empty space is calculated (Art. 24(3))

The regulation defines two quantities:

• Empty space is the difference between the total volume of the grouped, transport or e-commerce packaging and the volume of the sales packaging it contains.
• Empty-space ratio is the empty space divided by the total volume of that packaging.

Space filled with filling material counts as empty space. The regulation expressly names paper shreds, air cushions, bubble wrap, sponge or foam fillings, wood wool and polystyrene chips. An oversized carton is therefore not improved by filling it up.

Sales packaging: the rule from 2028

Sales packaging has its own rule without a fixed percentage limit: by 12 February 2028, economic operators who fill sales packaging must reduce empty space to the minimum needed for the function, including product protection (Art. 24(4)). Here too, filling material counts as empty space.

Packaging that only looks bigger (Art. 10)

Independently of Art. 24, since 12 August 2026: packaging designed only to increase the perceived volume, for example with double walls, false bottoms or unnecessary layers, may not be placed on the market (Art. 10(2), with exceptions). By 1 January 2030, manufacturers and importers must also ensure that weight and volume are reduced to the minimum needed for the function (Art. 10(1)).

A simple worked example

The following example is for illustration only. It uses simple outer dimensions and ignores wall thicknesses as well as the calculation method still to be set by the Commission.

A product in its sales packaging measures 20 × 15 × 10 cm, that is 3.0 litres.

	Carton A	Carton B
Carton dimensions	28 × 23 × 18 cm	22 × 17 × 12 cm
Carton volume	11.6 l	4.5 l
Sales packaging volume	3.0 l	3.0 l
Empty space	8.6 l	1.5 l
Empty-space ratio	74 %	33 %

In carton A the empty-space ratio stays at 74 %, even if the gaps are filled with air cushions. Only the smaller format brings the ratio clearly below 50 %. You can find an interactive example on our home page.

Fitting formats in practice

A format range instead of individual formats

Record the dimensions of your products and typical product combinations. From this you can derive a range of formats whose steps are close enough that a fitting carton exists for every product, without making the warehouse hard to manage.

Made-to-measure cartons

For very varied shipments, cartons made to measure for each order may be an option. Whether this pays off depends on shipment volume, space and the packing process.

Inserts instead of loose filling

An insert that fixes the product in place often allows a smaller carton than loose filling. The advantage lies in the smaller outer format. Whether and how the space of the insert itself counts depends on the calculation method. The regulation expressly names foam fillings as filling material.

Clear packing instructions

The best format range is of little use if the nearest carton is grabbed when packing. Packing instructions with pictures, an assignment of product to carton and trained staff ensure that the right format is actually used.

Further information on cartons, film and pallets is offered by the guide Transport packaging and the PPWR.

Review your empty space now

Format changes affect purchasing, warehousing and the packing process and therefore need lead time. Our packaging optimization combines product protection and fitting formats, and process and logistics optimization brings them into daily packing. For classifying the requirements, there is the PPWR and EU compliance service. If you want to know where your shipping packaging stands today, request an initial assessment.