FAQPPWREU

PPWR grouped and transport packaging What does Article 24 require for empty space?

Article 24 sets an empty-space control for economic operators that fill grouped, transport, and e-commerce packaging.

This FAQ helps classify the format, check the 50% empty-space rule, identify exemptions, and keep technical evidence tied to the packaging design.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Overview

Article 24's 50% empty-space rule applies to the natural or legal person that uses or fills grouped, transport, or e-commerce packaging. It does not set a 50% threshold for sales packaging. Classify the packaging format first, identify the filler, and keep the measurement and protection evidence needed when the Commission calculation methodology applies.

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Question 1

What should teams do about grouped and transport packaging under PPWR?

Classify the packaging format first. PPWR defines as packaging that groups sales units at the point of sale, including shelf-restocking or stock-keeping groupings that can be removed without affecting the product. It defines transport packaging as packaging used to handle and transport one or more sales units or grouped units to prevent handling and transport damage, excluding road, rail, ship, and air containers.

If the format is , transport packaging, or e-commerce packaging, identify the economic operator that fills it and test the packaging design against Article 24's excessive-packaging rule. The practical owner is usually the team that controls case pack design, fulfilment carton selection, protective fill rules, pallet or bundle configuration, or e-commerce packing instructions.

  • Map each packaging SKU or fulfilment configuration to sales, grouped, transport, or e-commerce packaging before applying the rule.
  • For grouped, transport, and e-commerce packaging, record the filled-package volume, the volume of sales packaging inside it, and any protective or legal reason for the remaining space.
  • Do not count paper cuttings, air cushions, bubble wrap, sponge fillers, foam fillers, wood wool, polystyrene, or Styrofoam chips as occupied product volume; Article 24 treats those filling materials as empty space.
Question 2

What is the PPWR empty-space rule for these formats?

Article 24 says that, by 1 January 2030 or three years from the entry into force of the Commission implementing acts on the calculation method, whichever is later, economic operators who fill , transport packaging, or e-commerce packaging must keep the maximum empty-space ratio to 50%. The Commission's 2026 guidance says the calculation act is to be adopted before 12 February 2028 and confirms that the obligated party is the natural or legal person using or filling the packaging.

The rule is not a simple visual judgment. Article 24 defines empty space as the difference between the total volume of the grouped, transport, or e-commerce packaging and the volume of the sales packaging inside it. The empty-space ratio is that empty space divided by the total volume of the grouped, transport, or e-commerce packaging.

  • Use the 50% ratio only for grouped, transport, and e-commerce packaging covered by Article 24(1).
  • Wait for and apply the Commission implementing methodology for the calculation details; Article 24 requires it to account for legally required space, product protection, irregular shapes, liquid products, multi-product packs, fragile contents, small items that can be damaged by larger products, and shipment-label space.
  • Keep sales-packaging minimisation separate: Article 24(4) requires sales packaging empty space to be reduced to the minimum necessary for packaging functionality, including product protection.
Question 3

Which exceptions and design constraints matter?

Do not remove protective or legally required space blindly. Article 24 instructs the Commission's calculation methodology to account for packaging that needs enough empty space to satisfy legal requirements or protect the product. That matters for irregular products, liquids, mixed sales packages, fragile contents, very small items, and shipment labels.

There is also an Article 24 exemption from the 50% grouped, transport, and e-commerce packaging ratio for economic operators using sales packaging as e-commerce packaging or using reusable packaging within a reuse system. The exemption does not remove the need to comply with packaging minimisation. Sales packaging has no predefined 50% threshold: the manufacturer assesses its empty space under the applicable minimisation framework, using EN 13428:2004 until 1 January 2030 according to the Commission's 2026 guidance, then the updated Article 10 framework.

  • Document why any empty space remains: product protection, legal requirement, mixed contents, liquid handling, label placement, or another reason recognised by the methodology.
  • If sales packaging is used directly as e-commerce packaging, record why Article 24(5) applies and still check the Article 10 minimisation requirements.
  • If reusable packaging is used within a reuse system, keep the reuse-system evidence and do not treat the exemption as permission for avoidable excess volume.
Question 4

What evidence should teams retain for grouped and transport packaging?

Keep evidence that proves the classification, calculation, design constraint, and owner decision for each packaging configuration. Annex IV, Part B requires the assessment of the minimum packaging volume and weight necessary to ensure packaging functionality to be explained in the technical documentation, including calculation details and reasons why further reduction would endanger that functionality.

The evidence file should let a reviewer trace the conclusion from a physical packaging configuration to the PPWR rule. Reassess it after a packaging design, fulfilment rule, product mix, protection test, reuse system, or Commission calculation methodology changes.

  • Packaging-format classification: sales, grouped, transport, e-commerce, reusable, or sales packaging used as e-commerce packaging.
  • Empty-space calculation record: total package volume, sales-packaging volume inside it, filling materials treated as empty space, and the resulting percentage where Article 24(1) applies.
  • Design-constraint record: product-protection tests, shipment-label needs, legal requirements, liquid or fragile-product handling, irregular-shape rationale, or mixed-pack rationale.
  • Technical documentation extract: the minimum necessary weight and volume assessment, including the reasons preventing further reduction.
  • Change log: updates after packaging redesign, supplier change, fulfilment-rule change, reuse-system change, or adoption of the Commission calculation methodology
Recommended next step

Turn PPWR packaging minimisation into evidence

Use Sorena to classify grouped, transport, and e-commerce packaging, track Article 24 empty-space evidence, and keep source citations with the packaging record.

Question 5

Questions and answers

Do grouped, transport, and e-commerce packaging have to follow the PPWR empty-space rule?

Yes, unless the Article 24(5) exemption applies. Article 24 requires economic operators who fill , transport packaging, or e-commerce packaging to keep the maximum empty-space ratio at 50% by 1 January 2030 or three years from the relevant implementing acts, whichever is later.

What counts as empty space in grouped or transport packaging?

Empty space is the difference between the total volume of the grouped, transport, or e-commerce packaging and the volume of the sales packaging inside it. Filling materials such as paper cuttings, air cushions, bubble wrap, sponge fillers, foam fillers, wood wool, polystyrene, or Styrofoam chips are treated as empty space.

Can reusable packaging or sales packaging used as e-commerce packaging rely on an exemption?

Yes. Article 24 exempts economic operators using sales packaging as e-commerce packaging or using reusable packaging within a re-use system from the 50% empty-space obligation, but they still need to meet the broader PPWR minimisation requirements.

Primary sources

References and citations

data.europa.eu5 citations
Referenced sections
  • Official PPWR text for definitions of grouped, transport, and e-commerce packaging; Article 24 empty-space controls; Article 10 minimisation links; and Annex IV and Annex VII technical documentation.
  • Article 3 defines grouped, transport, and e-commerce packaging; Article 24 applies the excessive-packaging rule to economic operators who fill those formats.
  • Article 24 sets the 50% maximum empty-space ratio and defines how empty space and the ratio are calculated for grouped, transport, and e-commerce packaging.
Show 2 more
  • Article 24 describes calculation-methodology factors, the exemption for sales packaging used as e-commerce packaging and reusable packaging in reuse systems, and the continuing link to Article 10.
  • Annex IV, Part B requires the minimum packaging volume and weight assessment to be explained in the technical documentation, including calculation details and reasons preventing further reduction.
"the maximum empty space ratio, expressed as a percentage, is 50 %."
More quoted passages
"grouped packaging, transport packaging or e-commerce packaging"
"the maximum empty space ratio, expressed as a percentage, is 50 %"
"Economic operators using sales packaging as e-commerce packaging or using reusable packaging within a system of re-use shall be exempt"
"details of the calculation of the minimum necessary weight and volume"
data.europa.eu3 citations
Referenced sections
  • Official Commission guidance distinguishing Article 24's 50% filler obligation from the separate sales-packaging minimisation assessment.
  • Commission guidance on the Article 24 obligated party, the implementing-act deadline, and the separate treatment of sales-packaging empty space.
  • Commission guidance that sales packaging has no predefined empty-space threshold and remains subject to a manufacturer-led minimisation assessment.
"The empty space ratio in Article 24 applies to grouped, transport, and e-commerce packaging"
More quoted passages
"The Commission will establish the methodology for calculation of the empty space ratio in an implementing act which will be adopted before 12 February 2028"
"For sales packaging, the minimisation requirements related to empty space are not linked to any predefined threshold"
environment.ec.europa.eu2 citations
Referenced sections
  • European Commission overview explaining PPWR's policy aim to reduce unnecessary packaging waste and encourage smaller, lighter packaging without empty space.
  • The Commission overview frames PPWR as reducing unnecessary packaging waste and promoting smaller, lighter packaging with less empty space.
"Small, light packaging without empty space."
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