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

Classify the packaging format first. PPWR defines grouped packaging 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 grouped packaging, 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.

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 grouped packaging, 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.

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.

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.