EU Packaging and Packaging Waste Regulation Packaging minimisation

Article 10 requires manufacturers or importers to ensure, by 1 January 2030, that packaging placed on the market is designed so its weight and volume are reduced to the minimum necessary to ensure its functionality. The assessment must take account of the packaging shape and material.

The same article blocks packaging that fails the Annex IV performance criteria and packaging features used only to increase perceived product volume, including double walls, false bottoms, and unnecessary layers. A design right or shape-trademark exception applies only where the right was protected before 11 February 2025 and applying Article 10 would alter the design's novelty or individual character, or stop the trademark from distinguishing the product. Protected geographical indications and specified Union quality schemes form a separate exception.

Annex IV is the practical checklist for a minimisation file. It recognises that packaging may need weight or volume for product protection, manufacturing and filling, logistics, functionality, information, hygiene and safety, legal requirements, recycled content, recyclability, and reuse.

A defensible decision explains the design requirement that prevents further reduction for each relevant criterion. It is not enough to say that the package is already lightweight or that a supplier supplied a standard format.

Article 10 says compliance with the minimisation duty must be demonstrated in the technical documentation referred to in Annex VII. The record should explain the technical specifications, standards, and conditions used to assess the packaging against Annex IV.

Annex IV Part B adds the operating detail: include the outcome of the assessment, the calculation of the minimum necessary weight and volume, production-batch variations, the design requirements blocking further reduction, the method used to identify those requirements, and the test results, market research, or studies relied on.

Article 10 is the broad design obligation for minimum necessary packaging weight and volume. Article 24 is a separate empty-space control for fillers of grouped, transport, e-commerce, and sales packaging.

For grouped, transport, and e-commerce packaging, Article 24 sets a maximum empty-space ratio of 50% by 1 January 2030 or three years from the entry into force of the relevant implementing acts, whichever is later. For sales packaging, Article 24 requires empty space to be reduced to the minimum necessary for packaging functionality by 12 February 2028.

Create one minimisation record per packaging type before approving a design change, supplier change, new SKU, or market launch. The record should be easy to update when harmonised standards, common specifications, the Article 24 methodology, or the packaging design changes.

Use narrow public claims. A statement such as "designed under an Article 10 minimisation assessment" is stronger than broad claims about optimal packaging unless the technical file actually supports the broader wording.