Is the PPWR packaging-minimisation duty live since 12 August 2026?

Not the minimisation requirements. The Regulation has applied since 12 August 2026, but the Commission's PPWR FAQ states that Article 10(1) and Article 10(2) apply from 1 January 2030, and that until the end of 2029 the essential requirements of the old Packaging and Packaging Waste Directive, including standard EN 13428:2004, continue to apply. That follows from Article 70(1)(b) of the Regulation.

What is the PPWR empty-space threshold and when does it apply?

Article 24(1) sets a maximum empty space ratio of 50% for grouped, transport and e-commerce packaging. According to the Commission's FAQ it has to be met from 1 January 2030, or three years after entry into force of the implementing act under Article 24(2), whichever applies. That methodology has to be adopted by 12 February 2028. For sales packaging there is no maximum threshold at all.

Are false bottoms and double walls banned under the PPWR?

Not outright, but they are restricted. Under Article 10(2) the use of characteristics such as double walls or false bottoms is not allowed when they increase the perceived volume of the product, and the Commission's FAQ adds that the economic operator must prove double walls, false bottoms, frontal flaps and additional layers are used only where functionality cannot be ensured otherwise, with tests and evidence in the technical documentation. Article 24 carries no equivalent exemption for design rights or trademarks.

KontorBund — Note Void fill and the PPWR minimisation duty
Last checked 4 October 2026
kontorbund.com/notes/eu-ppwr-void-fill.html

The Library

Void fill and the PPWR minimisation duty: what counts now, and the 2030 empty-space cap

Q: Does packaging filler such as bubble wrap or air cushions count towards empty space under the PPWR?

Yes, for sales packaging. The Commission's FAQ states that when assessing compliance with the 'minimum necessary' requirement, space filled by filling materials such as paper cuttings, air cushions, bubble wraps, sponge fillers, foam fillers, wood wool, polystyrene or styrofoam chips shall be considered as empty space. Packing an oversized box with filler therefore restates the empty space, it does not remove it.

Q: Who has to comply with the PPWR empty-space requirement?

The economic operator who fills the packaging — the Commission's FAQ says this may be the manufacturer as defined in Article 3(1), point (13), as well as other economic operators who make packaged products available on the market. In practice that is the seller and whoever packs the parcel, including a fulfilment partner, not the company that supplied the boxes.

Last checked4 October 2026

KeeperOpen — keeper wanted

StatusNot live yet — from 1 January 2030

The short version

Packing an oversized box with air cushions, bubble wrap, paper cuttings or foam does not fix the box: the Commission counts the space those materials fill as empty space, not as protection. But the duty around it is not live yet. The PPWR has applied since 12 August 2026; its minimisation requirements have not. The Commission's own FAQ dates Article 10(1) and (2) to 1 January 2030, and the 50% empty-space cap for grouped, transport and e-commerce packaging to 1 January 2030 or three years after the entry into force of the implementing act that fixes the calculation method — an act due by 12 February 2028. The duty falls on whoever fills the packaging, which for a parcel is the seller and whoever packs it.

What is live, and what is not

Two different things get mixed together in most of what is being written about this: the Regulation applying, and its minimisation requirements applying. The first happened on 12 August 2026. The second has not happened yet, and the Commission says so in the plainest place it could: its own FAQ, chapter VII, question 1 — "Do both Article 10(1) and (2) on packaging minimisation apply by 1 January 2030?" — answered "Yes."

The instrument: Regulation (EU) 2025/40 on packaging and packaging waste (PPWR). In force since 11 February 2025, application date 12 August 2026 — that is the Commission's own wording on its packaging page.
Packaging minimisation — Art. 10(1) and (2): From 1 January 2030. Until the end of 2029 the essential requirements of the old Packaging and Packaging Waste Directive continue to apply, and so does EN 13428:2004. The Commission attributes that to Article 70(1)(b).
Empty space — Art. 24(1): A maximum empty space ratio of 50% for grouped, transport and e-commerce packaging. To be met by the economic operator who fills such packaging.
When the 50% bites: 1 January 2030 — or three years after entry into force of the implementing act under Art. 24(2), depending on which of the two applies. The FAQ's own list of application dates puts it that way, and the cap is not in force before then.
The calculation method: Due by 12 February 2028. The Commission is to adopt implementing acts establishing how the empty space ratio is calculated for grouped, transport and e-commerce packaging. Until that method exists, there is nothing to compute the 50% against.
Sales packaging: No maximum threshold at all. Instead, whoever fills sales packaging has to minimise the empty space and demonstrate it in the technical documentation. The FAQ says to read that provision together with Article 10.
Conformity paperwork: Manufacturers must place on the market only packaging that complies with Articles 5 to 12, and the declaration of conformity is drawn up per packaging type, which the FAQ says should follow the level at which the packaging differs in view of the applicable requirements and the packaged product.

So is there anything to do today? Not because of this duty. The paperwork duties attached to the substantive requirements are live for what applies now, and the country desks cover the EPR side that did start on 12 August 2026. What is worth doing today is the cheap part of the exercise: measure a few parcels properly, so that when the method lands you already know your numbers — and stop treating filler as a solution to a box that is the wrong size.

The void-fill point, exactly

This is the part that is genuinely worth knowing early, because it is the part that changes what "we protected it properly" means. The Commission's FAQ, chapter XI, question 2, reads:

The Commission's own words

"The empty space ratio for sales packaging means the difference between the total internal volume of the sales packaging and the volume of the packaged product. For assessing compliance with this paragraph, space filled by filling materials, such as paper cuttings, air cushions, bubble wraps, sponge fillers, foam fillers, wood wool, polystyrene or styrofoam chips, shall be considered as empty space."

Read that twice, because it inverts the instinct. The filler is not subtracted from the empty space and it is not treated as part of the product's protection envelope. It is the empty space. A 30 cm box holding a 10 cm item padded out with paper is not a well-packed 30 cm box; on this counting it is a 30 cm box with room for a 10 cm item, restated in paper.

The same answer says that for sales packaging there is no maximum threshold — the obligation is to minimise the empty space and demonstrate it. That matters for the traps below, and it matters for the material question: swapping plastic pillows for paper crumple may change your EPR fee and your recyclability paperwork, and it does not change this ratio by one millimetre.

Where we are cautious. That filling-materials sentence sits in the answer on sales packaging (Art. 24(4), the "minimum necessary" test). We did not find the Commission saying the same thing about the 50% cap for grouped, transport and e-commerce packaging, whose calculation method is still to be adopted under Art. 24(2). The direction of travel is obvious and the counting rule is explicit for sales packaging — but do not quote the cap and the filling-materials list as one sentence. They are two.

False bottoms and double walls

This one is written into the Regulation rather than into the FAQ's arithmetic. Under Article 10(2) the use of certain packaging characteristics — the FAQ's examples are double walls or false bottoms — is not allowed when the perceived volume of the product is increased. The Commission's illustration is a 50 ml jar of face cream in a double-walled jar, or a jar in a cardboard box, that makes the contents look like more than 50 ml.

Not an outright ban: The test is perceived volume plus justification, not the feature itself.
Who has to prove it: The economic operator. The FAQ: double walls, false bottoms, frontal flaps and additional layers must be shown to be used only where the packaging's functionality cannot be ensured otherwise and/or where they add legitimate functionality — demonstrated via tests and proven in the technical documentation.
The exemptions: Products or beverages with a protected geographical indication; packaging design protected by a Community design or a design right before 11 February 2025, where minimisation would alter its novelty and individual character; packaging shapes protected as a trademark before 11 February 2025. A licence number is not enough — the FAQ says the existence and the other conditions must be assessed and evidenced in the technical documentation.
The asymmetry to remember: Article 24 — the empty space provision — has no design-right or trademark exemption, unlike Article 10. And the 50% threshold applies only to grouped, transport and e-commerce packaging in any case.
The updated standard: By 12 February 2027 the Commission is to ask the European standardisation organisations to prepare or update harmonised standards on the method for calculating and measuring compliance — an update of EN 13428:2004 taking account of the performance criteria in Annex IV. Once adopted, using it brings the presumption of conformity back.

Who carries the duty

Not the box supplier, and not, in the first instance, the material industry — and that is the second half of what is worth knowing early.

On empty space, the FAQ is specific: the maximum has to be met by the economic operator who fills such packaging, which may be the manufacturer as defined in Article 3(1), point (13), as well as other economic operators who make packaged products available on the market. For sales packaging the same answer puts the minimise-and-document duty on the economic operator who fills it. If you buy boxes and pack your own orders, that is you. If a fulfilment partner packs for you, the question is the one the German desk asks on the EPR side: who counts as filling the packaging. The Commission's wording leaves room for both the seller whose product it is and the operator who makes the packaged product available on the market, so settle it in writing with your fulfilment partner rather than assuming it is theirs — or yours.

Suppliers are outside it, with one exception. The FAQ states that suppliers of packaging or packaging material are not manufacturers — except where the manufacturer is a microenterprise and the supplier sits in the same Member State. What packaging suppliers do have is a delivery duty: they must give the manufacturer the information and documentation needed to show conformity. Do not expect your box supplier to hold this for you, and do not accept "our boxes are compliant" as an answer to a question about your parcels.

Right-sizing, practically

None of this is legal advice, and it is not a compliance programme — it is the afternoon of work that makes the 2030 dates cheap instead of expensive.

1. Measure the inside, not the outside: Internal volume, against the volume of what you actually put in it. Do it for one representative parcel per product family, write it down with the date, and keep it — the honest number is the whole exercise.
2. Count the filler as empty space: Before you conclude a box is fine because it is packed tightly, apply the Commission's list: paper cuttings, air cushions, bubble wrap, sponge and foam fillers, wood wool, polystyrene chips. If the parcel is mostly those, it is mostly empty space with a shipping label.
3. Fix it with the box range, not the filler line: The cheapest change is usually one or two more box sizes, or a height you can trim. That is also the change that survives the duty — filler inside an oversized box does not.
4. Keep the justification for the features you keep: Double walls, false bottoms, frontal flaps and extra layers need a functionality reason and tests in the technical documentation — not a design preference.
5. Watch the two standardisation dates: 12 February 2027 for the request that updates the minimisation methodology and 12 February 2028 for the empty-space calculation method. Both are the Commission's, both come before the 2030 obligations, and the second one defines the number you will have to hit.
6. Do not restructure on a headline date: If a supplier or a consultant tells you this is live now and that August 2026 packaging must change by Friday, ask them for the article and the date in the Regulation. Take it from the sources below, not from the pitch.

What we could not establish

This page is built on a Commission document, and we would rather print its limits than paper over them.

We have not read the Regulation's own text: EUR-Lex refused automated access when we tried, so every article and paragraph number on this page — Art. 10(1)–(3), Art. 24(1), (2) and (4), Art. 70(1)(b), Art. 3(1)(13), Art. 62 — comes from the Commission's FAQ quoting them. Check paragraph numbers against EUR-Lex before you rely on one, and read the FAQ's own disclaimer: it is not binding law and it says so about itself.
Whether filler counts towards the 50% cap: The filling-materials list appears in the Commission's answer on sales packaging. We found no equivalent statement for the 50% ratio, because its calculation method is not adopted yet.
How irregular goods are counted: Open, by design: the Art. 24(2) methodology must take account of irregular shapes, packaging with several items, liquids, easily damaged products, small products shipped with larger ones, and the space needed for a shipping label. Until it is adopted, nobody can tell you what a 50% ratio means for a bottle or a lamp.
The trade feature behind this note: A packaging-trade piece of 2 October 2026 is what put this question in front of us, and the summary that reached us described the duty as "already live" since 12 August 2026 and packaging as at risk of being "turned away at the border". We could not read the article itself — it serves scripts rather than text to our tools — so we cannot say what it claims in its own words, and neither proposition is supported by the Commission's FAQ as we read it. On the border point the FAQ is explicit: enforcement of the obligations applicable from 12 August 2026 "should not disrupt trade flows", and under Article 62 the operator gets a warning and the chance to correct the non-compliance before anything else is done. Nothing on this page rests on that feature.
What national authorities will actually ask for: Nothing we have read tells us how market surveillance authorities will test a minimisation claim in a small seller's technical documentation, or from what date they will start. That is a gap until the harmonised standards land.

Known traps

"I pack it tight, so there's no empty space"

There is: the space your filler takes up counts as empty space for sales packaging. Tightly packed with padding is not the same as right-sized.

"This has been live since 12 August 2026"

The Regulation has. The minimisation requirements in Art. 10(1) and (2) apply from 1 January 2030, and the 50% cap from 1 January 2030 or three years after the entry into force of the implementing act under Art. 24(2).

"It's my box supplier's problem"

The empty-space duty attaches to the operator who fills the packaging. Suppliers of packaging or material are not the manufacturer — unless they are supplying a microenterprise in their own Member State — though they do have to pass you the documentation.

"Swapping plastic pillows for paper fixes it"

It can change your EPR fee, your recyclability paperwork and your waste bin. It does not change whether the box is bigger than the goods.

"The 50% cap applies to my product box"

It applies to grouped, transport and e-commerce packaging. Sales packaging has no maximum threshold — the obligation there is to minimise the empty space and show your working.

"Our trademark covers the double wall"

Only if it was protected before 11 February 2025, only if minimisation would stop it distinguishing your goods, and you must evidence it in the technical documentation. A registration number is not evidence. And Art. 24 has no such exemption at all.

Sources

One official document does almost all of the work here, and we say which chapter each claim comes from rather than citing it as a lump.

European Commission — PPWR Frequently Asked Questions, 2nd edition (KH-01-26-068-EN-N), August 2026 Official: DG ENV Unit B01. Read in full for this page, from the copy we mirror and describe here. The source for nearly everything above: chapter VII question 1 on Article 10(1)–(2) applying from 1 January 2030 and on EN 13428:2004 until the end of 2029 (via Article 70(1)(b)); chapter VII question 2 for double walls and false bottoms, the perceived-volume test, the tests and technical documentation, and the geographical-indication and design-right and trademark exemptions; chapter VII question 3 for the standardisation request of 12 February 2027; chapter X question 2 for the application-date list, including the empty-space date and the minimisation date; chapter X question 3 and question 4 for suppliers of packaging not being manufacturers, except for a microenterprise in the same Member State, and for their duty to supply documentation; chapter X question 10 for the declaration of conformity being drawn up per packaging type; chapter XI questions 1 to 4 for the obligated party being the operator who fills the packaging (Art. 24(1)), the filling-materials list and the sales-packaging minimum-necessary rule (Art. 24(4)), the absence of a design-right or trademark exemption in Article 24, and the calculation methodology due by 12 February 2028 with the 1 January 2030 or plus-three-years date (Art. 24(2)); chapter XVI question 1 for enforcement not disrupting trade flows and for the warning-and-corrective-action sequence under Article 62; and the chapter list and the summary of main provisions in chapter I for the 50% figure. Note its own disclaimer: it reflects the views only of its authors and is not binding law
European Commission, DG Environment — Packaging waste Official. Read for this page. Regulation (EU) 2025/40 "in force since 11 February 2025", application date 12 August 2026, and the PPWD generally repealed on 12 August 2026 with some provisions continuing
Regulation (EU) 2025/40 (PPWR) — EUR-Lex The governing text, and what the FAQ interprets. We could not open it when writing this page — EUR-Lex declined our requests — so article and paragraph numbers here trace back to the FAQ quoting them. Where the two disagree, this is what governs
Packaging Gateway — Void fill now counts against EU packaging compliance (2 October 2026) Secondary, and the report that prompted this page. We could not read its body — the page returns tracking scripts rather than text to our tools and rejects direct requests — so we list it for transparency and nothing on this page is sourced to it. The summary of it that reached us put the duty as live since 12 August 2026 and packaging at risk of being turned away at the border; neither is supported by the Commission's FAQ as we read it

Help us keep this page honest

What would improve this page most is not more reading. It is two measurements from a real parcel: the internal volume of the box you use, and the volume of what goes in it — plus, if you have already changed box sizes this year, what your damage rate did afterwards. That is the number a duty about empty space should be argued with, and nobody publishes it.

Tell us on Discord The Commission's PPWR FAQ What counts as packaging