PPWR Art. 24: How the 50% Void Space Rule Works

What is PPWR Article 24?

The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, introduces binding void space limits for specific packaging categories. Article 24 targets the wasted space that consumers and logistics operators have long complained about: oversized boxes for small products, air-heavy mailers, and unnecessarily large grouped packs.

From 1 January 2030, empty space must not exceed 50% of the total package volume for:

• E-commerce packaging: boxes or mailers used to ship products ordered online and delivered directly to consumers
• Grouped packaging: formats that bundle multiple sales units together (e.g. multipacks, club packs)
• Transport packaging: outer boxes, pallets, and handling units in B2B supply chains

Sales packaging (the primary pack you see on a retail shelf) is generally exempt, as are service packaging formats used in takeaway food and beverage.

How to calculate your void ratio

The void ratio formula under PPWR Art. 24 is straightforward:

Void ratio = (Package volume − Product volume) / Package volume × 100%

Package volume is the total internal volume of the closed container, measured to the inner walls.

Product volume is the volume of all product units placed inside, measured as the displaced volume (not the minimal bounding box).

If you are shipping a book (25 × 18 × 3 cm = 1,350 cm³) inside a box (30 × 22 × 8 cm = 5,280 cm³), your void ratio is (5,280 − 1,350) / 5,280 = 74.4%: well above the 50% limit.

To comply, you would need to right-size the box to, say, 27 × 20 × 5 cm (2,700 cm³), giving a void ratio of (2,700 − 1,350) / 2,700 = 50.0%: exactly at the limit.

What counts as "necessary space"?

Art. 24 allows some justifiable empty space. The Commission is expected to publish delegated technical guidance, but the Regulation's recitals already indicate that the following may be considered necessary:

Cushioning and protective void: for fragile items, empty space filled with protective materials (air pillows, foam, paper) still counts as void, but may qualify for an exception under future delegated acts

Regulatory or labelling space: space required by product-specific regulations (e.g. medicines, pesticides) that mandate certain packaging dimensions

Technical design constraints: where the manufacturing process of the packaging material sets a minimum size (e.g. a minimum seam width on a carton)

Until the Commission publishes delegated criteria, operators should document and justify any space above 50%.

Who is responsible for compliance?

Under PPWR Art. 3 and Art. 24, the responsible parties are:

• Manufacturers of packaging, who must design packaging that meets the void ratio limit
• Brand owners and retailers who specify packaging dimensions to their supply chain
• Importers placing packaged goods on the EU market from outside the EU

E-commerce operators: brands selling directly to consumers online: are particularly in scope, as the regulation explicitly targets "e-commerce packaging."

Deadlines

• 1 January 2030: 50% void space limit applies to new e-commerce and grouped packaging
• 1 January 2035: The Commission may tighten the limit to 40% based on a review report

Practical steps now

Audit your current packaging portfolio: measure internal dimensions of your top 20 SKUs and calculate void ratios

Flag high-risk formats: anything above 60% void is likely to require redesign before 2030

Engage your packaging supplier: right-sizing requires supply chain coordination, especially for corrugated shippers

Document justifications: for any technically necessary void space, build the written record now

Use the free void space calculator on this site (PPWR Art. 24 tool) to check each format in under a minute.