PPWR packaging minimisation

PPWR Art. 10 requires weight and volume to be reduced to the absolute minimum. Assess your readiness (Reg. (EU) 2025/40, Art. 10 and Annex IV).

Standards pending 2027

Your role

Evidence level

Deadline: 1 January 2030

Packaging with characteristics exclusively aimed at increasing the perceived volume of the product (including double walls, false bottoms and unnecessary layers) shall not be placed on the market.

Annex IV criteria

0/5 confirmed

1. Weight & Volume JustifiedCan you document why the packaging is this exact size and weight?

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Yes: Documented business reason (e.g., "3mm wall needed for drop test").

No: Spec chosen from a catalog years ago; never reviewed.

ActionWrite a 1-paragraph justification document for your compliance file.

Manufacturer note: Run a spec review: can board, glass, or plastic drop 10 to 20% without failing transit tests?

2. No Deceptive ElementsDoes every structural element serve a function beyond looking bigger?

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Yes: Every layer has a purpose (insulation, impact absorption).

No: False bottoms, decorative inserts, unnecessary double walls.

ActionList each element and its function; flag anything decorative-only for redesign before 2030.

Manufacturer note: Walk SKUs: gift inserts, false bases, double walls for shelf appeal only are high risk.

3. Empty Space JustifiedIs there a functional reason for air gaps around the product?

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Yes: Gas flush, thermal expansion, or drop-protection clearance.

No: Product fills under 70% of the box mainly for shelf presence, with no documented reason.

ActionMeasure fill ratio; if below ~70%, write why (gas flush, cushioning, legal fill line, etc.).

Manufacturer note: Per SKU: document headspace / gap reasons on the product spec.

4. Minimal Material LayersIs every layer (primary, secondary, tertiary) functionally necessary?

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Yes: Each layer has a documented barrier, labelling, legal, or transit role.

No: An extra wrap or carton exists only for branding or shelf feel.

ActionTeardown one SKU layer-by-layer; remove or justify each layer in your file.

Manufacturer note: Top SKUs: layer list + purpose is the core of your Art. 10 technical record.

5. Wall Thickness MinimisedAre walls/bases reduced to the minimum viable thickness?

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Yes: Thickness matches drop/stack/moisture needs; lighter options were considered.

No: Same heavy gauge everywhere with no test rationale.

ActionFor each material: note thickness, requirement, and any thinner alternative tested.

Manufacturer note: Keep compression/drop reports if you reduced gauge; strong Art. 10 evidence.

Art. 24 limit

Void space ratio (preview)

Grouped, transport & e-commerce packaging: empty space ratio must not exceed 50%. Indicative only: use the full calculator below for your scenario.

Total package volume1000 cm³

Product volume650 cm³

Void ratio

35%

≤50% (indicative)

Void-space ratio for grouped / transport / e-commerce packaging → assessed under Art. 24. Open full PPWR void space (Art. 24)

Art. 10 derogations (design, trade mark, GI)

Art. 10 does not apply in specific cases (confirm against the consolidated text):

Packaging protected by a Community design or EU trade mark registered before 11 February 2025, where altering the packaging would alter the novelty or individual character of the design or trade mark.
Products benefiting from a protected geographical indication (GI) under Union law.

I've checked: no Art. 10 derogation applies (no pre-2025 design/trade mark or protected GI).

Optional: included on PDF export

Company / organisation

Product or SKU

Self-assessment only. Not legal advice. No EU-wide minimisation formula until harmonised standards publish.