The 40% empty-space rule, explained
For grouped packaging, transport packaging and e-commerce packaging, the empty-space ratio must not exceed 40%. Empty space is the volume of the packaging minus the volume of the products inside (including protective fillers that aren't strictly necessary). In practice: if your parcels ship a lot of air, they will fail.
How to estimate it: empty-space ratio = 1 − (volume of goods + necessary protection) ÷ internal packaging volume. Aim below 0.40.
Article 10 minimisation — what assessors look at
Packaging must be designed to the minimum adequate weight and volume, removing: double-walls, false bottoms, unnecessary layers, decorative or marketing-only additions that increase weight, and features that hinder recyclability. The Commission's harmonised measurement methodology for minimisation is due by 12 February 2027 — designing to the principle now avoids rework later.
Who must comply
Manufacturers, brand owners (fillers), importers and e-commerce sellers placing packaging on the EU market — including non-EU sellers shipping to EU consumers. There is no general size exemption.
What happens if you don't
Non-minimised packaging can be refused market access from 12 August 2026, and excess weight increases your EPR fees (contributions are weight-based and modulated). Minimisation is both a compliance and a cost lever.
Assess your packaging
Run the free PPWR readiness assessment to see which of your SKUs are at risk on minimisation and empty space — free up to 5 SKUs, live the same day.