Working paper
PPWR, and the day empty space becomes illegal
The EU is about to put a hard ceiling on how much air a box may contain. Fifty per cent, on transport and grouped packaging, not just e-commerce. This page works one case to the number, shows what compliance costs in millimetres, and corrects the two dates almost everyone has wrong.
Article 24 caps the empty space ratio at 50%
Regulation (EU) 2025/40. Whoever fills the packaging carries the obligation — not whoever made it. If you pack a case, a pallet or a parcel for supply to a distributor or an end user, it is yours.
| Article 24 at a glance | Detail |
|---|---|
| Maximum empty space ratio | 50% |
| Packaging in scope | Grouped, transport and e-commerce |
| Who is obliged | The operator who fills it |
| Counts as empty space | Air cushions, bubble wrap, foam, paper, wood wool, polystyrene |
| Out of scope | Reusable packaging |
↔ Scroll the table
Read that fourth row again Void fill is not a mitigation. It is the thing being measured. Every cushion you add to protect a product counts against the ratio exactly as if you had shipped the air neat.
The arithmetic, on one real case
Inner volume, less the volume of the goods, over inner volume. It is the same shape of calculation as freight density — and it is measured on the space the packaging encloses, not its outside.
Which makes compliance a case height
Hold the footprint and the contents still and the ratio is nothing but height — exactly as freight class is, one page over. The cap stops being a percentage and becomes a line you could mark on the box.
The number To reach 50% on this footprint the case has to come down from 290 mm to 203 mm — 87 mm out. That is the whole obligation, expressed in the only unit a packing bench can act on.
And the obvious fix does nothing
The instinct, faced with a half-empty case, is to fill it — cushions, paper, chips. Under Article 24 that is not a partial fix. It is not a fix at all.
| Add to the case | Product volume | Empty space ratio |
|---|---|---|
| Nothing | 23.33 L | 65% |
| 5 L of air cushions | 23.33 L | 65% |
| 10 L of paper void fill | 23.33 L | 65% |
| 87 mm off the case height | 23.33 L | 50% |
↔ Scroll the table
Why The regulation names filling materials — paper trimmings, air cushions, bubble wrap, foam, wood wool, polystyrene — as empty space. Only the volume of the product counts on the other side of the fraction. There is exactly one lever: a smaller box.
The two dates almost everyone has wrong
PPWR is being reported with a confidence the text does not support. Both errors run the same way — they make the deadline sound sooner and more certain than it is.
| Date | What actually happens |
|---|---|
| 22 Jan 2025 | Regulation enters into force |
| 12 Aug 2026 | PPWR starts applying — but what bites is narrow: PFAS limits on food-contact packaging and heavy-metal limits. Not the empty space rule. |
| 12 Feb 2027 | Commission must ask the standards bodies for a harmonised measurement method |
| 12 Feb 2028 | Deadline for the implementing act defining how the ratio is calculated |
| 1 Jan 2030 | The 50% cap applies — or three years after that implementing act enters into force, whichever is later. |
↔ Scroll the table
It is the same lever as freight class
Two regulators, two units, one instruction.
| NMFC, since Jul 2025 | PPWR Article 24 | |
|---|---|---|
| Measures | Weight ÷ volume | Product volume ÷ total volume |
| Rewards | Density | Fill |
| Punishes | Shipped air | Shipped air |
| Void fill | Raises cost | Counts against you |
| Failure looks like | A higher rate per cwt | A non-compliant product |
| The fix | A smaller box | A smaller box |
↔ Scroll the table
The real thing A pallet packed to win on freight class is already most of the way to Article 24, and the reverse holds. They are the same optimisation read by two different authorities — which means the work is done once. The regulatory clock puts both on one timeline.
Why 2030 is not far away.
The lever is the carton range, and a carton range is not a thing you change in a quarter. Tooling, artwork, pack-bench retraining, line trials, supplier minimums — the decision to add two case sizes is taken years before the cases exist. A cap that bites in 2030 is a specification decision being made now, mostly by people who have not read Article 24.
The freight-class version of this arithmetic · the parcel version · the full regulatory clock · send us a month of order lines and we will tell you your ratio.
Sources: Regulation (EU) 2025/40, Article 24, and the Commission’s own guidance and FAQs. Grade A — published regulation, not interpretation. The worked case is illustrative: the dimensions are ordinary rather than measured from a customer, and the arithmetic is the point. The methodology implementing act is not yet adopted, so the precise treatment of edge cases — irregular shapes, multi-product packs, liquids, fragile goods, small items shipped alongside large — is not yet settled; the recitals acknowledge that additional empty space may be operationally necessary in those cases. Nothing here is legal advice.