How the PPWR empty space rule really works (and why to act now, not in 2030)

Two rules keep getting mixed up whenever someone mentions "the PPWR empty space rule". One has been in force since 12 August 2026. The other only bites from 2030. They ask different things. Here is what applies now, and what you should actually be doing today.

What has applied since 12 August 2026

Article 10(2) of Regulation (EU) 2025/40 prohibits packaging whose format gives a misleading impression of volume. No double walls, no false bottoms, no design tricks that make a box look bigger than the goods inside justify.

This is a straight prohibition, enforceable from day one by national supervisory authorities. There is no grace period. If an inspector opens a shipment and finds a double-walled box hiding a small product, and you cannot produce the accompanying EU declaration of conformity, you have a problem.

What the 50% cap actually says

The rule people mean when they say "50% empty space" comes into force on 1 January 2030, or three years after the Commission publishes the calculation methodology, whichever is later. That methodology is due by February 2028.

For grouped, transport and e-commerce packaging, no more than 50% of the internal volume may be empty. The point most buyers miss: filler material counts as empty space. Air pillows, bubble wrap, foam chips, paper padding, all of it. The Commission guidance is explicit.

What this looks like for an average shipment

Most webshops we speak to run on three or four box sizes. For a broad SKU range, that is not enough. A book of 15 x 22 x 3 cm in a 30 x 20 x 20 box is already well above the 50% threshold, even when the rest is neatly filled with kraft paper.

The math: (30 x 20 x 20) = 12,000 cubic cm outer volume. The book is 990. Empty space = 11,010 / 12,000 = 91.75%. On that shipment, you are nowhere near compliant without redesigning the format.

Three things you can do this quarter

One, measure your top 20 SKUs. Product dimensions against box dimensions, work out the ratio, flag anything above 60%. That is your risk list.

Two, ask your supplier for two or three in-between sizes. For most webshops the missing formats sit between "small mailer" and "medium box". One extra size in the middle typically covers 40% of the risk list.

Three, give your pickers a simple rule. Grab the smallest box the product fits in without needing tape reinforcement. It sounds obvious, but most warehouses do not state it explicitly, and pickers default to the bigger box out of caution.

Where reusable fits in

Reusable shipping packaging generally needs no filler. Our Stonepacker box is ~30 x 20 x 20 cm and fits the standard formats that many webshops currently over-package. For smaller items, customers use our envelope, which removes the air pillow problem entirely.

As we cover in the TCO breakdown, the reusable business case starts to work above ~300 shipments per week. Below that threshold, sizing your existing cardboard properly is usually the shorter path to PPWR compliance. See also our walk-through of the 40% reuse targets for 2030.

What to do this week

Open your Shopify or WooCommerce analytics, export your top 20 products over the last three months, and list next to each SKU the box size you are using. If five or more sit above the 60% ratio, that is your starting point for a conversation with your packaging supplier about intermediate formats.

The 50% cap is three years out, but the ban on fake-volume design is already law. And the trip from "we have got the wrong mix of formats" to "we have got the right ones" takes six to nine months for a medium-sized webshop. Start in October 2026 and you are done by Q2 2027. Wait until 2029 and you are firefighting.

Want to see whether our Stonepacker fits your mix? Request a free sample and Roel replies personally within one business day.