PPWR Empty Space Ratio for Transport Packaging: Worked Example
Updated
Vojtech Dousa
Article 24 of Regulation (EU) 2025/40 sets a 50 % limit on empty space in grouped, transport and e-commerce packaging. The formula, dates, exemptions, re-use targets and a worked example.
Short answer: Article 24(1) of Regulation (EU) 2025/40 sets a maximum empty space ratio of 50 %. The limit applies to the economic operator who fills grouped, transport or e-commerce packaging. It applies from 1 January 2030 at the earliest. The ratio is the empty space divided by the total volume of the packaging. The empty space is the total volume minus the volume of the sales packaging inside. Reusable packaging within a re-use system is exempt from the limit. In the example below, the same 12 sales units give a ratio of 60.9 % in a 600 × 400 × 300 mm box and 21.8 % in a 400 × 300 × 300 mm box.
Each legal fact cites its article in the official text of Regulation (EU) 2025/40 on EUR-Lex. All inputs in the example are example assumptions. Replace them with the data of your packaging.
PPWR rules for transport, grouped and e-commerce packaging
The regulation was published in the Official Journal on 22 January 2025. It entered into force on 11 February 2025, the twentieth day after publication. It has applied since 12 August 2026 (Article 71). Several rules in the table below apply from later dates. The table lists the rules that concern transport, grouped and e-commerce packaging.
| Rule | Article | What the text requires |
|---|---|---|
| Packaging minimisation | 10(1) | By 1 January 2030, the manufacturer or importer designs packaging so that its weight and volume are the minimum necessary for its function. The shape and the material of the packaging are taken into account. |
| Minimisation standards | 10(3) | By 12 February 2027, the Commission requests harmonised standards for the calculation method. For common packaging types, the standards should give maximum weight and volume limits and, where appropriate, wall thickness and maximum empty space. |
| Minimisation evidence | 10(4) | The technical documentation shows compliance with Article 10(1) and 10(2). It can contain test results, studies, modelling and simulations used to find the minimum necessary volume or weight. |
| Empty space limit | 24(1) | The economic operator who fills grouped, transport or e-commerce packaging keeps the maximum empty space ratio at 50 %. The limit applies from 1 January 2030, or 3 years after the implementing acts under Article 24(2) enter into force, whichever is later. |
| Calculation method | 24(2) | By 12 February 2028, the Commission adopts implementing acts with the method to calculate the empty space ratio. |
| Sales packaging | 24(4) | By 12 February 2028, the economic operator who fills sales packaging reduces its empty space to the minimum necessary for its function. This paragraph sets no percentage. |
| Exemptions from the limit | 24(5) | Reusable packaging within a system of re-use, and sales packaging used as e-commerce packaging, are exempt from Article 24(1). Both must still meet Article 10. |
| Re-use target, transport packaging | 29(1) | From 1 January 2030, at least 40 % of the transport packaging that an economic operator uses in the EU is reusable packaging within a re-use system. From 1 January 2040, the operator endeavours to reach 70 %. The formats are pallets, foldable plastic boxes, boxes, trays, plastic crates, intermediate bulk containers, pails, drums and canisters. Pallet wrapping and straps are also in scope. |
| Transport between own sites | 29(2) | From 1 January 2030, transport packaging between the operator's own sites, or to the sites of a linked or partner enterprise, must be reusable within a re-use system. Recommendation 2003/361/EC defines linked and partner enterprises. |
| Deliveries in the same Member State | 29(3) | From 1 January 2030, transport packaging that delivers products to another economic operator in the same Member State must be reusable within a re-use system. |
| Outside Article 29(1) to 29(3) | 29(4) | Packaging for dangerous goods under Directive 2008/68/EC. Custom-designed packaging for large-scale machinery, equipment and commodities. Flexible packaging in direct contact with food or feed. Cardboard boxes. |
| Re-use target, grouped packaging | 29(5) | From 1 January 2030, at least 10 % of grouped packaging in the form of boxes, other than cardboard, is reusable within a re-use system. The aim for 2040 is 25 %. |
| Micro-enterprises | 29(13) | A micro-enterprise that makes available not more than 1,000 kg of packaging in a Member State in a calendar year is exempt from the targets for that year. |
| Counting and reporting | 30, 31 | The operator counts equivalent units of reusable and other packaging for each calendar year (30(1)). The Commission adopts the calculation method by 30 June 2027 (30(3)). Proof of the targets applies from 1 January 2030, or 18 months after that act enters into force, whichever is later (30(4)). The first reporting year is 2030 (31(3)). |
The date in Article 24(1) depends on the implementing acts. If they enter into force after 1 January 2027, the limit applies 3 years after their date. For example, implementing acts in force from 1 March 2028 move the date to 1 March 2031.
Definitions that decide the scope
- Sales packaging forms a sales unit of product and packaging for the end user at the point of sale (Article 3(1)(5)).
- Grouped packaging groups a number of sales units. The group can be sold as such, help to restock shelves, or create a stock-keeping or distribution unit. It can be removed without a change to the product (Article 3(1)(6)).
- Transport packaging helps to handle and transport one or more sales units, or groups of sales units, and prevents damage. Road, rail, ship and air containers are not transport packaging (Article 3(1)(7)).
- E-commerce packaging is transport packaging that delivers products sold online, or by other distance sales, to the end user (Article 3(1)(8)).
- Re-use system means the organisational, technical or financial arrangements, with incentives, that allow re-use in a closed loop or an open loop (Article 3(1)(31)).
- Empty space and empty space ratio have their definitions in Article 24(3). The formulas below use them.
How to calculate the empty space ratio
- Total volume = the volume of the grouped, transport or e-commerce packaging.
- Empty space = total volume − volume of the sales packaging inside it (Article 24(3)(a)).
- Empty space ratio = empty space ÷ total volume × 100 % (Article 24(3)(b)).
- Space that filling materials occupy is empty space. The text names paper cuttings, air cushions, bubble wraps, sponge fillers, foam fillers, wood wool, polystyrene and Styrofoam chips (Article 24(3)).
- Minimum number of sales units for a ratio of 50 % or less = 0.5 × total volume ÷ volume of one sales unit, rounded up. This step follows from formulas 2 and 3.
Article 24(2) leaves the calculation method to implementing acts. The text does not say if the total volume is the internal or the external volume of the packaging. It does not say which volume to subtract for products without sales packaging. Article 24(2) lists cases that the method must take into account. They include products of irregular shape, packaging with more than one sales packaging or product, fragile products and the space for shipment labels. The example below therefore calculates both volume bases.
Worked example: one order, two box sizes
A distributor ships spare parts in retail boxes. One order has 12 retail boxes. The distributor fills single-use corrugated boxes, which are transport packaging. Article 24(5) does not exempt them, and Article 29(4) keeps cardboard boxes out of the re-use targets. Two box sizes are available.
| Example assumption | Box A | Box B |
|---|---|---|
| Retail box (sales unit), outer dimensions | 190 × 130 × 95 mm | 190 × 130 × 95 mm |
| Retail boxes in the order | 12 | 12 |
| Transport box, internal dimensions | 600 × 400 × 300 mm | 400 × 300 × 300 mm |
| Wall thickness | 5 mm | 5 mm |
| Transport box, external dimensions | 610 × 410 × 310 mm | 410 × 310 × 310 mm |
| Retail boxes that fit in one orientation | 27 (3 × 3 × 3) | 12 (2 × 2 × 3) |
| Filling material | Air cushions in the free space | None |
- Volume of one retail box = 190 × 130 × 95 mm = 2,346,500 mm³ = 2,346.5 cm³.
- Sales packaging volume of the order = 12 × 2,346.5 = 28,158 cm³.
- Box A, internal basis: total volume = 600 × 400 × 300 mm = 72,000 cm³. Empty space = 72,000 − 28,158 = 43,842 cm³. Ratio = 43,842 ÷ 72,000 = 60.9 %.
- Box A, external basis: total volume = 610 × 410 × 310 mm = 77,531 cm³. Empty space = 77,531 − 28,158 = 49,373 cm³. Ratio = 49,373 ÷ 77,531 = 63.7 %.
- Box B, internal basis: total volume = 400 × 300 × 300 mm = 36,000 cm³. Empty space = 36,000 − 28,158 = 7,842 cm³. Ratio = 7,842 ÷ 36,000 = 21.8 %.
- Box B, external basis: total volume = 410 × 310 × 310 mm = 39,401 cm³. Empty space = 39,401 − 28,158 = 11,243 cm³. Ratio = 11,243 ÷ 39,401 = 28.5 %.
- The air cushions do not change the ratio of box A. Article 24(3) counts the space that they occupy as empty space.
- Minimum retail boxes in box A for 50 % or less: internal basis 0.5 × 72,000 ÷ 2,346.5 = 15.3, rounded up to 16. External basis 0.5 × 77,531 ÷ 2,346.5 = 16.5, rounded up to 17.
| Box | Volume basis | Total volume | Empty space | Empty space ratio | Against 50 % |
|---|---|---|---|---|---|
| A | Internal | 72,000 cm³ | 43,842 cm³ | 60.9 % | Above |
| A | External | 77,531 cm³ | 49,373 cm³ | 63.7 % | Above |
| B | Internal | 36,000 cm³ | 7,842 cm³ | 21.8 % | Within |
| B | External | 39,401 cm³ | 11,243 cm³ | 28.5 % | Within |
Box A is above the limit on both bases. Box B is within the limit on both bases, and the order fills it. The volume basis changes the ratio by 2.8 percentage points for box A and by 6.8 points for box B. Near 50 %, the basis can decide the result. In box A, the order needs 16 retail boxes on the internal basis and 17 on the external basis.
Map Optipacker data to the calculation
Optipacker calculates how many parts fit in a container and shows the layout in 3D. The table shows which Optipacker data gives each input of the calculation.
| Calculation input | Optipacker data | How to use it |
|---|---|---|
| Total volume, internal basis | Container internal dimensions | The packing calculation uses the internal dimensions. |
| Total volume, external basis | Container external dimensions | The container record stores the external and the internal dimensions. |
| Volume of one sales unit | Part dimensions | Enter the retail box as a box-shaped part with its outer dimensions. For a box, the bounding volume is the volume of the sales packaging. |
| Number of sales units | Packed quantity | The packing result gives the quantity that fits with the gaps, clearances and rotations that you set. |
| Empty space ratio, internal basis | 100 % − volume utilization | Volume utilization is the packed quantity × part volume ÷ internal volume. On the packing example, read the Void figure. In a saved configuration, read the parts-only Volume Efficiency. |
| Inserts and filling materials | Insert material volume | The configuration void space subtracts the insert material volume. Article 24(3) counts filling materials as empty space. Use the parts-only figure for an Article 24 estimate. |
To repeat the example, open the packing example and select the box shape. Enter 190 × 130 × 95 mm and the quantity. The page compares three prepared containers and shows Envelope space used and Void for each.
Optipacker shows the Article 24 basis next to the packing results. It does not ask for the packaging category, the re-use status or the calculation method. The EU Compliance card therefore shows Not assessed, and Optipacker gives no compliance verdict.
Parts can travel without sales packaging, for example machined parts in a container. For these parts, Article 24(3) does not name the volume to subtract. Optipacker can give the bounding volume of the parts or the part volume stored on the part. Keep the basis with each figure. Read shape-aware vs bounding-box packing measurements for the size of that difference on real parts.
Returnable containers and the re-use targets
A returnable container used within a re-use system is exempt from the 50 % limit (Article 24(5)). It must still meet the minimisation rule of Article 10. For reusable packaging, the Article 10 assessment takes into account the characteristics of reusable packaging and, first, the requirements of Article 11 (Article 10(4)).
From 1 January 2030, Article 29(2) and 29(3) require reusable transport packaging for transport between your own sites and for deliveries in the same Member State. Size the pool of containers and pallets for such a loop with the returnable loop calculator. Read the worked example of pool size and payback for example inputs and results.
Prepare your packaging data
- Classify each packaging item as sales, grouped, transport or e-commerce packaging (Article 3(1)).
- Mark the packaging that is reusable within a re-use system. Article 24(5) exempts it from the 50 % limit.
- Record the internal and the external dimensions of each box or container.
- Record the outer dimensions of each sales unit and the number of units in each pack.
- Record filling materials and inserts as separate items.
- Calculate the empty space ratio on both volume bases. Mark each pack above 50 % on either basis.
- Calculate the ratio again when the implementing acts under Article 24(2) set the method.
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