PPWR and empty space: what the EU regulation actually changes for your parcels

Quick answer:

• The PPWR (Regulation EU 2025/40) has applied since 12 August 2026. What actually bites on that date is mainly the PFAS restriction on food contact packaging, not the size of your parcels.
• The 50 % empty space cap is set by Article 24 for 1 January 2030, or three years after the EU calculation methodology enters into force, whichever is later. That methodology is due by 12 February 2028.
• It binds whoever fills the box, so you or your 3PL. The Commission has put that in writing.
• Void fill counts as empty space. Crumpled paper, air cushions, bubble wrap, polystyrene: all named in the text.
• Two exemptions almost nobody cites: shipping in the product's own sales packaging, and reusable packaging within a re-use system.
• Cardboard boxes are excluded from the 2030 re-use targets.
• Volumetric weight has nothing to do with this law. It is a carrier pricing rule, already in force, and it is the one costing you money today.

For a few months now an idea has been circulating in ecommerce: a new EU law bans oversized parcels, with fines attached. Some articles put the threshold at 40 % empty space and said it applied from January. That is wrong on the threshold, wrong on the date, and wrong on the mechanism.

The trouble is that the real rule does exist, it is written down, and it deserves to be read calmly rather than in a panic. We read the official text. Here is what it says.

The PPWR in one minute

Regulation (EU) 2025/40 on packaging and packaging waste, better known as the PPWR (Packaging and Packaging Waste Regulation), was adopted on 19 December 2024 and published in the Official Journal on 22 January 2025.

Article 71 leaves no room for doubt: "It shall apply from 12 August 2026." On that date the old Directive 94/62/EC is repealed, subject to the transitional carve-outs listed in Article 70.

Two practical consequences. This is a regulation, not a directive: it applies directly in all 27 Member States, with no national transposition law needed. And because it replaces a 1994 text, it carries a calendar spread over fifteen years, with most of the concrete obligations landing in 2030, not today.

That confusion, between the date the regulation applies and the date each individual obligation kicks in, is what fed every alarmist article on the subject.

Article 24, word for word

This is the provision that concerns you. Here is paragraph 1, in the official English text:

"By 1 January 2030 or 3 years from the entry into force of the implementing acts adopted pursuant to paragraph 2, whichever is the latest, economic operators who fill grouped packaging, transport packaging or e-commerce packaging shall ensure that the maximum empty space ratio, expressed as a percentage, is 50 %."

Let us take it apart, because every piece matters.

The deadline has two triggers

It is not "1 January 2030". It is "by 1 January 2030 or three years from the entry into force of the EU calculation methodology, whichever is the latest".

Paragraph 2 of the same article gives the Commission until 12 February 2028 to adopt the implementing act establishing that methodology. Do the arithmetic, bearing in mind that the countdown starts from the act's entry into force rather than its adoption, some twenty days later: if the Commission publishes on the deadline, three years takes us to spring 2031, and that is the date that applies. For the cap to actually bite on 1 January 2030, the methodology would have to be in force before 1 January 2027.

In other words, 2030 is the floor, not the ceiling. That is not a reason to do nothing. It is a reason not to panic.

Who is bound: whoever fills the box

The text targets "economic operators who fill" the packaging. This matters, because a lot of commentary pins the obligation on the box manufacturer.

The Commission settled it in its guidance published on 10 June 2026 in the Official Journal:

"The empty space ratio in Article 24 applies to grouped, transport, and e-commerce packaging and needs to be complied with by the natural or legal person using or filling such packaging."

In ecommerce, the person filling the box is you. Or your fulfilment provider if you are with a 3PL, in which case the question is settled in your contract. Your box supplier answers for something else, namely Article 10 on design.

What "e-commerce packaging" means

The regulation defines it precisely in Article 3: "transport packaging used to deliver products in the context of sale online or through other means of distance sales to the end user".

So it is the shipping box, the one your customer opens. Not the product box.

How empty space is calculated

Paragraph 3 sets out two definitions:

• Empty space is the difference between the total volume of the parcel and the volume of the sales packaging it contains.
• The empty space ratio is the ratio of that empty space to the total volume of the parcel.

Note the subtlety: the comparison is against the volume of the sales packaging, not the bare product. If your product arrives in its own box, that box counts as filled volume.

And the third subparagraph closes the obvious loophole:

"Space filled by filling materials, such as paper cuttings, air cushions, bubble wraps, sponge fillers, foam fillers, wood wool, polystyrene or Styrofoam chips, shall be considered as empty space."

Stuffing the box to fill it changes nothing in the calculation. It is written down, with the list of materials.

What the methodology will have to allow for

Paragraph 2 requires the Commission to take account of cases where empty space is legitimate: irregularly shaped products, parcels containing more than one sales unit, liquids, products whose contents are easily damaged, small products that could be crushed by larger ones. And one very concrete detail that is almost always overlooked: "the minimum space on the transport packaging to enable shipment labels to be affixed".

Translation: a parcel will not have to be so small that you can no longer stick the shipping label on it.

The two exemptions nobody talks about

Article 24(5) is the most useful passage in the text for a merchant, and the one you see cited least:

"Economic operators using sales packaging as e-commerce packaging or using reusable packaging within a system of re-use shall be exempt from the obligation laid down in paragraph 1 of this Article."

Two cases, then:

1. You ship the product in its own sales box, with no outer box. The 50 % cap does not apply.
2. You use reusable packaging within a system of re-use. Same result.

In both cases one condition remains: the packaging must meet the minimisation requirements in Article 10. It is not a blank cheque, but it is a real way out, and it rewards exactly the practice we already recommend on cost grounds.

What actually takes effect on 12 August 2026

Everyone asks this, so let us answer it plainly. For an ecommerce merchant, here is what is genuinely live today, and nothing else.

1. The PFAS restriction on food contact packaging. Article 5(5) has banned, since that date, placing food contact packaging on the market at or above 25 ppb of PFAS by targeted analysis. Relevant if you sell food. Otherwise, not at all.

2. The EU declaration of conformity. Article 15 requires the packaging manufacturer to run a conformity assessment, draw up technical documentation and issue an EU declaration of conformity. Relevant if your boxes carry your brand, because the regulation then makes you the manufacturer. More on that below.

3. EPR registration and the authorised representative, if you sell direct into another EU country. Articles 44 and 45 apply with no deferral. It is the only obligation on this list that blocks market access rather than merely triggering a fine. We cover it in full in our article on the EPR authorised representative.

4. The repeal of Directive 94/62/EC, and with it the handover of national packaging laws. In Germany, for instance, the VerpackG has given way to the VerpackDG.

And here, just as important, is what does not take effect in 2026:

Put differently: if an article tells you your boxes have been unlawful since 12 August, it is confusing the date the regulation became applicable with the date each obligation kicks in. Those are two different things, and that is where all the noise comes from.

The real timeline

Penalties: there is no EU fine

This is the other point the alarmist articles miss. The regulation sets no amount at all. Article 68 hands that job to the Member States, with a deadline of 12 February 2027, and a single substantive constraint: for breaches of Articles 24 to 29, penalties "shall include fines", and they must be "effective, proportionate and dissuasive".

Germany has already published its own. The Verpackungsrecht-Durchführungsgesetz, the German act implementing the regulation, published in the Federal Law Gazette on 17 July 2026, lists in its Section 66 the breaches that carry a fine. Its subsection 2, point 17, names the failure to keep the Article 24 empty space ratio at or below 50 %.

The amount is where the widely repeated "up to €200,000" gets it wrong. The German scale has three tiers: up to €200,000, up to €100,000, and up to €10,000 for everything else. The empty space ratio appears in neither the first nor the second list, so it falls into the third: up to €10,000. For comparison, the 40 % reusable transport packaging target does sit in the €200,000 tier.

In other Member States we have not found a published scale to date.

And in any case the amount stays theoretical for as long as the obligation itself does not apply, which means not before 2030.

Three obligations closer than the 50 % rule

If you are looking for what will actually land on you in the next two or three years, it is not the empty space ratio.

1. Cross-border EPR, if you sell direct into another EU country

This is the heaviest provision and the least discussed, and it is the only one of the three already fully in force.

Article 3 defines "producer" very broadly: a producer is anyone who, "regardless of the selling technique used, including distance contracts", makes packaged products available for the first time on the territory of another Member State, directly to end users.

Read that definition again if you ship from outside the EU. It catches operators "established in a Member State or in a third country". A UK, Swiss or US seller shipping direct to consumers in the EU is a producer in every destination country, exactly like an EU-based one.

Article 44 requires you to register in the national producer register of each Member State concerned, and paragraph 4 is blunt: without registration you have no right to make that packaging available on that territory. Article 45(3) adds that if you are not established there, you must appoint an authorised representative by written mandate.

Unlike the empty space cap, this obligation is not waiting on a deadline: Article 71 makes the regulation applicable from 12 August 2026 and defers neither Article 44 nor Article 45. The implementing act still outstanding only concerns the harmonised format of national registers, not the obligation itself. And Spain has required an authorised representative since 2022, and France since July 2026, under their own national law.

So this is the line to watch first if you ship across Europe, well before the size of your boxes. We cover it in full in our article on the EPR authorised representative, and it runs into the same territory as our guide to customs compliance for EU shipments.

2. The EU declaration of conformity, if your boxes carry your brand

Article 15 requires the manufacturer of packaging, before placing it on the market, to carry out a conformity assessment, draw up technical documentation and write an EU declaration of conformity. That obligation has been live since 12 August 2026.

And Article 3(1)(13) defines "manufacturer" as the person who has packaging designed or manufactured under its own name or trademark, "regardless of whether any other trademark is visible on the packaging". If you have your boxes printed with your logo, you are potentially the manufacturer for the purposes of the regulation, not your box supplier.

The Commission is explicit about the consequence: "there is always only one manufacturer in a supply chain within the meaning of the PPWR". So this is not a responsibility you share with your supplier. It moves to one of you.

There is one way out, and it is narrow: if you meet the EU definition of a micro-enterprise (fewer than 10 employees and EUR 2 million in turnover or balance sheet total, as set out in Recommendation 2003/361/EC as applicable on 11 February 2025) and your supplier is located in the same Member State as you, then your supplier is deemed the manufacturer. Above that threshold, the question is open. Ask your supplier who holds the declaration.

3. The sorting label, which does cover the ecommerce parcel

Article 12 requires a harmonised label showing material composition, by 12 August 2028 at the latest. It excludes transport packaging from that obligation, with the exception of e-commerce packaging. Your shipping box is in scope, while your supplier's pallet wrap is not.

No, your cardboard boxes do not have to become reusable

The 40 % reusable transport packaging target for 1 January 2030 does exist, in Article 29. It made a lot of noise. But paragraph 4 lists the exclusions, and point (d) runs to five words: "in the form of cardboard boxes".

The Commission locked the subject down in its guidance, noting that Member States cannot "set re-use targets for transport packaging, such as cardboard boxes, which are expressly exempted from re-use under PPWR".

The ordinary shipping box is out of scope. What Article 29 targets is pallets, foldable plastic boxes, crates, drums, buckets and bulk containers. If you are a merchant shipping in single-use cardboard, this line of the timeline is not about you.

Volumetric weight is not the PPWR

This is the underlying confusion in every article on the subject, and it deserves to be laid out plainly.

Volumetric weight (or DIM weight, for dimensional weight) is a carrier pricing practice with no connection whatsoever to environmental law. The carrier derives a weight from the parcel's volume, compares it to the actual weight, and bills the higher of the two. With most European carriers the formula is (L × W × H in cm) ÷ 5,000. The per-carrier detail is in our volumetric weight guide.

Both push in the same direction: stop sending a small item in a large box. But one costs you money this month, the other might cost you a fine in five years. If you have to prioritise, the answer is obvious.

What to do now

Nothing urgent in regulatory terms. Plenty that is useful in economic terms.

• Cut your box range down to three or four well-chosen sizes. Too many options on the packing bench guarantees that someone grabs the top box rather than the right one. Fewer formats, sized around your ten best sellers.
• Look at variable-height boxes. They adjust to the contents, cut volumetric weight straight away, and the empty space ratio with it.
• Treat void fill as empty space today. That is what the law will do. Minimal, well-placed protection guards a product as well as a box stuffed with paper, costs less to buy, and lightens the shipping invoice.
• Check whether you can ship in the sales packaging. It is the one genuine exemption in Article 24, and it is also the cheapest parcel you can send.
• If you sell direct into several EU countries, open the EPR file. It is the only obligation on this list already in force, and it blocks market access rather than merely triggering a fine. Start by checking whether you appear in the public registers of the countries you ship to, then read our article on the EPR authorised representative.
• If your boxes carry your brand, ask your supplier who holds the declaration of conformity. The answer fits in an email, and it is already enforceable.

Where ParcelRush helps, and where it does not

Let us be clear about scope: ParcelRush does not measure your empty space ratio and does not produce your PPWR compliance. That part happens on your packing bench and with your box supplier.

What the platform does is show you the cost of your packaging before you pay for it. From the order's dimensions, weight and destination, it applies the rules of every carrier connected to your account, works out the chargeable weight and shows each price. You see immediately what a 40 × 30 × 20 box costs against a 35 × 25 × 15, on the same order, with the same carrier.

It is the same judgement the law will ask of you in 2030, except that it pays for itself on your next shipment. Those trade-offs feed straight into your strategy to reduce shipping costs.

👉 See the carriers available

Sources

Everything quoted here comes from the official text or from the European Commission, not from second-hand coverage.

• European Union, Regulation (EU) 2025/40 on packaging and packaging waste, Official Journal of 22 January 2025. Articles 3, 10, 12, 15, 24, 29, 44, 45, 68, 70 and 71.
• European Commission, guidance on Regulation (EU) 2025/40, communication C/2026/3084, Official Journal of 10 June 2026.
• European Commission, New EU rules on packaging enter into application, 11 August 2026.
• European Commission, Recommendation 2003/361/EC, definition of micro-enterprise.
• Germany, Verpackungsrecht-Durchführungsgesetz, Section 66, fine provisions.

The Article 24 timeline depends on an implementing act that has not been published yet. National penalty regimes are due by 12 February 2027: Germany has published its own, most others have not. Both of those will move. The texts cited above are what stands.

Frequently asked questions

Does the PPWR ban oversized parcels from 12 August 2026?

No. Regulation (EU) 2025/40 has applied since 12 August 2026, but the 50 % empty space cap is set by Article 24 for 1 January 2030, or three years after the EU calculation methodology enters into force if that date is later. What kicks in on 12 August 2026 is mainly the PFAS restriction on food contact packaging.

Who has to comply with the 50 % empty space rule?

The natural or legal person who fills the box. The Commission guidance says it explicitly: the Article 24 empty space ratio needs to be complied with by the person using or filling the packaging. In ecommerce that is the merchant or their fulfilment provider, not the box supplier.

Do bubble wrap and air cushions count as empty space?

Yes. Article 24 names paper cuttings, air cushions, bubble wraps, sponge fillers, foam fillers, wood wool, polystyrene and Styrofoam chips. Adding void fill to bulk out a box does not lower the empty space ratio.

Are there exemptions to the 50 % rule?

Two, in Article 24(5). Operators using the product's sales packaging as e-commerce packaging are exempt, as are those using reusable packaging within a system of re-use. In both cases the packaging must still meet the minimisation requirements in Article 10.

Will my cardboard boxes have to be reusable in 2030?

No. Article 29 does set a 40 % reusable transport packaging target for 1 January 2030, but paragraph 4 expressly excludes cardboard boxes. The Commission confirmed in its guidance that Member States cannot set re-use targets for cardboard boxes.

Is volumetric weight the same thing as the PPWR?

No, they are two unrelated mechanisms. Volumetric weight is a carrier pricing rule, applied for years, that bills the higher of actual weight and weight derived from volume. The PPWR is an EU regulation. Both push in the same direction, but one hits your invoice and the other your compliance.