PPWR and void fill for boxes: box size decides, not the fill material
Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) applies from 12. 08. 2026. The 50 % empty space limit for transport and e-commerce packaging, however, applies at the earliest from 01. 01. 2030, realistically around 2031. Paper void fill, air cushions and bubble wrap all count as empty space under the limit. Only a smaller box improves the ratio.
What applies from 12. 08. 2026
From 12. 08. 2026 the Regulation as a whole applies. For void fill these points matter:
- Substances in packaging: the sum of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg (Article 5).
- Roles and documents: whoever places packaging on the market under their own name or brand is responsible for its conformity and keeps the documentation (Article 15 and following). For now these duties apply only to requirements that already apply.
- The 50 % empty space limit does not apply yet. No adopted act has postponed the Regulation, but the limit has its own, later date.
When the 50 % limit starts to apply
Article 24(1) says that economic operators who fill grouped, transport or e-commerce packaging must ensure a maximum empty space ratio of 50 %. The later of these dates applies: 01. 01. 2030, or three years after the implementing act with the calculation method enters into force. The Commission is to adopt the method by 12. 02. 2028. In our interpretation the limit therefore applies at the earliest in 2030 and realistically around 2031.
| Date | What happens |
|---|---|
| 12. 08. 2026 | the Regulation applies; the heavy-metal limit and the duties of economic operators apply |
| 12. 02. 2028 | the Commission is to adopt the empty space calculation method |
| 12. 02. 2029 | ban on loose plastic chips in packaging |
| 01. 01. 2030 or later | the 50 % limit starts at the earliest; minimisation of packaging volume and weight (Article 10) |
| 12. 02. 2032 | the Commission reviews the limit and the exemptions |
The Commission has already missed several other PPWR deadlines. A delay of the method cannot be excluded, but no source claims it so far.
Who the limit applies to
- The limit applies to grouped, transport and e-commerce packaging. E-commerce packaging is transport packaging for distance sales.
- The duty lies with whoever fills the shipment. This may be the e-shop or a warehouse that packs.
- Exemption: sales packaging used as e-commerce packaging (for example goods in the manufacturer’s original box). It must still meet Article 10.
- Exemption: reusable packaging within a re-use system.
- Cardboard boxes are not exempt from Article 24.
Does void fill count as empty space?
Yes. Article 24(3) says: “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.”
From the text it follows:
- Paper, air cushions and bubble wrap count the same. No material has an advantage.
- Void fill does not improve the ratio. Only a smaller box, or a larger sales packaging inside, does.
- The limit does not ban void fill. It allows it as long as the ratio does not exceed 50 %.
Example (indicative). A 40 × 30 × 20 cm box has a volume of 24,000 cm³. For the empty space not to exceed 50 %, the sales packaging inside must take up at least 12,000 cm³. A sales packaging of 3,600 cm³ may go into a box of at most 7,200 cm³. A box of 9,000 cm³ gives a ratio of 60 % and fails the limit. An official method does not exist yet. It does not cover, for example, goods without sales packaging or shipments with several products.
What this means for choosing a void fill
The material does not change the limit. Other criteria therefore decide:
- protection of the goods and whether it allows a smaller box,
- speed and effort of packing, storage space,
- shipment weight and carrier tariff,
- supplier documents and material composition,
- recyclability and how the customer disposes of it,
- packaging collection and recycling fees (EPR). From 2030 or later plastics will have a recycled-content requirement; paper will not.
The correct sentence is: Paper addresses recyclability and the ban on plastic chips. Volume is addressed by the size of the box. A claim such as “our void fill reduces empty space” or “paper meets the PPWR automatically” would contradict the text of the Regulation.
Frequently asked questions
From when does the 50 % limit apply?
At the earliest from 01. 01. 2030. The later of two dates applies: 01. 01. 2030, or three years after the implementing act enters into force (Article 24(1), (2)).
Does paper void fill or an air cushion reduce the empty space?
No. Article 24(3) counts them as empty space.
Will the PPWR ban plastic void fill and air cushions?
Not in general. From 12. 02. 2029 it bans loose plastic chips. Air cushions and bubble wrap are not named in the ban. We found no official confirmation.
Does the limit apply to a shipment in the manufacturer’s original packaging?
No. Sales packaging used as e-commerce packaging is exempt from the limit but must meet Article 10 (Article 24(5)). The Commission has not yet explained borderline cases.
What must I be able to document already now?
If the packaging carries your name or brand, you are responsible for its conformity. For now mainly heavy metals and substances are documented. Otherwise the packaging manufacturer keeps the documents and you act with due care.
We sell to Slovakia. What changes?
Whoever delivers goods directly to the end customer in Slovakia may have producer duties there (registration and an EPR representative). The suspension of the mandatory representative is so far only a proposal. The conditions are set by the Slovak Act No. 79/2015 Coll. on waste.
Common myths
- “The limit is 40 % and applies from 12. 08. 2026.” The 40 % figure was in the 2022 proposal. The final text has 50 % and applies at the earliest from 2030.
- “A supplier’s certificate is enough.” It depends on the role. For packaging with your name you are responsible, and the responsibility cannot be transferred by contract.
- “The PPWR is being postponed.” The Regulation applies from 12. 08. 2026. Only some implementing acts are late.
- “The PPWR bans plastics.” It does not ban plastics. It bans loose plastic chips from 12. 02. 2029.
Sources
- Regulation (EU) 2025/40, Articles 3, 5, 10, 24, 67, 71: EUR-Lex.
- Commission Notice C/2026/3084 (guidance on the Regulation): EUR-Lex. The guidance is not binding.
- Commission: PPWR frequently asked questions.
Do you need to find out how void fill and box size affect your shipments? Write to us the type of goods and the size of your most common parcel.
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