A European buyer asks for your empty space ratio, and you send the carton dimensions off your packing list. Wrong number. Those are external dimensions, and the ratio is measured against what fits inside the box — a figure most export packing lists never publish at all.
The rule behind the question is Article 24 of Regulation (EU) 2025/40, the EU Packaging and Packaging Waste Regulation (PPWR). It caps that ratio at 50% for grouped, transport and e-commerce packaging. It does not do that in August 2026, whatever your feed told you last month.
What the empty space ratio actually measures
The empty space ratio is the share of a grouped, transport or e-commerce package that is not occupied by the goods inside it. Under PPWR Article 24 it must not exceed 50%, and the duty sits on the economic operator who fills the packaging — not on whoever designed or sold the box.
As arithmetic:
Empty space ratio = (packaging volume − volume of the packaged products) ÷ packaging volume × 100
Two things about that formula matter before anyone builds a spreadsheet on it.
Filling material counts as empty space. Paper cuttings, air cushions, bubble wrap, sponge and foam fillers, wood wool, polystyrene and polystyrene chips are all void, not content. You cannot cushion your way under the cap — filler leaves the box the same size, so it moves the number in the wrong direction.
The official calculation method does not exist yet. The Commission still has to adopt an implementing act establishing the methodology, and its deadline for doing so is 12 February 2028. Until then, 50% is a fixed ceiling attached to a formula whose edge cases — board thickness, irregular shapes, how the sales packaging inside is measured — are not settled.
There is a second rule that gets merged into this one, and the two are not the same. Article 10 requires packaging to be designed so its weight and volume are reduced to the minimum necessary for functionality, assessed against the performance criteria in Annex IV and justified in the technical documentation. The Commission's guidance document gives the relationship between the two its own section, and the distinction it draws is the one to memorise: Article 10 minimisation has no predefined threshold, while Article 24 is a hard 50% ceiling on grouped, transport and e-commerce packaging. Your sales packaging is judged case by case. Your shipper is judged against a number.
The PPWR timeline: which date belongs to which rule
| Date | What happens | What it means for an exporter |
|---|---|---|
| 11 February 2025 | Regulation (EU) 2025/40 enters into force | Clock starts; no operational duty yet |
| 25 February 2026 | Commission decision exempts pallet wrappings and straps from the 100% intra-company reuse requirement | A reuse-target exemption, not an Article 24 exemption |
| 30 March 2026 | Commission publishes its PPWR guidance document, C(2026) 3702, plus an FAQ | First official reading of Articles 10 and 24 |
| 12 August 2026 | PPWR applies across the EU; the PFAS restriction on food-contact packaging starts | The regulation is live; the empty-space cap is not |
| 12 February 2028 | Deadline for the implementing act fixing the empty-space calculation methodology | The formula becomes official and auditable |
| 2028 | Harmonised packaging labelling applies EU-wide | Separate workstream, separate artwork |
| 1 January 2030 | Article 24's 50% cap and Article 10's minimisation duty apply | The number bites |
| 12 February 2032 | Commission review of whether the limit should be tightened | Treat 50% as a floor, not a ceiling |
Article 24 words its own start date as "1 January 2030 or 3 years from the entry into force of the implementing acts adopted pursuant to paragraph 2, whichever is the latest." If the methodology slips past early 2027, the cap slips with it. Nobody should be planning tooling around a date that can still move.
Why "August 2026" got attached to the wrong rule
Because 12 August 2026 is a real date, and a large one: it is the day the PPWR started applying across the EU. The Commission's own announcement is precise about what arrived with it and what did not. The measure entering into application that day was the restriction on PFAS in food-contact packaging, while "concrete measures to reduce the generation of packaging waste, such as new limits on empty space, restrictions on certain single-use plastic packaging or reuse targets, will apply as of 2030."
The regulation applies now. The 50% cap applies in 2030. Anyone selling you a compliance service against an August 2026 empty-space deadline is selling you the wrong deadline — which does not buy you four idle years, for a reason two sections down.
Working the numbers: three cartons, three verdicts
Take one boxed floor lamp, packed dimensions 300 × 200 × 150 mm, and run it through three packaging levels.
| Package | Internal volume | Contents volume | Empty space ratio | Article 24 |
|---|---|---|---|---|
| E-commerce carton, internal 400 × 300 × 200 mm, one lamp | 24.00 L | 9.00 L | 62.5% | Fails |
| Right-sized e-commerce carton, internal 330 × 230 × 175 mm, one lamp | 13.28 L | 9.00 L | 32.2% | Passes |
| Master carton, internal 620 × 420 × 320 mm, eight lamp cartons | 83.33 L | 72.00 L | 13.6% | Passes |
Three things fall out of that table.
Dense export cartons are rarely the risk. A master carton packed two-by-two-by-two clears the cap with room to spare, which is why suppliers shipping full cases into a distribution centre usually pass without changing anything. Getting there starts with publishing honest master carton dimensions rather than the rounded ones on the quotation.
The parcel is the risk. The first row fails not because the box is absurd but because it is one standard size too big — 70 mm of extra length, 100 mm of extra width and 50 mm of extra height, spread across three axes, is all it takes to cross 50%.
Each level is measured separately. The master carton in row three passes while row one fails, even though row one is what actually ships to the customer. Article 24 assesses each packaging level on its own merits, and Article 10 is what catches the level a 50% cap does not reach.
For scale on how much air is moving today: DS Smith's Empty Space Economy study, reported in 2018, found that 34% of global retail business leaders admitted the packages they ship are at least double the size of the product inside. Double the size is a 50% ratio — the exact line Article 24 draws. Only 36% of those leaders had ever audited the empty space in their packaging.
What counts as empty space, and what does not
| Counts as empty space | Does not count |
|---|---|
| Air gaps between product and wall | The packaged product itself |
| Paper cuttings and shredded paper | The product's own sales packaging (measured as contents) |
| Air cushions and inflatable pillows | — |
| Bubble wrap | — |
| Sponge and foam fillers | — |
| Wood wool | — |
| Polystyrene sheets and polystyrene chips | — |
The practical reading: everything you add to stop the product moving is scored against you. The compliant answer to fragile goods is a smaller cavity, not a softer one — which for glassware, lighting and ceramics means a die-cut insert sized to the product rather than a generic box plus a bag of chips.
The two exemptions, and the one that is not an exemption
Article 24 carves out two cases:
- Reusable packaging operating within a system for re-use.
- Sales packaging used as e-commerce packaging — the retail box shipped exactly as it is, with no outer carton around it. Ship the product in its own printed box and there is no second volume to measure.
And the one that keeps getting miscited: pallet wrapping and straps are not exempt from Article 24. The Commission decision of 25 February 2026 removed pallet wrappings and straps from the 100% intra-company reuse requirement. That is the reuse target — a different article, a different obligation. Nothing in that decision touches Article 24. If a supplier tells you palletised transport packaging is out of scope, ask which article they are reading.
The measurement nobody has: internal carton dimensions
Here is why 2030 does not mean 2029. The ratio is computed on the volume inside the box. Export documentation is built almost entirely on the volume outside it — external carton dimensions drive container fill, pallet patterns and freight, so that is the number that gets measured, quoted and printed. The gap between the two is two board thicknesses on every axis, and nobody records it.
That leaves most suppliers unable to answer a question their EU customers are already asking, four years before anyone is obliged to answer it. Importers are writing packaging clauses into supplier agreements now, because corrugated tooling, die-cut inserts and carton ranges are two-to-three-year projects, not compliance sprints.
The fix is not complicated, but it is a measurement discipline rather than a paperwork exercise. Every carton in your range needs its internal dimensions measured once and published on the drawing next to the external ones, with the packed product cube alongside them. Doing that by hand across a hundred SKUs is where it dies; software that snaps a dimension line to the real edges of the item in a photograph, holds one scale across a whole SKU set, and exports the drawing at the size a buyer's spec template expects turns it into minutes per carton. Note the word measured — an AI image generator will happily render a confident "400 mm" onto a box it never measured, and a fabricated internal dimension is worse than a missing one, because the missing one does not end up in a contract.
Pick your outer cases from standard carton box sizes and the internal dimensions arrive with the specification instead of having to be reverse-engineered later.
The packaging block worth adding to every spec sheet
| Field | Unit | Why it is there |
|---|---|---|
| Internal length × width × height | mm | The denominator of the ratio |
| External length × width × height | mm | Freight, pallet pattern, container fill |
| Board grade and flute | — | Explains the gap between internal and external |
| Packed product cube | L | The numerator's other half |
| Units per carton | pcs | Converts single-unit cube to contents volume |
| Void fill type and volume | L | Scored as empty space, so declare it |
| Calculated empty-space ratio | % | The answer, pre-computed, before the buyer asks |
Seven fields, one table, dropped into the export spec sheet you already send. A buyer who can read the ratio off your document does not open a compliance thread with you.
What to do during the rest of 2026
- Measure and record internal dimensions for every carton in your standard range
- Calculate the current empty-space number for your five highest-volume EU SKUs
- Flag anything over 50% and every SKU between 40% and 50%, which the 2032 review could catch
- Convert loose void fill to fitted inserts on fragile lines, starting with the worst ratio
- Add the packaging block above to your spec sheet template
- Read your EU customer contracts for packaging clauses that pull the 2030 date forward
- Diarise 12 February 2028 — the implementing act is when the formula stops being an estimate
FAQ
Does the 50% empty space rule apply from August 2026?
No. The PPWR started applying on 12 August 2026, but Article 24's 50% cap applies from 1 January 2030, or three years after the relevant implementing acts enter into force, whichever is later. The European Commission's announcement of the August date lists "new limits on empty space" among the measures that "will apply as of 2030." The measure that actually started on 12 August 2026 was the PFAS restriction on food-contact packaging.
How do you calculate the empty space ratio?
Subtract the volume of the packaged products from the volume of the packaging, divide by the volume of the packaging, and express it as a percentage. A 24 L carton holding a 9 L boxed product has a ratio of 62.5%. The Commission has until 12 February 2028 to publish the binding methodology, so treat any figure you calculate today as a planning number rather than a certified one — but the ranking of your SKUs from worst to best will not change when the method is fixed.
Does bubble wrap count as empty space under the PPWR?
Yes. Bubble wrap, air cushions, paper cuttings, sponge and foam fillers, wood wool, polystyrene and polystyrene chips are all treated as empty space rather than contents. Adding protective filler to a box that is already too large increases the ratio instead of reducing it. Reducing the cavity is the only move that changes the number.
Is transport packaging on pallets exempt from the empty space ratio?
No. Article 24 names grouped, transport and e-commerce packaging together. The confusion comes from a separate measure: the Commission's decision of 25 February 2026 exempted pallet wrappings and straps from the 100% intra-company reuse requirement, which is a reuse target, not Article 24. Two different obligations, two different articles.
Who is responsible for the empty space ratio — the supplier or the importer?
Article 24 places the obligation on the economic operator who fills the grouped, transport or e-commerce packaging. In an export chain that is usually the factory packing the master carton or the fulfilment operator packing the parcel, while the EU importer carries the placing-on-market duties. In practice the importer pushes the requirement down the contract to whoever fills the box, which is why the packaging clause is appearing in supplier agreements well ahead of 2030. If you want the broader picture of what else lands on exporters, the EU packaging regulation for exporters covers the other obligations in the same regulation.
Sources & References
- EUR-Lex — Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), full text including Article 10 minimisation and Article 24 empty space ratio
- European Commission — New EU rules on packaging enter into application (12 August 2026; confirms limits on empty space apply as of 2030)
- European Commission — Commission Notice, guidance document for Regulation (EU) 2025/40, C(2026) 3702 (including the relationship between Article 10 minimisation and the Article 24 empty space ratio)
- EU Publications Office — Frequently asked questions on the Packaging and Packaging Waste Regulation
- European Commission — Pallet wrapping and straps exempt from 100% reuse requirement (decision of 25 February 2026)
- Latham & Watkins — European Packaging and Packaging Waste Regulation: Summary of Provisions and New Guidance (12 February 2028 methodology deadline; 12 February 2032 review)
- Keller and Heckman — The New EU Packaging and Packaging Waste Regulation: Highlights and Challenges Ahead
- ECOS — Recommendations on the European packaging minimisation standard supporting PPWR Article 10 and Annex IV
- Packaging Europe — The Problem of Shipping Empty Space (DS Smith, The Empty Space Economy, 14 September 2018: 34% of retail leaders ship packages at least double the product size)