Is Your Packaging Too Big? PPWR Article 24’s Empty Space Rules for Packaging

The EU’s Packaging and Packaging Waste Regulation (PPWR) marks a major step forward in packaging sustainability. Among its many provisions, Article 24 addresses a critical but often-overlooked dimension: the amount of empty space within grouped, transport, e-commerce and sales packaging. For businesses in e-commerce and takeaway food services—where packaging volume and efficiency are already central—this poses both a challenge and an opportunity.

What Article 24 Requires

Under Article 24 of the PPWR:

  • For grouped packaging, transport packaging and e-commerce packaging, the empty-space ratio must not exceed 50% by 1 January 2030, or three years from the entry into force of the implementing acts defining the methodology. 

  • By 12 February 2028, operators filling sales packaging (i.e., packaging sold directly to consumers) must ensure that empty space is reduced to the minimum necessary to ensure packaging functionality.

  • The regulation clarifies that space filled by filler materials such as air cushions, bubble wrap, foam chips, polystyrene, paper cuttings, wood wool, etc., counts as empty space. Clarity

Why It Matters for E-Commerce and Takeaway Packaging

E-Commerce Packaging

Online retailers frequently use oversized boxes, air cushions, lots of filler, and packaging that is far beyond the minimal volume needed to protect the product. Under Article 24, when these boxes become transport or grouped packaging, the 50% cap on empty space will apply. Failing to comply could mean redesigning processes, reducing filler, and optimising packing volumes.
 Given the scale of e-commerce, this is a substantial operational shift—one that also benefits logistics, cost savings, and brand sustainability credentials.

Takeaway & Delivery Packaging

For takeaway food services, e-commerce packaging rules may not directly apply to in-store sale packaging, but the sales packaging (e.g., meal boxes, cups, bags) are subject to the obligations for reducing empty space by 12 February 2028. Moreover, takeaway packaging often involves delivery or transport (e.g., meal boxes inside delivery bags), making design efficiency and minimised filler materials even more relevant. The consumer-facing nature of these products means that packaging design and material usage combine both functional and brand-related imperatives.

Practical Implications for Packaging Design & Operations

  • Conduct a volume audit of your grouped, transport and e-commerce packaging: what proportion is filler or excess space?

  • Redesign packaging to fit more snugly around products, reducing voids, eliminating unnecessary double walls or oversized formats.

  • Replace traditional filler (bubble wrap, foam chips) with minimal, optimized protection (e.g., shaped fibre inserts) that reduce void volume.

  • For takeaway brands: review the meal box-to-delivery bag relationship, ensure boxes are sized appropriately, and avoid unnecessary internal space or inserts.

  • Communicate your compliance and packaging efficiency as part of your brand story—smaller, smarter packaging aligns well with sustainability-focused customers.

Benefits for Your Brand

  • Cost savings: Less void space means less material, less filler, lower shipping volume, and potentially lower logistic cost.

  • Sustainability credentials: Demonstrating alignment with PPWR minimisation rules positions you ahead of regulatory curve and improves brand image.

  • Operational efficiency: Optimised packaging can streamline packing stations, reduce waste, improve transport utilisation.

  • Competitive edge: Especially in e-commerce and food-delivery markets, brands with smarter packaging design can differentiate in a crowded field.

Compliance Challenges

  • Filler materials still count as empty space—so even if you’ve made your box smaller, use of large void-fill may undermine compliance.

  • The methodology to calculate empty space is still under definition, so packaging teams should stay updated with the implementing acts.

  • Ensuring protective functionality isn’t compromised: packaging must still protect products or food during transport, maintain hygiene, and meet logistics constraints—compliance doesn’t mean minimal packaging at any cost.

  • For takeaway food operators, the dual role of packaging (consumer-facing and delivery-transport) means both aesthetic and volumetric efficiency need balancing.

Final Thoughts

With Article 24 of the PPWR setting specific limits on packaging empty space, businesses in e-commerce and takeaway sectors have a clear regulatory signal: pack smarter, use less filler, optimise design. While the deadlines are some years away, preparation now gains advantages—from cost savings to stronger brand positioning.

At MBA Green, we provide a wide range of sustainable, fit-for-purpose packaging solutions—designed for compliance, customisation and performance in e-commerce, delivery and takeaway food sectors. We’re closely monitoring emerging trends and the evolving regulatory landscape so your business can stay ahead of the curve.

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