Article 24 • Void Space • August 2026 Deadline
Article 24 Explained: The "Empty Box Ban" & The 50% Void Space Rule
Executive Summary
- The Rule: Maximum 50% void space in e-commerce, grouped, and transport packaging
- Critical Date: August 12, 2026 — main PPWR provisions become applicable
- Enforcement: 50% void space limit enforced from January 1, 2030
- Filler Materials: Bubble wrap, air cushions, and foam count as empty space
- Solution: Reduce box sizes — you cannot "stuff" your way to compliance
While the EU's "Recyclability at Scale" targets are set for 2030, the most critical immediate risk for e-commerce and logistics brands is Article 24 — colloquially known as the "Empty Box Ban."
What is PPWR Article 24?
Under Article 24 of the PPWR (Regulation (EU) 2025/40), economic operators who supply products in grouped packaging, transport packaging, or e-commerce packaging are required to minimise empty space.
Specifically, you must ensure that the "empty space ratio" does not exceed what is necessary for protection, handling, and transport. The regulation sets a clear trajectory toward a mandatory 50% maximum threshold which sees full enforcement by 2030.
The Official PPWR Timeline: 2025 to 2032
Understanding when each requirement takes effect is essential for planning. The complete timeline based on Regulation (EU) 2025/40:
| Date | Milestone |
|---|---|
| 22 Jan 2025 | Regulation (EU) 2025/40 published in EU Official Journal |
| 11 Feb 2025 | PPWR entered into force |
| 12 Aug 2026 | Main PPWR provisions become applicable (labelling, minimisation principles, etc.) |
| 12 Feb 2028 | European Commission must publish implementing acts defining the void space calculation methodology |
| 1 Jan 2030 | 50% void space limit takes effect (or 36 months after implementing acts, whichever is later) |
| 12 Feb 2032 | Commission reviews the 50% threshold; may expand scope to toys, cosmetics, electronics, DIY kits |
Does Bubble Wrap Count as Product?
No.
The regulation is explicit: space filled by "filler materials" such as paper cuttings, air cushions, bubble wrap, sponge fillers, foam wool, wood wool, or polystyrene is considered empty space.
You cannot "cheat" the ratio by stuffing the box with paper. You must reduce the box size.
| Counts as Void Space | Does NOT Count as Void Space |
|---|---|
| Bubble wrap | Protective gases inside food packaging |
| Air cushions and pillows | Headspace needed to protect food products |
| Foam fillers | Space for products that settle during transport |
| Paper shreds and cuttings | Space required for safety compliance |
| Wood wool | Space for shipment labels and legal markings |
| Polystyrene chips (packing peanuts) | — |
| Sponge fillers | — |
How to Calculate Your Void Space Ratio
The calculation compares the total volume of the grouped/transport packaging against the volume of the actual products inside.
Worked Example
You ship a perfume bottle in a cardboard box.
- Box Dimensions: 30cm × 20cm × 15cm = 9,000 cm³
- Product Volume: 1,200 cm³
- Calculation: (9,000 - 1,200) / 9,000 = 0.867 (86.7%)
Which Packaging Types Are Affected?
The 50% rule applies to:
- Grouped packaging — boxes containing multiple sales units
- Transport packaging — pallets, shipping containers, outer cartons
- E-commerce packaging — direct-to-consumer shipment boxes
Exemptions from the 50% Void Space Rule
The regulation includes several exemptions:
Key Exemptions
- Sales packaging used as e-commerce packaging: If you ship a product in its original retail box without an outer shipping box, the 50% rule does not apply (though Article 10 minimisation still does).
- Reusable packaging in a system for reuse: Packaging designed for multiple trips within a closed-loop system is exempt from the 50% threshold (but must still comply with general minimisation principles).
Special Assessment Considerations
The Commission's methodology must account for:
- Irregular or non-uniform product shapes
- Packaging containing multiple sales units
- Liquid products requiring specific handling
- Fragile items requiring protective space
- Space needed for shipment labels and legal markings
- Products subject to safety compliance requirements
Who Must Comply?
The void space requirements apply to economic operators who fill and use the affected packaging types. This includes:
- Manufacturers
- Distributors
- Warehouses and fulfilment centres
- E-commerce retailers
- Third-party logistics providers (3PLs)
- Any business shipping goods in grouped, transport, or e-commerce packaging
5 Steps to Prepare for 2026 and 2030
1. Audit Your "Worst Offenders" Now
Do not wait for 2028. Run a report on your top 20 best-selling SKUs and calculate the void space for each. If your best seller is 75% empty space, your risk exposure is significant.
2. Switch to Adjustable Packaging
Many brands are adopting "height-adjustable" cartons with pre-scored creases that fold down to fit the product. This creates variable-volume boxes that help stay under 50% without maintaining 50 different box sizes in your warehouse.
3. Monitor the Implementing Acts
The Commission must publish the official calculation methodology by February 2028. Follow updates from the European Commission's packaging waste page and industry bodies like EUROPEN.
4. Document Your Justifications
If you have legitimate reasons for extra packaging space (fragile products, irregular shapes, legal marking requirements), start documenting these now. You will need to demonstrate compliance to authorities.
5. Automate the Calculations
If you have 500+ SKUs, you cannot manage this in spreadsheets. You need systems that ingest product dimensions and box dimensions to flag non-compliant packaging automatically.
PPWR Copilot includes a built-in Article 24 Calculator that checks your void space ratio instantly as you build your compliance dossier.
Check Your Void Space Ratio
Generate complete compliance dossiers with automatic void space calculations for all 27 EU countries + UK.
Start Free TrialFrequently Asked Questions
What is the PPWR Article 24 void space rule?
PPWR Article 24 sets a maximum 50% void space ratio for grouped packaging, transport packaging, and e-commerce packaging in the EU. This means at least 50% of your shipping box must be filled with actual products, not air or filler materials like bubble wrap.
When does the 50% void space limit take effect?
The 50% void space limit takes effect on January 1, 2030, or 36 months after the European Commission publishes the calculation methodology, whichever is later. However, general packaging minimisation requirements under PPWR become applicable on August 12, 2026.
Does bubble wrap count as void space under PPWR?
Yes. Bubble wrap, air cushions, foam fillers, paper shreds, wood wool, and polystyrene chips all count as void space under PPWR Article 24. You cannot meet the ratio by stuffing boxes with filler materials — you must reduce the box size.
How do I calculate void space ratio for PPWR compliance?
Void Space Ratio = (Internal Box Volume - Product Volume) / Internal Box Volume × 100. For example, a 9,000 cm³ box containing a 1,200 cm³ product has a void space ratio of 86.7%, which exceeds the 50% limit.
What packaging types are affected by the 50% void space rule?
The 50% rule applies to: (1) Grouped packaging containing multiple sales units, (2) Transport packaging like pallets and shipping containers, and (3) E-commerce packaging for direct-to-consumer shipments. Sales packaging (primary consumer packaging) is NOT subject to the 50% limit.
Are there exemptions to the PPWR void space rule?
Yes. Key exemptions include: (1) Sales packaging used directly as e-commerce packaging without an outer box, and (2) Reusable packaging in a certified system for reuse. Special considerations apply for fragile items, irregular shapes, and products requiring protective space.
What happens if my packaging exceeds 50% void space?
After the 2030 deadline, packaging exceeding the 50% void space threshold will be non-compliant with EU regulations. This could result in products being refused at EU borders, fines from national authorities, and inability to sell in EU markets.
Why does August 12, 2026 matter for PPWR compliance?
August 12, 2026 is when the main PPWR provisions become applicable, including general packaging minimisation requirements, labelling obligations, and the prohibition on certain single-use packaging. While the 50% void space rule enforcement is in 2030, you must start minimising packaging from 2026.
Sources & Further Reading
- Regulation (EU) 2025/40 — EUR-Lex — Full text of the Packaging and Packaging Waste Regulation
- European Commission — Packaging Waste — Official updates and implementing acts
- EUROPEN — European Organisation for Packaging and the Environment