PPWR 06 - Am I Using Too Much Packaging?

“We’ve used this packaging for ten years. What’s the problem?”

A manufacturer uses a 40-gram bottle.
The bottle works. It doesn’t leak. It survives transport. The customer is happy. The filling line runs smoothly.

Why would it need to change?
This is one of the questions PPWR brings onto the factory floor. Because, going forward, the fact that packaging works won’t always be enough.

The question becomes: does it really need all 40 grams?
If the same packaging could fulfil its functions at 36 grams, that difference needs to be examined.
But the reverse matters just as much. If, at 35 grams, the bottle starts to deform, fails on the filling line, or can’t survive transport, PPWR doesn’t simply say “reduce it anyway.” Minimisation doesn’t mean stripping out functionality.

This is the central idea of PPWR 06: packaging has to be reduced to the minimum necessary, but that minimum has to be set against the actual functions the packaging needs to perform.


An important clarification:
12 August 2026 is not the deadline for the new Article 10

An important distinction needs to be made here. PPWR generally applies from 12 August 2026. But that doesn’t mean every obligation under the Regulation becomes applicable on that same day.

For packaging minimisation, there’s a transition period. Until the end of 2029, the current European minimisation regime continues to apply, based on the requirements of Directive 94/62/EC and the EN 13428:2004 standard. The new requirements under Article 10(1) and (2) of PPWR become applicable from 1 January 2030.

This difference matters. It doesn’t mean companies have nothing to do until then. Packaging minimisation already exists in European law. What changes in 2030 is the regime under which that minimisation will need to be assessed and demonstrated.


What does “minimum necessary” actually mean?

Back to our 40-gram bottle. We could say: “let’s make the wall thinner.” But how thin? 30 grams? 35? 38?
PPWR doesn’t currently set out a table saying: “a one-litre HDPE bottle must weigh no more than X grams.”
Article 10’s principle is different. Packaging weight and volume must be reduced to the minimum necessary to ensure its functionality, taking into account the format and material used and the criteria set out in Annex IV.

In other words: minimum doesn’t mean the lowest weight technically achievable. It means the lowest weight at which the packaging still fulfils its necessary functions. That’s a fundamental difference.


What can justify the material that’s there?

Annex IV sets out the criteria that need to be taken into account when assessing how much packaging is necessary. These include product protection, manufacturing and filling-process requirements, logistics, transport and storage, safety and hygiene, information required by the consumer, and compliance with other legal requirements.

PPWR’s other objectives also have to be taken into account, including recyclability and the use of recycled content.

This means a company can have perfectly legitimate reasons not to reduce a package further. But there’s a difference between “we believe we need this thickness” and “we tested a thinner version and the packaging no longer meets requirement X.” Under PPWR’s new logic, the second situation is far easier to justify.


Can I take out another 5 grams?

Say we have a 40 g detergent bottle. We test: 38 g - works. 36 g - works. 34 g - the drop test shows deformation and seal failures.

From a practical minimisation standpoint, we’ve just obtained something genuinely valuable. Not just a lighter bottle - technical proof of the limit down to which the packaging can be reduced without compromising its function. The same principle applies to a film. Reduce the gauge. Test the seal. Test the strength. Test how it behaves on the line. Test transport. Or to a cardboard box. Reduce the grammage. Test compression. Test stacking. Test transport.

PPWR shifts the conversation from “that’s how we’ve always made this packaging” to “can we demonstrate why we make it this way?”


But what if the problem is the machinery?

Things get more interesting when the limit isn’t the product, but the process. Say a 28 g bottle is strong enough on its own. But the current filling line can’t handle it stably. At 30 g it works. At 28 g it falls or deforms.

Manufacturing and filling-process requirements are among the criteria taken into account in the minimisation assessment. But there’s still a question the current framework doesn’t answer with enough precision: can the limitation of an existing machine permanently justify using a heavier package?
We don’t yet have a sufficient basis for a categorical answer. Which is why, for a company, the statement “our machine can’t process less” is weaker than “we tested the reduction and this is the documented technical limit of the process.”


Another kind of unnecessary packaging: “making it look bigger”

PPWR also targets a very concrete practice. From 2030, Article 10 bans packaging characteristics whose only purpose is to make the product look bigger. The Regulation explicitly names examples such as double walls, false bottoms and unnecessary layers.

Here the conversation is no longer just about a few grams. It’s about design. A very thick cosmetic jar, an oversized box, or a false bottom that creates the impression of a larger product volume can become compliance problems if those elements have no justifiable function.
The argument “consumers perceive it as premium” should not be confused with a technical necessity.

There are special, limited exceptions, including for certain design or trademark rights predating the date set by the Regulation. But these shouldn’t be read as a general exemption for premium packaging.


The 50% rule: it doesn’t apply to all packaging

One of the most common oversimplifications of PPWR goes: “packaging won’t be allowed more than 50% empty space.” That statement is incomplete.

The limit set out in Article 24 covers: grouped packaging; transport packaging; e-commerce packaging.
It is not a general 50% limit applicable to primary/sales packaging. A shampoo bottle, a yoghurt cup or a cosmetic container are assessed from the Article 10 minimisation perspective, but as sales packaging they are not subject to Article 24’s numeric 50% cap. That difference matters a great deal.


The simplest example: e-commerce

We order a small product online. The product takes up about two litres. It arrives in a ten-litre box. The rest of the box is filled with crumpled paper or air cushions.

Intuitively, we spot the problem immediately. But a question arises: if the space is filled with paper, is it still “empty space”?
Yes. Under Article 24’s logic, materials used to fill space - paper, air cushions, bubble wrap, foam or similar materials - are treated as empty space, not as product. The fact that the paper is recyclable doesn’t change the problem. The objective is reducing unnecessary packaging volume.


But how exactly do we calculate the 50%?

Here we need to be careful. The limit is set. The final calculation methodology is not yet established. The European Commission must adopt the implementing act on the calculation methodology by 12 February 2028. Until then, there are situations for which no formulas should be invented: irregularly shaped products; e-commerce orders combining several products; highly fragile products; situations where a certain amount of protective volume is unavoidable.

So a company can already identify obviously oversized packaging. But it shouldn’t claim today to have carried out a legally definitive empty-space-ratio calculation using a methodology that doesn’t yet exist.


When does the 50% limit apply?

There’s an important nuance here too. Article 24 sets the maximum 50% limit as applying from 1 January 2030, or three years from the entry into force of the implementing act on the calculation methodology, whichever is later.

So 2030 is the working date companies should plan around, but the final deadline also depends on the methodology being adopted on time.


Who is responsible for empty space?

There’s an interesting difference here compared to primary packaging. For Article 24, responsibility is tied to the economic operator that actually fills the grouped, transport or e-commerce packaging.
Take an example. A manufacturer sells its product through a logistics operator. The product itself is perfectly packaged. But the logistics operator puts it into a much-too-large box and fills the rest with paper. The empty-space problem arises at the fulfilment stage.
That’s why PPWR won’t only affect packaging manufacturers. It will directly affect retailers, distributors, warehouses, 3PL operators, fulfilment centres, and e-commerce companies.


Industrial packaging shouldn’t be forgotten

The issue isn’t limited to the supermarket shelf. Take a corrugated transport box. Two different questions apply.
First:
Is the board heavier than actually needed for the real stacking and transport load? That’s a minimisation question.
Second:
Is the box much bigger than the products carried inside it? That can also become an empty-space question.

The same applies to crates, trays, boxes for industrial components, protective inserts, separators, or other transport packaging. For many B2B companies, formats were designed years ago for a logistics scenario that may not even exist any more. PPWR is a good reason to reassess them.


Stretch film: how many wraps are actually needed?

Another example very close to industry. A pallet is wrapped in stretch film. The operator does 15 wraps. Why 15? Because that’s how the machine is set.
But maybe the load stays stable with 12? Or 10? The answer shouldn’t be guessed. Load stability gets tested. If 10 wraps are enough for the actual transport conditions, systematically using 15 is worth examining.
This is a clear illustration of the difference between arbitrary reduction and documented technical minimisation.


Less material can create a different PPWR problem

In PPWR 04 we discussed recyclability. In PPWR 05, recycled content. Now we add minimisation. The three can’t be treated separately.
Say we reduce a package’s gauge. To preserve mechanical or barrier properties, we add another layer. We’ve reduced weight. But we may have reduced recyclability.
Or we add more recycled content. Mechanical properties change and we need to slightly increase thickness. We’ve improved recycled content. But we’ve increased weight.

There isn’t always a solution where every objective moves in the same direction. Which is why Article 6 (recyclability), Article 7 (recycled content), Article 10 (minimisation) and Article 24 (empty space) need to be analysed together. Packaging has to be treated as a system.


What should an internal file contain?

There is no official PPWR form today that a company fills in for each package. But we can already start building the information that will be needed. For each important format, we should be able to answer at least the following:
●	What is the packaging?
●	How much does it weigh?
●	What volume does it have?
●	What material is it made of?
●	What functions does it need to perform?
●	What protection requirements does the product have?
●	What demands arise during transport and storage?
●	What constraints does the filling or manufacturing process impose?
●	Have we tested weight reduction? Down to what point? What happened when we reduced it?
●	What tests demonstrate the limit?
●	Is there a smaller-volume variant?
●	How does the change affect recyclability?
●	How does it affect the use of recycled content?
This isn’t an official PPWR form. It’s simply a smart way to start preparing.


What can a company do now?

There’s no need to wait for the final standards to get started.

What we can do now
●	Take stock of active packaging.
●	Classify it: sales, grouped, transport, e-commerce.
●	Measure weight and dimensions.
●	Identify obviously oversized packaging.
●	Identify formats with a lot of filler material.
●	Document the packaging’s technical functions.
●	Check why we use the current thickness or grammage.
●	Identify variants where reduction can be tested with low risk.

What we’re preparing and validating
●	downgauging trials;
●	mould or tooling modifications;
●	reducing film thickness;
●	optimising box sizes;
●	modifying protective systems;
●	optimising pallet wrapping;
●	transport and stacking tests;
●	customer approval of new variants.

What we’re tracking
●	the update to the European minimisation standard;
●	the official methodology for calculating empty space;
●	any further Commission clarifications on documentation and conformity assessment.

What I wouldn’t do yet
●	I wouldn’t invest in a new mould just because someone claims PPWR will impose a specific maximum weight for a bottle. We don’t yet have final figures like that for any format.
●	I wouldn’t legally calculate an exact empty-space percentage using a commercial formula marketed as “PPWR methodology.” The official methodology isn’t finalised yet.
●	I wouldn’t assume that “our line can’t process less” will remain a sufficient justification forever.

But I wouldn’t wait until 2029 either.


The question worth asking every package

In PPWR 05, the question was: “how much recycled material do I use, and can I prove where it comes from?”
In PPWR 06, the question is different: “why does my packaging have exactly this weight and this volume?”
If the answer is “because that’s how we’ve made it for ten years,” we have a problem.
If the answer is “because we tested lighter variants, and this is the limit at which the product stays protected, the line runs, transport is safe, and the other PPWR requirements are met,” we’re in a completely different position.

That’s the mindset shift minimisation brings. Not: “use as little material as possible.” But: “use what’s necessary, and be able to explain why it’s necessary.” For industry, that difference is enormous.


Sources

Official Sources
●	Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste - in particular Articles 10, 24 and 70, and Annexes IV and VII.
●	European Commission - Guidance document for Regulation (EU) 2025/40, C(2026) 3702.
●	European Commission - C(2026) 2151 final, 30 March 2026.
●	Directive 94/62/EC on packaging and packaging waste.
●	EN 13428:2004 - Packaging - Requirements specific to manufacturing and composition - Prevention by source reduction.

Context Sources
●	European Commission - Packaging and Packaging Waste Regulation (PPWR).
●	EUROPEN - materials on PPWR implementation and industry obligations.
●	European technical sources and packaging-industry organisations, used for context on lightweighting, packaging optimisation, transport and e-commerce.