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Requirement · EXC-01

Keep empty space in grouped, transport and e-commerce packaging at or below 50%, counting filling materials such as paper cuttings, air cushions, bubble wrap and foam chips as empty space.

Economic operators who fill grouped, transport or e-commerce packaging must comply, and this is law in force.

Why it matters

This is law in force, not a proposal.

  • It is Art. 24(1), in the Packaging and Packaging Waste Regulation. as of 2026-08-18
  • The act gives its timing as: From 1 January 2030 or 3 years after the Art. 24(2) implementing acts, whichever is later (Art. 24(1)). as of 2026-08-18
  • It names 2 industries by name: Retail and Food and drink. as of 2026-08-18
  • Compliance is checked by self-assessment against the Art. 24(2) methodology, continuous. as of 2026-08-18
Addressee Economic operators who fill grouped, transport or e-commerce packagingAct Regulation (EU) 2025/40, base actArticle Art. 24(1)Class Businesses

What changes

E-commerce and distribution most of all. Genuinely new: 94/62/EC's Annex II required packaging volume and weight to be the minimum needed, but set no ratio and no measurable test. Art. 24(5) exempts operators using sales packaging as e-commerce packaging or reusable packaging within a re-use system.

The rule

New — no predecessor
Trigger

filling grouped, transport or e-commerce packaging

Obligation

Keep empty space in grouped, transport and e-commerce packaging at or below 50%, counting filling materials such as paper cuttings, air cushions, bubble wrap and foam chips as empty space.

Who is affected

Addressee
Economic operators who fill grouped, transport or e-commerce packaging
Class
Businesses
Sectors
Names Retail and distribution, Food, drink and tobacco · Reaches Paper and board, Plastics converting, Waste and landfill
Applies
From 1 January 2030 or 3 years after the Art. 24(2) implementing acts, whichever is later (Art. 24(1))

Burden drivers

D4 · D7 — 2 of 7 marks fire on this provision.

No size threshold.

Source text

Verbatim

economic operators who fill grouped packaging, transport packaging or e-commerce packaging shall ensure that the maximum empty space ratio, expressed as a percentage, is 50 %.

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