PPWR empty-space ratio: What B2B companies should consider for shipping packaging

What does the PPWR empty-space ratio mean?

The PPWR empty-space ratio describes the share of unused space in certain types of packaging. Put simply, the available internal space of packaging should not be significantly larger than necessary for the packaged product.

This particularly affects:

• Grouped packaging: Packaging that groups several sales units together.

• Transport packaging: Packaging that protects goods during transport and facilitates handling.

• E-commerce packaging: Shipping packaging used for online retail or direct shipping.

It is important to note that void-fill material such as paper, air cushions, protective padding or similar materials does not automatically solve the problem. Under many interpretations, this material still counts as empty space because it does not represent the actual product volume. Companies should therefore not only replace void-fill material, but also assess whether the packaging itself is a better fit for the product.

Why is empty space in packaging regulated?

The PPWR aims to prevent packaging waste, improve the recyclability of packaging and use resources more efficiently. Oversized shipping boxes create several problems at once:

1. More packaging material is used than necessary.

2. More void-fill material is required.

3. Transport capacity is wasted.

4. Storage and shipping costs may increase.

5. Environmental impacts may rise because of avoidable losses in transport efficiency.

For companies, the issue is therefore not only legally relevant. Better-fitting packaging can also improve processes, reduce material costs and lower complaint rates, provided products continue to be protected safely.

We advise you on all matters relating to the VerpackDG/PPWR:

Legal framework: What applies under the PPWR?

The PPWR is the new EU regulation on packaging and packaging waste. Unlike a directive, it generally does not first need to be fully transposed into national law; it applies directly in the Member States. The European Commission describes the regulation as the successor to the previous Packaging Directive. It entered into force on 11 February 2025 and generally applies from 12 August 2026.

With regard to the empty-space ratio, the relevant requirement is that grouped packaging, transport packaging and e-commerce packaging must not exceed a maximum empty-space ratio of 50%. According to published summaries of Article 24, this limit must apply no later than the point in time specified in the provision; 1 January 2030, or a later date linked to implementing acts, is sometimes mentioned. Companies should therefore not wait until shortly before 2030, but start building packaging data, packing processes and supplier information from 2026 onwards.

Another point remains important: The PPWR empty-space ratio does not replace existing obligations under German packaging law. Anyone who first places sales packaging subject to system participation on the German market on a commercial basis must still assess registration, packaging licensing and data reporting obligations. The empty-space ratio concerns the design of certain packaging; packaging licensing concerns participation of packaging subject to system participation in a dual system.

Who is affected in the B2B sector?

Any company that commercially fills, uses or places packaging on the market may be affected. The following groups are particularly relevant for zmart customers:

• Online retailers shipping goods to businesses or private end consumers

• Manufacturers delivering products in boxes, grouped packaging or shipping sets

• Importers bringing packaged goods into the EU or Germany

• Wholesalers operating their own shipping warehouses

• Fulfilment service providers when they fill packaging on behalf of clients

• Brand owners defining packaging requirements for suppliers

The exact scope of obligations depends on the company’s role in the individual case. A company may, for example, be a manufacturer, importer, distributor or fulfilment partner. For this reason, the review should involve not only the legal department, but also procurement, logistics, product management and packaging development.

How to calculate the empty-space ratio in practice

The exact method may be specified further through additional EU requirements. For internal preparation, however, a pragmatic approach is already helpful:

Empty-space ratio=unused packaging volumetotal internal volume of the packaging×100\text{Empty-space ratio} = \frac{\text{unused packaging volume}}{\text{total internal volume of the packaging}} \times 100Empty-space ratio=total internal volume of the packagingunused packaging volume​×100

A simple example:

• Internal volume of the shipping box: 10,000 cm³

• Volume of the product, including necessary product-adjacent protective elements: 6,000 cm³

• Unused space: 4,000 cm³

• Empty-space ratio: 40%

Under the 50% approach, this example would initially be less critical than a box consisting of 70% air and void-fill material. However, the calculation does not replace a legal assessment of the individual case. It does, however, help identify conspicuous packaging.

Practical implementation: Preparing for the PPWR step by step

1. Create a packaging inventory

Start with a list of all shipping, grouped and transport packaging used regularly. At a minimum, record:

• Packaging type

• Internal dimensions

• Material

• Supplier

• Typical products or product groups

• Void-fill material

• Shipping route

• Annual quantities

This overview is the basis for every further assessment.

2. Review product-packaging combinations

Many companies do not have too much packaging; they have too few suitable sizes. As a result, small products are regularly shipped in boxes that are too large. Therefore, do not assess individual boxes only. Review the most common product-packaging combinations.

3. Prioritise conspicuous packaging

Focus first on packaging with high shipping volumes or obviously large empty spaces. Best-selling products, spare parts, accessories and small items shipped in standard boxes often offer quick improvement opportunities.

4. Optimise boxes and packing logic

Possible measures include:

• Introducing additional box sizes

• Using variable-height creasing

• Reviewing mailing bags or close-fitting corrugated cardboard packaging

• Evaluating automated box-erecting or cutting systems

• Combining product bundles more effectively

• Updating packing instructions in the warehouse

The key is to balance packaging minimisation and product protection. Smaller packaging must not lead to increased product damage.

5. Involve suppliers

Ask suppliers for technical data, material composition and packaging dimensions. If you use own brands or individually developed packaging, PPWR requirements should in future be reflected in specifications, purchasing terms and packaging specifications.

6. Build documentation

Record which packaging has been reviewed, which assumptions were used and which measures are planned. This documentation can later help make decisions traceable and clarify internal responsibilities.

We advise you on all matters relating to the VerpackDG/PPWR:

Common mistakes regarding the PPWR empty-space ratio

Mistake 1: Only replacing void-fill material

Paper instead of plastic may appear more sustainable at first glance. However, for the empty-space ratio, the decisive issue may still be whether the box is too large. Replacing void-fill material alone may not solve the sizing problem.

Mistake 2: Confusing packaging licensing with the PPWR

Packaging licensing is part of the obligation to participate in a system under German packaging law. The PPWR empty-space ratio, by contrast, concerns the design and filling of certain packaging. Both issues may affect the same company, but they are not identical.

Mistake 3: Considering B2C shipping only

B2B companies can also be affected, for example through transport packaging, spare-parts shipping, sample deliveries or e-commerce packaging for business customers.

Mistake 4: Starting data collection too late

Companies that only start collecting dimensions, volumes, supplier information and packing process data shortly before the compliance deadline may quickly face time pressure. It makes sense to build this data base early, starting in 2026.