Of all the PPWR requirements, the rule on dead space receives the least attention — even though it is the only one where compliance and cost savings go hand in hand.
The sector is now aware that the PPWR will come into force on 12 August 2026. However, one requirement remains under-emphasised, even though it involves the most tangible change: from 2030, grouped, transport and e-commerce packaging may contain no more than 50 per cent empty space. An important detail that is often overlooked is that filling material counts as empty space. Air cushions or paper padding therefore do not help in staying below the threshold.
‘In e-commerce in particular, empty space is not a theoretical compliance issue, but a recurring monthly cost,’ says Valentine Dejager, CEO of Europal NV. Carriers are increasingly charging based on volumetric weight, meaning that an oversized box adds to the cost of every consignment. But the rule applies just as much at pallet level: making an outer box a few centimetres smaller can sometimes allow for an extra layer per pallet — and immediately reduces the transport cost per item.
Five questions to help you assess where you stand
Any business can get an initial idea with minimal effort:
- How many sizes do you use today, relative to the breadth of your product range? Few sizes for a wide range almost inevitably means a lot of wasted space.
- What is your average packing density? Measure this based on a sample of actual consignments, not on the best-fitting box.
- How much packing material do you use per consignment? That volume will be taken into account later — it’s a direct indicator.
- Do you factor in volumetric weight when calculating your postage costs? If you only look at the box rate, you’re missing part of the cost.
- Which packaging items are already above 50% today? Often, just a few items determine the average. That’s where your action list starts.
‘That exercise usually results in a list of priorities straight away,’ says Dejager. ‘You don’t have to tackle everything at once.’
And what if you need to go to the loo?
Sometimes it’s enough simply to optimise the range of sizes; sometimes it’s worth making custom-sized boxes on the spot. And sometimes the solution lies in the protective material: packaging that requires less filling automatically meets the criteria. For many applications, paper-based alternatives offer the same level of protection as foam — even for heavy goods. First, analyse your order profile, and only then consider the technical aspects.
One point to note for those using cardboard packaging: cardboard boxes are exempt from the recycling targets, but not from the rule on empty space. “When it comes to volume, everyone has to do their bit,” says Dejager.
Europal NV will be exhibiting at Empack Ghent on 22 and 23 September 2026 at Flanders Expo, in the Belgian Packaging Festival area — anyone wishing to go through the process for their own packaging is welcome to visit. More information: europal-packaging.com.
