Fulfill Team·November 13, 2026·Add Fulfill as a preferred source on GoogleIf you ship orders to EU customers, the EU's packaging regulation will cap how much of an e-commerce box can be empty, and it counts paper and air pillows as empty. This guide covers what US brands and 3PLs need to know: the rule, the math, who it binds, when it starts and what to change at the pack station.
It explains the regulation's own text and is not legal advice; confirm your obligations with an EU compliance advisor.
PPWR is short for the Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40 of 19 December 2024 on packaging and packaging waste. It entered into force on February 11, 2025 and applies from August 12, 2026, replacing the Packaging and Packaging Waste Directive 94/62/EC. As a regulation, it is binding in its entirety and directly applicable in all member states.
Article 2 says it applies to all packaging, regardless of the material used, and the European Commission's FAQ adds that it applies to all packaging placed on the EU market, including packaging imported from third countries. Much of it sets obligations such as recyclability and reuse targets, restrictions on hazardous substances, and labelling. Article 24 governs how a box is filled, which makes it a pack station rule.
Article 24 is headed Obligation related to excessive packaging. Its first paragraph sets the cap: economic operators who fill grouped packaging, transport packaging or e-commerce packaging must ensure the maximum empty space ratio is 50%. The deadline is January 1, 2030 or three years after the Commission's calculation method enters into force, whichever is later.
Article 3 defines the packaging types. E-commerce packaging is transport packaging used to deliver products sold online or by other distance sales to the end user. Sales packaging forms the sales unit of product and packaging sold to the end user: the product's own box. Recital 84 gives the reasoning: excessive packaging waste cannot be fully addressed by rules on packaging design, so the duty to reduce the empty space ratio is placed on the operators who fill the packaging.
Article 24(3) defines both terms. Empty space is the total volume of the outer packaging minus the volume of the sales packaging inside it. The empty space ratio is that empty space divided by the total volume of the outer packaging. Space taken up by filling materials, such as paper cuttings, air cushions, bubble wrap, foam fillers or polystyrene chips, counts as empty space.
Two details matter at a pack station. The rule subtracts the sales packaging, not the product, so a retail box is the volume that counts. And void fill earns nothing: a box padded out with kraft paper has the same ratio as the same box left loose.
Take one product in a retail box that measures 8 x 6 x 4 inches, or 192 cubic inches, and pack it in three box sizes:
In a 12 x 10 x 8 inch box (960 cubic inches), 768 cubic inches are empty space, a ratio of 80%. In a 10 x 8 x 6 box (480 cubic inches) the ratio is 60%. Only the 9 x 7 x 5 box (315 cubic inches) comes in under the cap, at 39%. Stuffing the 12 x 10 x 8 box with paper or air pillows would not help: the fill counts as empty space, so its ratio stays at 80%.
The Commission's calculation method, due by February 12, 2028, will set how the ratio is calculated in practice.
The Commission's FAQ says the 50% ratio must be met by the economic operator who fills the packaging, which may be the manufacturer or other economic operators who make packaged products available on the market.
Article 3's list of economic operators includes the fulfilment service provider, alongside the manufacturer, the importer, the distributor and the final distributor. The PPWR takes its definition of a fulfilment service provider from Regulation (EU) 2019/1020: a business offering at least two of warehousing, packaging, addressing and dispatching, without owning the products. A 3PL that stores, packs and ships your orders fits that description, and when it packs your orders, it is the one filling the box. Separately, Article 20 requires fulfilment service providers to make sure their warehousing, handling, packing, addressing and dispatching do not jeopardise the packaging's compliance with Articles 5 to 12.
The regulation puts the duty on whoever fills the box; how a brand and its 3PL split the work behind it is for your contract, so agree in writing who picks the boxes and who keeps the box records.
Article 24(5) exempts two cases from the 50% cap: sales packaging used as e-commerce packaging, such as a product shipped in its own retail box with no outer carton, and reusable packaging used within a system of re-use. Sales packaging shipped that way must still meet Article 10, under which, by January 1, 2030, manufacturers and importers must keep packaging weight and volume to the minimum necessary to ensure its functionality.
By February 12, 2028, whoever fills sales packaging must cut its empty space to the minimum needed for the packaging to work, including protecting the product. The Commission's FAQ says there is no maximum empty space threshold for sales packaging, and by February 12, 2032, the Commission must review the 50% ratio and its exemptions.
The biggest open question is the method. Article 24(2) gives the Commission until February 12, 2028 to adopt implementing acts setting out how the ratio is calculated. The method must take account of products of irregular shape, packaging holding more than one sales packaging or product, liquid products, contents that are easily damaged, small products that larger ones can damage, and the minimum space needed on the outside for a shipping label. For a fulfillment operation, the treatment of multi-item orders is the line to watch.
The regulation reaches past the EU's border. Its definition of a producer includes a manufacturer, importer or distributor established in a third country that makes packaged products available for the first time in a member state, directly to end users. Producers must register in each member state where they first make packaging or packaged products available, under Article 44, and Article 45(3) adds that a producer selling directly to end users in another member state must appoint, by written mandate, an authorised representative for extended producer responsibility in each of those states.
That last duty may change: in December 2025 the Commission proposed, in its Environmental Omnibus, to suspend the obligation for producers to appoint an authorised representative when they sell packaged products directly to consumers in other member states. The proposal is being examined by the European Parliament and the Council of the European Union.
The fulfillment link is direct. Under Article 45(7), producers offering packaging or packaged products to consumers in the EU must give their fulfilment service provider their registration details when they sign the contract. Under Article 45(8), the fulfilment service provider must do what it can to assess whether that information is reliable and complete, and suspend its service if the producer fails to correct it. Have your registration numbers ready before you sign with an EU warehouse.
These are the dates in the regulation that set the empty space clock, with the article behind each:
The cap applies from January 1, 2030 only if the method enters into force by January 1, 2027. If it enters into force later, the cap starts three years after that date, so a method adopted at the February 2028 deadline would push the cap into 2031.
Most of the work can start before the method is out. Here is what to check, with the part of Article 24 behind each step:
| At the pack station | Why it matters under Article 24 |
|---|---|
| Record each SKU's retail box dimensions at receiving | The ratio subtracts the volume of the sales packaging, not the product inside it |
| Choose the box before the void fill | Filling materials count as empty space, so only a smaller box lowers the ratio |
| Test your box sizes against past orders | The cap covers the grouped, transport and e-commerce packaging you fill, apart from the Article 24(5) exemptions |
| Flag products that can ship in their own retail box | Sales packaging used as e-commerce packaging is exempt from the cap, though Article 10 still applies |
| Log the box used for every order | A record lets you recalculate your ratios once the Commission's method is out |
| Set rules for multi-item, fragile and liquid orders | The method must take these cases into account |
If a 3PL packs for you, ask it the same things: how many box sizes it stocks for your products, whether its system or the packer picks the box, and whether it can report the box used on each order.
Picking the box for each order is the job of cartonization software. Fulfill.com partner Paccurate is one such tool, listed with Fulfill.com under packaging for 3PLs and brands. It calls its product the Packing Control System, with four components: PacSimulate to plan, PacManage to control, PacAPI to execute and PacHealth to monitor. Paccurate says its analysis of live cartonization data found the average shipped carton is 40% larger than necessary. Per its own site:
For 3PLs, Paccurate says it works alongside existing systems through an API and does not replace the WMS, and that client-specific packing rules deploy without WMS changes or IT involvement. Paccurate says the system can send an order to a box-making machine, to a station with stock boxes or to an autobagger.
As listed on November 13, 2026, the Startup plan starts at $249 a month with 5,000 shipments a month included, then 5 cents per shipment. The Enterprise plan, for more than 20,000 shipments a month, is priced by quote and adds a dedicated endpoint or on-premise option and PacSimulate.
Two cautions. Volume utilization is the tool's own measure; the regulation's ratio subtracts the sales packaging and counts fill as empty space, and its method is not out yet, so treat any score as an estimate. And while Paccurate lists PPWR compliance among its use cases, whether your packing complies is a legal question for you and your advisors.
The 50% cap applies from January 1, 2030, or three years after the Commission's calculation method enters into force if that is later. The method is due by February 12, 2028. The regulation as a whole applies from August 12, 2026.
Yes. Article 24(3) says space filled by filling materials, such as paper cuttings, air cushions, bubble wrap, foam fillers or polystyrene chips, counts as empty space. Adding fill does not lower the ratio; a smaller box does.
No. The cap covers grouped, transport and e-commerce packaging. Sales packaging has no maximum ratio, but whoever fills it must cut its empty space to the minimum needed for the packaging to work by February 12, 2028.
The duty falls on the economic operator who fills the packaging, and the regulation's list of economic operators includes the fulfilment service provider. How you and your 3PL split the work is for your contract.
It applies to all packaging placed on the EU market, including packaging imported from third countries. A US brand selling directly to EU end users can be a producer under the regulation, with registration duties in each member state it sells into.
If you are choosing a warehouse for EU orders, tell us what you sell and where it ships, and we will match you with 3PLs that fit. Ask each one how it picks boxes and whether it can report the box used on each order.
We read each source on November 13, 2026:
The worked example and the timeline are our analysis of the regulation's text. Paccurate's details come from its own website, Packsize's and Optioryx's from theirs, and MagicLogic's from its own website.
Disclosure: Paccurate is a Fulfill.com vendor partner. Fulfill.com is paid when readers click through to its website.
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