§11 Relationship between the minimisation requirements in Article 10 and the empty space ratio in Article 24

Legal provisions: Article 10(1): ‘By 1 January 2030, the manufacturer or importer shall ensure that the packaging placed on the market is designed so that its weight and volume is reduced to the minimum necessary to ensure its functionality, taking account of the shape and material from which the packaging is made.’ Article 10(2): ‘The manufacturer or importer shall ensure that packaging which does not comply with the performance criteria set out in Annex IV of this Regulation and packaging with characteristics that aim only to increase the perceived volume of the product, including double walls, false bottoms and unnecessary layers, is not placed on the market, unless: (…).’ Article 24(1): ‘By 1 January 2030 or 3 years from the entry into force of the implementing acts adopted pursuant to paragraph 2, whichever is the latest, 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 %.’ Commission’s interpretation: The empty space ratio in Article 24 applies to grouped, transport, and e-commerce packaging and needs to be complied with by the natural or legal person using or filling such packaging. The Commission will establish the methodology for calculation of the empty space ratio in an implementing act which will be adopted before 12 February 2028. For sales packaging, the minimisation requirements related to empty space are not linked to any predefined threshold and will therefore have to be assessed based on the existing standard EN 13428:2004 (23) , which applies until 1 January 2030, and will be updated in line with the updated performance criteria provided for in Part A of Annex IV and the requirements set out in Article 10. The obligated party is the manufacturer who will need to carry out the conformity assessment and draft the technical documentation and the EU declaration of conformity for the packaging.

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07