PPWR Minimisation Applies From 2030: What to prepare for.

Several guides list packaging minimisation among the duties that started on 12 August 2026. Article 10(1) of Regulation (EU) 2025/40 opens with the words "By 1 January 2030". The three and a half years in between are the time a packaging team needs to build the evidence the 2030 file will demand. This article sets out the dates and the method.

The dates in Articles 10, 24 and 70

Article 10(1) requires the manufacturer or importer to ensure, by 1 January 2030, that packaging is designed so that its weight and volume are reduced to the minimum necessary to ensure its functionality. Article 10(2) adds the ban on packaging that fails the performance criteria in Annex IV and on characteristics that aim only to increase the perceived volume of the product: double walls, false bottoms, unnecessary layers. Exceptions exist for designs and trademarks protected before 11 February 2025 and for products with a protected geographical indication. Paragraph 2 carries no date of its own. Commission Notice C/2026/3084 (point 10) and the Commission-published FAQ (Section VII) read it together with paragraph 1 as applying from 1 January 2030. Both are non-binding guidance, and that is the reading we work with; a Member State could take a different view.

Until then, the existing rule stays in force. Article 70(1)(b) keeps Article 9(1) and (2) of Directive 94/62/EC alive for the essential requirement in the first indent of point 1 of its Annex II until 31 December 2029. That is the Directive's minimisation requirement. The essential requirement, and the presumption of conformity attached to EN 13428:2004, continue for this purpose until 31 December 2029 under Article 70(1)(b).

Two further dates shape the work:

• By 12 February 2027, the Commission must request harmonised standards for measuring compliance with minimisation; for the most common packaging types and formats, those standards should specify maximum weight and volume limits, wall thickness and maximum empty space (Article 10(3)).
• By 12 February 2028, the Commission must adopt the implementing act with the methodology for the empty space ratio (Article 24(2)). The 50 percent maximum for grouped, transport and e-commerce packaging then applies from 1 January 2030 or three years after that act, whichever is later (Article 24(1)). Filling materials such as air cushions, paper cuttings and foam count as empty space.

One date is earlier than most teams expect. Article 24(4) requires economic operators who fill sales packaging to reduce empty space to the minimum necessary for functionality, including product protection, by 12 February 2028. Headspace required to protect food and settling during transport are excluded.

On this reading, Article 10 is not yet an applicable requirement for a declaration of conformity issued today. The Directive's essential requirement is, exactly as before.

Why 2030 is closer than it looks

Annex IV Part A lists eight performance criteria: product protection, packaging manufacturing processes, logistics, packaging functionality, information requirements, hygiene and safety, legal requirements, and recycled content, recyclability and re-use. Criterion 8 allows additional weight or volume where a mono-material or a reusable design needs it.

Article 10(4) then defines what the technical documentation must contain: the specifications and standards used to assess the packaging against those criteria, the design requirement under each criterion that prevents further reduction, and the test results, studies or modelling used to establish the minimum. That is engineering evidence: drop tests, compression tests, shelf-life studies, line trials, transport simulations.

A redesign cycle for a mid-market portfolio, from brief to first production run, takes between twelve and twenty-four months; that is a PSL experience figure rather than anything in the Regulation. Most portfolios will go through one such cycle before 2030. Every redesign between now and then should produce the Annex IV file as a by-product, so that 2030 is a review rather than a rebuild.

How to document the trade-off

The five steps below are PSL preparation practice; the legal anchor is the documentation content defined in Article 10(4). Per packaging family:

1. List the eight criteria and state which ones are relevant for this product.
2. Identify the binding constraint. Which criterion stops further reduction, and why? For a glass jar it may be hygiene and safety. For a shipping carton it is usually logistics.
3. Attach the evidence for that constraint: the test, the standard, the simulation, the line trial.
4. Record the alternatives considered and the reason each was rejected.
5. Note what would change the answer: a new material, a new filling line, a change in distribution.

Then apply the perceived-volume test to every structural feature. Can each wall, insert, layer or base be justified by one of the eight criteria? A feature whose only function is shelf presence is exposed from 2030 unless one of the Article 10(2) exceptions applies, and those are narrower than they look: the design or trademark must have been protected before 11 February 2025, and the minimisation requirement must affect its novelty, individual character or distinctiveness. Products under a protected geographical indication or an EU quality scheme form the second exception.

E-commerce packaging carries two numbers: the empty space ratio of the outer, and the volume of fill material inside it, because fill material counts as empty space. A right-sizing programme that addresses only carton dimensions solves half of the problem.

Key takeaways

• Article 10 minimisation applies from 1 January 2030. Until 31 December 2029, the Packaging Directive essential requirement continues under Article 70(1)(b).
• Standards mandate by 12 February 2027; empty space methodology by 12 February 2028; sales packaging empty space duty from 12 February 2028.
• The 2030 file needs engineering evidence per Annex IV criterion: tests, studies or modelling behind each binding constraint.
• Every redesign before 2030 should generate the Annex IV documentation as a by-product.
• Fill material counts as empty space. Right-sizing must cover both the outer and the void inside.

Minimisation is the requirement where regulation and packaging engineering meet, and where a paper exercise will not survive the first test report. If your team is planning redesigns before 2030, PSL can help you set the evidence standard now so that each project builds the file. Book a call with us to start the conversation.

This article distinguishes binding PPWR requirements from non-binding Commission guidance and from PSL's implementation approach. It is general information rather than legal advice for a specific packaging format, transaction or Member State.

PSL connects PPWR requirement planning with material reduction and packaging development, so minimisation decisions can be tested against product protection and production requirements.