Our e-commerce parcels are mostly air

E-commerce packaging is a defined term. Under the Packaging and Packaging Waste Regulation (EU) 2025/40 it is transport packaging used to deliver products to the end user in online or other distance sales (Article 3(1), point (8)). Transport packaging facilitates handling and transport to prevent damage (point (7)), and grouped packaging groups sales units at the point of sale (point (6)).^[1]

The ratio rule targets whoever fills these packages. By 1 January 2030 or 3 years from the entry into force of the implementing acts on the calculation method, whichever is later, economic operators who fill grouped packaging, transport packaging or e-commerce packaging ensure that the maximum empty space ratio is 50 % (Article 24(1)). The Commission adopts the method by 12 February 2028, taking into account cases such as irregular shapes, several sales units in one package, liquids, fragile products, small products that larger ones could damage, and the space needed for shipping labels (Article 24(2)).^[1]

The calculation is fixed in the text. Empty space is the difference between the total volume of the grouped, transport or e-commerce packaging and the volume of the sales packaging it contains; the ratio is that empty space divided by the total volume (Article 24(3)(a) and (b)). Space filled by paper cuttings, air cushions, bubble wrap, sponge and foam fillers, wood wool, polystyrene or Styrofoam chips counts as empty space (Article 24(3)).^[1]

Two exemptions apply to the 50 % rule. Operators that use sales packaging as e-commerce packaging, and operators that use reusable packaging within a re-use system, are exempt, but their sales packaging must still meet the minimisation requirements of Article 10 (Article 24(5)). Article 10 requires the manufacturer or importer to design packaging, by 1 January 2030, so that its weight and volume are reduced to the minimum necessary for its functionality (Article 10(1)), and to keep off the market packaging with characteristics that only increase the perceived volume of the product, such as double walls, false bottoms and unnecessary layers, with exceptions for designs and trade marks protected before 11 February 2025 and for products with a protected geographical indication or under a Union quality scheme (Article 10(2)(a) and (b)). Article 10(2) carries no date of its own.^[1]

Sales packaging has its own, earlier rule. By 12 February 2028, operators who fill sales packaging reduce empty space to the minimum needed for functionality, including product protection (Article 24(4)). Fulfilment service providers make sure warehousing, handling and packing do not jeopardise compliance with Articles 5 to 12 (Article 20). The Commission reviews the ratio and its exemptions by 12 February 2032 (Article 24(6)).^[1]

The old rule has not disappeared yet. Article 9(1) and (2) of Directive 94/62/EC, which make the essential requirements in its Annex II a condition for placing packaging on the market, continue to apply until 31 December 2029 as regards the first requirement of Annex II, point 1 (PPWR Article 70(1)(b)): packaging is manufactured so that its volume and weight are limited to the minimum adequate amount to maintain the necessary level of safety, hygiene and acceptance for the packed product and for the consumer (Directive 94/62/EC, Annex II, point 1).^[1][2]