Summary
The EU Packaging and Packaging Waste Regulation (PPWR) replaces the Packaging Directive on 12 August 2026. It introduces hard, measurable rules for anyone who packs and ships goods in the EU: packaging minimised by design from 2026, a maximum empty space ratio of 50% for e-commerce, grouped and transport packaging from 2030, and reuse targets for transport packaging.
For logistics service providers this turns fill rate from a cost metric into a compliance metric, with a duty of care toward the clients they ship for.
The practical way to get there is cartonization: algorithmic box selection that lifts fill rates, cuts shipping costs by 15-30%, and logs the per-parcel evidence regulators and clients will ask for.
What is the Packaging and Packaging Waste Regulation (PPWR)?
The Packaging and Packaging Waste Regulation (PPWR) is the new EU packaging law. It applies in all 27 EU countries from 12 August 2026 (Regulation (EU) 2025/40, EUR-Lex) and replaces the 30-year-old Packaging Directive.
The rules cover packaging size, recyclability and reuse. The one that hits warehouses hardest: a limit on how much empty space a shipped box may contain.
Most coverage of PPWR is written by lawyers and EPR consultants. It talks about registrations, declarations of conformity, and recyclability grades. All real, all necessary. But if you run fulfillment operations, the regulation lands somewhere else first: at your pack stations. The box your packer grabs, the void fill they stuff around the product, the fill rate nobody measures today. That is where PPWR becomes operational.
PPWR is a regulation, not a directive. In plain terms: the old directive let every EU country write its own version of the rules. The regulation is one set of rules, identical everywhere, starting on the same date.
The goal: cut packaging waste in the EU by at least 15% by 2040 compared to 2018. Packaging consumes roughly 40% of plastics and 50% of paper used in the EU, according to the European Commission. The obligations roll out in waves:
One number deserves extra attention. The 2022 proposal said e-commerce parcels could contain at most 40% empty space.
The final regulation settled on 50%, measured against the volume of the products inside, and it applies from 1 January 2030. Void fill like air cushions, bubble wrap, foam and crumpled paper counts as empty space. The general duty to minimise packaging already starts in August 2026.
What does PPWR mean for logistics service providers?
If you are a 3PL or fulfillment provider, you do not own most of the packaging decisions in your building. Your clients do. PPWR does not care.
Article 20 gives fulfillment service providers a duty of care: you must make sure that storage, packing, addressing and dispatch do not compromise packaging compliance, and you may only work with companies that meet their own PPWR obligations (Greenberg Traurig, 2025).
In practice, three things change on the warehouse floor:
- Fill rate becomes a regulated KPI. Today, shipping air costs you money and nobody fines you for it. From 2030, a parcel that is more than half empty is a compliance problem on top of a cost problem.
You will need to know, per parcel, how much of the box the products filled. Most warehouses cannot produce that number today.
- Master data becomes a prerequisite. You cannot calculate an empty space ratio without accurate product dimensions. Warehouses running on estimated or missing SKU dims will not be able to prove anything, let alone optimize.
Dirty dimensional data was always expensive. Now it blocks compliance evidence.
- Clients will push compliance downstream. Brands and retailers facing PPWR obligations will write packaging requirements into 3PL contracts: approved box assortments, void fill limits, fill-rate reporting.
The LSPs that can offer compliant packing as a service win business. The ones that cannot will explain themselves in QBRs. Industry groups are already asking the Commission for clarity on exactly who proves what (Packaging Europe, 2026).
PPWR requirements: what to start working on now
August 2026 is the legal start, but 2030 is the operational deadline that requires lead time. Box assortments, packing processes and data quality do not change in a quarter.
A realistic preparation sequence:
- Map your packaging portfolio against the deadlines. Rows: packaging types you use (e-commerce boxes, transport cases, pallets, wrap). Columns: 2026, 2028 and 2030 obligations. This shows where documentation is missing and which formats are at risk.
- Fix your dimensional data. Accurate SKU dimensions are the foundation for every fill-rate calculation. Audit your master data before you trust any empty space number it produces. Capturing dims no longer requires a fixed dimensioning station: with Flux mobile dimensioning, any recent mobile device measures SKUs, parcels and pallets on the spot, so you can enrich master data during inbound instead of running a separate measuring project.
- Measure your current fill rate. Run your last 6-12 months of order data against your box assortment. Most warehouses that do this for the first time find average fill rates between 40% and 60%, which means a meaningful share of parcels already sits on the wrong side of the 2030 line.
- Review your box assortment. The right set of box sizes for your order profile does more for fill rate than any packing instruction. Often the analysis shows you need different sizes, not more sizes.
- Get documentation flowing from suppliers. Declarations of conformity and technical documentation are your suppliers' job to produce and your job to have on file from August 2026.
- Talk to your clients early. If you pack for brands, agree now on who measures what, which packaging is approved, and how fill rate gets reported. A duty of care works both ways.
Fill rate matters, but cost matters more
The obvious response to PPWR is to chase the highest possible fill rate: always pick the smallest box that fits. It is also the wrong response.
Squeezing every order into the tightest box can backfire in ways every operations manager has seen. Fragile items packed too tight get damaged in transit. An order forced into one overstuffed box sometimes ships cheaper, and safer, as two well-filled parcels.
And carrier tariffs do not scale linearly with size: a slightly larger box that stays inside a cheaper rate bracket can beat a smaller one that tips into dimensional-weight surcharges. Pure fill-rate optimization treats all of these as wins. Your P&L disagrees.
The smarter objective is cost-optimal packing: minimize total cost per shipment (box cost, void fill, transport, damage risk) with the PPWR empty space ratio as a hard constraint.
Done well, compliance is not a tax. It is the same exercise as cutting your shipping costs, finished properly. Less void fill is a side effect, not the goal.
How cartonization software gets you there
Deciding the optimal box for every order, across thousands of orders a day, is not a job for gut feeling at the pack station. It is a 3D bin-packing problem, and it is exactly what cartonization software solves: calculate the best box (or set of boxes) for each order before anyone touches a carton.
This is where Pulse comes in. Two design choices matter specifically for PPWR:
Configurable algorithms. Every operation has its own packing reality, and Pulse lets you set those rules instead of fighting a black box:
- Stacking constraints: rules like "this side up", no tilt, weight limits, stackability and crush limits.
- Diagonal rotation: place long items on the diagonal axis instead of jumping to a bigger box.
- Envelopes: select a flat mailer instead of a rigid box for thin, durable items.
- Adjustable height boxes: trim or set box heights to match the order contents.
That same configurability covers compliance: set a maximum empty space ratio per parcel, and the PPWR threshold becomes just another packing rule the algorithm respects.
Cost-awareness. Pulse does not just maximize fill. It weighs box cost, material use and carrier rates to pick the cheapest compliant option, including the call to split an order into two parcels when that beats one oversized box. Customers typically ship 15-30% less air, which shows up directly in transport spend.
In day-to-day operations that plays out in four places:
- At the pack station: packers get a box recommendation and packing instruction per order. No guessing, faster ramp-up for temp workers, consistent fill rates across shifts.
- Pick-to-box: assign the right box type at order release, so items go straight into the destination box during picking. No repacking step, no second touch.
- At order entry or checkout: cartonization runs before the warehouse touches the order, predicting box count and dimensions. That feeds accurate transport cost calculations and quotes, before the cost is locked in.
- In your KPIs: every calculated parcel logs its fill rate and empty space ratio. That is your compliance evidence for 2030 and your cost dashboard today, in one dataset.
This is not theory. Van Moer Logistics uses Pulse to optimize packing across its operations, CleanFilter cut its order packing costs the same way, and Voltex runs Pulse to support its pick-to-box operations.
The benefits of cartonization were already solid business before PPWR. The regulation just removed the option of ignoring them.
Questions?
The Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40) is the EU law replacing the 1994 Packaging Directive. It sets directly applicable rules on packaging minimisation, recyclability, reuse, labelling and empty space for all packaging placed on the EU market, with the goal of cutting packaging waste at least 15% by 2040 compared to 2018.
PPWR entered into force on February 11, 2025 and applies in all 27 EU member states from August 12, 2026. Some obligations come later: harmonised labelling applies from August 2028, and the empty space ratio, recyclability grades and reuse targets apply from January 1, 2030.
Under Article 24 of the EU Packaging and Packaging Waste Regulation (PPWR), e-commerce, grouped and transport packaging may contain a maximum of 50% empty space from January 1, 2030. Void fill such as air cushions, bubble wrap and foam counts as empty space. The broader duty to minimise packaging weight and volume applies from August 12, 2026. Cartonization software helps warehouses measure and meet these limits per parcel.
Yes. Fulfillment service providers must ensure that storage, packing, addressing and dispatch do not compromise packaging compliance, and they may only work with clients that meet their own PPWR obligations. In practice, LSPs that pack e-commerce orders will also need to measure and manage fill rates on the parcels they ship.
Three building blocks: accurate product dimension data, a box assortment matched to your order profile, and cartonization logic that selects the best box per order within a maximum empty space constraint. Cartonization software automates this per parcel and logs fill rates as compliance evidence, typically reducing shipped air by 15-30% at the same time.