Packaging Minimisation and Empty Space: Articles 10 and 24 Explained
Design packaging down to the minimum its function justifies - and ship no consignment more than half air. The pillar guide to the minimisation duty, the performance criteria that justify material, and the 50 percent empty-space ratio.
The short answer
Article 10 requires packaging to be designed so that its weight and volume are limited to the minimum necessary to ensure its functionality - judged against the performance criteria listed in Annex IV: product protection, manufacturing practicality, logistics, presentation of information, hygiene, safety, legal requirements and the rest of the honest list. Article 24 adds the measurable edge for shipped packaging: the empty space ratio in grouped, transport and e-commerce packaging may not exceed 50 percent from 1 January 2030 - the share of a consignment's packaged volume that is neither product nor packaging material, capped at half.
Between them the two articles convert 'less packaging' from a sentiment into two auditable questions: can you justify every gram against a criterion, and can you measure your air? This station works both - the justification discipline, the measurement method, the trade-offs, the misleading-design prohibitions, and the right-sizing programmes that answer them.
Two logics: justification and measurement
Minimisation is a justification duty: it does not set gram limits per category, because the necessary minimum is a property of the product and its journey. Its evidence is a documented argument - this weight, this volume, because these Annex IV criteria require them - and its enemy is not heavy packaging but unjustified packaging: the double wall that protects nothing, the oversized carton that exists because the assortment has three sizes, the false bottom that sells air as product. The empty-space cap is the opposite kind of rule: a number, measured at the consignment, indifferent to arguments except the qualifications its methodology writes in. Programmes need both crafts - engineers who can argue function and analysts who can measure volume - and the station is organised so each article builds one of them.
How the station runs
The ratio comes first, in full - definition, calculation, what counts as space and what counts as material. Measurement practice follows: how to actually measure a consignment, irregular shapes and all. Then the justification system: Annex IV's criteria worked one by one, and the misleading-design prohibitions that give minimisation its teeth in marketing-facing formats. Then the programmes: lightweighting that survives validation, the protection trade-off argued with damage data, e-commerce right-sizing, void-fill choices, and grouped/transport application. Documentation closes the station, because in this area more than any other the file is the difference between a design philosophy and a compliance position.
One consignment, both questions
A worked miniature joins the two logics. A mail-order consignment: a 4-litre carton holding a 1.6-litre product, 0.2 litres of packaging material and 2.2 litres of air and fill. Ratio: 55 percent - the cap fails it before any argument begins. The right-sizing answer is a 2.5-litre carton: ratio falls to roughly 28 percent, freight volume drops by more than a third, and the product rides tighter and safer. Now the justification question on the product's own pack: a glass bottle at a wall thickness 20 percent above the lightest validated rung, justified in the file by the drop-test record on the worst distribution lane and the returns data at the lighter gauge. Same business, two articles, two different crafts - and the file answers both without confusing them.
Programme order for a mixed estate
Sequence for a business starting from zero. First, measure: the dispatch-week audit finds the ratio distribution and names the tail. Second, fix the tail's cheap causes: carton assortment gaps, picking rules, single-item defaults. Third, build the justification files for the heavy end of the product range, where Article 10's questions will concentrate. Fourth, run the lightweighting ladder on the highest-volume specifications, where grams compound into tonnes. Each step funds the next - freight savings from right-sizing are real money in the first quarter - and each produces its own evidence as it goes. Programmes that start at the fourth step, redesigning flagship packs while the fulfilment tail ships air, are optimising the photograph, not the position.
Primary sources on the record
- Regulation (EU) 2025/40 of 19 December 2024 on packaging and packaging waste, Official Journal text on EUR-Lex.
- European Commission, packaging waste topic page - guidance and act progress.
- European Parliament and Council Directive 94/62/EC of 20 December 1994 on packaging and packaging waste, text on EUR-Lex - the directive the PPWR repeals and replaces.
Legal status: Articles 10 and 24 and Annex IV of Regulation (EU) 2025/40. Application position for this topic: Minimisation duty applies with the regulation; its enforceable design form and the empty-space cap bite from 1 January 2030.