Packaging minimisation under the PPWR – how to demonstrate compliance?

What does packaging minimisation under Article 10 of the PPWR mean?

Minimisation means designing packaging so that its mass and volume are limited to the minimum necessary to fulfil the packaging’s functions.

It is therefore not about achieving the smallest possible box at all costs. Packaging may still require adequate strength, barrier properties, space for legally required information, resistance to the filling process or parameters enabling safe transport.

However, where particular grams of material or centimetres of volume serve no justified function, their presence will become increasingly difficult to defend under the PPWR.

When does PPWR packaging minimisation apply?

The requirement in Article 10(1) to reduce mass and volume to a minimum is linked to the date of 1 January 2030.

This does not mean, however, that packaging design is irrelevant until 2029. From the general date of application of the PPWR, the prohibition on packaging features whose sole purpose is to increase the perceived volume of the product is also relevant.

From a business perspective, preparation for 2030 should therefore begin much earlier. If a company has hundreds of packaging types, carrying out minimisation assessments only at the end of 2029 will be operationally difficult.

Article 10(1) and (2) – two different requirements

Article 10 covers both the future obligation to systematically minimise mass and volume and the restriction on designs intended solely to artificially increase the perceived size of the product.

Therefore, simply stating that ‘the packaging has looked the same for years’ is not a technical argument demonstrating minimisation.

What does ‘minimum necessary’ mean in practice?

The minimum necessary is not a single figure common to an entire product category.

For one product, the limiting factor may be the packaging’s resistance to dropping. For another, it may be a barrier against moisture or oxygen. Other packaging may require a specified surface area due to mandatory legal information.

The minimisation assessment should therefore answer two questions:

1. Is the specified mass or volume needed to fulfil one of the justified functions?
2. Can the packaging be reduced further without losing that function?

If the answer to the second question is “no”, the company should be able to show why.

Annex IV to the PPWR – criteria justifying the mass and volume of packaging

Annex IV provides a practical reference point for assessing minimisation. It covers functional criteria that may justify a specific packaging design.

Each criterion should be applied only to the extent that it genuinely limits the possibility of further reduction of the specific packaging.

1. Product protection – packaging reduction must not increase losses

Minimisation should not lead to a situation where saving a few grams of material results in an increase in the number of damaged products.

If a lower wall thickness causes packaging to crack, loss of barrier properties, shorter product shelf life or an increased number of complaints, there may be justification for retaining a greater amount of material.

However, it is important to document this link. Simply stating that “thicker is safer” is not as strong evidence as a comparison of options and test results.

2. The manufacturing and packaging process may determine minimum parameters

The packaging design must work not only after the product is placed on the market, but also during its manufacture and filling.

For example, film that is too thin may cause problems with forming, sealing or material handling on the line. A bottle that is too light may deform during the filling process.

In such a case, it is worth retaining data from production trials showing at which parameter problems arise and why the selected option is the minimum stable solution.

3. Logistics may justify packaging strength

Packaging must withstand storage, order picking, transport and other real-life supply chain conditions.

If a further reduction in carton grammage results in a loss of compression resistance during stacking, this may be an important functional argument.

Evidence may include, among other things:

• compression tests,
• vibration tests,
• transport tests,
• drop tests,
• pilot distribution results,
• product damage data.

4. Hygiene and safety may also limit reduction

For food, pharmaceuticals, cosmetics and other sensitive products, packaging integrity, protection against contamination or the provision of barrier properties may be important.

Minimisation should not undermine requirements arising from other EU legislation.

Therefore, the PPWR assessment should be carried out together with product requirements, rather than separately from them.

5. Legal and information requirements may require a specific packaging surface area

Some products must contain an extensive set of mandatory information. If specific markings must appear on the packaging and meet legibility requirements, this may affect its minimum size.

However, this does not automatically mean that every large marketing surface area is justified.

The company should be able to distinguish between:

• information required by law,
• information needed for safe use,
• voluntary information,
• purely promotional elements.

6. Consumer acceptance is not a universal justification for a larger box

One of the riskiest arguments is the statement:

“the customer expects large packaging”.

The PPWR is specifically aimed at reducing unnecessary packaging and designs that increase the perceived volume of a product.

Any user-related argument should refer to an actual function – for example ergonomics, accessibility, safe opening or dispensing – and not merely to increasing visual appeal.

How to carry out a packaging minimisation assessment step by step?

The best documentation is not created after the project is completed. It should be created alongside the optimisation process.

1. Identify the specific packaging type and version.
2. Record the current weight and key dimensions.
3. Define the packaging functions.
4. Review the criteria in Annex IV.
5. For each criterion, indicate whether it limits the possibility of further reduction.
6. Propose a lighter or smaller variant if technically feasible.
7. Compare the variants.
8. Carry out the necessary tests.
9. Record the parameter at which loss of functionality occurs.
10. Select the smallest variant meeting the requirements.
11. Keep the results and justification in the technical documentation.

Comparing variants is one of the strongest pieces of evidence for minimisation

It is much easier to justify a weight of 38 g if the company can show that the 35 g variant did not meet a specific criterion.

Such a record creates a clear chain: the reduction was carried out, the limit was checked, and the selected option does not result solely from the designer’s preference.

What tests can help demonstrate minimisation?

The Packaging and Packaging Waste Regulation does not establish one mandatory set of tests for every packaging.

The test should correspond to the function that limits further reduction.

Laboratory tests are therefore an evidential tool, not an end in themselves.

Mass minimisation and volume minimisation are two separate parameters

Lighter packaging does not necessarily have to be smaller, and smaller packaging does not necessarily have to be lighter.

The assessment should therefore take both aspects into account.

For example, a company may reduce the grammage of cardboard without changing the dimensions of the box, or reduce the dimensions while retaining the same material grammage.

It is advisable to record separately in the documentation:

• the mass of the packaging unit,
• external dimensions,
• volume,
• parameters of key components.

Double walls, false bottoms and unnecessary layers – when do they become a problem?

The Packaging and Packaging Waste Regulation pays particular attention to solutions whose sole purpose is to create the impression of a larger product.

Examples of problematic elements include:

• a false bottom without a technical function,
• an unnecessary double wall,
• an unnecessary divider increasing the size,
• a layer used solely to visually enlarge the packaging.

However, the mere presence of a double wall does not automatically mean non-compliance. If it performs an actual protective, structural, barrier or safety function, that function must be demonstrated.

Packaging minimisation and the 50% empty space limit are not the same provision

One of the more common errors is combining Article 10 and Article 24 into one universal ‘packaging size limit’.

Article 10 concerns the general minimisation of packaging mass and volume.

Article 24, by contrast, introduces a maximum empty space ratio of 50% for certain grouped, transport and e-commerce packaging.

Packaging may therefore comply with the empty space limit and still be too heavy. It may also be very light but, in a particular use, breach the future empty space limit.

PPWR provides for 50% empty space – not 40%

Article 24 of the PPWR sets a maximum empty space ratio of 50%.

Other values may be found in some online publications. However, when preparing documentation, you should rely on the applicable text of the Regulation and the relevant implementing acts.

The date from which the limit applies is also phased: 1 January 2030 or three years from the entry into force of the relevant implementing acts – whichever is later.

Filling materials specified in Article 24 are included as empty space, so adding more paper or air cushions is not a way to “reduce” the result.

What should technical documentation on minimisation contain?

The most important thing is to record the reasoning process and evidence.

The documentation should make it possible to determine:

• which packaging type the assessment concerns,
• its current weight and volume,
• which Annex IV criteria apply,
• which criterion limits further reduction,
• which options were analysed,
• which tests or calculations were carried out,
• why a lighter or smaller solution was rejected,
• which option was considered minimal while maintaining functionality.

A well-prepared document should not be limited to one sentence: “the packaging has been optimised”.

Example of a minimisation assessment record

Instead of:

“The bottle cannot be reduced further.”

the documentation may state:

“Options weighing 24 g, 22 g and 20 g were analysed. The 20 g option did not meet the load resistance criterion under the transport conditions specified in procedure X. The 22 g option met all required parameters and was therefore adopted as the minimal option.”

Such a record shows both the reduction attempt and the technical limit to further optimisation.

What data do you need from the packaging supplier?

If the packaging or one of its components comes from an external supplier, you may need, among other things:

• the weight of the packaging and components,
• dimensions,
• material thickness,
• strength parameters,
• technical drawings,
• production tolerances,
• results of relevant tests,
• information on earlier design options.

Article 16 of the PPWR requires suppliers to provide the information and documentation needed by the manufacturer to demonstrate conformity.

A product change may require a reassessment of minimisation

The minimisation assessment should not be treated as a document that remains valid indefinitely, regardless of changes.

The following may require a further review, among other things:

• change in product weight,
• change in product dimensions,
• change in formulation affecting barrier requirements,
• change in distribution channel,
• change in packaging material,
• change of supplier,
• change in the packaging process,
• change in mandatory information on the label.

If the basis that previously justified a particular dimension or weight has changed, the previous result may need to be updated.

Most common errors when demonstrating PPWR minimisation

• assuming that every weight reduction automatically means compliance;
• no volume analysis;
• no reference to the criteria in Annex IV;
• no evidence as to why further reduction is impossible;
• using a marketing argument as a technical argument;
• confusing Article 10 with the empty space limit in Article 24;
• using a value of 40% instead of the 50% limit resulting from Article 24;
• no versioning of test variants;
• no identification of the packaging assessed;
• retaining the result without a report or methodology;
• no reassessment after a change to the product or material.

PPWR packaging minimisation – compliance checklist

1. Identify the packaging type and version.
2. Weigh the packaging.
3. Record its dimensions and volume.
4. Define all packaging functions.
5. Review each criterion in Annex IV.
6. Identify the criteria limiting reduction.
7. Check whether a lighter variant is possible.
8. Check whether a smaller variant is possible.
9. Test variants if required by the function.
10. Record test results.
11. Document the reason for rejecting lighter or smaller versions.
12. Select the minimum variant meeting all justified requirements.
13. Include the assessment in the technical documentation.
14. Link the assessment to the relevant packaging type and declaration.
15. Monitor subsequent changes.

How can minimisation assessments be managed for multiple packaging items?

With several hundred variants, manually maintaining separate spreadsheets quickly becomes a problem.

One packaging type may undergo several revisions:

42 g → 40 g → 38 g → test failed at 35 g → 38 g variant approved.

If a company retains only the final 38 g specification, it loses some of the most important evidence: the history showing that further reduction was actually assessed.

A PPWR system should therefore enable versioning of designs, test results and justifications, and then link the final assessment to the technical documentation for the specific packaging type.

How can compliance with the PPWR minimisation requirement be demonstrated?

The best evidence is not a statement that packaging “is light”, but a documented limit for further reduction.

The company should show which functions the packaging must retain, which Annex IV criteria apply, which variants were assessed and why lower weight or volume would result in the loss of the required functionality.

In this way, minimisation ceases to be a general environmental objective and becomes a repeatable technical process:

parameters → criteria → variants → tests → result → justification → technical documentation.

FAQ – packaging minimisation under the PPWR