PPWR packaging minimisation is a design-and-evidence requirement, not an instruction to choose the lowest mass regardless of performance. Article 10(1) requires manufacturers or importers, by 1 January 2030, to ensure packaging is designed so that its weight and volume are reduced to the minimum necessary for its functionality, taking account of its shape and material. [1]
The distinction matters when a lightweight option protects the product differently, or when a heavier reusable design performs a different service. A mass comparison can describe a change without establishing that the legally relevant design question has been answered.
Function constrains the reduction
Article 10 links the design assessment to performance criteria and the technical documentation. The file should explain which design requirements prevent further weight or volume reduction and the evidence used to assess the necessary minimum. Tests, studies, modelling and simulations can contribute where relevant. The regulation does not turn an unexplained percentage reduction into a complete assessment. [1]
The Spanish original’s Article 10(2) annex reference was corrected in May 2025 from Annex VI to Annex IV. That correction is material when following the performance criteria. This guide reads the original together with that correction, rather than repeating the incorrect cross-reference. [2]
| Question | Rule or evidence | Important boundary |
|---|---|---|
| Design objective | Minimum necessary weight and volume | Article 10(1) retains functionality, shape and material |
| Artificial bulk | Features solely increasing perceived volume | Article 10(2) identifies examples and conditional exceptions |
| Evidence | Design constraints, assessment basis and relevant results | Article 10(4) connects the conclusion to technical documentation |
| Reuse | Consider the reusable system’s characteristics | Do not compare weight without the required function |
Artificial bulk is a different problem
Article 10(2) addresses packaging that fails the relevant criteria and features intended only to increase the perceived volume of a product, including double walls, false bottoms and unnecessary layers. The provision also contains specific exceptions involving certain protected designs or shape trademarks and protected geographical or quality schemes. [1]
Those exceptions have conditions. For the design and trademark route, the protection date and effect on the protected design or distinguishing function matter. It would be misleading to summarise the provision as “premium packaging is exempt”, or to assume that registering a new shape now supplies the exception.
Keep minimisation separate from an empty-space ceiling
Article 10 concerns the necessary weight and volume of packaging. Article 24 separately addresses empty space, including a conditional future maximum for specified grouped, transport and e-commerce packaging. Passing a void-ratio calculation does not, on its own, demonstrate that the pack has the minimum necessary weight.
Conversely, reducing material mass does not establish the Article 24 result. A thinner but oversized shipping box can change one variable while leaving another largely unchanged. The two provisions should therefore be examined as related but distinct design questions.
Build a record of the design trade-off
A useful record identifies the protected product and service, relevant design constraints, options examined and evidence explaining why further reduction would compromise the required functionality. For reusable packaging, the regulation requires attention to its reusable characteristics and the applicable reuse requirements. [1]
This is an explanation of the provision’s structure, not an assessment of a particular packaging design. The next meaningful evidence is the actual construction and its performance record; a generic sustainability label cannot supply it.
The wider implementation context is covered in our PPWR overview; the present guide isolates the provision identified above.
Sources
Sources checked 21 October 2026. Legal text, official interpretation and editorial examples are distinguished above. No individual product or business conformity assessment was performed.
- European Parliament and Council / Official Journal via BOE. Regulation (EU) 2025/40 on packaging and packaging waste. 19 December 2024; OJ 22 January 2025. Locator: Article 10 and Annex IV; Spanish corrigendum 22 May 2025. Relevant full original provisions read in the official Spanish rendition; English explanation is an editorial paraphrase, not an official translation.
- Official Journal / BOE. PPWR Spanish Article 10(2) corrigendum. 22 May 2025; corrected reference is Annex IV. Locator: Article 10 and Annex IV; Spanish corrigendum 22 May 2025. Relevant official text read; scope is the cited provision or guidance.
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