The EU packaging rules apply now. The half-empty box limit still waits

Regulation brief / World

The packaging law starts now, but the visible deadlines do not

Four dates separate the rulebook that already applies from the packaging changes shoppers will notice later.

1. The regulation applies from 12 August 2026The EU Packaging and Packaging Waste Regulation is now the common legal framework, even though many operational duties carry later dates.
2. Food-contact PFAS limits are an immediate changePackaging that touches food must comply with three concentration thresholds from the application date.
3. The half-empty box rule mostly belongs to 2030Grouped, transport and e-commerce packaging face a 50% maximum empty-space ratio from 2030 or later if the measurement method arrives late.
4. Fillers count as void, but protection still mattersBubble wrap, air cushions and paper cuttings count toward empty space; exemptions protect necessary space for irregular products and damage prevention.

The European Union's packaging regulation began applying on 12 August 2026. That sentence sounds like every parcel, takeaway cup and shampoo bottle changed overnight. It did not. The legal framework is live, but its most visible design mandates are distributed across 2028, 2029 and 2030.

The useful question is therefore not simply whether the law has started. It is which obligation has reached its own clock. The answer separates an immediate chemical limit in food-contact packaging from future empty-space controls, collection targets, recyclability requirements and bans on selected single-use formats.

The law starts before its most visible deadlines

Regulation (EU) 2025/40 now applies directly across the Union. It replaces a model built mainly around a directive with a shared rulebook covering the full life of packaging: substances, design, labelling, reuse, collection and recycling. The Commission's August guidance is meant to keep national authorities and businesses aligned while the remaining technical acts are prepared.

Application date12 August 2026

One rulebook, several implementation clocks

Application makes the regulation legally operative. It does not pull every later deadline forward. A claim that "the new EU packaging rules are in force" is correct; a claim that every 2030 pack is already unlawful is not.

This distinction resembles other European transitions in which the legal gate and the consumer experience move at different speeds. The first ETIAS year also changes its enforcement rule more than once. Packaging goes further: different product features sit on genuinely different statutory dates.

Food-contact PFAS limits are one of the immediate rules

The clearest immediate design constraint is chemical. From 12 August 2026, food-contact packaging cannot be placed on the market when per- and polyfluoroalkyl substances reach or exceed any of three thresholds: 25 parts per billion for a targeted individual PFAS, 250 parts per billion for the sum of targeted PFAS, or 50 parts per million for total PFAS including polymeric PFAS.

That makes supplier declarations and laboratory methods part of the packaging record now. A coating may still look, seal and repel grease exactly as it did before the application date; what changes is whether its chemistry can be documented beneath the statutory limits.

A half-empty delivery box becomes a measured failure in 2030

Article 24 creates the rule most likely to be photographed, shared and misunderstood. From 1 January 2030, or three years after the Commission's calculation method takes effect if that is later, grouped packaging, transport packaging and e-commerce packaging must keep their empty-space ratio at or below 50%.

The numerator is not just visible air. The regulation expressly treats filling materials such as paper cuttings, air cushions, bubble wrap, sponge and foam as empty space. A warehouse cannot make a large box compliant merely by filling the gap with more material.

Signature module / The Parcel Void Meter

Measure the room the product does not use

The meter treats protective filler as part of the gap. Its job is to expose a packaging decision, not to judge the parcel by sight alone.

Void plus filler

Product volume

50% threshold

Core ratio(package - product) / package

The Commission must still specify the detailed methodology. The legal test applies to the final packed configuration, not an empty carton catalogue.

Protection remains part of the decision. Necessary space for irregular shapes, multiple products and damage prevention can qualify for exemptions. The rule targets avoidable volume, not safe delivery.

Sales packaging follows a related but separate path. By 12 February 2028, manufacturers and importers must ensure that empty space is reduced to the minimum necessary for the packaging to perform its function. That duty is not the same as imposing the 50% logistics threshold on every retail pack.

The bans target specific uses rather than every single-use pack

From 2030, the regulation restricts a defined group of single-use plastic formats. The list includes some grouped packaging used to encourage multi-unit purchases, packaging for small quantities of fresh fruit and vegetables, selected food and drink containers consumed in hotels, restaurants and cafés, individual condiment portions, small hotel toiletry bottles and very lightweight carrier bags.

2030

Read the use case before declaring a ban

A ketchup sachet offered for consumption on hospitality premises is a different legal case from every flexible pouch. A miniature hotel shampoo bottle is not evidence that all small cosmetic packaging disappears. Scope is defined by material, format and use.

There are exceptions where hygiene, safety or food-waste prevention justify a format. The practical compliance record therefore needs more than a product photograph: it needs the material, intended setting, portion logic and any claimed exemption.

Deposit return and recyclability run on separate clocks

Member states must reach a 90% separate-collection rate by 2029 for single-use plastic bottles and metal beverage containers up to three litres. Deposit return systems are the default route unless a country can demonstrate that it has already achieved sufficiently high collection and can meet the target without one.

Recyclability moves on a 2030 design date. Packaging placed on the EU market must be recyclable, with performance grades and later tightening connected to recycling at scale. Recycled-content targets for plastic packaging also begin in 2030 and vary by packaging type. Those clocks affect bottle design, material sourcing and collection infrastructure differently, so one recycled-content percentage cannot summarize the whole regulation.

The result is a connected system rather than one ban. A pack can meet a chemical threshold but still use avoidable volume. It can be recyclable in design but enter a weak collection stream. It can contain recycled plastic yet fall within a prohibited single-use format. Compliance has to preserve all four answers.

Use the regulation as a dated specification. Record the packaging component, its function, food-contact status, material, measured void, market date and claimed exception. "PPWR compliant" without those fields is a slogan, not an auditable conclusion.

Questions about the packaging rulebook

Official packaging sources

EU packaging materials checked 21 August 2026

• European Commission - New packaging rules for less waste and easier recycling
• Regulation (EU) 2025/40 on packaging and packaging waste
• Commission guidance on Regulation (EU) 2025/40
• European Commission - Facts about the new EU packaging rules
• European Commission - Packaging and Packaging Waste Regulation FAQ