What is the PPWR minimisation requirement and how is it measured?

The PPWR minimisation requirement is the obligation under EU law for manufacturers and importers to ensure that packaging placed on the EU market uses the minimum weight and volume necessary to fulfil its function. It also bans packaging formats that artificially inflate perceived product volume, such as double walls, false bottoms, and unnecessary layers. The sections below unpack how the requirement is defined, measured, what packaging types it covers, and when each deadline applies.

How is packaging minimisation defined under PPWR?

Under the EU Packaging and Packaging Waste Regulation (PPWR), packaging minimisation is a dual obligation: packaging must be designed so that its weight and volume are reduced to the minimum necessary for functionality, and packaging that uses structural tricks to inflate the apparent size of a product must not be placed on the market. The regulation explicitly names double walls, false bottoms, and unnecessary layers as prohibited characteristics.

This is not an entirely new concept. Packaging minimisation was already required under the earlier Directive 94/62/EC, so businesses that have been assessing their packaging against European standards for years are working on familiar ground. What the PPWR changes is the criteria used to judge whether a packaging design is genuinely minimised. Under the old directive, consumer acceptance and marketing considerations were valid reasons to justify extra material. The PPWR regulation text removes both of those justifications entirely. In their place, the regulation adds recyclability, recycled content, and suitability for reuse as legitimate performance criteria that can justify additional material where genuinely necessary.

In practice, this means a packaging design can no longer be defended on the grounds that consumers prefer a larger-looking box or that the format supports brand presentation. Every gram of material must serve a functional purpose, whether that is protecting the product, enabling safe handling, supporting transport, or meeting recyclability requirements. For food packaging professionals, this represents a meaningful shift in how design decisions need to be documented and justified.

Fiber-based food trays, such as the Jospak cardboard tray, are well positioned within this framework precisely because their structure is built around functional requirements. A gas-tight fiber tray used for modified atmosphere packaging (MAP) of fresh meat, fish, or ready meals contains no decorative structural elements. The material is there to protect the product, maintain the gas barrier, and survive the supply chain, which is exactly the kind of justification the PPWR minimisation framework is designed to reward.

How is the PPWR minimisation requirement measured?

The PPWR minimisation requirement is measured through a qualitative technical assessment documented in the Annex VII technical file. Manufacturers must identify, for each relevant performance criterion, the specific design constraint that prevents further material reduction. This is not a single calculation or a pass/fail threshold test. It is a structured, documented justification of why the packaging cannot be made lighter or smaller without compromising its function.

Until 1 January 2030, the applicable methodology is the existing harmonised standard EN 13428:2004, which sets out a self-assessment approach using qualitative checklists and the identification of a “critical area” that prevents further reduction. Companies already familiar with this standard from compliance under the old directive can use the same framework as a transitional tool under the PPWR.

What must the technical documentation include?

The Annex VII technical file must contain the design and manufacturing specifications for every packaging component, including substrates, coatings, inks, adhesives, closures, and labels. It must list the harmonised standards or technical specifications applied, and it must include the minimisation assessment itself, showing how the packaging was evaluated against the Annex IV performance criteria and why no further reduction was possible. The PPWR Annex VII documentation requirements make clear that this is a self-certification process with no notified body involved in the standard case, but full legal responsibility sits with the manufacturer or importer.

What role does the Declaration of Conformity play?

Once the technical file is complete, manufacturers must draw up a Declaration of Conformity (DoC) in the format set out in Annex VIII of the regulation. The DoC is the formal statement that the packaging meets the applicable PPWR requirements. For minimisation specifically, the DoC obligation is tied to the broader documentation requirement, meaning the technical justification must be in place before the declaration is signed.

Looking ahead, the Commission is required to request updated harmonised standards from CEN by February 2027. Those future standards are expected to specify maximum weight and volume limits for common packaging formats, and conformity with them will create a legal presumption of compliance, simplifying the assessment process considerably for manufacturers.

Which packaging categories does the minimisation rule apply to?

The PPWR minimisation requirement applies to all packaging placed on the EU market, regardless of material or origin. This covers sales packaging (primary), grouped packaging (secondary), and transport packaging. There are no general exemptions for small businesses, and the rule applies equally to packaging produced outside the EU if it is sold into the EU market.

The PPWR classifies packaging by its role in the supply chain rather than by the material it is made from. Sales packaging is what consumers interact with directly at the point of purchase. Grouped packaging bundles multiple sales units together. Transport packaging protects products during distribution. All three categories are subject to the Article 10 minimisation obligation.

It is worth distinguishing the general minimisation requirement from the separate empty space ratio rule in Article 24. The empty space cap, which limits empty space to a maximum of 50%, applies specifically to grouped packaging, transport packaging, and e-commerce packaging from 1 January 2030. Sales packaging is not subject to a fixed percentage threshold. Instead, it is assessed under the Article 10 minimisation framework, which requires empty space to be reduced to the functional minimum without specifying a numeric ceiling.

For food manufacturers, this means that primary food trays used for fresh meat, fish, poultry, ready meals, plant-based proteins, and salads all fall directly under the Article 10 minimisation rules. Any secondary or outer packaging used in distribution is also covered, and if that packaging is sold through e-commerce channels, the Article 24 empty space rules will apply on top of the general minimisation obligation from 2030 onward. The PPWR scope for global businesses confirms that no company selling packaged goods into the EU can treat this as someone else’s compliance problem.

What are the deadlines for PPWR minimisation compliance?

The PPWR’s minimisation requirements apply in two phases. The general minimisation principle, assessed using the transitional EN 13428:2004 standard, has been in effect since the regulation’s general application date of 12 August 2026. The full Article 10 minimisation obligations, including the updated Annex IV performance criteria that remove marketing and consumer acceptance as justifications, apply from 1 January 2030.

The key dates for packaging minimisation compliance are as follows:

• 12 August 2026: PPWR general application date. The transitional minimisation framework under EN 13428:2004 applies. Annex VII technical documentation and the Declaration of Conformity become mandatory for other applicable requirements. Formal Article 10(1) and 10(2) compliance is not yet required in the DoC, but the general minimisation principle is in effect.
• 12 February 2027: The Commission must formally request CEN to develop updated harmonised standards for packaging minimisation, including maximum weight and volume limits for common formats.
• 12 February 2028: Companies filling sales packaging must ensure empty space is reduced to the functional minimum. The Commission must also adopt implementing acts establishing the methodology for calculating the Article 24 empty space ratio.
• 1 January 2030: Full Article 10 minimisation requirements apply under the updated Annex IV criteria. The 50% empty space cap for grouped, transport, and e-commerce packaging takes effect. Design for recyclability requirements and minimum recycled content thresholds also begin.

The phased timeline gives businesses a meaningful window to prepare, but the 2030 deadline is binding and the updated methodology will require more rigorous documentation than many companies currently maintain. Starting the technical file process now, under the EN 13428:2004 framework, is the most practical way to build the internal capability needed before the stricter 2030 criteria arrive. The PPWR compliance timeline published by Latham & Watkins provides a useful reference for the full sequence of obligations across all PPWR articles.

For food packaging teams evaluating format changes ahead of 2030, switching from rigid plastic trays to fiber-based alternatives addresses the minimisation requirement at a structural level. A fiber tray with up to 90% less plastic compared to equivalent fully plastic packaging eliminates the material categories most likely to face scrutiny under the updated Annex IV criteria, while also supporting the recyclability and recycled content requirements that arrive alongside minimisation in 2030.