PPWR packaging minimisation: Article 10 and what to expect

PPWR packaging minimisation requirements will introduce new rules designed to reduce unnecessary packaging and improve resource efficiency across the EU. Under Article 10, manufacturers and importers must ensure packaging weight and volume are reduced to the minimum necessary while maintaining functionality, with enforcement scheduled from 1 January 2030.


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With PPWR now applying, it is important to understand how PPWR packaging minimisation requirements will affect businesses placing packaging on the Northern Ireland and EU market.

Article 10 sets out the new packaging minimisation requirements and is scheduled to come into force on 1 January 2030. It is one part of the wider Packaging and Packaging Waste Regulation (PPWR), which aims to improve harmonisation and sustainability across the EU.

Key points

  • Article 10 introduces mandatory packaging minimisation requirements.
  • Packaging weight and volume must be reduced to the minimum necessary for functionality.
  • Packaging designed to artificially increase perceived product volume will not be permitted.
  • Non-compliant packaging may not be placed on the Northern Ireland or EU market.
  • Certain protected designs and geographical indications may be exempt.
  • Enforcement is scheduled to begin from 1 January 2030.

Key takeaways from Article 10

There are two central obligations that define the new packaging minimisation requirements under Article 10.

1. Weight and volume optimisation

By 1 January 2030, the manufacturer or importer must ensure that packaging placed on the market is designed so that its weight and volume are reduced to the minimum necessary to ensure its functionality, taking account of the shape and material from which the packaging is made.

2. No excessive or inflationary components

Manufacturers and importers must ensure that packaging does not contain features that fail to meet the required performance criteria or are intended solely to increase the perceived volume of a product.

Examples specifically referenced within Article 10 include:

  • Double walls
  • False bottoms
  • Unnecessary layers

Failure to meet these requirements may result in product non-compliance, meaning the packaging or packaged product cannot be placed on the Northern Ireland or EU market.

Article 10 exemptions

The Regulation includes specific exemptions to the packaging minimisation requirements.

Protected designs

Packaging protected by a Community design or trademark shape before 11 February 2025 may be exempt where compliance with Article 10 would affect its novelty or individual character.

Geographical indication

An exemption may apply where the packaged product or beverage benefits from a geographical indication protected under Union law or is covered by a recognised quality scheme.

What PPWR Article 10 means for manufacturers

While the detailed technical specifications are still to be published, Article 10 already identifies the areas that manufacturers will need to consider when demonstrating compliance.

Manufacturers should expect to document:

    1. Technical specifications and standards
      An explanation of the technical specifications, standards and conditions used to assess packaging against the performance criteria and methodology set out in Annex IV.
    2. Design requirements
      Identification of the design requirements that prevent any further reduction in packaging weight or volume.
    3. Supporting evidence
      Any test results, studies or other relevant sources, including modelling and simulations, used to assess the minimum necessary volume or weight of the packaging.

Manufacturers should also be aware of the closely related Article 24: Obligations related to excessive packaging, which addresses excessive empty space within packaging and may have implications for packaging design decisions.

PPWR packaging minimisation timeline

The PPWR generally applies from 12 August 2026. Packaging minimisation requirements, however, follow a later implementation timeline.

Date Milestone
12 August 2026 General application of PPWR. Article 10 packaging weight and volume minimisation requirements do not yet apply.
12 February 2027 Deadline for the European Commission to request that European standardisation organisations prepare or update harmonised standards setting out the methodology for assessing packaging minimisation compliance.
1 January 2030 Article 10 packaging weight and volume minimisation requirements apply. Packaging must be reduced to the minimum weight and volume necessary to ensure its functionality.

Why businesses should start preparing now

Although the Article 10 deadline may appear some way off, packaging redesign programmes, supplier engagement and packaging data collection can take significant time.

Businesses that understand their packaging portfolios now will be in a stronger position to:

  • Identify packaging that may require redesign
  • Understand future compliance risks
  • Collect supporting evidence
  • Reduce the likelihood of disruption as implementation dates approach

Early preparation can help businesses make informed design decisions and avoid potential non-compliance when the requirements become enforceable.

How Valpak can help

Preparing for PPWR packaging minimisation requirements requires an understanding of how Article 10 applies to your packaging portfolio and the evidence needed to support compliance.

Understand your obligations

Valpak’s PPWR Advisory Service can help businesses understand upcoming obligations, assess packaging impacts and identify areas where future changes may be required.

Build the data needed for compliance

For organisations that need detailed packaging information and supporting documentation, Valpak’s PPWR Data Service can help build and maintain the packaging datasets needed to support compliance activities.

Review and optimise packaging

Where packaging redesign or optimisation may be necessary, Valpak’s Packaging Technology Consultancy team can help businesses review packaging formats, assess opportunities to reduce weight and volume, improve resource efficiency and identify packaging changes that support both compliance and wider sustainability objectives.

See packaging optimisation in practice

For example, our work with Volac demonstrated how targeted packaging optimisation can deliver significant material savings while maintaining performance and functionality, helping businesses reduce environmental impact and packaging costs.

Prepare for PPWR packaging minimisation requirements

Understand how Article 10 could affect your packaging portfolio and start preparing for future compliance requirements.

Explore the PPWR Advisory Service

Speak to a PPWR specialist

Written by: Edgar Olmedo

International Account Manager

Topics:

Blog, Packaging Technology Consultancy, PPWR

FAQs

Article 10 introduces packaging minimisation requirements designed to ensure that packaging weight and volume are reduced to the minimum necessary while maintaining functionality.

Article 10 is scheduled to become enforceable from 1 January 2030.

Packaging minimisation means reducing packaging weight and volume to the minimum necessary to ensure functionality while avoiding unnecessary components or features designed to increase perceived product volume.

Examples referenced in Article 10 include double walls, false bottoms and unnecessary packaging layers that do not contribute to the functionality of the packaging.

Yes. Certain protected designs and products benefiting from geographical indication protection may be exempt under specific circumstances.

Manufacturers should review existing packaging portfolios, identify potential redesign requirements, gather supporting evidence and understand how packaging weight and volume are justified against functionality requirements.