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:
-
- 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.
- Design requirements
Identification of the design requirements that prevent any further reduction in packaging weight or volume.
- 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
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