The Packaging and Packaging Waste Regulation began to apply across the EU on 12 August 2026, and most retailers have filed it under materials. Swap the plastic for paper, tick the sustainability box and move on. That reading misses where the pressure actually sits. The regulation is far less interested in what a parcel is made from than in how much of it is wasted space. For any business shipping physical goods into Europe, that turns packaging from a procurement decision into a design one, and the retailers who work that out early will spend a good deal less time reworking their range once enforcement tightens.
The rule that changes the maths
Two provisions do the heavy lifting. Article 10 makes packaging minimisation a documented obligation, and it applies now. Article 24 caps empty space in e-commerce and transport packaging, with a 50% ceiling that takes full effect in 2030 and a calculation method the European Commission is due to finalise by 2028. The duty falls on whoever fills or uses the packaging, which puts online sellers and their fulfilment partners squarely in scope rather than leaving it with material suppliers upstream.
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The part that trips sellers up is the definition of empty space, because filler counts towards it. Air pillows, bubble wrap, paper crumple and foam are treated as void rather than protection, so packing a half-empty box with cushioning doesn’t fix the problem, it simply restates it. False bottoms and double walls that exist to inflate perceived size are restricted outright. The trajectory is set well before the hard cap arrives. Measure the gap between product and box, then close it.
The cost of shipping air
There’s a commercial case for closing that gap whatever the regulation says. Oversized parcels cost more to ship, because carriers increasingly price on parcel volume as well as weight. They cost more to pack, since void has to be bought in and filled by hand, and they cost more when they go wrong, because a product sliding around inside too much space is more likely to arrive damaged and be sent back. Returns are already a serious drain on margin, and damaged deliveries push up reverse-logistics costs, with packaging that fails in transit sending more parcels straight back. Compliance cost now stacks on top of all of it, since a parcel that fails the minimisation test is a parcel that has to be redesigned anyway. Every one of those numbers points in the same direction, towards packaging that fits the thing inside it.
The fix is dimensional, not material
The answer is a better fit rather than a different material, and that starts with the box range. Single-wall corrugated suits lighter items, while double-wall earns its place where weight or fragility calls for it, so protection comes from how the box is built rather than from whatever is packed around the product. A paperback shipped in a box sized for a pair of boots needs cushioning on every side to survive the journey, while the same paperback in a right-depth mailer needs almost none.
Many retailers ship a small set of standard sizes and make up the difference with fill, when the real saving comes from bespoke delivery boxes designed in the right size and board grade to match each order. Treetop Design & Print, for example, specifies corrugated delivery boxes to the dimensions of the products a retailer actually ships and offers them in recycled board with water-based inks, which takes out the void rather than swapping one kind of fill for another. Get the structure right and the empty space problem largely designs itself out.
Why swapping fill for fill isn’t enough
This is where a materials-only response comes unstuck. Replacing plastic air pillows with paper ones changes the waste stream, yet it leaves the void exactly where it was and the parcel no smaller. It also misreads where packaging is heading, because material substitution alone is a less reliable strategy once a pack is judged as a whole system rather than by the material it is made from. A greener-looking filler inside an oversized box is the sort of half-measure that no longer convinces. Shrinking the box, by contrast, is a visible and measurable change that holds up when customers ask questions.
What UK sellers should do now
For UK retailers, Brexit offers no way around this. The rules apply wherever the parcel is received, so any business selling packaged goods into the EU has to comply, and non-compliant packaging risks being turned away at the border. The sensible first move is an audit. Map the current box range against the products that actually move, find where standard sizes are forcing in fill, and rebuild the range around real dimensions and the right board grade. Treat it as an operational project with logistics, buying and design working together, rather than a line-item swap left to procurement.
The hard cap doesn’t bite until 2030, but the minimisation duty is live today, and the retailers auditing their boxes this year are the ones who won’t be scrambling when it does.
