From 1 January 2030, packaging weight and volume must be limited to the minimum needed to maintain functionality. A company should be able to show why a lighter or smaller alternative would fail to meet the relevant performance criteria.
Packaging minimisation does not mean reducing at any cost
Article 10 of the PPWR requires the manufacturer or importer to ensure, by 1 January 2030, that packaging is designed with its weight and volume reduced to the minimum needed to maintain functionality.
1. A design requirement from 2030
Minimisation should be demonstrated in the technical documentation. The assessment is not limited to a single weight in grams: it must consider the packaging's function and conditions of use.
2. Product protection
Reduction must not cause an unacceptable increase in damage, product losses, loss of barrier performance or safety risks. Product protection is one of the fundamental performance criteria.
3. Manufacturing and packing processes
The design must remain compatible with packaging production and filling. Relevant factors include thickness tolerances, strength, line speed, process temperature and effective closure.
4. Logistics
Packaging must withstand transport, storage, palletisation and handling. The analysis should consider not only unit weight but also the effect on logistics space utilisation.
5. Functionality and information
Packaging must allow the intended use of the product and provide space for required information, instructions and markings. Marketing arguments or a “premium” appearance alone should not justify excessive weight or volume.
6. Hygiene, safety and legal requirements
The analysis may consider user safety, child resistance, security features, hygiene and requirements under other legislation. In sectors such as food, pharmaceuticals and dangerous goods, these can significantly affect the design.
7. Recycled content, recyclability and reuse can affect weight
Providing recyclability, recycled content or reusability may justify a weight above the absolute minimum derived from other criteria. For example, reusable packaging may need thicker walls to withstand multiple rotations.
8. Double walls, false bottoms and unnecessary layers
Article 10 addresses features intended only to increase the perceived volume of a product. If an additional layer has a genuine technical function, that function must be demonstrable.
9. How should minimisation be documented?
- the weight and volume of the current packaging;
- the reduction alternatives considered;
- constraints arising from the Annex IV criteria;
- transport or use test results;
- reasons for rejecting lighter alternatives;
- the approved configuration and safety margin.
10. Minimisation as an ongoing process
A change in material, product, production line, transport or recycling requirements may allow further reduction. Review the portfolio periodically and compare actual weight with the justified minimum.
The main principle
Minimum does not mean as little as possible at any cost. It means the lowest weight and volume that can be technically and legally justified while retaining the required functionality.
FAQ
Can marketing justify larger packaging?
Consumer acceptance or a marketing effect alone should not be a standalone criterion for justifying additional weight or volume.
Can reusable packaging be heavier?
Yes, if the additional weight is needed to provide durability and the required number of rotations.
Should the minimisation assessment be included in technical documentation?
Yes. The PPWR requires compliance with Article 10 to be demonstrated in the technical documentation.