21 Aug, 2026
Coffee is light, often fragile, and frequently shipped in small orders. That combination can create a packaging problem under the EU’s Packaging and Packaging Waste Regulation, especially when one 250 g bag, a sample set, or a sleeve of capsules travels inside a box built for something much larger.
For coffee businesses, empty space is no longer just a freight cost or sustainability issue. It is becoming a compliance topic. The PPWR affects businesses placing packaged goods on the EU market, including importers, distributors, fulfilment partners, marketplaces, e-commerce sellers, and wholesale teams. If your coffee reaches EU buyers in grouped, transport, or e-commerce packaging, the way that parcel is filled, protected, and documented deserves attention.
This guide focuses on the coffee shipment use case: what PPWR packaging minimisation means, what counts as empty space, which dates matter, how to estimate the empty-space ratio, and how to reduce excess packaging without damaging coffee quality.
PPWR stands for the EU Packaging and Packaging Waste Regulation. Unlike a directive that each country must transpose into national law, a regulation applies directly across the EU. For packaging teams, that means the direction of travel is clearer: less unnecessary packaging, better recyclability, more documentation, and tighter controls over formats that create waste.
What Packaging Minimisation Means Under PPWR
Packaging minimisation is not simply “use less cardboard.” For coffee, that would be too blunt.
A coffee pack still has to protect the product. It may need to preserve aroma, keep moisture out, avoid punctures, support a degassing valve, carry legal and product information, survive palletisation, and arrive in saleable condition. The PPWR approach is closer to this question:
What is the minimum amount of packaging needed for the product to perform its real functions safely and legally?
Article 10 deals with packaging minimisation by weight and volume. It pushes businesses away from non-functional features that only make a pack look bigger, heavier, or more premium. This matters for retail coffee gift boxes, oversized presentation cartons, unnecessary double-wrapping, and decorative structures that do not protect the coffee or support handling, labelling, safety, or legal requirements.
Coffee teams should treat this as a design and evidence exercise. If a feature is needed, explain why. If it is there only to create shelf presence or perceived value, it may become harder to justify.
Article 10 vs Article 24: The Difference Coffee Teams Need to Know
Article 10 and Article 24 are related, but they are not the same thing.
Article 10 is about minimising packaging weight and volume more broadly. It applies to packaging design and pushes companies to remove avoidable excess.
Article 24 focuses on empty space in grouped packaging, transport packaging, and e-commerce packaging. This is the part many people describe as the “empty box” issue. It is especially relevant to coffee parcels, subscription boxes, sample shipments, and wholesale cartons with mixed product formats.
For coffee businesses, the distinction matters because primary packaging and shipping packaging solve different problems. A valve bag or pouch protects freshness and carries consumer information. A shipping carton protects that sales unit during handling. A grouped carton may hold several retail packs for a distributor or store. Each layer needs its own reason to exist.
A practical PPWR workflow should connect packaging design, warehouse rules, supplier specifications, and documentation. Treating it as a single 50% box-fill calculation is too narrow.
The PPWR timeline gives coffee businesses time to prepare, but not much room to ignore the issue. Packaging changes often involve suppliers, artwork, shelf-life testing, 3PL processes, carton stock, and customer expectations. Those do not change overnight.
2025 and 2026: Start Removing Non-Functional Excess
The PPWR entered into force on 11 February 2025. Its main provisions generally apply from 12 August 2026.
For coffee teams, that means packaging reviews should already be in motion. Start by checking whether any current formats look excessive when compared with the product they contain. This includes decorative retail boxes, gift packaging, oversized e-commerce cartons, large void-filled sample packs, and subscription formats with more presentation space than protection value.
The 2026 stage is also a good time to start documenting why each layer exists. Keep records of packaging specifications, food-contact declarations, recyclability information, damage data, supplier correspondence, and test results. The goal is not paperwork for its own sake. It is to make sure that future buyer questions can be answered with evidence rather than guesswork.
2028: Watch the Calculation Methodology
By 12 February 2028, the European Commission is expected to set out implementing acts for the Article 24 empty-space calculation methodology.
This date matters because many teams are already using simple void-space calculations for planning, but the final legal method may include specific definitions or measurement rules. Coffee businesses should use today’s calculations as a readiness tool, then verify the final wording against Regulation (EU) 2025/40 and later implementing acts before making compliance claims.
2030: Plan for the 50% Empty-Space Cap
From 1 January 2030, or later if the implementing-act timing shifts the application date, grouped, transport, and e-commerce packaging will need to meet a maximum empty-space ratio of 50%.
The year 2030 also matters for recyclability and other PPWR workstreams, so do not isolate empty-space planning from the rest of your packaging roadmap. A smaller parcel that uses a difficult-to-recycle material may solve one problem and create another. Coffee packaging decisions need to balance volume, weight, protection, food-contact suitability, recyclability, and operational reliability.
In simple terms, empty space is the difference between the internal volume of the packaging and the volume of the products or sales packages inside it.
That sounds straightforward until you look at real coffee orders. Coffee bags are flexible. Stand-up pouches change shape. Pillow bags settle. Tins and glass jars are rigid. Pods and capsules may need crush protection. Sample sachets can slide around unless restrained. Gift boxes may contain both product and presentation structures.
Void Fill Is Not a Workaround
Paper fill, air pillows, bubble wrap, foam, wood wool, and similar dunnage generally count as empty space. They may protect the product, but they do not become product volume just because they occupy the gap.
This is a common misunderstanding. Filling a large carton with more paper may reduce movement, but it does not fix an oversized packaging format. If the void fill is necessary to prevent damage, document the reason and test whether a smaller carton, divider, wrap, or molded insert could do the same job with less volume.
Coffee Packaging Examples: Bags, Pods, Tins, and Cartons
Different coffee formats create different empty-space risks.
A single 250 g valve bag in a large box is one of the clearest risks. The product is light and flexible, so packers may default to a box that is easy to handle, then add paper fill to stop movement.
Stand-up pouches can also be tricky because their real packed shape depends on fill level, seal shape, and whether the base is expanded. A pouch measured flat may not reflect its packed volume.
Tins and glass jars are easier to measure because they are rigid, but they may need more protection against dents or breakage. That protective space should be purposeful, not accidental.
Pods and capsules deserve separate attention. A small capsule pack inside an oversized carton can create a high empty-space ratio, but capsules may also need compression protection. Compostability, recyclability, and material separation questions may sit alongside the empty-space review.
Retail gift boxes and subscription boxes often carry the biggest presentation risk. Inserts, tissue, dividers, cards, sleeves, and outer cartons can create a premium feel, but premium presentation does not automatically justify excess volume.
When Protective Space May Be Justified
PPWR packaging minimisation does not mean coffee should be shipped in the smallest possible package at any cost. Necessary space may be justified for protection, handling, legal markings, food-safety needs, or mixed-item fulfilment.
The key word is necessary.
A glass jar may need a protective sleeve. A valve bag may need enough room to avoid puncture at the seal or valve. A mixed subscription box may need dividers so bags do not crush sample sachets or damage printed retail packs. These are practical reasons. They should be backed by packaging tests, damage data, and written packing rules.
Until the final EU methodology is confirmed, coffee teams can use a simple readiness calculation:
Empty-space ratio = (internal packaging volume - product or sales-package volume) / internal packaging volume x 100
Use the internal dimensions of the shipping box or mailer, not the external courier dimensions. For a carton, multiply internal length by internal width by internal height. Then compare that with the volume of the product or sales packages inside.
This method is useful for finding obvious problem formats, even though final legal calculations should be verified when the implementing acts are published.
Worked Example: One Coffee Bag in a Shipping Carton
Imagine a single 250 g coffee bag shipped in a carton with internal dimensions of 30 cm x 20 cm x 12 cm.
The internal carton volume is:
30 x 20 x 12 = 7,200 cm³
If the packed coffee bag occupies about 1,500 cm³, the empty-space ratio is:
(7,200 - 1,500) / 7,200 x 100 = 79.2%
That is far above a 50% planning benchmark. Even if some protective space is needed, this order type should be reviewed.
Now place the same bag in a tighter mailer or smaller carton with an internal volume of 2,800 cm³.
(2,800 - 1,500) / 2,800 x 100 = 46.4%
This is a much better planning result. The business still needs to test puncture resistance, valve protection, label placement, and customer experience, but the packaging is closer to the product.
Worked Example: Subscription Box or Mixed Coffee Order
A three-bag subscription box may look better at first. Suppose the internal box volume is 6,000 cm³ and the three coffee bags together occupy about 4,200 cm³.
(6,000 - 4,200) / 6,000 x 100 = 30%
That seems reasonable. But add a large insert tray, tissue layers, and a rigid presentation sleeve, and the real packaging-minimisation question changes. The empty-space ratio may still be acceptable, while Article 10 concerns about unnecessary packaging volume and non-functional presentation features remain relevant.
That is why coffee teams should not treat Article 24 as the only test. A pack can be fairly full and still overdesigned.
Reducing empty space is only useful if the coffee still arrives in good condition.
Coffee is sensitive to oxygen, moisture, aroma loss, punctures, crushed corners, leaking seals, and poor presentation. Roasted coffee bags may include degassing valves that should not be crushed or blocked. Printed retail packs can become unsaleable if rubbed, bent, or dented during transport. Green coffee samples may be packed for evaluation rather than retail display, but they still need clean, secure handling.
Protecting Aroma, Valves, and Seals
Primary coffee packaging is the pack that directly contains the coffee, such as a valve bag, pouch, sachet, capsule, tin, or jar. Secondary shipping packaging is the mailer, carton, wrap, divider, or sleeve used to move that product.
Do not weaken primary packaging just to improve a shipping-box ratio. If a valve bag needs a certain barrier structure or seal width to protect freshness, that belongs in the product specification. Focus first on right-sizing the outer packaging and reducing avoidable void fill.
Useful options include right-sized corrugated mailers, adjustable-height cartons, paper wraps, molded pulp, dividers, protective sleeves, and carton assortments matched to common order profiles. The best option depends on the coffee format and fulfilment model. A snug mailer may work well for one bag, while a divider may be better for mixed jars and pouches.
Pods and Capsules Need a Separate Review
Pods and capsules are small, regular, and often shipped in retail sleeves or cartons. That can make them good candidates for right-sized packaging. But they can crush under compression, especially if shipped with heavier items.
They also raise material questions beyond empty space. Some capsule systems involve plastics, aluminium, compostable materials, or mixed structures. A PPWR review should look at the whole pack, not only the air inside the box.
Test Before Changing Fulfilment Rules
The goal is minimum necessary packaging, not the absolute smallest possible package.
Before changing live fulfilment rules, run practical tests. Use drop tests, compression tests, leak checks, puncture checks, valve inspections, shelf-life reviews where relevant, and customer complaint monitoring. Compare damage rates before and after the change. If a smaller box saves space but doubles replacements, the result may be worse commercially and environmentally.
The most useful PPWR work often starts with ordinary shipment data.
Start With Shipment Data
Audit the last 30 to 90 days of orders. Capture SKU, order type, sales unit dimensions, parcel dimensions, carton or mailer type, dunnage type, damage rate, destination, and fulfilment location.
Look for high-void configurations first:
- Single-bag roasted coffee orders
- Green coffee sample packs
- Small capsule or pod orders
- Mixed subscription boxes
- Gift boxes with presentation inserts
- Wholesale cartons with small retail units inside large shippers
- Marketplace orders packed by default rules rather than coffee-specific rules
These are the shipments most likely to produce quick improvements.
Fix Carton Selection and Pack-Station Rules
Many empty-space problems come from weak carton logic. A warehouse may technically stock a suitable small carton, but packers choose a larger one because it is closer, easier to fold, or safer when they are busy.
Improve SKU master data with accurate dimensions for each sales unit and common packed configuration. Then update cartonisation rules so fast-moving coffee formats map to the right mailer, carton, divider, or sleeve.
If you work with a 3PL, make the instructions specific. Do not rely on broad guidance such as “use the smallest suitable box.” Define the approved packaging for common order types, including exceptions for fragile jars, mixed orders, export labels, and distributor cartons.
Document Exceptions Before They Become Disputes
Some shipments will need extra space. That is fine when there is a clear reason.
Record exceptions for protection, legal marking, mixed-item handling, food-contact separation, or transport conditions. Keep test evidence and complaint data with the packaging specification. If an EU buyer, distributor, or marketplace asks why a format uses a certain pack, your team should be able to answer without rebuilding the history from memory.
The first mistake is assuming void fill solves the problem. It may protect the product, but it still represents space that is not product.
The second is reviewing e-commerce parcels while ignoring grouped and transport packaging. Wholesale and distributor supply can involve cartons inside master cartons, pallet layers, dividers, and wraps. Those formats need attention too.
Another mistake is treating sustainability and compliance as separate projects. A smaller parcel, recyclable material, food-contact suitability, and product protection all need to work together.
Coffee brands should also avoid making claims too early. Until the Article 24 calculation methodology is final, use empty-space calculations for readiness and improvement planning. Be careful with public compliance language unless legal and technical teams have verified it.
If your team needs a Vietnam-based coffee supplier for wholesale, bulk coffee, OEM/private-label, or MR.VIET branded products, MR.VIET can support practical buyer conversations around packaging, traceability, EUDR, and PPWR documentation. The next step is simple: contact the team with your target market, product format, and expected order type so the sourcing discussion starts with the right packaging questions.
Does PPWR Apply to Coffee Shipments?
Yes, coffee shipments are part of the wider packaging system when packaged goods are placed on the EU market. Importers, distributors, e-commerce sellers, fulfilment partners, and wholesale teams should review the packaging they use for retail units, grouped packs, transport cartons, and e-commerce parcels.
Is a Coffee Bag’s Degassing Space Counted as Empty Space?
The empty-space discussion mainly concerns the relationship between packaging and the product or sales packages inside it, especially grouped, transport, and e-commerce packaging. A degassing valve or pack structure may be necessary for coffee quality, but it should be justified as part of the primary packaging design.
Do Paper Fill and Air Pillows Count as Product Volume?
No. Paper fill, air pillows, bubble wrap, foam, wood wool, and similar protective materials should not be treated as product volume. If they are necessary, document why. Then check whether a smaller carton or better insert could reduce the need for them.
Should Coffee Businesses Wait Until 2030?
No. The 50% empty-space cap is a 2030 planning issue, but packaging changes take time. Coffee companies should start with shipment audits, carton-size reviews, supplier conversations, and 3PL packing rules now, then verify final legal details as the EU calculation methodology develops.
