PPWR 2030 – packaging minimization, Annex IV and certificate of analysis | Word/PDF/Excel

How can a packaging manufacturer or importer demonstrate that a package’s weight and volume are as small as its function allows? This slim PPWR package provides a documented workflow for packaging specification, Annex IV assessment, real-world reduction trials, technical evidence, and redesign decisions. It fills the gap between a general PPWR policy and the product-specific justification required by Article 10.

New minimisation requirements from 1 January 2030: Regulation (EU) 2025/40, Articles 10.1–10.2, requires manufacturers or importers to design packaging with the minimum weight and volume necessary to fulfil its actual function. This is a 2026 preparation package for upcoming requirements, not a claim that the 2030 requirements already apply. Older relevant minimum requirements during the transition must be checked separately.

Is the Package Right for Your Company?

For packaging manufacturers, importers, packaging developers, technical buyers, quality managers, and brand owners with their own packaging responsibilities who need to gather real evidence before making design changes. The package is particularly relevant when product protection, hygiene, logistics, information space, or recycling requirements prevent a simple weight reduction. For a full EU declaration or a broad overview of PPWR, the broader PPWR basic package is better suited; for evidence from material suppliers, see PPWR Article 16 – Supplier Material Evidence.

Exactly What Is Included in the ZIP Package?

The Eight Criteria in Annex IV

The assessment systematically covers product protection; manufacturing and filling processes; logistics; packaging function; necessary product information; hygiene and safety; legal requirements; and recycled content, recyclability, and reuse. For each criterion, the user must document the functional requirement, why further reduction is not possible without compromising function, the investigation carried out, actual test evidence, and any remaining uncertainty. Marketing or general consumer acceptance is not sufficient as a standalone reason for larger packaging.

Excel – Check Weight, Volume, and Evidence Without False Approvals

The workbook’s nine tabs link packaging ID → Annex IV criterion → design alternative → testing → evidence → non-conformance → decision. It calculates percentage changes in weight and volume from the user’s own numerical input and warns of incorrect zero values, missing tests, failed tests, closed non-conformances without retesting, and GO without a named sign-off. The results refer only to administrative and mathematical checks, not a legal minimum level. Calculated rectangular outer volume is not the same as actual empty space or the legally minimum permitted packaging dimension. No fictitious test customers or fabricated test reports are included.

How to Use the Templates

1. Determine whether the company is responsible as a manufacturer or importer under the relevant article and which packaging object the assessment applies to.
2. Determine the baseline version, material, actual dimensions, weight, function, and batch variation.
3. Test each of Annex IV’s eight criteria with technical reasons and applicable legal sources.
4. Conduct real before/after tests; link the method, test result, failure, and evidence ID to the design candidate.
5. Explain the minimum necessary weight/volume and why further reduction cannot be made without compromising function.
6. Gather relevant evidence for the technical documentation under Article 10.4 and Annex VII.
7. Have a responsible person assess the risks, document a manual decision, and update the design.

Article 10 Is Not the Same as Article 24

Regulation (EU) 2025/40 has two separate obligations. Article 10 applies to packaging design, necessary weight and volume, and the Annex IV assessment, and these requirements enter into force on 1 January 2030. Article 24 has a separate limit on maximum empty space of 50 percent for certain grouped, transport, and e-commerce packaging, applying from the later of 1 January 2030 and three years after the entry into force of the relevant implementing act. Article 24 has its own methodology. This package does not perform an Article 24 calculation, and 50 percent is not a general minimisation limit for all retail packaging.

Article 10.4 requires technical documentation with method, functional requirements, and test/study evidence in connection with Annex VII. The EU Commission’s guidance C/2026/3084 from June 2026 explains the relationship between the new requirements and earlier standards. Updated harmonised standards may be introduced later; verify the correct version before making a final decision. Exemptions for certain protected designs, trademarks, and geographical indications require separate legal assessment.

Frequently Asked Questions

Does every package have to reduce its weight by a certain percentage?

No. Article 10 does not prescribe a general percentage. The minimum necessary weight and volume must be assessed against actual functional requirements and documented.

Is a reported weight reduction the same as being approved under PPWR?

No. Even a large reduction may be unsuitable if product protection or other applicable requirements are compromised. The template therefore requires testing and manual sign-off.

Does the 50 percent empty space limit apply to a standard consumer package?

Not generally. The specific requirement is in Article 24 and applies to certain types of packaging and operators, with its own method and date.

Can I use Excel as complete technical documentation?

No. The Excel and Word files support the Article 10 assessment; Annex VII and other applicable sustainability requirements require separate documentation.

Can I claim an older design protection and avoid minimisation?

Only after an individual assessment of all conditions in Article 10.2. The template does not claim a general exemption.

Is there an English contract or technical template in the package?

No. The five main templates are in Swedish. The English file is a user guide to the Swedish documentation.

Are the images real test results?

No. The percentages in the main image are illustrative examples. The actual customer package contains no fictional test values or test certificates.

Version and Limitation of Liability

Version 1.0, 10 November 2026. AI-assisted source review against the EU Regulation and Commission guidance; no independent lawyer or laboratory has reviewed or certified the product. It is not an official EU form, EU declaration, or legally final approval. Check current law, applicable standards, technical requirements, and conduct your own tests before practical use. Delivery via digital ZIP after manual file linking and publication on Shopify.