The PPWR Minimisation Assessment: The Document Almost Nobody Has Written Yet

Eight Legal Reasons Your Box Is Allowed to Exist

Annex IV of Regulation (EU) 2025/40 contains a list of eight performance criteria. Under the EU Packaging and Packaging Waste Regulation, these are the only acceptable justifications for the weight and volume of your packaging. Product protection is one. Logistics is another. Criterion 4 covers "sales for gift purposes, or on the occasion of seasonal events", which means the EU wrote gift wrap into primary legislation. If your packaging is heavier or larger than these eight criteria can explain, it does not belong on the EU market.

Here is the part most companies have missed: you have to write this down. Article 10(4) requires compliance to be demonstrated in technical documentation. Criterion by criterion. With evidence. The EU has produced a regulation that requires you to write an essay about why your box is not bigger than it needs to be, and almost nobody has written theirs yet.

What Article 10 Requires, and When

Two obligations, two dates.

From 12 August 2026, the date the regulation applies, Article 10(2) prohibits placing packaging on the market that does not comply with the Annex IV performance criteria. The same paragraph bans packaging "with characteristics that aim only to increase the perceived volume of the product, including double walls, false bottoms and unnecessary layers".

By 1 January 2030, Article 10(1) requires the manufacturer or importer to ensure that packaging is "designed so that its weight and volume is reduced to the minimum necessary to ensure its functionality, taking account of the shape and material from which the packaging is made".

Read the duty holder carefully. Not the packaging converter. Not the design agency. The manufacturer or importer of the packaged product. If you fill jars in Lyon or import gadgets through Rotterdam, this is your document.

Article 10(2) carries two exceptions, both narrow. Packaging shapes protected as registered designs or trademarks before 11 February 2025 are grandfathered where minimisation would destroy the design's individual character or the trademark's distinctiveness. And products covered by protected geographical indications or EU quality schemes, wine and spirits mostly, keep their traditional formats. Your perfume bottle shaped like a torso may survive. Your false-bottom cream jar will not.

The Eight Performance Criteria

Annex IV Part A lists them. Names as in the regulation, scope in plain language:

#	Criterion	What it covers
1	Product protection	Preventing damage, loss, deterioration, waste. Mechanical and chemical protection, vibration, compression, humidity, oxidation, light, microbiological infection, pests.
2	Packaging manufacturing processes	Compatibility with manufacturing and filling lines: tooling feasibility, thickness tolerances, line speed, heat resistance, minimum headspace.
3	Logistics	Distribution, transport, handling, warehousing. Dimensional coordination, palletisation, integrity in transit.
4	Packaging functionality	The purpose of the product and the particularities of its sale, including gift purposes and seasonal events.
5	Information requirements	Mandatory product information, instructions, safety warnings, bar codes, best-before dates must physically fit on the packaging.
6	Hygiene and safety	Child resistance, tamper evidence, anti-counterfeit features, hazard warnings, safe opening, pressure-release closures.
7	Legal requirements	The packaging must allow the packaged product to comply with other applicable law.
8	Recycled content, recyclability and re-use	Weight or volume may increase beyond the minimum where needed for reuse rotations, recyclability, or recycled content.

Criterion 8 runs in the opposite direction from the other seven. It is the one place the regulation concedes that heavier packaging can be the correct answer: a reusable crate built for 50 rotations weighs more than a single-use tray, and Annex IV explicitly permits that trade.

What the Assessment Document Contains

Annex IV Part B sets the minimum content. Three elements.

(a) The outcome, with numbers. A description of the assessment result, including the calculation of the minimum necessary weight and volume. Variations between production batches must be taken into account and documented.

(b) A justification for every criterion. For each of the eight criteria in Part A, a description of the design requirement that prevents further reduction of weight or volume, plus the method used to identify it. Part B adds two sharp edges here. All reduction opportunities within a given material must be investigated, including "the reduction of any superfluous layer which does not perform a packaging function". And substitution of one packaging material with another "shall not be considered sufficient". Swapping plastic for cardboard is a material change, not an assessment. The regulation wants to know why the cardboard box is the size it is.

(c) Evidence. Test results, market research or studies used for (a) and (b). Article 10(4) adds modelling and simulations to the list of acceptable sources.

In practice the working format is a criterion-by-criterion table: one row per Annex IV criterion, the binding constraint in one column, the reason further reduction fails in the next, the evidence reference in the last. For criteria that do not bite ("logistics does not constrain this 30 g sachet"), you record that they were considered and found non-binding. An empty row is an invitation for a market surveillance authority to fill it in for you.

Who writes it

The legal duty sits with the manufacturer or importer of the packaged product. The data sits with your packaging supplier: wall thickness minima, drop test results, filling line tolerances, migration studies. The assessment is therefore usually a joint production. Larger converters have started offering Annex IV data packs alongside their quotes. If yours has not, ask. If yours cannot, you have learned something useful about your supplier.

The Perceived Volume Ban

Article 10(2) singles out packaging designed to make the product look bigger than it is: double walls, false bottoms, unnecessary layers. The test is whether the characteristic aims only to increase perceived volume. A double wall that provides thermal insulation has a function. A double wall that makes a 30 ml jar occupy a 100 ml silhouette has a marketing department. This applies from 12 August 2026, with no numerical threshold and no transition period. Cosmetics, confectionery and supplements are the categories market surveillance authorities will reach for first, because that is where the false bottoms live.

Minimisation and the Empty Space Rule Are Different Tests

Article 24 caps the empty space ratio of grouped, transport and e-commerce packaging at 50% from 2030. That is a numerical test for specific packaging categories, covered in our guide to the PPWR empty space rules. Article 10 is qualitative, applies to all packaging, and starts earlier. Passing one does not pass the other: an e-commerce box at 45% empty space can still fail Article 10 if a smaller or lighter design would do the same job.

A Worked Example: 50 ml Cream Jar

Product: 50 ml face cream, glass jar, folding carton. Three rows from the assessment table:

Criterion	Justification
Product protection	The formula degrades under UV light; violet glass at the supplier's minimum mouldable wall of 2.8 mm passed stability testing, clear glass at any thickness did not.
Information requirements	21 mandatory label elements in 3 languages do not fit on a 45 mm jar face, which is what the folding carton is for.
Hygiene and safety	The tamper seal requires a lid skirt of 6 mm; shorter skirts failed the torque test.

Three sentences, three constraints, each traceable to a test report or a labelling count. That is the register the document should be written in. What this jar cannot carry: a 12 mm recessed base lifting the cream to eye level. That is a false bottom, it aims only at perceived volume, and no criterion in Annex IV rescues it.

Honest Assessment of the Assessment

No notified body reviews this document. Nobody certifies it, stamps it, or approves it. It is self-assessment: you write it, you keep it in your technical documentation, and you produce it when a market surveillance authority asks. Harmonised standards with concrete weight and volume limits for common formats are coming, the Commission must request them by 12 February 2027, but until they land, the eight criteria and your own reasoning are the whole methodology.

Which means the realistic bar is a defensible written justification, not perfection. An authority reviewing your file wants to see that you identified the binding constraint for each criterion and can point to evidence. The companies with a problem are the ones holding no document at all: the assessment feeds the technical documentation behind your declaration of conformity, and a DoC with nothing behind it is a signed confession with extra steps.

Complydex walks you through PPWR compliance requirement by requirement, minimisation included. Start your compliance check.