Yes. Loose shredded paper and crinkle paper used as filling materials count as empty space under the EU Packaging and Packaging Waste Regulation (PPWR). Article 24(3) and (4) of Regulation (EU) 2025/40 expressly include paper cuttings among the filling materials whose space must be counted as empty.

A box can therefore look full and feel securely packed while still containing substantial empty space for this assessment. Paper cushioning can perform a useful protective job, but adding more of it cannot improve the empty-space ratio. The useful design question is how much room the product needs for protection, and whether a smaller pack could provide that protection reliably.

A retail gift box and its mailer face different rules

A gift box that forms the sales unit with its products is sales packaging. A separate mailer used to deliver that box following an online purchase is e-commerce packaging, a type of transport packaging. Shredded paper may sit inside the gift box, around it in the mailer, or both. Each layer needs the appropriate assessment.

PPWR has generally applied since 12 August 2026, but these specific obligations have their own deadlines. Article 24 requires the Commission to adopt the calculation methodology for the 50% ratio by 12 February 2028. The cap’s application date must retain the “whichever is later” condition; it is not an unconditional January 2030 deadline.

Article 24(5) exempts sales packaging used directly as e-commerce packaging from the 50% obligation—for example, a suitable retail box shipped without a separate mailer. It also exempts reusable packaging used within a system of re-use. Sales packaging still has its own minimisation duties, including the Article 24(4) requirement above and the requirements of Article 10.

From 1 January 2030, Article 10 also requires packaging weight and volume to be reduced to the minimum necessary for functionality. Our guide to PPWR packaging minimisation and empty-space rules explains how these wider design requirements fit together.

How the outer-pack calculation works

For grouped, transport and e-commerce packaging, Article 24(3) defines empty space as the difference between the total packaging volume and the volume of the sales packaging contained inside. The basic relationship is:

Empty-space ratio = (total outer-pack volume − contained sales-packaging volume) ÷ total outer-pack volume × 100%

Consider a skincare gift set sent in a stock mailer also used for larger orders. For a simplified design comparison, assume the mailer has a volume of 8 litres and the gift box, which constitutes the sales packaging, occupies 3.2 litres. The remaining 4.8 litres count as empty space even when shredded paper fills the visible gaps.

The improvement comes from reducing the mailer volume while keeping the same sales packaging. These assumed volumes illustrate the statutory relationship; formal measurement must follow the applicable implementing methodology. The smaller design also needs its protective performance assessed before adoption.

The gift box’s internal space remains a separate question. A snug mailer can have a low outer ratio even when the gift box itself is unnecessarily large. At CMIC, we can develop both layers together, examining how a smaller retail box changes the appropriate mailer size and the protective clearance around it.

Paper’s recycling credentials answer a different question

Recycled content describes the material’s origin. Recyclability concerns its suitability for collection, sorting and recycling after use. The empty-space requirement addresses packaging volume. A paper filler can have useful material credentials and still occupy space counted as empty under Article 24.

Switching from air cushions to paper may change material use, handling and disposal considerations. If the outer pack and contained sales packaging retain the same volumes, however, that substitution leaves the basic empty-space ratio unchanged. Assess the paper’s actual composition and recycling suitability alongside the pack’s dimensions and protection needs.

Make the pack smaller while preserving protection

A glass skincare jar may need room for cushioning to compress under impact, as well as restraint to prevent it from striking another item. Loose paper’s performance depends on its form, quantity and placement. A paper bed can settle during handling, so the neat arrangement seen when the lid first closes is only the beginning of the assessment.

PPWR recognises these functional needs. Annex IV includes protection against mechanical damage, vibration and compression, as well as logistics and gift-purpose functionality. Article 24(2) requires the calculation methodology to take account of protective needs involving, among other things, fragile contents and irregular shapes. Necessary cushioning nevertheless remains subject to the rule that filling materials count as empty space.

For the skincare set, a useful comparison could put a smaller box with a controlled amount of paper cushioning alongside a folded paperboard insert or shaped pulp tray. An insert may keep the items separated and hold them in a consistent position, reducing dependence on a deep bed of loose fill. Finger access, product visibility and a deliberate opening sequence can still give the set a considered gift presentation.

A fitted insert has no blanket exemption from the empty-space rules. Its regulatory treatment needs a basis in its function, the packaging layer and the applicable calculation methodology. Replacing loose paper with a tray inside an unchanged box does not, by itself, establish a lower ratio. The practical gain to investigate is whether the structure enables a smaller pack while maintaining protection.

We can develop these alternatives around the actual product, compare samples and coordinate testing appropriate to the product and distribution route. The comparison should examine movement, surface damage, crushing or breakage, together with packing consistency and ease of removal. A design that requires every packer to judge a handful of shredded paper by eye may need a clearer filling method to reproduce the approved sample.

Keep the chosen dimensions, component specifications and packing arrangement connected to the reasons that space is needed. Annex IV’s minimisation assessment calls for an explanation of what prevents further reduction without compromising functionality, supported by any tests or studies used. A sample comparison becomes more useful when it records why the smaller successful arrangement was selected.

Article 24 places its obligations on the economic operators filling the relevant packaging, so the agreed design needs to reach the actual packing operation. If your retail box is developed with us and a separate fulfilment partner selects the delivery mailer, coordinating those specifications helps prevent the final shipment from acquiring unnecessary space again.

Through our EU packaging solutions, we can help compare box sizes, protective structures and paper-fill arrangements for your product. Your current packed configuration, product dimensions and shipping conditions give us a useful starting point for developing a closer fit with the protection and presentation you need.