A custom paper insert can reduce empty space when it allows the surrounding box to become smaller. A folded tab can stop a bottle sliding, a divider can keep glass items apart, and a cradle can support their weight in a defined position. Those features can reduce the need for generous margins and loose cushioning while preserving a considered opening experience.

For brands supplying the EU, the useful connection with the Packaging and Packaging Waste Regulation (PPWR) is the opportunity to reconsider the complete pack. At CMIC, we can develop the insert, presentation box and delivery carton together, checking where a smaller layout saves space and where a clearance still performs a protective function.

The packaging layer matters. A box forming the unit sold to the customer is sales packaging. Packaging grouping several sales units for sale or restocking is grouped packaging. A carton protecting sales units during handling and transport is transport packaging; when used to deliver an online order to the end user, it is e-commerce packaging. An insert holding and protecting the product is a packaging component. A gift box containing two products can still form one sales unit: the number of products alone does not determine its category.

PPWR generally began to apply on 12 August 2026, but its minimisation provisions have separate dates. Articles 10 and 24 of Regulation (EU) 2025/40 distinguish the design of the packaging from the way it is filled.

The sales box therefore needs its own minimisation assessment even when the delivery carton meets the 50% limit. Article 24(5) exempts sales packaging used as e-commerce packaging, and reusable packaging used within a system of re-use, from that 50% obligation. Article 10 still applies to those formats.

Article 24 expressly counts space occupied by filling materials—including paper cuttings, air cushions and foam fillers—as empty space. Replacing loose fill with paper consequently does not establish a reduction in regulated empty space. A fitted insert may perform useful structural work, but the Article provides no blanket deduction for custom paper inserts. Its treatment in a formal calculation must follow the applicable methodology. The clear design benefit to pursue is a smaller enclosure made possible by better positioning, separation and support.

Positioning and cushioning solve different problems. A collar or folded tab keeps an item in place; a divider prevents neighbouring products from touching. Cushioning manages the shock transmitted during handling, often by allowing material to deform. A tightly held glass bottle can still receive a damaging impact if its support transfers the force directly from the box wall. A controlled gap and a support that can compress may therefore be necessary. The insert should also direct loads towards suitable bearing surfaces, keeping pressure away from a pump, delicate cap or decorative detail.

A compact cosmetic case and a dense glass fragrance bottle place very different demands on a cut edge or retaining tab. We can compare paperboard and corrugated options around the same product layout, looking at the assembled size, packaging weight and packing effort. An elaborate insert can reduce box volume while adding weight or too many folding steps. Annex IV also makes clear that substituting one packaging material for another is insufficient by itself: opportunities to reduce unnecessary material still need to be investigated.

Manufacturing variation determines how closely the insert can fit. Product dimensions, label seams, board thickness and cutting or folding variation all affect the finished cavity. A sample that grips one bottle perfectly may jam a slightly larger bottle or leave a smaller one free to move. Working from the agreed product dimensions and tolerances allows the fit to accommodate that variation, while finger openings or accessible edges make removal comfortable.

Consider an illustrative skincare gift set in which a glass serum bottle lies beside an upright cream jar. The original box has a raised presentation platform, broad margins around the products and an unused cavity beneath the platform. The first opportunity is to reconsider those dimensions together with the product supports.

A candidate redesign lowers the platform and brings the products closer together, with a divider maintaining separation. Folded supports contact the bottle’s body and base while keeping pressure off the dispenser. A shallow pocket locates the jar, and finger access allows each item to be lifted without dragging its label against a cut edge. The layout leaves the clearances needed for support and cushioning, but removes margins that have no useful role.

For illustration, compare an original sales box measuring 200 × 150 × 80 mm externally with a candidate measuring 170 × 125 × 65 mm externally. These are proposed design dimensions; testing would determine whether the smaller construction provides adequate protection. The change involves both the insert geometry and the surrounding box.

The lower tray can still give each item a deliberate position and a clear reveal. Annex IV recognises packaging functionality for gift purposes, while Article 10 targets features aimed only at increasing perceived product volume, including false bottoms. Proportion, paper texture and accurate placement can carry the sense of occasion as the pack becomes more compact.

The next decision belongs at the delivery carton. A smaller sales box leaves more space inside an unchanged shipper. This matters because Article 24(3) defines empty space in grouped, transport and e-commerce packaging using the volume of the sales packaging contained within it. An insert inside the sales box is already within that box’s dimensions; a support surrounding the sales box must not simply be counted as another sales unit.

The statutory relationship, expressed as a percentage, is (total outer-pack volume − volume of the sales packaging contained within it) ÷ total outer-pack volume × 100. For a delivery carton containing several sales boxes, the contained volume covers all of those boxes.

The comparison below uses rectangular volumes calculated from the delivery carton’s internal dimensions and the sales box’s external dimensions. These are working design assumptions. Formal measurement must follow the applicable implementing methodology: Article 24 requires the Commission to establish that methodology by 12 February 2028, taking account of protection needs and other specified characteristics.

The smaller sales box makes the unchanged shipper substantially less full. Reducing the delivery carton carries the improvement through to dispatch, but its remaining clearance still has a job to do. In this example, the new carton provides 20 mm of total height clearance—10 mm above and below a centred sales box. The chosen protective supports must work within that space. The percentage alone cannot establish adequate protection.

For our packaging projects serving the EU market, we can turn these choices into a small number of complete-pack prototypes, with proposed dimensions, materials and an assembly sequence. An unprinted sample can reveal layout and access; protection and finish checks need representative products, materials and construction. This gives the customer’s team something concrete to compare before committing to production tooling or a new carton specification.

• Fit and opening: check product variation, secure retention, comfortable removal and any rubbing on labels or decorated surfaces.
• Protection: agree drop, vibration or compression checks suited to the product and distribution route, with environmental conditioning where relevant. Inspect whether products shift, touch or transfer loads to vulnerable parts.
• Packing consistency: confirm that the insert assembles reliably, stays located during packing and allows the box to close correctly. Include the delivery supports and shipment-label area in the review.
• Total packaging: compare dimensions and the weight of the sales box, insert, delivery carton and additional protection. A reduction in one component should be assessed alongside changes elsewhere.

The insert itself helps explain the test result. A fold that compresses as intended may have absorbed an impact; a torn tab that lets two glass items collide has lost its separating function. Those observations guide the next adjustment—perhaps a broader bearing surface, a different fold or slightly more clearance—without automatically returning to the original oversized box.

These comparisons can also support the minimisation assessment. Article 10(4) and Annex IV require technical documentation explaining the assessment basis, the design requirements that prevent further reduction, and supporting evidence. Retaining dimensions, component weights, material specifications, design versions and relevant test results makes the reasoning traceable. The useful outcome is an explanation of why the remaining material and space are needed for the particular product and packaging system.

Our guide to PPWR packaging minimisation and empty-space rules explains the wider requirements across a packaging range.

If your current pack feels larger than the product needs, talk to us with a product sample or dimensions and an example of how it is shipped. We can develop a more compact box and insert together, then coordinate appropriate checks to establish which protective space needs to remain.