The EU Packaging and Packaging Waste Regulation (PPWR) sets a maximum empty-space ratio of 50% for grouped, transport and e-commerce packaging. Under Article 24 of Regulation (EU) 2025/40, the deadline is the later of 1 January 2030 or three years after the relevant implementing acts enter into force.

For a typical online order, the calculation compares the shipping packaging’s volume with the volume of the sales packs inside it. Paper cushioning, air cushions, bubble wrap and foam count as empty space. A parcel can therefore look full while still having a high empty-space ratio. For brands, the useful design question is how closely the shipper fits the actual order while preserving the protection those products need.

The dates distinguish parcel filling from packaging design

The 50% obligation falls on the economic operator who fills the packaging. That makes the packing arrangement important: orders may be packed by the brand itself or by a fulfilment provider. The parties need shared box-selection rules, packing instructions and a way to handle substitutions. A carton’s dimensions alone cannot establish the empty-space ratio of every order later packed inside it.

Understand the two packaging layers in the calculation

PPWR defines sales packaging as packaging conceived to form a sales unit with the product for the end user. A boxed skincare set is a familiar example. E-commerce packaging is transport packaging used to deliver products to the end user following an online or other distance sale. When that skincare set travels inside a separate corrugated shipping carton, the sales box and the shipper perform different functions in the parcel.

Article 24 defines empty space as the difference between the total volume of the grouped, transport or e-commerce packaging and the volume of the sales packaging contained inside. Expressed for a shipping box, the relationship is:

Empty-space ratio (%) = (total shipping-packaging volume − enclosed sales-packaging volume) ÷ total shipping-packaging volume × 100.

Filling materials remain part of the empty-space amount even when they provide necessary protection. Replacing air cushions with crumpled paper changes the material choice, but neither material increases the enclosed sales-packaging volume used in this comparison. The rule therefore directs attention towards the dimensions and arrangement of the parcel.

A worked example: two sales packs in a shipping carton

Consider an illustrative order containing two skincare products, each in a sales carton measuring 150 × 100 × 60 mm externally. Each sales pack occupies 0.9 litres, giving a combined sales-pack volume of 1.8 litres.

For an early rectangular-box comparison, we can use the shipping carton’s internal dimensions and the sales packs’ external dimensions. These are explicit design assumptions: the estimates below help compare options, while a formal compliance calculation must follow the applicable Article 24 implementing methodology.

For the smaller candidate, the arithmetic is (3.366 − 1.800) ÷ 3.366 × 100 ≈ 46.5%. It falls below 50% in this preliminary model. That makes it worth developing into a packed sample; the figure alone does not establish that the products fit safely or that the finished parcel complies.

Placed flat beside each other, the two sales packs form a 200 × 150 × 60 mm arrangement. Centred in the smaller carton, that leaves 10 mm around each side and 30 mm of total height clearance. At CMIC, we can use those clearances to develop the protective layout and compare samples. The remaining space must accommodate the chosen protection, dimensional variation and practical loading of the products.

Choose the carton range around actual orders

Now put only one of those 0.9-litre sales packs in the smaller carton. Its estimated empty-space ratio rises to 73.3%. The carton that looked promising for a two-item order is a poor volume match for a single item. This is why the review needs to connect box sizes with common order combinations: individual products, pairs, sets and mixed orders.

Mixed orders introduce a second problem: shape. A tall serum carton beside a shallow cosmetics palette can leave considerable unused height above the palette, even when their combined volume seems modest. A different orientation may help where the products and their handling requirements allow it. An adjustable-depth carton can remove spare height above the whole order, but it cannot resolve every gap between differently shaped items.

A useful development exercise compares a manageable range of carton sizes against representative orders, including awkward combinations and small items ordered alone. The aim is to make a suitable box easy to select and keep in stock. Order averages can show where redesign will have the greatest effect, but they do not by themselves demonstrate compliance with a maximum empty-space limit.

Reduce space through controlled protection

Article 24 requires the calculation methodology to account for particular protection and legal needs. It specifically identifies irregular shapes, multiple sales packs or products, liquids, easily damaged contents, small products vulnerable to larger ones, and the minimum space needed for shipping labels. These are factors the methodology must address; they do not create a general exemption for fragile goods.

A closer fit can reduce sliding and rubbing during transport. Yet pushing a glass product against a carton wall may remove clearance needed to absorb an impact. The useful improvement is a layout that holds the sales packs in position and protects vulnerable faces and corners. A shaped paperboard or corrugated support may achieve that more compactly than loose cushioning, depending on the product and route.

We can develop and compare packed samples around those requirements, then arrange appropriate testing. Drop, vibration or compression testing can help reveal whether the smaller structure preserves protection under the relevant handling conditions. For a gift product, the assessment may also need to consider damage to the presentation box: an intact bottle inside a visibly scuffed gift box may still fail the intended customer experience.

When the 50% ceiling does not apply

Article 24(5) provides two exemptions from the 50% obligation:

• Sales packaging used as e-commerce packaging. The sales pack itself serves as the shipping pack.
• Reusable packaging used within a system of re-use. The condition concerns its use within that system; a durable box that a customer might keep does not establish this on its own.

Using the sales pack directly for shipping can remove an entire packaging layer, but it changes the design brief. That pack must accommodate the shipping label, stay securely closed and withstand the intended distribution conditions. Carrier handling may also expose its printed surfaces to scuffing and dirt. A presentation box whose appeal depends on an unmarked, textured surface may still benefit from a separate protective shipper.

If a separate shipping carton is added around the sales pack, that outer carton needs assessment under the rule. A brand logo on the shipper does not, by itself, make it the sales packaging used directly for shipping; the packaging’s actual function matters.

The exempt routes remain subject to Article 10’s packaging-minimisation requirements. Sales packaging also has its separate Article 24 duty to minimise empty space by 12 February 2028 while preserving functionality. Enlarging the inner presentation box merely to occupy more of a shipper therefore moves the excess into another packaging layer. The design needs to make sense at both levels.

Our broader guide to PPWR packaging minimisation and empty-space rules explains the wider assessment of packaging weight, volume and functional requirements.

Connect the approved sample to the fulfilment operation

From our base in Shenzhen, China, CMIC can develop custom paper packaging around a customer’s products and fulfilment arrangements. For a brand having orders packed at an EU fulfilment centre, the centre’s working conditions belong in the sample brief: how products arrive, which order combinations recur, how cartons are assembled and what packing space is available. Those details help us compare useful structures without adding unnecessary box sizes.

The comparison should make the decisions visible through drawings, dimensions, packed-sample photographs and relevant test results. It should also explain why remaining clearances are needed. These records can support the wider Article 10 minimisation assessment: Annex IV requires the technical documentation to explain the minimum necessary weight and volume, the functional constraints preventing further reduction, and any test results or studies used.

The approved drawing, sample and packing instructions need to describe the same arrangement. If the fulfilment centre substitutes a larger carton during a stock shortage, or the brand adds a taller product to a set, the fit and ratio need another look. Clear alternatives agreed in advance make it easier to preserve the design’s benefits during a busy dispatch day.

A well-developed parcel brings the box size, product protection and packing method into agreement. If you are reviewing packaging for EU e-commerce orders, share your sales-pack dimensions and typical order combinations with us. We can use them to compare carton options, develop protective layouts and prepare samples that reflect how your orders will actually be shipped.