A double wall, raised support or lining can be compatible with PPWR’s packaging minimisation rules when its function and the amount of material and space it requires are justified. The regulation expressly targets features aimed only at increasing perceived product volume. For a brand developing premium packaging, the important distinction is between structure that performs a necessary job and structure that adds bulk without a sufficient functional reason.

What Article 10 requires

Article 10(1) of Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, requires manufacturers or importers to ensure that packaging weight and volume are reduced to the minimum necessary for functionality, taking account of its shape and material. That paragraph sets a deadline of 1 January 2030.

Subject to the narrow exceptions explained below, Article 10(2) prohibits placing on the market packaging that fails the performance criteria in Annex IV, as well as packaging with “characteristics that aim only to increase the perceived volume of the product, including double walls, false bottoms and unnecessary layers”. These are related concerns: a feature may create an exaggerated impression of the contents, while a redundant layer may add unjustified material even without creating that impression.

Both Article 10(1) and Article 10(2) apply from 1 January 2030. The European Commission’s guidance on packaging minimisation confirms this timing. PPWR generally began applying on 12 August 2026, while Article 70(1)(b) preserves the existing packaging-minimisation requirements through 31 December 2029.

A design already in use must meet the requirements applicable during the transition. Packaging first placed on the EU market from 1 January 2030 must satisfy Article 10’s requirements, subject to its specified exceptions, even if the design is older. A design’s age alone gives it no exemption. The separate obligation to minimise empty space in sales packaging applies by 12 February 2028 and may require earlier changes. These rules cover packaging placed on the EU market regardless of where it was manufactured.

Annex IV explains what functionality can involve. Its criteria include product protection, manufacturing and filling processes, logistics, information, hygiene and safety, and requirements concerning recyclability, recycled content and reuse. A wall that resists compression or a lining that prevents damaging contact may therefore have a sound purpose. The assessment must also explain what prevents that wall or lining from being reduced further.

Gift presentation has a place in this assessment: Annex IV expressly recognises sales for gift purposes and seasonal occasions within packaging functionality. A gift set may need to hold several pieces together and make them accessible when opened. However, the regulation’s explanatory text makes clear that marketing and consumer acceptance cannot, on their own, justify additional weight or volume. Describing a pack as “luxury” leaves the reason for its extra structure unexplained.

How the distinction changes three familiar designs

A raised base beneath a skincare jar

Consider a shallow skincare jar presented near the opening of a deep rigid box, with a tall platform concealing the void beneath it. If the platform’s only purpose is to make the contents appear larger, it matches the concern expressly identified in Article 10(2). If its purpose is simply to lift the jar into view, the design still needs an explanation of why that much height and material is necessary.

A raised support can also help locate a jar, provide protective clearance or make removal easier. Those functions give the comparison something concrete to examine. A shallower outer box with a lower retaining insert and finger recesses may offer the same access. Compare how securely the jar sits, whether it rubs against the insert, and whether a person can lift it comfortably. If the lower version preserves the required performance, the taller platform becomes difficult to justify through that function.

A reinforcing wall around a perfume bottle

A glass perfume bottle creates a different problem. An inner frame or folded wall may help resist compression, retain the bottle or provide separation from impacts at the outer wall. That is a plausible protective role. The name “double wall” alone tells us little about whether the structure is necessary; its geometry, material, relationship to the bottle and performance in the complete pack matter.

At CMIC, we can develop comparisons between a full inner wall, reinforcement confined to the vulnerable area, and a revised insert that supports the bottle differently. Each should be assessed with the intended product and distribution conditions. Reducing board everywhere may weaken a critical corner, while changing the fold or support position may remove material from an area doing little useful work. Comparative samples help locate that difference before the structure is approved.

A decorative lining inside a gift box

The regulation names unnecessary layers, so a lining deserves examination according to its contribution. A soft contact layer that prevents a polished cap from scuffing has a protective role. A thick padded panel added for a plush appearance needs a different justification, particularly when an existing insert already provides the required protection and support.

A useful sample comparison might include the original padded lining, a lighter protective sheet and a printed interior without separate padding. Look at contact marks after handling, movement during distribution, and removal of the product. Colour and pattern can carry much of the intended character without building another layer into the box. Where the lighter option performs the necessary functions, it offers a clearer basis for reducing the construction.

Material composition also matters. A bonded fabric or foam lining introduces a different recycling question from a paper lining; coatings and firmly attached components can affect separation, sorting and recycling. A layer’s protective function therefore belongs alongside an assessment of its effect on the finished pack’s recyclability. Simply replacing one material with another does not complete the minimisation assessment: Annex IV requires reduction opportunities within the chosen material to be investigated.

The exceptions are narrowly defined

Article 10(2) provides two exception routes. Neither is a general exemption for premium packaging:

• Qualifying protected designs or packaging shapes. The relevant design rights, or trademarks protecting the packaging’s shape, must have been protected before 11 February 2025 under the legal regimes specified in the article. Applying the requirements must also alter the design’s novelty or individual character, or affect the trademark so that it can no longer distinguish the marked product from other undertakings’ goods. A longstanding brand name or a logo printed on an ordinary box does not by itself establish these conditions.
• Qualifying geographical indications or quality schemes. The provision covers packaged products or beverages benefiting from geographical indications protected under Union law, or covered by the quality schemes referred to in Regulation (EU) 2024/1143. General claims of heritage, craftsmanship or quality do not establish qualification.

Reliance on an exception needs a basis in the specified rights or schemes and their conditions. These exceptions do not remove other applicable PPWR requirements, such as those concerning recyclability.

How this connects to empty space

The often-quoted 50% empty-space cap concerns grouped, transport and e-commerce packaging, subject to Article 24’s scope and exemptions. It is not a universal allowance for an individual retail box. A perfume presentation box sold with its bottle is typically sales packaging; the parcel carton used to deliver it after an online sale is e-commerce packaging. The assessment therefore operates at different levels.

For sales packaging, Article 24(4) requires the economic operators filling it to reduce empty space to the minimum necessary for functionality, including product protection, by 12 February 2028. That paragraph does not establish a general percentage allowance. Space occupied by filling materials such as paper cuttings or foam fillers counts as empty space for this purpose. Filling a void therefore does not, by itself, resolve it.

A compact shipping carton cannot settle whether the raised platform inside the retail box is necessary. A useful design sequence is to review the product’s fit and support within the sales packaging, then size the delivery packaging around that assessed design. Our guide to PPWR packaging minimisation and empty-space rules explains the wider relationship between these obligations.

Make the reason for each retained feature demonstrable

Article 10(4) requires compliance with its minimisation requirements to be demonstrated in technical documentation. This includes the assessment conditions, the design requirements preventing further reduction for each performance criterion, and supporting tests, studies or other relevant evidence. Annex IV also requires calculations of minimum necessary weight and volume and consideration of production-batch variations. A statement such as “the insert protects the product” starts the explanation; the assessment must establish why the retained design needs its particular construction.

• Identify the assessed pack. Keep the drawing, material specification, dimensions, weights and version connected to the product it contains.
• Connect the feature to a requirement. Explain the role of the wall, platform or lining—for example, maintaining protective clearance or preventing damaging contact—and what limits further reduction.
• Record the alternatives and evidence. Show which reductions were investigated, the conditions used to assess them, and the relevant calculations, tests, studies or modelling supporting the decision.
• Explain the final dimensions and weight. Include the necessary tolerances and expected production variations, so the justification applies to manufactured packs rather than only to one carefully fitted sample.

A transport test showing that the current box protects its contents supports the protection argument. On its own, it does not establish why a smaller or lighter construction would be insufficient. Comparing alternatives can help identify the point at which further reduction compromises a required function. For a skincare jar, that may involve fit and access as well as transport performance; for a heavy perfume bottle, compression and retention may deserve particular attention.

Our contribution at CMIC can include developing structural alternatives, preparing comparative samples, coordinating appropriate testing and supplying specifications and version records for the project’s technical documentation. This makes the choice easier to assess: the customer can see what changes, which functions are preserved and what evidence supports the retained structure. Article 16 also requires suppliers to provide the information and documentation manufacturers need to demonstrate conformity.

Build the experience around the product

Premium character can come from considered proportions, a controlled opening movement, an appealing paper surface and the way a product is revealed. The design task is to give those choices a coherent physical form while accounting for the structure they require. Where reinforcement or a lining is necessary, establish its useful extent. Where a platform only conceals excess depth, a closer-fitting box may give the product a more confident presentation.

For an EU-bound packaging project, share your product and packaging details with us, including the intended delivery route and the parts of the experience you want to preserve. We can use those requirements to develop meaningful alternatives and compare their protection, handling, presentation, weight and volume.