PPWR packaging minimisation changes what brands need to ask of a packaging design: how much material and space does the product actually need, and what explains the amount retained? Answering that well means considering the retail box, insert and shipping pack together. A smaller gift box can be a useful improvement, yet leave more empty space in the shipping carton if that carton stays unchanged.

The EU’s Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, covers packaging placed on the EU market regardless of material or origin. That includes paper packaging manufactured in China for products sold in the EU. For product brands, Articles 10 and 24 and Annex IV connect three concerns: minimum necessary packaging weight and volume, empty space inside sales packaging, and empty space around sales packs during distribution.

Three duties, with different deadlines

The PPWR generally applies from 12 August 2026. The specific provisions below set their own deadlines, so a packaging programme needs to track each one.

The 50% limit therefore has a conditional start date. The regulation requires the Commission to adopt its calculation methodology by 12 February 2028. Separately, Article 10 requires the Commission to request new or updated harmonised minimisation standards by 12 February 2027; that is a deadline for requesting the standards, rather than for their completion. These implementation steps matter when turning an early design calculation into a formal assessment.

Identify the packaging layer before applying a percentage

• Sales packaging forms the sales unit offered to the end user. A fragrance bottle with its retail gift box is an example.
• Grouped packaging brings sales units together, for example in a removable tray used to restock a shelf or create a distribution unit.
• Transport packaging facilitates handling and transport while preventing damage, such as a shipping case containing several retail packs.
• E-commerce packaging is transport packaging used to deliver products sold online or through other distance sales to the end user.

The category follows the packaging’s role. A gift set sold as one unit can have sales packaging even though it contains several products. Inserts, supports and other packaging components also belong in the assessment of the design. This distinction matters because the 50% ceiling in Article 24(1) applies to grouped, transport and e-commerce packaging; sales packaging has its own functional-minimum requirement.

What needs to change inside the retail pack

Under Article 24(4), operators filling sales packaging must minimise its empty space by 12 February 2028 while preserving functionality, including protection. There is no universal 50% allowance for a retail gift box. A gap may be needed to separate glass components, accommodate product variation or allow safe removal. Its purpose and size need to make sense for the product. Filling the same gap with shredded paper or foam does not remove it from the empty-space assessment.

Article 24(4) also addresses products that settle during transport, food needing protective headspace and other products with those characteristics. For these, compliance is assessed at the pack-fill level when filled; air between or within packed food and protective gases are excluded from empty space. A settling product therefore needs assessment under those conditions, rather than a judgment based only on how full the pack looks after delivery.

Article 10(2) separately addresses packaging that fails the Annex IV performance criteria and features aimed only at increasing perceived product volume, including double walls, false bottoms and unnecessary layers. The purpose of the construction matters. A reinforced wall that protects a heavy glass bottle presents a different design question from a hidden platform whose sole purpose is to make a small product appear larger. The protective construction still needs assessment for opportunities to reduce its weight and volume.

Gift presentation has a place in that assessment. Annex IV expressly recognises packaging functionality associated with gift sales and seasonal occasions. A watch may need a secure cushion and accessible opening; a gift set may need separation between its contents. Marketing preference and consumer acceptance, however, do not on their own justify additional packaging weight or volume. For a premium paper box, attention can move towards precise proportions, a well-fitted insert, paper texture and a satisfying opening movement—details that give the product presence without depending on a large empty interior.

Specific exceptions require their own basis. Article 10(2) includes exceptions for certain designs or packaging-shape trademarks protected before 11 February 2025, where applying minimisation requirements would alter the design’s novelty or individual character, or the trademark’s ability to distinguish the product. It also covers products benefiting from protected EU geographical indications or the specified quality schemes. Eligibility depends on the actual right or product status and the conditions in that provision; ordinary branding does not establish it.

How the 50% empty-space rule works

For grouped, transport and e-commerce packaging, Article 24 defines empty space as the difference between the packaging’s total volume and the volume of the sales packaging contained inside it. Space occupied by filling materials—including paper cuttings, air cushions, bubble wrap and foam fillers—counts as empty space. Protective filler can perform a useful job while still being included in the calculation.

Empty-space ratio (%) = (total outer-pack volume − combined volume of the sales packs inside) ÷ total outer-pack volume × 100.

Here, “outer pack” means the grouped, transport or e-commerce packaging being assessed.

The detailed methodology must take account of special characteristics such as irregular shapes, multiple products, fragile or liquid contents, small products vulnerable to larger ones, and the minimum space needed for shipment labels. Those considerations inform the methodology; they are not automatic exemptions from the ceiling. The following assumed volumes illustrate the basic relationship, while formal measurement must follow the applicable method.

The second configuration brings the illustrated ratio below 50%. The third shows why retail and shipping changes need coordination: reducing the retail packs creates more space around them in the unchanged shipping box. The next design task is to reconsider the outer pack and its protective arrangement. Adding filler leaves the calculated ratio unchanged.

A result below 50% addresses that particular ceiling. The broader minimisation requirement still asks whether the packaging’s weight and volume are necessary. A parcel can meet the percentage limit while containing an oversized retail box or a superfluous packaging layer.

When the sales pack is also the shipping pack

Article 24(5) exempts operators using sales packaging as e-commerce packaging, or using reusable packaging within a system of re-use, from the paragraph 1 ceiling. It expressly retains Article 10 compliance for those sales packs. Direct shipment in the sales pack is therefore worth exploring where protection, closure, label placement and arrival appearance can work together. Reusable packaging also needs a minimisation assessment that accounts for its reuse functions; a gift box that a customer might keep does not by itself establish a system of re-use.

Develop the retail box, insert and shipping pack together

For paper-packaging projects, CMIC can help turn a broad request such as “make this smaller without losing the gift experience” into a small number of structural and material options. The useful starting point is the product and its journey: what must stay secure, what can change, and where one packaging layer affects another. That gives sampling a clear question to resolve.

Find what sets the dimensions

Product dimensions, weight, vulnerable surfaces and normal variation establish the first constraints. Accessories and instructions need room too. Then consider distribution: a pack handled individually through parcel delivery may experience different conditions from retail units travelling together in a shipping case. Annex IV’s protection criterion extends from packing or filling through to end use, so the assessment needs to follow the product beyond the packaging factory.

Consider a fragrance gift box with a glass bottle, a tall insert and generous clearance under the lid. Lowering the bottle may allow a shallower box, but the revised insert must still restrain it without putting damaging pressure on the cap or neck. A tighter footprint also changes finger access and how easily the bottle lifts out. These relationships determine which millimetres can be removed and which serve a useful purpose.

Review structure and material as connected choices

A wrap, sleeve, internal platform or separate support may duplicate a function performed elsewhere. Removing that part can reduce both material and overall dimensions. In other cases, a folded support may need a little more material locally to hold the product securely while allowing a smaller box. Compare the weight, volume and performance of the complete alternatives so that a saving in one component does not conceal a larger addition elsewhere.

Annex IV requires reduction opportunities within a given material to be investigated; substituting one material for another is not sufficient by itself. Moving from foam to a paper insert therefore still calls for assessment of the paper structure’s dimensions and material use. The same annex recognises that recyclability, recycled content or reuse can justify additional weight or volume where needed. The explanation should identify the requirement and the design feature that fulfils it.

Use samples to resolve the important uncertainties

Physical samples let the team examine the product, insert, box and outer pack together. A layout that looks efficient on a drawing can press on a pump, allow a bottle to rotate or make removal awkward. Check filling and closing as well as opening: the selected structure needs to work consistently in production, with enough usable space for necessary product information and shipping labels.

Validation should address the risks of the actual route. Depending on the product and distribution conditions, that may involve suitable drop, vibration, compression or environmental testing, alongside fit and handling checks. Record the configuration tested, including the product, insert, board specification and packing arrangement. CMIC can coordinate sampling and appropriate testing so that the comparison between alternatives produces evidence for the selected design, rather than only a visual preference.

Carry the change into everyday fulfilment

The outer-pack result depends on what is actually shipped. A carton that suits a three-piece skincare order may leave excessive space around a single replacement serum. Review common order combinations and give the packing operation suitable choices. A manageable range of carton sizes, with clear selection guidance, can accommodate those differences without requiring a bespoke box for every order. When the retail pack changes, review those choices again: its dimensions are part of the shipping calculation.

Keep the evidence attached to the approved design

Article 10(4) and Annex IV make the reasoning part of the technical documentation. The assessment must explain the minimum necessary weight and volume, the design requirements preventing further reduction and the evidence used. Annex IV includes protection, manufacturing and filling, logistics, functionality, information, hygiene and safety, legal requirements, and recycled content, recyclability and reuse. A useful project file brings together:

• The identified design: drawings, component and material specifications, dimensions, weights and the approved packing arrangement, linked to a clear version.
• The minimisation assessment: calculations of minimum necessary weight and volume, with relevant variation between production batches taken into account.
• The functional limits: an assessment against each Annex IV performance criterion, explaining which design requirements prevent further reduction and how they were identified.
• The supporting evidence: relevant test results, studies, modelling or other sources used to assess the design, linked to the configuration they cover.

“Needed for protection” becomes useful when it identifies what must be protected and how the retained construction does that. For example, a bottle restraint, a documented clearance around a fragile component and a test of the assembled pack can explain a dimensional limit. A material certificate may support a material claim; the minimisation assessment needs evidence about the actual packaging and the product it serves.

The PPWR’s manufacturer can be the brand commissioning the packaging. A brand that has packaging designed or manufactured under its own name or trademark can hold that role even when a separate factory makes the boxes. Under Article 15, the manufacturer is responsible for conformity assessment, technical documentation and an EU declaration of conformity once compliance with the applicable requirements has been demonstrated. It can have assessment work carried out on its behalf while retaining that responsibility.

Consider an EU brand commissioning boxes under its own name from a packaging factory in China and engaging an EU contractor to fill them. Responsibilities divide by role, and one business may hold more than one:

Article 15(12) provides a specific exception: when the business commissioning packaging under its own name or trademark qualifies as a microenterprise and its packaging supplier is located in the EU, that supplier is treated as the manufacturer for Article 15. The EU-supplier condition matters: direct supply from a Chinese factory does not meet it.

Under Article 15, manufacturers retain the technical documentation and EU declaration of conformity for five years from placing single-use packaging on the market, or ten years for reusable packaging. They must also maintain conformity in series production and reassess when changes could affect it. A revised insert, board specification or box depth should therefore remain connected to the approved version and the evidence supporting it. Recording production variation matters because the assessment concerns the packaging supplied, as well as the sample originally approved.

Make the next brief about the whole pack

A compact pack can still make a product feel carefully presented: the bottle sits securely, the contents are easy to lift out, and the lid closes neatly. Reaching that result takes more than reducing the old box by a fixed percentage. It comes from deciding which functions matter, developing the structure around them and carrying the changes through to the shipping pack.

At CMIC, we can help develop those alternatives, coordinate samples and suitable testing, and organise the selected specifications and supporting evidence. Our EU packaging solutions explain that support. To explore a redesign, share your product details, current packaging and delivery route with us; those give the discussion a concrete starting point.