Void Fill Under the PPWR: How to Choose It and Use Less

Under the PPWR, paper cuttings, air cushions, bubble wrap, foam, wood wool and polystyrene chips all count as empty space, not product volume. The 50% cap applies from 1 January 2030 or three years after the calculation rules enter into force, whichever is later, under Article 24 of Regulation (EU) 2025/40.

Key takeaways

• Void fill cannot turn an oversized parcel into a compliant one because the filled volume still counts as empty space.
• The 50% cap starts on 1 January 2030 or three years after the calculation rules enter into force, whichever is later.
• Right-sizing the outer pack comes before choosing paper, air pillows or another protective material.
• Product protection still matters. The aim is the minimum packaging needed for functionality, not zero cushioning at any cost.

What counts as void fill under the PPWR?

Void fill is the material placed around a product to stop it moving, absorb shocks or occupy unused space inside a parcel. Article 24 expressly names paper cuttings, air cushions, bubble wrap, sponge and foam fillers, wood wool, polystyrene and Styrofoam chips.

The material itself is not prohibited simply because it is void fill. The legal point is how its volume is treated. For the empty-space calculation, the PPWR counts filling materials as empty space, even when the parcel looks full after packing.

Filling a gap does not remove it from the PPWR calculation: the volume occupied by void fill remains empty space.

That distinction matters for online sellers using a small range of standard boxes. A product in an oversized carton may be well protected, but adding more paper or air pillows does not improve its empty-space ratio.

How is the 50% empty-space ratio calculated?

The PPWR empty-space ratio is the empty volume divided by the total volume of the outer packaging. For e-commerce packaging, empty space is the difference between the parcel's total volume and the volume occupied by the products inside it.

For a simple rectangular parcel, the operational calculation is:

empty-space ratio = (outer pack volume - product volume) / outer pack volume × 100

The PPWR empty-space calculation requirement applies to operators who fill grouped, transport or e-commerce packaging. The Commission must adopt implementing acts establishing the detailed methodology by 12 February 2028.

The binding 50% limit then applies from 1 January 2030 or three years after those implementing acts enter into force, whichever is later. This timing is more precise than treating 1 January 2030 as an unconditional date.

For a fuller worked example, see the guide to the PPWR 50% empty-space ratio.

Which void-fill material should you choose?

The best void-fill choice is the smallest amount that protects the product in the smallest practical outer pack. Material choice comes after right-sizing because paper, plastic and foam fillers all count as empty space under Article 24.

This table is an operational comparison, not a claim that one material is always environmentally superior. Recyclability depends on the complete packaging design and the waste stream available where the packaging becomes waste. The separate guide to proving packaging recyclability explains the evidence trail for that question.

How can an online seller reduce void fill?

An online seller can reduce void fill by matching pack sizes to real order profiles instead of choosing one box for every order. Start with the orders that create the most unused volume, then change the packaging specification in a controlled sequence.

1. List every dispatch format. Record the internal dimensions and material weight of each box, mailer, insert and filler.
2. Group common order combinations. Use real order data to find the product combinations shipped most often.
3. Measure the current ratio. Calculate product volume and outer-pack volume for each common profile, keeping filler inside the empty-space figure.
4. Right-size the outer pack. Add smaller boxes or adjustable formats where the same oversized carton appears repeatedly.
5. Test product protection. Confirm that the smaller format still handles impact, compression, moisture and returns as required.
6. Save the evidence. Keep dimensions, component specifications, test results and the reason for any necessary protection space with the packaging record.

The same component record can support both PPWR documentation and weight-based EPR reporting. Gramta combines your real sales with the packaging specification you provide once, including materials, weights and design evidence. It does not infer packaging composition from sales alone.

What exceptions and edge cases matter?

Article 24 excludes an operator using sales packaging directly as e-commerce packaging from the 50% rule. Reusable packaging used within a system for reuse is also excluded from that specific cap.

Those exclusions do not remove every PPWR obligation. Packaging still has to meet the applicable minimisation, substance, recyclability and documentation requirements. The PPWR rules for transport and B2B packaging cover how the wider duties fit around grouped and transport formats.

Fragile, irregular or unusually small products may need protective space that a simple box-volume calculation cannot explain well. The Commission's forthcoming methodology is important for these cases. Until it is adopted, document the product-protection function, the available alternatives and why the selected dimensions are necessary rather than inventing a private exemption.

What should you prepare before 2030?

Businesses should prepare a repeatable packaging record rather than a one-off spreadsheet. Each format should connect the product or order profile to its outer dimensions, component weights, filler specification, protection evidence and current empty-space calculation.

That record makes packaging changes auditable. It also gives procurement a clear brief: reduce the ratio without trading product damage for a superficially smaller parcel.

Get started with Gramta to connect real order volumes to the packaging specifications you provide, keep PPWR evidence together and produce filing-ready EPR reports for each country.

Sources:

• Regulation (EU) 2025/40, Article 24 empty-space rules