PPWR Void Space: The 50% Limit, the 40% E-commerce Limit and How to Measure It

Last reviewed 23 October 2026 · Written by HuanCheer New Protection Material, Jiangsu, China

PPWR requires packaging to be no larger than necessary, with a void-space limit of 50% — tightening to 40% for e-commerce shipments from 2030. This is the requirement that most directly changes what a packing bench looks like.

What "void space" means in practice

Void space is the share of a parcel's internal volume that is not product. Air is void. So, functionally, is cushioning material that is present because the box is too big rather than because the product needs protecting.

The Regulation's logic is that oversizing is the cheapest waste to eliminate: a smaller box is less material, more units per pallet, more per container, and fewer lorries. It is one of the few PPWR obligations where the compliance outcome and the cost outcome point the same way — which is why it is also the easiest one to sell internally.

Where most operations lose the percentage

In almost every packing operation the void comes from one of three places:

1. A box range that is too coarse. Five carton sizes serving a four-hundred-SKU catalogue guarantees that most orders ship in the second-largest box. Adding three intermediate sizes usually recovers more void than any cushioning change.
2. Fill used as a sizing patch. Void fill is protective material; used to fill a gap it is a symptom. If an order needs two handfuls of fill, the box is wrong.
3. A protective format that pre-consumes volume. A pre-formed padded mailer has a fixed internal volume that does not follow the product. Where the product is flat and the mailer is not, the difference is void.

The 2030 e-commerce threshold is the one to plan against

The 50% limit is the general rule and has applied since 12 August 2026. The 40% limit for e-commerce distribution arrives on 1 January 2030. Any operation shipping direct to consumers should treat 40% as the design target now, because the packaging specified in 2026 will still be in use in 2030 and the gap between 50% and 40% is usually a size-range decision, not a material one.

How to measure it on a real order

A defensible measurement is simpler than it sounds and does not require modelling:

1. Pack one representative order as you normally would.
2. Measure the internal dimensions of the closed outer and take the volume.
3. Subtract the volume of the product. If there are several items, take them as packed, not as individual shots.
4. The remainder — including the cushioning — is void.
5. Express it as a percentage of internal volume.

Twenty orders across the size range gives a distribution, and the top of that distribution is the number that matters. An average of 42% with a tail at 68% does not pass a 50% limit; the tail does the failing.

The tension with protection, stated plainly

Minimisation is not a licence to under-protect. The Regulation couples the void limit with the requirement that packaging performs its protective function — a parcel that arrives damaged has failed a different obligation. The design question is not "less material" but "less volume for the same protection".

That is where the choice of cushioning format does real work. A structural cushion — honeycomb core — delivers its protection through the geometry of the material rather than through bulk, so the protective layer can be thin. A loose fill delivers protection through volume by definition. Under a percentage-void rule, the format that protects with less volume is the one that leaves headroom.

The honest caveat: for a genuinely irregular or fragile item, no format gets you to a tight percentage. Minimisation has to be read against the actual product, and a damaged-delivery rate is a worse commercial outcome than a void percentage.

What to keep

Minimisation is part of the technical documentation behind the declaration of conformity. What that means operationally is that the void calculation has to exist on paper for representative SKUs, dated, with the method stated. It does not need to be a formal model; a spreadsheet of twenty measured orders with dimensions and a percentage is a defensible record. A statement that "we minimise packaging" is not.