Does void fill count as empty space? The EU 50% rule, and what to change in 2027

Open the last parcel you packed for a customer in Europe. Take the product out in its own box. Now look at what is left: air pillows, crumpled paper, a few rounds of bubble wrap.

Under the EU's packaging regulation, all of that is empty space.

So yes, void fill counts as empty space. Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR), says so in Article 24(3). The same article caps empty space at 50% in e-commerce, transport and grouped packaging. That cap starts on 1 January 2030 at the earliest. Nothing changes on your box sizes in 2027. But 2027 is the year to measure, because the fix takes time.

Checked against official sources on 28 October 2026.

One note before we start. Air cushions and paper void fill are both products we make at our plant in Jaipur, and this rule treats both of them as air.

I will not pretend that is good news for a void fill maker. Since we sell the paper and the plastic, we have no favourite between them here. I still think the push is right. This guide is about how to live with it.

What does the 50% rule actually say?

Article 24(1) says that whoever fills grouped packaging, transport packaging or e-commerce packaging must keep the empty space ratio at 50% or less.

The regulation defines e-commerce packaging as transport packaging used to deliver products sold online or through other distance sales. Your shipping carton is in. So is your courier mailer.

Article 24(3) gives the arithmetic:

1. Empty space is the total volume of the outer pack minus the volume of the sales packaging inside it.
2. The empty space ratio is that empty space divided by the total volume of the outer pack.

Read point 1 slowly.

The law compares the outer box with the product's own packaging. Everything else in between is empty space, whatever job it is doing.

Does void fill count as empty space?

Yes, and the regulation does not leave room for argument. The same paragraph names the filling materials it means: paper cuttings, air cushions, bubble wrap, sponge and foam fillers, wood wool, and polystyrene chips. Space filled with any of them counts as empty space.

This surprises people, because the void fill is there to stop the product moving. It is doing real work. The rule only looks at the size of the box, and what you put in the gap does not change the sum. A box that is 70% air pillows is a box that is 70% empty, as far as Article 24 is concerned.

It is like booking a full tempo for two cartons and then stuffing the rest with pillows so the cartons do not slide. The cartons arrive safely. You still paid for the whole tempo.

Protection is not forgotten, though. It moves into the method act. Article 24(2) says the Commission's method must take into account products that need space to be protected, for example:

1. Products with an irregular shape.
2. Packs with more than one product or sales unit inside.
3. Liquids.
4. Products that are easily damaged.
5. Small products that larger products in the same box could damage.
6. The space needed on the outside of the box for the shipping label.

We know the list. We do not know the allowance each item will get, because the method act is only due by 12 February 2028.

My guess is that fragile products will get some room. I would not bet a box range on that guess.

When does it start, and what happens in 2027?

The 50% limit applies from 1 January 2030, or 3 years after the method act enters into force, whichever is later. If the act comes late, the start date moves with it.

So 2027 brings no new limit on your boxes.

It brings the standards work and the penalty rules. The 2027 standards request matters to box buyers because the standards are meant to spell out maximum weight, volume and empty space for the most common packaging types.

Who has to meet it?

The duty sits with the "economic operator" who fills the outer pack. That covers EU sellers and EU fulfilment centres, and any importer or distributor that repacks orders.

If your stock sits in an EU fulfilment centre and they pack your orders, the centre fills the box. Expect them to push the rule back to you through their packing specs and box choices.

If you pack in India and ship straight to a customer in Europe, you fill the box. The text does not say how an EU country will enforce this on a seller outside the EU.

I would plan as if it applies to you. Your marketplace or 3PL will ask, and we would rather you had the answer ready.

Are there exemptions?

Two, in Article 24(5):

1. Sales packaging used as e-commerce packaging. If the product's own box goes to the customer as it is, with a label on it, the 50% rule does not apply to it.
2. Reusable packaging used within a re-use system.

Both still have to meet the general minimisation duty in Article 10, which applies by 1 January 2030. And shipping in the product's own box only works if that box survives the courier on its own. I would not send a glass product that way without a drop test first.

How do you work out your own ratio?

You can do this with a tape measure this week. For each of your top EU sellers:

1. Measure the inside of the outer box, in centimetres, and multiply length by width by height.
2. Measure the product's sales packaging the same way.
3. Subtract the second number from the first. That is your empty space.
4. Divide the empty space by the outer box volume. That is your ratio.

Let us take an example with made-up sizes. A box of 30 x 20 x 15 cm holds 9,000 cubic centimetres. The product box inside is 20 x 12 x 10 cm, or 2,400 cubic centimetres. Empty space is 6,600, and the ratio is 6,600 divided by 9,000, which is 73%.

To get to 50%, the outer box can be at most twice the volume of what is inside it. Here that is 4,800 cubic centimetres. A box of 24 x 16 x 12.5 cm would do it.

That "twice the volume" check is the one I would give every packer.

It is easy to remember, and anyone in our team or yours can test it with a tape in a minute.

Two cautions. The method act will decide whether volumes are measured inside or outside the box walls, so keep a small margin. And for orders with several products, add up all the sales packs before you divide.

What should you change in 2027?

Do the measuring and the testing now, while it costs nothing to get wrong. I would start in January 2027, before the year gets busy:

1. List every SKU and box pairing you ship to the EU, with its ratio. Mark everything above 50%.
2. Look for the pattern. Often the cause is a short box range, with a few sizes covering too many products. One or two extra sizes, or a mailer for small items, can fix a large share of the list.
3. Move protection closer to the product. A tight wrap and good corner protection in a snug box can do the job of a lot of loose fill around a product in a big box. Our guide to choosing cushioning by product weight and fragility explains how much space each material needs.
4. Drop test every smaller pack before it goes live. Pack three boxes the old way and three the new way, and follow our warehouse drop test. A smaller box that breaks more products is no saving.
5. Keep the test records. If a product genuinely needs more space to survive, a written test result is the best answer you can give when a buyer, a marketplace or an inspector asks why the box is bigger.
6. Check whether any product box is strong enough to ship on its own. That is the one route the rule exempts.
7. Ask your EU 3PL or fulfilment centre what box range they plan for 2030, and when they will change it.

Do not throw away your void fill. It is not banned, and it will still be needed in smaller boxes. You will simply need less of it per order.

What this means for void fill buyers

We make the fill, so we see this rule from the supplier's side. Our view is simple: right-size the box first, then choose the cushioning for the space that is left.

If your void fill bill falls after you right-size your boxes, that is the rule working as intended. I would rather sell a customer less air cushion film than see their orders arrive broken in a box that was too small, so test before you cut.

If you want a second pair of eyes on your box and product sizes, send us the list of your top EU SKUs with both sets of dimensions. We will tell you where the ratio looks hard to meet and what we would test first.