Four functions, four different conversations
Start by asking what the material must do
The PPWR (Packaging and Packaging Waste Regulation) entered into force on 11 February 2025 and has largely applied since 12 August 2026; other obligations are being phased in. It assesses packaging as a whole — box, tape, label and void fill — and requires that it contain no more material than its function requires. For void fill, this is more difficult than it sounds, because “void fill” can mean four different things:
- Blocking. Holding the product in place so it cannot slide into the wall. This requires dimensional stability, but not necessarily resilience.
- Cushioning. Absorbing energy during a drop or impact. This requires resilience and a certain thickness, and depends on the product's weight.
- Insulating. Protecting against moisture, dust, temperature or damage between products. This presents a completely different material question from the first two.
- Filling. Closing empty space so the contents do not rattle. This is the only one of the four in which the material has no independent function.
The last function is where the saving lies. If the material merely fills empty space, the material is not the problem; the box is. This is also why changing material, for example from plastic to paper, is often the wrong first step: it replaces the symptom.
The cheapest void fill is a smaller box
What a few centimetres can change
Void fill and box size are communicating vessels. Every litre of air removed from the box is a litre that no longer needs filling, while also reducing board, film per pallet and loading space.
Before taking that step, one point must be checked: the 20 mm clearance must be sufficient. For a fragile or heavy product, protective space is a functional requirement rather than spare room. It then falls into the cushioning category, and a tighter box may create a risk. If in doubt, calculate the strength of the new box with the box calculator and examine whether a different FEFCO style with integrated retaining folds can take over part of the void-fill function.
This is the most underestimated route. An insert or divider made from the same corrugated board often blocks more effectively than loose fill, enters the paper stream as a single material, and removes an operation from the packing line. The page on empty space and box ranges explains how to identify systematically which boxes contain this air.
Compare protection per gram and per litre
And do not overlook the process
If a genuine protective function remains after examining the box, the decision becomes one of material. The pitfall is to compare feedstocks — paper versus plastic — rather than performance. Two measures make the discussion concrete:
- Protection per gram. How much mass is needed for the cushioning or blocking function your product requires? Air cushions perform well on this measure because they consist mostly of air; paper requires more mass to provide the same cushioning.
- Protection per litre of storage. Pre-filled material occupies warehouse space that air cushions inflated on site do not. Those cushions, however, require a machine, maintenance and another potential point of failure in the line.
The second measure is why changing material is seldom just a purchasing decision. Moving to paper fill with a crumpling machine changes the throughput time per box, storage volume and susceptibility to stoppages. Include those effects before adding up the environmental benefit.
Where it ends up at your customer's site
The route after use matters
Void fill is the first component your customer discards, making its collection route a real part of the assessment. Most recipients place paper fill with waste paper, together with the box. Plastic film and air cushions require a separate film stream, which is manageable for a business with a baler but more difficult for a small recipient. Foam and foam-in-place materials are the hardest to separate in practice.
This is not a ranking but a trade-off. A supplier serving industrial customers with a film stream will reach a different answer from one shipping to small businesses or consumers. Simply ask a few customers; it is the least expensive information in the entire assessment.
For each packaging unit, record the void-fill material, quantity, function and assumed collection route. Those four lines make the difference between a substantiated choice and an assumption. The page on supplier information explains which data to request from your supplier.
Frequently asked questions about void fill
Brief, practical answers in plain English
Not automatically. The PPWR does not prohibit plastic or make paper automatically better. What matters is whether the material fulfils its function with the least possible mass and volume, and where it ends up at the recipient. A paper solution requiring three times the volume to provide the same protection is not an improvement.
Blocking holds the product in place so it cannot slide into the wall. Cushioning absorbs energy during a drop or impact. These are different requirements: a material that blocks effectively is not automatically a good cushion, and vice versa. Establish the function first, then select the material.
When it merely fills empty space. The box is then too large, and the issue can be solved with a better-fitting size or an insert made from the same corrugated board. Void fill that blocks, cushions or insulates cannot simply be removed, because it performs a function the box does not take over.
Yes. Under the PPWR, packaging is assessed as a whole, including void fill, tape and labels. For each packaging unit, record which void-fill material it contains, how much, and the function it performs.
Sources and scope
What this guidance is based on
- EUR-Lex — Regulation (EU) 2025/40 — the Regulation itself. Opens in a new window.
- Netherlands Enterprise Agency (RVO) — EU packaging requirements (PPWR) — Dutch government information. Opens in a new window.
- Verpact — All about the PPWR — timeline and implementation for the Netherlands. Opens in a new window.
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