Worked calculation sheet
Which space are
you counting?
The outer carton, sales packs and bare products are different objects. Keep their boundaries straight before using a percentage.
Three boundaries,
one outer-pack ratio.
- Outer pack
- The total volume of the grouped, transport or e-commerce packaging is the denominator.
- Sales packaging
- Paragraph 3 subtracts the sales-packaging volume inside that outer pack. It does not silently substitute the bare product volume.
- Product & filler
- The product sits inside its sales packaging. Paper, air cushions and foam used as filling material remain on the empty-space side of the calculation.
Start with ten units.
Change one fact.
Every number below is invented to explain the arithmetic. These examples do not establish a measurement method or certify a shipment.
10Sales-pack volume
6Empty space
44 ÷ 10
40%
The example’s 40% is a result, not the legal maximum. Article 24(1) specifies 50%, subject to its timing and scope. Keep the date condition with the number.
Add more paperStill 40%
(10 − 6) ÷ 10 = 40%
Two of the four empty-space units now contain paper. The sales-packaging volume is still six. Counting the paper as product would incorrectly produce 20%.
The changed fact is the filling material, not the outer volume or the sales-pack volume.
Use an eight-unit outer pack25%
(8 − 6) ÷ 8 = 25%
The same six units of sales packaging sit in an invented eight-unit outer pack. Both the empty space and the denominator change. Dividing the new two-unit gap by the old ten-unit volume would incorrectly produce 20%.
This arithmetic says nothing about whether the contents actually fit or remain protected.
Count two sales packs: four plus one50%
(10 − (4 + 1)) ÷ 10 = 50%
With a ten-unit outer pack, count both contained sales packs. Their total is five. Counting only the larger one would wrongly produce 60%.
A result at or below 50% is not a compliance badge. Category, measurement method, date and exceptions still matter.
8 units³
Equal volumes. Different shapes.
Schematic, invented dimensions.
A ratio cannot tell you whether it fits.
An 8 × 1 × 1 rigid rod and a 2 × 2 × 2 cube each have a volume of eight cubic units. The longest straight line inside the cube is its space diagonal: √12, about 3.46 units. The eight-unit-long rod cannot fit inside it, even diagonally.
Orientation, clearance and protection remain separate design questions. Paragraph 2 calls for a methodology that takes account of special characteristics, including fragile or irregular products. It is not a blanket permission to ignore the limit.
Two parcels.
Three different percentages.
Averages can conceal the parcel you need to inspect. This invented example concerns arithmetic only: it does not prescribe the official measurement or aggregation method.
Parcel A
Outer volume: 12
Sales-pack volume: 9
Empty space: 3
3 ÷ 12 = 25%
Parcel B
Outer volume: 8
Sales-pack volume: 2
Empty space: 6
6 ÷ 8 = 75%
The simple average of the two percentages is (25% + 75%) ÷ 2 = 50%. Combining their volumes instead gives (3 + 6) ÷ (12 + 8) = 45%. The results differ because the parcels have different total volumes. Neither number changes Parcel B’s own 75% result.
A report that contains only “45% empty space” has lost a useful fact. Keep each parcel’s numerator, denominator and identifier beside any summary. When someone asks what the percentage means, you can show whether it describes one parcel, an average of percentages, or a ratio of summed volumes. Do not select whichever calculation produces the smallest number and label it compliance.
What to write down before doing the division
Give the outer pack a record ID. List each sales pack once and state which measurements or supplier data produced its volume. Record the unit, the packaging layer and any uncertain boundary. Keep filling material in a separate description so it is not accidentally relabelled as sales packaging when a colleague repeats the calculation.
Use the same volume unit on both sides. A litre is 1,000 cm³: 6 litres inside 10,000 cm³ is the same conceptual example as 6,000 inside 10,000, giving 40%. Typing “6” beside “10,000” without the units produces a meaningless result. Converting linear dimensions also happens before multiplying: 200 mm is 20 cm, not 200 cm.
Finally, preserve the questions the arithmetic did not answer: which obligation applies, what date condition is relevant, how an irregular shape is measured, and whether the proposed arrangement protects the goods. Use the layer-and-date comparison and the Commission’s official PPWR resources alongside the underlying legal text. This sheet makes a calculation inspectable; it does not decide those questions.
Download the two-parcel example and blank calculation record · Includes both summary calculations so they cannot be silently interchanged.
Inside the sales pack, the question changes.
Article 24(4) addresses the space needed for the sales pack’s function. It also has specific treatment for settlement and required headspace: assessment is at filling, and air within or between packed food or protective gases is not treated as empty space under the stated conditions.
Do not carry an outer-parcel percentage into every bottle, cereal box or retail carton. Read the relevant packaging layer in the obligations comparison. If the sales pack also makes the delivery, read the same-pack exception.
Article 24(2)–(4) · Commission guidance on minimisation and the ratio