3 Real Boundaries of GB 23350-2021 Excessive Packaging Requirements: Packaging Layers, Void Ratio, and Cost Ratio—Which Requirement Applies First to Gift Box Structures

In March 2025, a tea customer sent us a corrective action notice with photographs attached. The package contained 250 g of spring tea and, when opened, revealed a tin, tissue paper, outer box, gift bag, and shipping box—five layers. He said, “The market supervision people told us that we had exceeded the limit.”

The problem lay in his understanding—the shipping box is transport packaging and does not count toward the number of sales packaging layers. The standard is clear: it applies to sales packaging for food and cosmetics, but not to transport packaging. Only the tissue paper around the tin and the gift bag need to be counted.

However, this is not the main point of this article. I want to discuss something else: the customer later came to us with the corrective action notice and asked, “Can you stop making this gift bag for me?” He was right to ask, but he had calculated in the wrong direction.

This is because “excessive packaging” under GB 23350-2021 is not a concept of one layer nested inside another. It is divided into three independent indicators that are calculated and assessed separately: packaging layers, packaging void ratio, and packaging cost ratio. All three must be calculated and pass their respective limits; exceeding any one of them constitutes excessive packaging.

The third indicator is the one printing companies are most likely to misapply. Under the standard, “packaging cost” is defined as the packaging procurement price agreed between a food or cosmetics enterprise and a packaging supplier—in terms a printing company understands: the packaging price the customer pays is itself the numerator subject to regulatory scrutiny.

The First Boundary: Count Layers from the Inside Out, Excluding a Film Closely Attached to the Outside

Let us begin with the number of layers, because this is the printing company’s most direct responsibility.

The calculation method in the standard is: packaging that directly contacts the contents is Layer 1, with subsequent layers counted in order and the outermost layer designated Layer N. Two details are often overlooked.

The first detail is that “a film closely attached to the outside of the sales packaging with a thickness below 0.03mm is excluded.” In other words, the thin OPP bag used for dust protection does not count as a layer. However, if the customer replaces it with a thicker 0.08mm film to improve the feel, that film counts as one layer. This is not mere formalism: when many customers ask why a package they believe contains only one layer was found to exceed the limit, the reason often turns out to be that moisture-barrier film.

The second detail is even more important: the calculation applies to sales packaging, not transport packaging. A shipping box does not count, but a gift bag does. Why? Because the gift bag is sold to the consumer together with the product, and the consumer can continue using it to hold other items. It therefore forms part of the sales packaging.

What about a gift box? How many layers does a gift box have?

That depends on what is inside the gift box and how it is sold:

Amendment No. 2 to GB 23350-2021, released in March 2024, changed the limit for tea from “no more than four layers” to “no more than three layers.” This provision took effect upon issuance, with no transition period. Other additions and amendments received a 12-month transition period.

Our factory now requires the layer count to be entered on quotations for tea customers. It states whether the quotation is based on sales packaging with X layers, including or excluding the gift bag.

The Second Boundary: The Void Ratio Is Not How Empty the Box Is, but Is Back-Calculated from Net Content

The void ratio is the most misunderstood of the three indicators and the one most likely to cause disagreements within a printing company.

The formula is: X = (V_n − Σ(kV₀)) / V_n × 100%

Broken down:

• V_n is the volume of the sales packaging. For a rectangular cuboid, use length × width × height; for non-rectangular shapes, use the water-displacement method.
• V₀ is the volume of the contents, not the actual product volume, but converted from net content—1 mL or 1 g of contents is calculated as 1000 mm³.
• k is the necessary space coefficient for the product, which varies significantly by category.

The limits are tiered by net content per unit:

There is also a critical exemption: products with sales packaging consisting of only one layer do not need a void ratio calculation and are directly deemed compliant. This explains why void ratio is rarely raised in connection with many single-item packages, such as a lipstick or a bar of soap.

The k value is the element most prone to error in the entire calculation because it varies by category, and further subdivisions exist within the same category:

Here is a calculable example. For 50 mL of skin-toning water in an 8×7×15 cm box, the volume is 840 cm³ and k = 9:

X = (840 − 9 × 50) / 840 = 46.4%

A net content of 50 mL falls within the “30 < Q ≤ 50” tier, whose limit is 40%. The 46.4% void ratio exceeds the limit. What, then, is the maximum legal volume for the box? Working backwards: 840 × (1 − 0.4) = 504 cm³. In other words, the necessary space is 9 × 50 = 450 cm³, and the total packaging volume cannot exceed 504 cm³.

For the same box of skin-toning water, if k is incorrectly taken as 15, the value used for loose powder, the result becomes (840 − 750)/840 = 10.7%, which appears to pass. An incorrect k value can reverse the conclusion outright. This is why I consider k the element most prone to error in these calculations—it depends on category classification, not on the box itself.

The Third Boundary: What Percentage of the Selling Price May Packaging Cost Represent—The Printing Company’s Quoted Price Is the Numerator

The third indicator is the most counterintuitive.

The standard states: Production organizations shall take measures to ensure that the cost of all packaging other than packaging that directly contacts the contents does not exceed 20% of the product’s selling price.

Two definitions must be distinguished carefully:

• Packaging cost = the packaging procurement price agreed between a food or cosmetics enterprise and a packaging supplier. It is the packaging price paid by the customer to the printing company, not the retail price or the ex-factory price.
• Selling price = the contract selling price agreed between a food or cosmetics enterprise and a sales enterprise; when the contract selling price cannot be obtained, the product’s normal market selling price, excluding discounted prices, may be used.

Applying these definitions to a printing company quotation leads to a somewhat sobering conclusion: if you quote RMB 0.50 more, the product’s packaging cost ratio rises accordingly. If the product sells for RMB 200 and the packaging costs RMB 40, the ratio is exactly 20%, right at the limit; increasing the packaging cost from RMB 40 to RMB 41 puts it over the limit.

This does not mean that a printing company cannot make a profit. It means that making a gift box “thicker” may be unlawful in certain categories, while the customer’s cost ratio is subject to spot checks.

Tea, mooncakes, and zongzi are subject to stricter requirements:

The requirement that “packaging mass must not exceed 8 times the mass of the contents” should be the first calculation made by a printing company when producing a tea gift box. For 250 g of tea, compliance is easy if only the paper weight of the outer box and gift bag is counted. If the tin is included, however, the “packaging mass” includes the tin. The standard refers here to packaging mass, meaning weight, so the weight of the tin directly determines how heavy the outer gift box may be. When calculating this for customers, we usually work from both ends: backward from the maximum paper weight of the gift box and backward from whether the tin wall thickness can be reduced.

What All Three Indicators Should Look Like on a Printing Company Quotation

Once these three indicators are laid out, the conclusion is straightforward. Excessive packaging is not something that can be changed merely because a customer makes a request; it involves three calculations that require specific figures.

Our factory uses a fixed template for the quotations of color boxes and gift boxes for food and cosmetics. No quotation is issued until all three fields are completed. Customers initially considered this unnecessarily cumbersome, until one used our quotation to respond to a spot check and managed to withstand two months more than another supplier.

Finally, a related point. None of these three indicators can be determined unilaterally by a printing company. The customer determines the net content, the product category determines the k value, and the customer also determines the retail price. What a printing company can do is convert the box dimensions and structural proposal into figures the customer can use directly. Once you define the boundary for how large the box may be, the customer can determine on their side whether the proposal will pass.

Further Reading

These topics form part of the same set of calculations discussed in this article:

• 3 Real Calculations of Packaging Void Ratio—volumetric weight, loading rate, and pallet layers; the void ratio on the logistics side is a separate calculation
• 4 Real Calculations for Gift Box Packaging Bags / Shopping Bags—whether a gift bag counts as one layer is answered in the layer calculation in this article
• 3 Real Cost Differences in Gift Box Window Designs—whether a window saves material or adds layers depends on how it is calculated
• Does Higher-Weight Packaging Paper Cost More? 3 Real Pricing Logic—when the packaging cost ratio exceeds the limit, the first element to adjust is the paper weight
• 3 Real Boundaries of Packaging Reverse Logistics—downstream of excessive packaging governance, how the recycling endpoint responds