Many claim that they have been optimising packing in many years alone because the normal business competition has been forcing the company to do so. "Cost cutting is an every day business in all companies surviving today".
This argument is correct. What the companies have done is using the "salami method". The companies have from one design to the next slowly cut a little out of the packaging protection in order to save money/resources on the packaging materials. Packaging is cut down "slice by slice" until the company run into problems. Then the "bad" packaging is re-designed and the company will stay on this protection level some time before competition once again the company is forced to proceed.
BUT the company is under normal conditions not able to document such an assessment process.
On the following pages you can find a description to fulfil the requirements to the Directive and still use these methods.