Guide 2/4 Marketing & product development May 2026

Packaging is changing its rules.
Your brief has to change too.

The PPWR and the AGEC law are transforming what you can put on the market, how you label it and how you design packaging from the initial brief onwards. This guide explains what needs to enter your process now.

Packaging briefEco-designLabelling & legal noticesProduct launch

For a long time, packaging was often dealt with late in the product development process: the product was defined, the positioning settled, and packaging came in to dress it all up. Regulatory constraints were a matter for the packaging or quality teams.

That model no longer works. The PPWR and the AGEC law impose constraints on materials, formats, packaging volumes and labelling that have to be built in from the product brief stage. A launch planned for 2027 whose packaging was not designed with these constraints in mind risks having to be reformulated in a hurry or, worse, being impossible to place on the market as it stands.

The one thing to remember

Packaging designed in 2026 for a 2027-2028 launch already has to anticipate the 2030 rules. Packaging development cycles run to 18 to 36 months. What you brief today will be on the market when the major PPWR obligations take effect.

What the PPWR changes in practice for a product brief

The rules that need to enter the initial scoping of every new project

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The size of the packaging has to be justified

The PPWR sets a maximum empty-space ratio of 50% for grouped and e-commerce packaging from 2030. For sales packaging, the rule is to use the minimum. In practice: any packaging with significant empty space will have to be justified or redesigned.

What changes in the brief: build in minimum-format constraints, consistent with the product, from the outset. "Generous" packaging designed to showcase the product on the shelf will be under regulatory pressure.

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The material has to be recyclable (class A, B or C) by 2030

Any packaging placed on the market from January 2030 will have to obtain a recyclability rating. Packaging rated D or E will be banned. The precise criteria will be published in 2028, but current guidance already lets you identify the at-risk materials now.

What changes in the brief: the choice of material can no longer be driven solely by aesthetics, cost or barrier performance. Recyclability is a go/no-go criterion. Any complex material (multilayer, plastic-aluminium combinations, cardboard with a coating > 5% plastic) has to be validated by the packaging R&D team before it goes into a brief.

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Sorting labels are going to change — don't over-invest in the current system

The French Triman system and Info-tri pictograms will be gradually replaced by a harmonised European pictogram labelling system (with an optional QR code alongside) from 2027-2028. Any heavy investment in artwork based on the current system will need revising.

What changes in the brief: don't create consumer recycling information systems that are incompatible with the future European pictogram. Avoid "recyclable packaging" claims with no reference to the official system; they could be treated as greenwashing under the Green Claims regulation (currently being adopted).

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Certain formats will be banned from 2030

Annex V of the PPWR lists the formats banned from 1 January 2030: single portions in sit-down catering (ketchup, sugar, salt sachets), plastic packaging for fresh fruit and vegetables under 1.5 kg, individual cosmetic kits in hotels, and potentially shrink film for multipacks.

What changes in the brief: if your product falls into one of these categories, the current packaging format is living on borrowed time. Any new development in these categories must anticipate the transition. The product ranges concerned need a dedicated portfolio review.

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Environmental claims on packaging are regulated

The Green Claims regulation (currently being adopted) and the PPWR require any environmental claim to be verifiable, based on a recognised methodology and not misleading. Vague claims such as "eco-responsible", "environmentally friendly" or "green" with no proof will be banned.

What changes in the brief: any environmental claim under consideration for the packaging has to be validated by the compliance teams before it is briefed to the creative agency. It is no longer a marketing-only decision.

The post-PPWR packaging brief: what has to change

The structure of a brief that builds in the regulatory constraints from the start

Packaging brief — new mandatory sections Post-PPWR / AGEC

Regulatory constraints to validate before any creative direction

PPWR category: Is this format listed in Annex V (formats to be banned in 2030)? Packaging R&D check.

Material recyclability validated: Is the proposed material compatible with the 2030 recyclability guidance? R&D validation required before the creative brief.

Absence of PFAS: If the packaging is food-contact, supplier confirmation is required before validation.

Empty-space ratio: Does the target format meet the minimisation constraint? If empty space > 50%, technical justification is required.

Labelling & legal notices

Sorting pictogram: Use the current Triman system but don't create a custom system. Plan for the move to the European system in 2028.

Environmental claims: Any "recyclable", "eco-designed" or "durable" claim must be validated by compliance before it goes into the creative brief.

Labelling area: Reserve space in the artwork architecture for the harmonised PPWR pictogram labelling (mandatory from 2027-2028) and, alongside it, an optional QR code.

Graphic palette & packaging coverage

Recyclability inks: Check with packaging R&D that the inks and varnishes under consideration are compatible with the recyclability of the substrate. Some inks and varnishes lower the recyclability class.

Ink coverage rate: For plastic packaging, a high coverage rate (> 50-60%) can affect recyclability. Check with R&D depending on the material. Note: reducing ink coverage also brings down packaging cost, so there are two good reasons to brief lean.

Black pigments: Black plastic packaging (carbon pigment) is not detectable by optical sorters. This aesthetic choice has a direct impact on recyclability.

Colours and packaging: the concrete regulatory impacts

What the regulation does (and does not) say about colour choices

What the regulation actually requires

Neither the PPWR nor the AGEC law directly bans a packaging colour. The constraint is not aesthetic, it is technical: some pigments or coverage rates lower the recyclability of the material. It is a formulation constraint, not a design one.

Carbon black (plastic)

Carbon pigment: not detectable by NIR optical sorters. A direct impact on recyclability.

Avoid

Carbon-free black (plastic)

NIR-detectable organic black pigments. A viable technical alternative depending on the substrate.

Check with R&D

Heavy coverage (plastic)

A high ink rate can reduce the value of recycled plastics. To be assessed depending on the substrate.

Check coverage rate

White / Light (plastic)

Generally compatible depending on the white pigment used (TiO2 acceptable in small quantities).

Generally OK

Natural cardboard / kraft

On cardboard with no plastic coating: no colour-related recyclability constraint.

OK on bare cardboard

Metallised / Gilding (plastic)

Metallised layers or gilding on plastic: a strong impact depending on thickness and coverage.

Recyclability impact

What to stop doing, and the alternative

Practices to drop and concrete replacements

Current practice Regulatory problem Recommended alternative
"Recyclable packaging" claim with no detail Potential greenwashing under Green Claims. Not verifiable without reference to an official system. A notice compliant with the current Triman system. Wait for the PPWR pictogram in 2028.
Black plastic (carbon pigment) for food packaging Not sortable by optical sorting systems. Lowered recyclability class. NIR-compatible organic black pigments. Or a change of colour: a non-black dark shade (green, dark blue) depending on positioning.
An outer pack far larger than the product to stand out on the shelf Empty space > 50%: non-compliant from 2030 for grouped packaging. Work the format as tight to the product as possible. Stand out through material, finish, typography — not volume.
Plastic shrink film (grouping) on multipacks (store/retail format) Potentially banned in 2030 subject to the Annex V clarification expected in February 2027. Anticipate the move to cardboard, repositionable glue or a clip. Don't launch a new design in this format before the clarification.
Splitting into individual sachets for sit-down catering Banned by PPWR Annex V from 2030 (salt, sugar, ketchup, condiments in HORECA). Refillable formats, dispensers, bulk portions. To anticipate in foodservice ranges.

For a full action plan with all the PPWR deadlines by packaging type and by sector, see the detailed roadmap.

Go to the full PPWR roadmap

Sources: Regulation (EU) 2025/40, Commission guidance 30 March 2026, AGEC law, Green Claims regulation (currently being adopted). Content verified as of 10 May 2026.