The Artwork Changeover: Running 2028 and 2029 as One Programme
Two regulatory waves, hundreds of SKUs, finite studio capacity: the programme management of the label transition - waves, plate and stock run-outs, approval gates and the register that keeps it honest.
The short answer
The label transition is a production programme: every SKU's artwork revised (twice if the waves are handled separately, once if they are combined intelligently), plates and print stock run out against placing dates, approvals gated on the label register, and a hard legal edge - packs placed from the changeover dates must carry the new system. The programme plan has four workstreams: the design system (label components generated from the component data map, not hand-drawn per SKU), the wave plan (which SKUs change when, aligned to natural artwork cycles and print reorders), the stock plan (existing printed packaging inventoried and its lawful placing window calculated), and the approval system (register-based gates that check marks, claims and carrier resolution together).
This guide is the programme manager's version of the station.
Combining the waves: one touch per SKU
The 2028 sorting label and the 2029 reusable and content elements land eleven months apart - close enough that touching each SKU twice is waste, far enough that doing everything in 2028 means printing 2029 elements before their specifications are final. The resolution is architectural: in the 2028 touch, reserve and prepare the 2029 elements' space, carrier and data plumbing (the QR infrastructure serves both waves), and print the 2029-specific content only where its specification is already fixed by the regulation's text (the reusability label for known reusable lines is the safest candidate). High-value SKUs with annual artwork cycles may still take two touches; the long tail takes one combined touch timed to its reorder cycle. Model both patterns against the estate and publish the per-SKU wave assignment in the register.
Stock run-outs and the placing line
Printed packaging stock is inventory with a legal expiry: stock printed under the old system remains placeable for units placed before the relevant date, under the transition logic the timeline station works through - and becomes waste paper the day the window closes. The stock plan therefore works backwards from placing velocity: per SKU, stock on hand and on order, weeks of cover, and the reorder point at which new artwork must be in the print queue. Seasonal and slow SKUs are the risk tail (a Christmas format printed eighteen months ahead is the classic casualty). Where run-out fails, the remedies are over-labelling for defined cases (check the market's acceptance), component-level updates, or write-off - priced in the plan rather than discovered in the warehouse.
Approval gates that catch the real errors
Changeover errors are systematic, not artistic: a retired national mark left on one market's variant; the sorting pictogram for the wrong component on a separable pack; the QR resolving to the campaign page because the resolver rule was bypassed for a launch; the recycled figure printed from last year's certificate. The gate checklist runs the register against the proof: marks present and absent per market matrix; component indications against the component map; carrier scan test on the physical proof; claims against the claims register; and the placing date the artwork is intended for. Gates staffed by the label owner, with authority to stop a print run, are the programme's cheapest insurance - a stopped run costs a day, a wrong run costs the stock.
Resourcing the studio honestly
One programme-management truth to close: regulatory artwork waves fail on capacity arithmetic, not on intent. Count the estate's true touch cost - design, proofing, plate changes, approval cycles, translation and market-variant handling per SKU - against the studio's real throughput, and the wave plan either fits or visibly does not, two years before the deadline rather than two months. Where it does not fit, the levers are known: external studio capacity booked early (it will be the whole industry's bottleneck in 2027), estate rationalisation (the long tail of zombie SKUs is an artwork tax on every transition), and the design-system automation that generates label variants from data. Choose the levers while they are still cheap.
Primary sources on the record
- Regulation (EU) 2025/40 of 19 December 2024 on packaging and packaging waste, Official Journal text on EUR-Lex.
- European Commission, packaging waste topic page - guidance and act progress.
- Directive (EU) 2024/825 of 28 February 2024 empowering consumers for the green transition, text on EUR-Lex - the ban on generic environmental claims and unverified sustainability labels.
Legal status: Programme practice under Articles 11-13 of Regulation (EU) 2025/40. Application position for this topic: Programme runs 2026-2029.