Recycled Content on the Label: The Harmonised Information Layer
Recycled-content information joins the harmonised label family. How the printed figure, its basis and the digital depth fit together - and the artwork decisions to bank in the 2028 round.
The short answer
The labelling framework provides for recycled-content information on packaging in harmonised form, so that the figure a consumer reads in Lisbon means the same as the figure read in Lublin: the post-consumer recycled share, expressed on the calculation basis Article 7 defines, for the packaging or its plastic part as the specification prescribes. The printed element is necessarily brief - the percentage and its basis marker - while the method, the certification chain and the dated validity of the figure live in the digital layer behind the data carrier. Claims discipline for the wording itself is the recycled-content station's claims guide; this guide covers the label as an artefact: placement, production and change management.
The practical point for planners: content labelling rides the same artwork changeovers as the sorting label, and a pack whose content figure will change with supply (transition years) should be designed digital-first, as the claims guide advised.
Designing for a figure that changes
Recycled content is a moving number in the transition years - supply contracts step up, percentages climb toward 2030 values - while printed packs move at artwork speed. Three production patterns manage the mismatch. Print the floor: the figure guaranteed across the print run's life, conservative and always true. Carry the figure digitally: the carrier resolves to the current certified figure with its validity stated, the pack printing only the basis and the invitation. Or segment: flagship lines with stable supply print their figure; volatile lines go digital-first. The prohibited pattern is the fourth: printing the aspiration. Every printed figure is a placed claim with the technical file behind it; the claims register records which pattern each line uses and why.
Placement and adjacency discipline
Content information sits in the label system's regulated zone, and its neighbours matter: beside the sorting label it reads as system information (correct); inside a marketing roundel it reads as promotion (and will be judged as a claim with promotional standards). Keep the harmonised elements visually grouped and typographically sober, and resist the design temptation to restyle them - the harmonised system's value is its uniformity, and a brand that restyles its sorting and content labels into house typography has spent the recognition the system exists to build. The artwork gate checks adjacency explicitly: what touches the regulated elements, and what a hurried reader might merge them into claiming.
Multipacks, outers and the inner-unit question
Where packaging layers nest (unit, multipack film, shelf tray), content and sorting information allocate by the rule the sorting guide set for components: each layer that the consumer handles and discards carries its own answer, and the outer layer carries the aggregate story where the inner is invisible at purchase. For content specifically, a multipack's printed figure must state its basis across the unit it describes - the film's percentage is not the bottles' - and the register should hold the layer map per SKU, since layer confusion is the most common honest error in content labelling and the least forgivable in a competitor's screenshot.
One label, worked end to end
A shampoo bottle, 2029 artwork round. The sorting label shows the bottle and cap components and their streams. Beside it, the content element: the certified post-consumer figure for the bottle, printed as the floor figure the supply contract guarantees, basis marker naming the plastic part. The QR resolves (scan-tested on the production proof, on the actual pearlescent substrate) to the governed page: the current figure with its validity window, the certification chain summary, the sorting depth, the substance information. The claims register holds the figure's evidence version; the label register holds the artwork version; both carry the same review trigger - the supply contract's renewal date. That is the whole apparatus, unremarkable in operation, which is what finished compliance looks like.
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: Article 12 of Regulation (EU) 2025/40, read with Article 7. Application position for this topic: Phased with the labelling implementing acts (2028-2029).