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How Regulation (EU) 2025/40 is changing packaging production and why upgrading existing converting lines can be a smarter strategy than replacing them

The European packaging industry has entered a new regulatory phase. Regulation (EU) 2025/40, better known as the Packaging and Packaging Waste Regulation (PPWR), entered into force on 11 February 2025 and applies generally from 12 August 2026. The Regulation introduces new requirements covering packaging sustainability, recyclability, minimisation, reuse, labelling, information and waste management.

The European Commission published additional guidance in June 2026 to support companies and Member States in applying the Regulation consistently. For packaging manufacturers and converters, however, an important distinction needs to be made: The PPWR does not require companies to install a particular type of printing machine. Instead, it establishes requirements that, depending on the packaging and the applicable provision, can create a need for additional information, markings or digital access to information.

This raises a practical production question: How can converters add the necessary printing capability without replacing productive existing equipment?

For many applications, one possible answer is to retrofit an existing extrusion or converting line with a compact inline flexographic printing unit. Rather than introducing a separate printing and handling operation, inline flexographic printing can add selected graphics directly during the existing production process. The objective is not simply to print more. It is to add the right printing capability with the least possible disruption to production.

Key Takeaways

• The PPWR generally applies from 12 August 2026.
• New harmonised packaging labelling requirements will apply later, with important dates specified in Article 12.
• The harmonised material-composition and sorting label is scheduled from 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later.
• The PPWR does not prescribe a specific printing technology.
• Depending on the application, an inline flexographic printing unit can provide a practical way to add selected graphics or information during existing production.
• Retrofitting can allow converters to preserve productive equipment instead of replacing an entire production line.
• The right solution depends on factors such as substrate, web width, production speed, print repeat, number of colours, drying requirements and available installation space.

What Does the PPWR Mean for Packaging Printing?

The PPWR is designed to harmonise packaging requirements across the European Union and support objectives including waste prevention, recyclability, reuse and a more circular packaging economy. One important area is packaging labelling and information.

Article 12 introduces a harmonised label containing information on packaging material composition to facilitate consumer sorting. The Regulation also contains provisions concerning information on reusable packaging, recycled content and other packaging characteristics.

Where the Regulation requires information to be placed directly on packaging, Article 12 provides that certain labels and digital data carriers must be applied, printed or engraved in a visible, legible and durable way, subject to the specific provisions and exceptions in the Regulation. For converters, this means that packaging printing needs to become increasingly flexible. The challenge is not necessarily the production of sophisticated decorative graphics.

In many cases, the requirement may involve relatively small areas containing:

• regulatory symbols;
• material or sorting information;
• identification marks;
• reuse-related information;
• recycled-content information;
• barcodes or other production information;
• digital data carriers where applicable.

The result is a growing need for efficient, repeatable and adaptable printing directly within packaging production processes.

When Will the New PPWR Packaging Labelling Requirements Apply?

The PPWR contains several different implementation dates. It is therefore important not to treat 12 August 2026 as the date on which every packaging-labelling requirement suddenly becomes mandatory.

A simplified overview is:

* Article 12 contains provisions that can move the effective date later where the relevant implementing act enters into force later. This distinction matters for machinery investment decisions. Converters do not necessarily need to change their production equipment immediately simply because the PPWR generally applies from August 2026.

However, equipment investment decisions made today can determine how easily a production line responds to future labelling and information requirements. That is where retrofit-friendly printing technology becomes strategically interesting.

Does PPWR Require a New Printing Machine?

No.

Regulation (EU) 2025/40 establishes regulatory requirements; it does not prescribe that converters must install a particular printing technology. The appropriate technical solution depends on the packaging format, substrate, production process and specific requirements that apply.

Can additional printing capability be integrated into the existing process?

In many cases, the answer can be yes. A compact inline flexographic unit can be engineered as an additional printing station within an existing production line. Depending on the machine configuration, the unit can print selected graphics directly onto the web as part of the normal production process.

This approach can avoid the need to redesign the entire manufacturing workflow simply to introduce additional printing capability.

Why Retrofit an Existing Converting Line?

Across Europe, many extrusion and converting lines remain productive long after their initial installation. Replacing an entire line can involve substantial capital expenditure, installation work, commissioning, operator training and production downtime. If the objective is to add a relatively small amount of additional printing, a complete line replacement may not always be the most logical starting point.

A retrofit approach can allow manufacturers to:

• preserve existing production assets;
• add printing capability where it is needed;
• reduce the scope of a machinery investment;
• minimise changes to established production processes;
• reduce the need for additional material handling;
• maintain greater flexibility for future artwork changes.

The economic case must always be evaluated against the specific line configuration and production requirements. But the principle is straightforward: If an existing production line is still productive, adding a new capability can sometimes make more sense than replacing the capabilities that already work.

What Does a Printing Retrofit Involve?

A successful inline flexographic retrofit starts with the existing production line rather than with the printer itself.

A technical assessment should typically consider:

1. Substrate — including film type, surface characteristics and printability.
2. Web width — to determine the appropriate printing configuration.
3. Production speed — to ensure the printing unit matches the existing process.
4. Print repeat — particularly where small regulatory graphics must be positioned consistently.
5. Number of colours — many regulatory applications may require only one or two colours.
6. Available installation space — a critical factor in existing plants.
7. Ink and drying requirements — depending on the substrate and printing application.
8. Registration requirements — especially for small symbols and machine-readable graphics.
9. Controls integration — allowing the printing unit to operate effectively with the existing line.
10. Maintenance and plate changes — which influence production flexibility and downtime.

This assessment determines whether an inline printing unit can be integrated effectively and what configuration is appropriate.

Inline Printing vs. Secondary Printing Operations

Without inline printing capability, additional graphics may require a separate process.

Depending on the product, alternatives can include:

• purchasing pre-printed material;
• outsourcing printing;
• applying labels;
• performing additional converting operations;
• transporting material between production stages.

Each additional operation can introduce more handling, inventory and planning requirements. Inline printing takes a different approach. The printing station is integrated into the existing production flow so that selected graphics can be applied while the material is already being produced or converted.

Inline printing can offer several operational advantages

This does not mean inline printing is automatically the lowest-cost solution for every application. The correct choice depends on production volumes, substrate, artwork requirements, equipment configuration and the economics of the existing process. The key advantage is process integration.

Why Flexographic Printing Is Suitable for PPWR-Related Graphics

Regulatory and identification graphics have different priorities from conventional decorative packaging printing.

The most important requirements can include:

• repeatability;
• accurate positioning;
• legibility;
• consistent print quality;
• production efficiency;
• durability;
• reliable operation at production speed.

Compact inline flexographic printing units are particularly well suited to applications where relatively small graphics need to be reproduced consistently within an existing manufacturing process.

Accurate Registration

Small symbols and other defined graphics need to remain consistently positioned on the web. Accurate registration is therefore an important consideration when selecting an inline printing system.

High Readability

Regulatory information must be clear and legible. The printing process needs to produce well-defined graphics suitable for the intended application, including machine-readable elements where these are required and technically appropriate.

Efficient Ink Usage

Many identification and regulatory applications do not require full-colour decorative printing. A compact printing configuration can therefore be matched to applications requiring only one or a limited number of colours.

Compact Footprint

Floor space is often limited in existing extrusion and converting plants. A compact inline printing unit can provide additional printing capability while limiting the amount of new equipment that needs to be incorporated into the production environment.

Production Integration

The greatest advantage is often not the printing technology itself, but its integration into the manufacturing process. The printer becomes part of the production line rather than creating an entirely separate production stage.

What About QR Codes and Digital Data Carriers?

QR codes and other digital data carriers are increasingly relevant to packaging information strategies, but an important distinction is necessary: The PPWR does not simply require a QR code on every package.

Article 12 contains specific provisions concerning QR codes and other standardised, open, digital data carriers in particular circumstances. Where applicable, the Regulation also establishes requirements concerning how such information is made available.

This means converters should avoid treating QR codes as a universal PPWR printing requirement.Instead, they should consider whether their specific packaging, product and regulatory obligations require or benefit from machine-readable or digitally accessible information.

From a production perspective, however, the same principle applies: If a small digital data carrier needs to be printed reliably on the web, the printing system must provide the necessary registration, resolution and process control.

Future-Proofing Packaging Production

Packaging requirements will continue to evolve. Artwork changes. Customers introduce new specifications. Brand owners update packaging designs. Retailers modify requirements. Regulatory implementation develops over time.

For converters, flexibility therefore has value beyond today’s requirements. A dedicated inline printing station can allow the production line to accommodate different graphics and artwork without fundamentally changing the overall converting process. Plate changes and other setup operations can be managed as part of the printing system, allowing the converter to adapt the printed content as requirements change. The objective is not to predict every future regulation. It is to make the production line more adaptable to change.

Retrofit vs. Replacing the Entire Production Line

When additional printing capability is required, converters should compare two fundamentally different investment strategies: Replace the existing production line or upgrade the existing line with an integrated printing solution.

The right choice depends on the individual application. However, a retrofit assessment should consider more than the purchase price of the printer.

Key factors include:

• equipment investment;
• installation costs;
• production downtime;
• commissioning;
• operator training;
• available floor space;
• existing ancillary equipment;
• controls integration;
• maintenance requirements;
• production continuity;
• future printing flexibility.

For a line that is otherwise productive, the ability to preserve existing equipment can be a significant advantage. A retrofit does not have to mean compromising on technology.

It can mean adding the technology that is actually needed while retaining the equipment that already performs well.

How OEMs Can Prepare Converting Machinery for the PPWR

The PPWR also creates an opportunity for machinery manufacturers. OEMs can consider printing capability as part of a broader production solution rather than treating it as an external process.

Integrating a compact inline flexographic printing unit into extrusion or converting equipment can give OEM customers:

• greater production flexibility;
• integrated printing capability;
• reduced dependence on external printing operations;
• easier adaptation to changing artwork requirements;
• a more complete production solution.

For machinery manufacturers, this creates an opportunity to add value without fundamentally changing the core converting process. The machine does not simply produce packaging material. It can become a more adaptable production platform.

Sustainability Also Means Efficient Manufacturing

The PPWR focuses strongly on packaging sustainability, waste prevention, recyclability and resource efficiency. For manufacturers, sustainability is not limited to the final packaging design. Production efficiency also matters.

An integrated printing process can potentially reduce unnecessary:

• material handling;
• transport between production stages;
• intermediate inventory;
• secondary converting operations;
• production planning complexity.

The environmental benefit will depend on the specific production configuration and should not be assumed automatically. Nevertheless, reducing unnecessary process steps can contribute to a simpler and potentially more efficient manufacturing workflow. In many production environments, process simplicity and resource efficiency can reinforce each other.

What Should Converters Consider Before Installing an Inline Flexographic Printing Unit?

Before investing in a printing retrofit, converters should answer several practical questions:

1. What needs to be printed?

Identify the required graphics, symbols, identification information or digital data carriers.

2. What substrate is being processed?

The printing system must be compatible with the actual substrate and its surface characteristics.

3. At what production speed?

The printing unit needs to match the operating conditions of the existing extrusion or converting line.

4. How much print width is required?

The required print area determines the appropriate printing configuration.

5. How many colours are necessary?

Regulatory applications may require fewer colours than conventional packaging graphics.

6. What level of registration is required?

Small graphics and machine-readable elements can place particular demands on positioning accuracy.

7. Is drying required?

Ink selection and drying configuration depend on the substrate, ink system and production conditions.

8. Where can the unit be installed?

The available space, web path and accessibility of the existing line must be evaluated.

9. How will artwork changes be managed?

A flexible printing system should make it practical to change plates and graphics as customer or regulatory requirements evolve.

10. Can the printer be integrated with the existing line controls?

Controls integration can be important for reliable operation and efficient production management.

A detailed engineering assessment is therefore essential before selecting a retrofit configuration.

Frequently Asked Questions About PPWR and Inline Flexographic Printing

Does PPWR require packaging manufacturers to install printing equipment? No. The PPWR establishes packaging sustainability, labelling and information requirements but does not prescribe a specific printing technology. The appropriate production solution depends on the packaging and the applicable regulatory requirements.

When does the PPWR apply? The Regulation entered into force on 11 February 2025 and generally applies from 12 August 2026.

When will harmonised PPWR packaging labelling become mandatory? Article 12 states that the harmonised label containing information on packaging material composition applies from 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later.

Does PPWR require QR codes on all packaging? No. QR codes and other standardised digital data carriers are addressed in specific provisions of the Regulation. They are not a universal requirement for every package.

Can an existing extrusion line be retrofitted with an inline flexographic printer? In many cases, yes. The feasibility depends on the existing line configuration, substrate, web width, production speed, available space, print requirements and integration requirements.

Why use flexographic printing for regulatory graphics? Flexographic printing can provide repeatable, clearly defined graphics at production speed while allowing a compact printing unit to be integrated into an existing manufacturing process.

Is inline printing better than offline printing? Neither approach is automatically better for every application. Inline printing can reduce additional handling and integrate printing into the existing production process, while offline printing may be appropriate for other production models. The right choice depends on the specific manufacturing requirements.

Is retrofitting cheaper than replacing a production line? Not necessarily in every case. The economics depend on the existing machinery, required printing configuration, installation work, production volumes and other factors. The principal potential advantage of retrofit is that productive existing equipment can be retained while adding the required capability.

What should a converter evaluate before a printing retrofit? The key factors include substrate, web width, production speed, print repeat, number of colours, registration, drying, installation space, controls integration, maintenance and artwork-change requirements.

The Strategic Value of Inline Printing in the PPWR Era

The PPWR is more than a change in packaging legislation. For converters, it is also a reason to examine how flexible their production equipment is.

As packaging information and labelling requirements evolve, manufacturers need ways to adapt without unnecessarily disrupting established production processes. For many applications, the answer may not be a completely new production line. It may be an additional capability integrated into the line that already works. Compact inline flexographic printing units can provide that capability by bringing printing directly into the extrusion or converting process.

The benefits can include:

• greater production flexibility;
• reduced dependence on secondary operations;
• efficient application of selected graphics;
• compact equipment integration;
• easier adaptation to changing artwork;
• the potential to extend the useful capabilities of existing machinery.

The strategic objective is therefore simple: Don’t replace productive equipment simply because the production process needs one new capability. Where technically and economically appropriate, upgrade the line instead.

The future of packaging printing is not necessarily about printing more. It is about printing smarter, with greater flexibility and closer integration with the production process.

About Giugni®

For more than 50 years, Giugni® has specialised in the design and manufacture of compact inline flexographic printing machines for extrusion, converting and packaging applications. Giugni solutions are engineered to integrate into new or existing production lines, providing reliable printing performance while maintaining a compact footprint and production flexibility.

For converters evaluating an inline printing retrofit, the first step is to understand the existing production process and define the required printing application. Giugni® can assess the technical requirements and develop an inline flexographic printing solution tailored to the line, substrate and production conditions. Looking to add inline printing capability to an existing extrusion or converting line? Contact Giugni® to discuss your application.

Regulatory sources

This article is based on Regulation (EU) 2025/40 and the European Commission’s June 2026 guidance document. The PPWR itself remains the legally binding source; Commission guidance is intended to support consistent application and may be updated as implementation develops.

Regulation (EU) 2025/40 — EUR-Lex: Read the official PPWR

European Commission guidance — June 2026: Read the Commission’s PPWR guidance. This article provides technical and commercial information and should not be considered legal advice. Packaging manufacturers and converters should assess the PPWR requirements applicable to their specific packaging, products and markets.

Would you like to add inline printing capabilities to an existing extrusion or converting line? Contact Giugni® to discuss your application.

Written by Francesco Giugni – Production Manager | Team Giugni®

Discover Francesco’s other insights into flexographic printing and its applications: Meet the Pocket Rocket: new Miniflex® 540 Superfast – Giugni