A pack may be designed once, but it is read in every market where the product appears. The recycling instruction on the carton, the information behind a QR code and the documents an authority may request all need the right language, audience and version.
Regulation (EU) 2025/40 on packaging and packaging waste was published on 22 January 2025 and entered into force on 11 February 2025. It generally applies from 12 August 2026, with several labeling duties on later schedules.
It changes the framework for packaging itself, while making the information that travels with packaging an important part of any multilingual launch. Read the Regulation on EUR-Lex ↗
Four language tracks to plan together
1. Labels, sorting information and digital content
Article 12 provides for a harmonized label explaining material composition to help people sort packaging. Its start date is 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later.
The rule is based on understandable pictograms; a reusable pack has a separate later labeling timetable. These are future stages, not a new universal label due in February 2025.
Under Article 12(5), information in the relevant labels and QR codes or other open digital carriers must be available in one or more languages easily understood by end users, as determined by the Member State where the packaging is marketed. The same information must be available before purchase in online sales.
Digital compliance information should be kept distinct from sales and marketing material. For a launch team, that means checking the physical pack, the online product page and the QR destination as one connected experience.
2. The EU declaration of conformity
The manufacturer’s conformity process involves technical documentation under Annex VII and an EU declaration of conformity following the model in Annex VIII. Article 39(2) expressly requires the declaration to be drawn up in, or translated into, one or more languages required by the Member State where the packaging is placed or made available on the market.
A single English master file may therefore be useful for coordination, but cannot be assumed to meet every destination market’s language requirement.
3. Technical evidence across the supply chain
Article 16(1) requires suppliers to provide the manufacturer with the information and documentation needed to demonstrate conformity in a language the manufacturer can easily understand.
Under Articles 15(10) and 18(8), manufacturers and importers must provide the relevant conformity information and technical documentation, upon a reasoned request, in a language or languages easily understood by the requesting national authority.
This is a different audience from the shopper reading a sorting label. Material specifications, test evidence and regulatory terms need consistent, traceable wording.
4. Environmental claims that stay precise
A statement such as “recyclable” or “reusable” cannot be translated in isolation from its approved meaning and evidence.
Article 14 addresses claims about packaging properties covered by the Regulation. The claim must concern properties beyond applicable minimum requirements and identify whether it describes a component, the pack as a whole or all packaging placed on the market by the operator.
Legal and product teams should approve the claim and supporting data before local language versions and artwork are released.
What belongs in a multilingual packaging brief?
Begin with a market and packaging map, rather than a word count alone. Give your language team:
- Markets and channels: destination Member States, physical and online routes, and who the end user is.
- Controlled source files: final artwork, label copy, QR landing pages, product pages, declaration templates and technical annexes.
- Approved facts and terms: materials, layers, reusability, collection instructions and substantiated environmental claims.
- Responsibilities: the person who confirms legal requirements in each market, the owner of technical evidence and the reviewer who approves each language version.
- Version control: a record linking each market and packaging format to the released artwork, web content and documentation.
For example, one jar may have a cardboard sleeve, a cap and an online product page. A change to the cap material can affect the sorting message, the source terminology, the QR page and the technical file.
If those files are translated independently, a customer may see one instruction while the evidence describes another. A connected workflow catches the discrepancy before release.
Where translation ends and regulatory review begins
The Regulation does not say that every piece of product marketing or every technical file must be translated into all EU languages. It assigns language requirements to particular information and audiences.
Other rules for the packaged product—such as food, cosmetics, medicines or medical devices—may create additional labeling and information duties. The regulatory owner should determine those requirements; translators and revisers then make the approved information accurate, consistent and usable in each target market.
Legal source: Regulation (EU) 2025/40, Official Journal of the EU ↗, especially Articles 12, 14–16, 18, 39 and 71 and Annexes VII–VIII. The dates above follow the text published in January 2025; the relevant implementing acts and each destination market’s requirements should be checked when preparing release artwork.