Extended Colour Gamut Printing and the PPWR: What a Fixed Ink Set Changes
Does the PPWR Require or Prohibit Extended Colour Gamut Printing?
Neither. Regulation (EU) 2025/40 contains no provision that requires or restricts a printing process or the number of inks on a job. Extended colour gamut printing is a production choice. What the Regulation governs is the printed packaging itself: its substances under Article 5, its recyclability under Article 6, and the technical documentation behind the EU declaration of conformity.
The choice concerns two parties: the brand owner who specifies the colours, approves the artwork and signs the EU declaration of conformity, and the label or flexible-packaging converter who runs the press.
Key Facts
- Under Article 6(1), all packaging placed on the market shall be recyclable, an obligation that has applied since 12 August 2026, transport packaging included.
- Under Article 5(4), the sum of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components must not exceed 100 mg/kg.
- The Article 6(4) delegated act is due by 1 January 2028 and has not been adopted.
- Under Article 6, the A/B/C grades become binding on 1 January 2030, or later if the delegated act is delayed.
- The four statements above, and the Article 5(4) component rule quoted below, are confirmed by our dated PPWR referential (baseline reviewed 15 September 2026); every other regulatory statement is read on the linked text and listed in the section on what the referential does not confirm.
What Is Extended Colour Gamut Printing?
Extended colour gamut (ECG) printing is a printing method that uses one fixed set of process inks, typically cyan, magenta, yellow and black plus orange, green and violet, to build most brand colours from screened combinations instead of printing each one with its own spot ink. A spot colour is a colour printed with a dedicated, premixed ink.
Veoria, from the same group as Rutherford, the publisher of PPWR Connect, develops inline colour measurement for label and packaging presses. Its article of 10 September 2026, Extended color gamut lives or dies on process control, describes the method as a way to "replace the spot-ink carousel with a fixed set" and "build most brand colors from combinations that never leave the press".
What Does a Fixed Ink Set Change on the Press?
Mainly the changeovers. Veoria writes that "the economics of ECG are changeover economics": every spot colour that becomes a screened combination of the fixed set "is a washup that does not happen, a scheduling constraint that disappears, and an ink inventory line that closes". The saving depends on the job mix, and no source we can cite gives a figure.
Veoria also lists fewer ink changes, shorter makereadies and no one-job spot inks left on the shelf. A makeready is the set-up phase in which a press is brought to colour and register before saleable production, and the substrate printed during it is usually discarded. Fewer makereadies mean fewer occasions for that waste, which no source we can cite quantifies. Any environmental gain sits in the plant: fewer wash-ups, fewer one-job inks, less spoiled substrate.
The price is process control. According to Veoria, a drifting spot ink ruins its own colour, whereas in ECG "a density drift in a single channel moves every color that contains it". Veoria's first prerequisite is reference data: spectral targets for the seven inks and for every converted brand colour, "with the tolerance defined on the brand color, not only on the channel". That tolerance is the brand owner's decision; holding seven channels to it at production speed is the converter's.
What Does the PPWR Say About Inks?
Regulation (EU) 2025/40 names inks in three places: recital 13, the definition of composite packaging in Article 3(1)(24), and Table 4 of Annex II, which lists inks and lacquers, printing and coding among the parameters for the design-for-recycling criteria. None of the three prescribes or forbids a printing method or an ink set.
Recital 13 states that inks applied directly on a product should not be considered to be packaging, while labels hung on or affixed to a product should. Article 3(1)(24) leaves labels, varnishes, paints, inks, adhesives and lacquers out when deciding whether a packaging unit is composite packaging. Table 4 of Annex II adds: "The use of inks with substances of concern hinders recycling, as those packaging units cannot be recycled. Printing inks when released can contaminate the recycling stream through the washing water. Likewise, printing inks which are not released can impair the transparency of the recycling stream."
Is the Ink Part of the Packaging Component for the 100 mg/kg Limit?
In practice, yes, on our reading. Under Article 5(4), the 100 mg/kg limit on the sum of lead, cadmium, mercury and hexavalent chromium applies in the packaging or in any packaging component, and concentrations are never added up across components. A printed ink film is part of the label, sleeve or film that carries it.
The Regulation does not settle the point in a definition. Article 3 gives "packaging component" no definition of its own: within Article 3, the term appears only inside the definitions of integrated and separate components, points (43) and (44). Our reading is that the limit is met, or not, in the printed component, ink included, not in the ink as delivered; the referential does not confirm it.
Under Article 5(6), compliance with the heavy-metals limit of Article 5(4) and the PFAS limit values of Article 5(5) is demonstrated in the technical documentation drawn up in accordance with Annex VII. An ink maker's declaration speaks for an ink, while the limit speaks for the printed component: the declaration is an input to that demonstration, not the demonstration itself. Our article on Article 5 substances of concern describes the rest of the file.
How Does a Smaller Ink Set Change the Evidence File?
A smaller ink set shortens the list of sources to document, as a practical consequence rather than an obligation. Every distinct ink printed on a component is one more input the Article 5 demonstration has to cover, per supplier and per version. A fixed set of seven process inks, used across a portfolio, lets the same declarations serve many references.
| Question for the file | Spot-colour printing | Fixed ECG set |
|---|---|---|
| Inks to document | The process inks, plus one ink per spot colour | The seven inks, plus colours out of reach and varnishes |
| New brand colour in the artwork | A new spot ink, unless an existing one matches | A new combination of documented inks, if within reach |
| Reuse of declarations | Limited to the inks that references share | Every job printed with the set |
| Change of one ink | Touches the references printed with that ink | Touches every reference printed with the set |
The last row is the other side of the gain: a fixed set concentrates the evidence as it concentrates process control. Under Article 3(1)(13)(a), where a person has packaging designed or manufactured under its own name or trademark, that person is the manufacturer, subject to the micro-enterprise case of point (b). Under Article 16(1), suppliers shall provide the manufacturer with all the information and documentation necessary to demonstrate conformity, including the technical documentation referred to in Annex VII.
A converter delivering printed labels or pouches to a brand owner is such a supplier under Article 3(1)(16). Our article on supplier declarations sets out what counts as usable evidence.
Does Extended Colour Gamut Printing Make Packaging More Recyclable?
No provision of Regulation (EU) 2025/40 rates extended colour gamut against spot colours for recyclability. The design-for-recycling criteria that settle how inks weigh on a recyclability grade belong to the delegated act of Article 6(4). The Article 6(4) delegated act is due by 1 January 2028 and has not been adopted.
The text fixes the frame of those criteria, not their content. Under Article 6(4), point (a)(ii), the design for recycling criteria shall cover all packaging components. Under Article 6(4), point (a)(v), the design for recycling criteria shall, where appropriate, impose restrictions on the presence of substances of concern in packaging or packaging components for reasons not relating primarily to chemical safety.
ECG changes the number of inks, not necessarily their chemistry or their behaviour in a recycling wash, the two properties Table 4 of Annex II describes for inks. Under Article 6, the A/B/C grades become binding on 1 January 2030, or later if the delegated act is delayed. Our article on recyclability grades A, B and C explains how to read a grade shown today.
How Can a Documented Ink Set Help When the Article 6(4) Criteria Are Adopted?
A smaller, documented ink set is easier to re-assess when the Article 6(4) criteria are adopted. Under Article 6(3), the manufacturer shall assess packaging recyclability on the basis of the delegated acts of Article 6(4) and the implementing acts of Article 6(5). Each ink is one input, and a shared set keeps that number fixed as the portfolio grows.
Three provisions describe how restrictions can be added, without fixing their content. Under Article 5(2), the Commission, assisted by the European Chemicals Agency, shall prepare by 31 December 2026 a report on the presence of substances of concern in packaging and packaging components. Article 5(2), point (b), names the establishment of restrictions as part of the Article 6(4) design for recycling criteria as a follow-up measure for substances of concern that negatively affect the re-use and recycling of materials. Under Article 5(7), the Commission may adopt delegated acts to lower the 100 mg/kg sum of lead, cadmium, mercury and hexavalent chromium. None of these provisions names an ink or a pigment.
A switch to ECG is itself a change to the packaging. Under Article 15(4), manufacturers shall adequately take into account changes in packaging design or characteristics and, where conformity could be affected, carry out a re-assessment. Documenting the new set once, before the first production run, avoids rebuilding the evidence reference by reference. See our article on what applies now and what waits on a delegated act.
Is Reducing Makeready Waste a PPWR Obligation?
No. The packaging waste prevention targets of Article 43 bind Member States: each Member State shall reduce the packaging waste generated per capita, compared with 2018, by at least 5% by 2030, 10% by 2035 and 15% by 2040. No provision of Regulation (EU) 2025/40 sets a makeready or spoilage target for a printer or a brand owner.
Under Article 3(1)(25), packaging waste means any packaging or packaging material that is waste, with the exception of production residues. On our reading, substrate spoiled at the press is a production residue and falls outside that definition; the referential does not confirm the reading. Cutting makeready waste remains a cost and environmental decision for the plant.
What Does the Referential Not Confirm?
Our dated PPWR referential (baseline reviewed 15 September 2026) confirms the Key Facts and the Article 5(4) component rule. Its claim check returned no match for the following statements, which are read on the linked text and presented as such, not as verified facts.
- The absence of any provision on printing processes, ink sets, makeready targets or tests per ink, the three places where the Regulation names inks, and the absence of a definition of packaging component in Article 3.
- Our two readings: a printed ink film counts in the concentration of its component, and makeready spoilage is a production residue.
- Article 3(1)(13), (16), (24) and (25), Articles 5(2), 5(6) and 5(7), Article 6(3), Article 6(4), points (a)(ii) and (a)(v), Article 15(4), Article 16(1), Article 39(2), Article 43(1), Table 4 of Annex II and Annex VII, as phrased here.
- Everything about ECG on press, attributed to Veoria: the referential covers the Regulation, not printing.
Frequently Asked Questions
Does switching to extended colour gamut require a new EU declaration of conformity?
Not automatically. Under Article 15(4), the manufacturer re-assesses where a change in packaging characteristics could affect conformity, and under Article 39(2) the EU declaration of conformity is continuously updated. Whether a new declaration is needed is answered reference by reference.
Does each ink of an extended colour gamut set have to be tested for heavy metals?
Regulation (EU) 2025/40 sets the heavy-metals limit on the packaging or the packaging component, not on the ink. No provision of Regulation (EU) 2025/40 requires a heavy-metals test for each ink. Annex VII lists test reports among the elements of the technical documentation, wherever applicable.
How PPWR Connect Helps
PPWR Connect keeps the ink question on the packaging reference and its components. Each SKU carries its components and materials, and a label, cap or liner defined once in the shared component library is reused across SKUs. PPWR Connect does not measure colour and does not choose inks.
For each packaging component, heavy metals, PFAS against the Article 5(5) limit values, substances of very high concern and bisphenol A can be declared, each with its source and supplier evidence. Supplier documents such as test reports and datasheets are filed as evidence against the SKU for the declaration of conformity. Dated packaging versions keep the before and the after of an ink change, and the Impact screen lists the declarations of conformity a data change touches. Start with our PPWR compliance software or the PPWR readiness assessment.
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Rutherford (rutherford.fr) develops production control software for offset printers and converters, including ColorLoop. Veoria (veoria.com) develops inline colour measurement for label and packaging presses, including DeltaOne.