Beverage regulation in Europe 2026: labelling, claims, PPWR, Nutri-Score
European beverage regulation tightened on 5 axes in 2025-2026: labelling, health claims, packaging (PPWR), Nutri-Score V2, and sugar taxes. A poorly prepared file = 3 to 6 months of launch delay, or worse, a product recall. Here is the state of applicable law in 2026 and the points where most brands get tripped up.
1. INCO labelling (EU 1169/2011): the fundamentals
Any beverage marketed in the EU must legibly display: - Sales name (e.g. 'Citrus-flavoured refreshing drink') - Ingredient list in decreasing order - Allergens in bold / underlined (milk, gluten, soya, sulphites > 10 mg/L, etc.) - Nutrition table per 100 ml (energy, fat, saturates, carbs, sugars, protein, salt) - Best-before or use-by date + batch number - Net quantity in ml - Name and EU address of the responsible operator - Storage conditions - Origin if relevant
Minimum font size: 1.2 mm (x-height). For containers < 80 cm², 0.9 mm is tolerated and the nutrition table can be omitted.
2. Nutrition and health claims (EU 1924/2006)
Two distinct families:
Nutrition claims (authorised without an EFSA filing): - 'Sugar free' < 0.5 g / 100 ml - 'Low sugar' ≤ 2.5 g / 100 ml (beverages) - 'No added sugar' (no mono/disaccharide added) - 'Source of [vitamin]' ≥ 15% NRV / 100 ml - 'High in [vitamin]' ≥ 30% NRV / 100 ml
Health claims (only those on the EU Health Claims register): - 'Vitamin C contributes to normal energy metabolism' - 'Magnesium contributes to the reduction of tiredness' - 'Caffeine helps to improve concentration' (only with ≥ 75 mg / serving + mandatory wording)
Forbidden without a validated EFSA dossier: 'detox', 'immunity', 'slimming', 'boost', 'energy' (except under the strict energy-drink framework).
3. PPWR: the packaging revolution rolling out gradually
The Packaging and Packaging Waste Regulation (EU 2025/40), applicable progressively from 2026 to 2030, mandates: - 2030: at least 30% recycled plastic in PET bottles - 2030: all packaging must be recyclable 'at scale' - 2026: ban on single-use plastic packaging for some formats (condiment sachets, hospitality mini-portions) - Harmonised sorting marking mandatory on all packaging from 2028 - Beverage reuse targets: 10% by 2030, 40% by 2040
For beverage brands, the aluminium can remains the best-scored packaging (> 75% recycling rate in the EU). 100% rPET is becoming the standard. Glass keeps its aura but with a carbon footprint to justify.
4. Nutri-Score V2: what changes for beverages
Nutri-Score V2 (applicable since 2024, broader rollout 2026) significantly tightens scoring for sweet drinks: - Pure water remains the only beverage scored A - Sweetened drinks > 4 g/100 ml almost always land in E - Intense sweeteners now penalise the score (previously neutral) - 100% no-added-sugar fruit juices cap at C - Semi-skimmed milk moves from B to C
Nutri-Score is not mandatory but has become a de facto prerequisite for grocery listings in France, Belgium, Spain, Germany, the Netherlands. A brand showing E loses ~30% of listing probability.
5. Sugar taxes: the 2026 map across Europe
About a dozen EU countries apply a sweet-drink tax in 2026: - France: progressive scale by sugar content (€3.07 to €27.17/hl) - United Kingdom (non-EU): Soft Drinks Industry Levy (18 or 24 p/L by tier) - Ireland, Portugal, Spain (Catalonia), Belgium, Hungary, Finland, Norway: varied scales - Netherlands: new tax planned 2026-2027
A brand selling pan-European must map these taxes from formulation onwards. Reformulating to drop a tier can save €0.05–0.12 per can.
6. The regulatory file: pre-launch checklist
To build BEFORE the first industrial run: - Full technical product sheet (quantitative composition, calculated and analysed nutrition values) - Label mock-up validated by a regulatory consultant or specialised firm - Release analysis certificates (microbiology, heavy metals, contaminants) - 12 or 18-month stability test - Notification to the market-launch country if required (food supplements: yes; classic beverages: no) - Allergen file and co-packer HACCP plan - Food-contact material compliance (cans, caps, internal varnishes)
Regulatory consultant budget: €1,800 to €4,500 to validate a complete file. Trivial vs the cost of a recall.
7. DGCCRF and EU authorities: what they enforce in 2026
2025-2026 enforcement priorities: - Unauthorised health claims (the DGCCRF tripled controls since 2023) - French / EU origin of raw materials (misleading claims) - Undeclared or misdeclared sweeteners - Abusive 'natural' or 'no additives' mentions - Upcoming PPWR compliance (first controls 2026-2027)
Sanctions range from warning to product recall + administrative fine (up to €1,500,000 for a legal entity). Reputational risk often exceeds the fine.
FAQ
Is Nutri-Score mandatory on beverages in 2026?
No, it remains voluntary. But it is de facto mandatory to enter grocery retail in most European countries. A brand without a visible Nutri-Score is now suspect to buyers and consumers.
Can I write 'energy boost' on my can?
No, unless you have an EFSA-validated dossier for that specific claim (extremely rare). 'Boost' is treated as an implicit health claim under Regulation 1924/2006. Prefer factual 'with caffeine' plus the authorised concentration claim.
How much recycled plastic must my bottle contain in 2026?
For PET beverage bottles: minimum 25% recycled PET in 2025, 30% in 2030, 65% in 2040 (per PPWR). Thresholds apply on member-state average, not SKU by SKU, but retail buyers already impose 30% minimum.
Who is legally responsible for the compliance of a private-label beverage?
The operator whose name and address appear on the label (article 8 of the INCO regulation). Even if the co-packer manufactures the product, the brand carries full legal responsibility towards consumers and authorities.
Ready to move into production?
Our industrial team replies within 24 business hours: feasibility, MOQ, unit cost, timeline.