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Artwork Management

What Regulatory Affairs Must Check Before Approving Seasonal or Limited-Edition Artwork  

Gouri Sasidharan headshot

Written by Gouri Sasidharan

Content Specialist, Esko

Holidays are around, and one thing hard to miss is the Starbucks themed holiday cup.

For brands, seasonal and limited-edition packs are one of the most exciting projects to work on, such as customized Christmas packaging for your favorite cosmetics, personalized Diwali chocolate wrappers, limited editions of Star Wars cereal boxes, summer refresh editions, and more. They’re designed to delight, stand out, and tap into a seasonal storyline.

But behind the shimmer is a harsh truth: these SKUs are risk magnets.

They’re fast-moving, heavily marketing-led, and often built on top of an existing base of SKUs. And that’s exactly why errors slip in — outdated ingredient lists, old claim icons, text squeezed into decorative layouts, and panels misplaced on unfamiliar dielines.

Regulatory Affairs teams already run on tight bandwidth, so when a last-minute festive SKU lands in the inbox, it often means firefighting mode.

What Typically Goes Wrong in Seasonal or Limited-Edition Artwork

What makes seasonal SKUs especially tricky is that they’re rarely built from scratch. They’re almost always variations of existing products that are expected to follow the same regulatory rigor as a full-time SKU.

Seasonal projects usually start as hopeful emails like:
“Just a small fall edition with minimal changes. Need approval today.”
And from there chaos begins.

Reuse of Old Ingredient Decks

Teams often take last year’s festive file, add new design flair, and forget that the base SKU went through a formulation update in March. So, the artwork now proudly carries an ingredient list that belongs to the archives. It’s like giving your product a throwback moment no one asked for, and it’s definitely not compliant.

Obsolete Icons and Declarations

Your design folders tend to have collections of brand assets, including outdated cruelty-free icons, obsolete vegan badges, or a recyclable logo that is quietly retired. A new designer might drag and drop them without realizing they’re technically extinct. Regulatory affairs usually discover this when they have a deja vu moment and ask themselves, “Why does this look so familiar?”.

Decorative Layouts Breaking the Hierarchy

Festive packs come loaded: mandalas, glitter strokes, snowflakes, fairy lights, and the poor ingredient list gets 1.5pt font size and a gold-on-gold treatment. Good luck spotting the allergens through the sparkle.

Misplacement or Missing Mandatory Panels

New shapes or pack formats like hampers, tins, or cylindrical boxes almost guarantee some shifts. Nutrition panel on the wrong side, address block under a flap, MRP box hiding behind a fold (which I have encountered a lot of times); seasonal dielines are the Bermuda Triangle for mandatory content.

Conflicts Between Pack Size and Legally Required Information

Mini-packs and promotional SKUs are festive favorites. But as the pack shrinks, something has to shrink with it, and it’s rarely the festive artwork. Mandatory text suffers first. The RA team ends up decoding information that looks like it was printed specifically for ants.

How Regulatory Affairs Reviews These SKUs Today

One festive campaign often means multiple variants such as different colors, formats, languages, or retailer-specific versions, all needing to review. Regulatory teams end up repeating the same checks across artwork that is mostly similar, but not similar enough to skip.

Here’s what actually happens behind the scenes:

Manual Checklist Reviews

Reviewers open the same Excel checklist they’ve been using since forever, such as multiple tabs, cryptic comments, and that one mysterious row labelled “DO NOT DELETE.” They go line-by-line, hoping muscle memory will catch what festive enthusiasm may have broken.

Cross-Checking Across Multiple Files

Regulatory ends up toggling between PDFs, formulation decks, reference claims, and base SKU specs. You might even end up staring at a third file named “Final_Final_v3_Final(UseThisOne).pdf”.

Comparing Text Manually

RA either copy-pastes ingredients into Notepad or cross-checks two PDFs side-by-side, playing a compliance version of “Spot the Difference.” The allergens are the tiny, almost invisible Easter eggs no one wants to miss.

No Centralized Rulebook

Every reviewer has their own unofficial list of “things that always go wrong in festive packs.” None of these lives in a shared system. So, each review gets done from scratch, every single year, for every single variant.

What’s at Stake When Seasonal Artwork Goes Wrong

Seasonal packs may be short-lived on shelves, but errors live long in audit trails, retailer rejections, and consumer shout outs, sorry…call outs.

Compliance Violations

Even if sold for just a few weeks, a seasonal SKU is a proper product with real regulatory obligations. Outdated claims, missing allergens, or incorrect declarations can all trigger legal issues.

Recalls and Reprints

Festive SKUs often get printed in large pre-booked batches. One mistake, wrong icon, or missing line, and everything gets scrapped. And by the time you reprint, the season is over.

Brand Image Impact

Seasonal launches get amplified on social media. When a claim or allergen error surfaces, it spreads far faster than in regular SKUs.

Retailer/Distributor Friction

Missing MRP boxes, incorrect pack declarations, or tiny mandatory text often get blocked at Quality Check checkpoints. Nothing kills festive momentum like a shipment stuck in sorting.

Lost Creative Investment

It’s the chance of the year for your copywriter or designer to bring that zing to your packaging artwork. It can sometimes get overcarried, and missing one compliance element can derail the entire campaign.

Don’t Skip These Checks: A Regulatory Affairs Checklist for Seasonal & Festive Packs

Here’s your go-to list of things to tick off before signing off on festive or limited-edition packaging. Think of it as your compliance radar plus a few extra warning flares for seasonal surprises.

1. Content & Ingredient Accuracy

  • Ingredient list check: Confirm the ingredient deck matches the latest approved formulation. You don’t want old allergens creeping back or last season’s copy-paste.
  • Complete mandatory text: Ensure required declarations (allergens, nutritional info, legal statements) are present and correct.
  • Vet event-specific messaging: Any seasonal claims like “Holiday Edition,” “Festival Special,” or “Limited Availability” are clearly defined and compliant.

Why it matters: Even a tiny typo in ingredient lists or missing allergen info can trigger compliance issues, and seasonal SKUs are just as regulated as year-round ones.

2. Regulatory & Legal Compliance

  • Regulatory required elements: All regulatory head requirements (font sizes, placement rules, symbols, warning statements) are present and legible.
  • Confirm latest claim status: Icons like “vegan,” “cruelty-free,” or “recyclable” are current and applicable to the SKU.
  • Language/localization checks: All required languages and translations meet standards and use accredited phrasing.

Why it matters: Seasonal artwork often uses creative typography and decorative versions of symbols. Make sure your regulatory must-haves didn’t get lost under the sparkle.

3. Artwork Integrity & Technical Checks

  • Version control verified: Your entire team is reviewing the right file.
  • File format & quality checks: PDFs and final print files meet resolution, bleed, trim, and dieline specs.
  • Barcode functionality: Barcodes scan correctly and link to the right product information.

Why it matters: Minor graphic shifts like moving a barcode off the dieline or cutting the nutrition panel into a fold can ruin compliance just as easily as a mislabeled ingredient.

4. Brand & Seasonal Design Consistency

  • Brand elements follow guidelines: Logos, colors, and typography stay true to brand rules even while wearing seasonal themes.
  • Festive elements don’t obstruct legal text: Decorations around mandatory information don’t interfere with legibility or hierarchy.
  • Consistent cross-SKU execution: If you have multiple sizes or formats (gift sets, tins, tubes, and more), design and compliance are consistent across.

Why it matters: Seasonal creativity is fun as long as it doesn’t eclipse the essentials that keep your packaging compliant and recognizable.

5. Seasonal-Specific Checks

  • Verified seasonal claim eligibility: Ensure claims like “Holiday Fresh,” “Festival Fun,” or “Winter Special” aren’t interpreted as unsubstantiated product benefits.
  • Temporary promos & disclaimers added: If the pack is a combo or gift set, check that any regulatory disclaimers (MRP/quantity stack, multi-item declarations) are correctly shown.

Why it matters: Seasonal SKUs often introduce new structural formats, and each format shift means new compliance traps unless you check them off deliberately.

6. Approval & Documentation

  • Documented approvals from all teams: Regulatory, marketing, quality, and manufacturing sign off on the same version before print.
  • Audit trail intact: Every version change, reviewer note, and final sign-off is logged for future audits.

Why it matters: Documentation helps if an auditor asks why a seasonal claim or ingredient list changed at the last minute.

With an AI-powered label compliance tool such as Comply, you can cross all the above-mentioned labeling and branding checkpoints.

How to Set Up Comply Rulebooks for Seasonal SKUs

Comply lets you customize rulebooks that act like a compliance safety net for every Christmas, Eid, Winter, or limited-edition design. Here’s how you can set up your seasonal rulebooks:

1. Start with Your Base SKU Rulebook

Begin by duplicating your existing, everyday rulebook (on Comply) where all the details are added that already check:

  • Mandatory declarations
  • Ingredient lists
  • Nutrition panels
  • Net quantity and price
  • Legal disclaimers

This ensures your seasonal SKU doesn’t accidentally drop a fundamental requirement just because it’s wearing festive decor. Think of this as your compliance backbone.

2. Add Typography Rules for Festive Designs

Festive layouts love to push boundaries, which is great for creativity, and sometimes questionable for legibility.

Your rulebook can enforce a minimum font size and range for every text or copy.

If the designer sacrifices compliance to make room for fireworks, Comply catches it first.

3. Add image checks for icons, logos, and visual claims

Seasonal SKUs are mostly image-heavy, and that’s exactly why image validation matters.

With image checks, ComplyAI can:

  • Detect whether the correct version of the warning symbol or the non-veg symbol is used.
  • Flag unapproved logos or third-party seals.
  • Ensure seasonal illustrations don’t visually imply unapproved claims (e.g., “eco” cues on non-sustainable packs).

You don’t have to rely on visual memory anymore to spot whether that icon is from 2021 or 2025.

4. Set up barcode checks

Barcodes are often treated as an afterthought in seasonal packs until they don’t scan.

Rulebooks can automatically check:

  • Barcode presence on every sellable unit.
  • Correct value, format, and resolution.

This avoids last-minute panic when retailers flag scanning failures during inbound quality check.

5. Add claim eligibility logic

Seasonal packs sometimes tweak formulations or reuse old messaging.

Rulebooks can enforce logic such as:

  • If ingredient X is present, then claim Y is not allowed.
  • If the formulation is unchanged, then claims must match the base SKU exactly.

This removes subjective interpretation from claim approvals.

Once you set up your rulebooks, you can:

  1. Upload your artwork.
  2. Select the seasonal rulebook.
  3. Trigger automated label check.
  4. Review only flagged issues such as missing allergen statements, wrong logo, or typos.
  5. Avoid repeated manual checks across variants.
  6. Leave contextual feedback on the right version where every stakeholder is in loop.

Conclusion

Now we know that with limited timelines, manual checks simply can’t keep up with decorative layouts, reused assets, or shifting dielines across packaging files. With the right guardrails, your seasonal packs can shine without putting RA through a holiday horror story.

Comply helps you cut review time, catch predictable festive errors early, and prevent costly reprints.

To give your regulatory affairs team the compliance confidence they crave, book a demo.

About the Author

Gouri, a content specialist at Esko, loves adding a dash of creativity to everything she writes. She dedicates her craft to creating and optimizing content for clarity and impact. On weekends, you can probably spot her exploring new cafés or at movies.

Gouri Sasidharan headshot