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14 October 2021

Environmental labeling updates

Environmental labeling legislation will come into force from January 2022

Circular No. 52445 of 17 May 2021 of the Minestry of Ecological Transition has provided some clarifications on the regulation. The Ministry clarifies that in general, the obligation to correctly identify the packaging material falls on the producer and the user, therefore this labelling obligation also falls on the user.

Main clarifications

Shared responsibility between Producer and Unser:
the circular issued by MITE clarifies that "packaging producers are certainly the subjects oblieged to correctly identify the packaging material according to the alpha numeric coding provided by Decision 97/129/EC, being aware of the actual composition of the packaging, whether it is finished or semi-finished, and guaranteeing complete and suitable information in favour of all the subjects of the supply chain, it is necessary to highlight that the information provided for a correct labelling of packaging is very often shared between the producer and the user of the packaging itself, in realtion to its actual use (e.g.: preparation of graphics with contents and form, as well as layout to be printed on the packaging). This modus operandi is regulated by the operators through commercial contractual agreements that define the responsibilities and burdens falling on them in a shared manner".

Neutral Packaging Labelling:

The above-mentioned circular also specifies that "in order to ensure correct environmental labelling also for finished packaging seen directly by producer, which is neutral, without graphics or printing and packaging for transport or tertiary packaging, it is necessary to consider a possible alternative to the traditional labelling to be affixed to the packaging itself. Furthermore, in some of these cases, the packaging may be a simple workpiece for some or all of the production, which will undergo further processing and/or lamination before becoming finished packaging.

In view of the above, the obligation to identify the material of which the packaging is made shall be deemed to have been fulfilled in the case of packaging if the manufacturer enters this information in the transport documents accompanying the goods or on other external media, including digital media".

Specifically, with regard to this type of product, we will provide information on the composition of the material, both on the transport documents and on the relevant data sheets.

The legislation provides for two different labels depending on the intended use of the packaging:

  • If the packaging is used within the production cycle of the companies (BtoB), in the production, processing, movement of their own articles, the manufacturer is obliged to indicate only the composition of the material (HDPE 02 / LDPE 04)
  • If the packaging is intended to be placed on the market to reach the final consumer (BtoC), the producer and the user must indicate both the composition of the material and how it is to be disposed of in separate collection (BAG LDPE 04 - PLASTIC separate collection, che the regulations of you municipality)

Packaging for the Export

The MITE circular specifies that the obligation of environmental labelling derives from the transposition of Community directives, which lay down the principles and leave their implementation to the Member States. This obligation, since it has not yet been harmonised at European level, must be referred exclusively to packaging released for consumption in the national territory, as well as produced, filled and imported in Italy. Pending coordination of the reference regulations, packaging destined for third countries is excluded from the labelling obligation and must therefore be subject to the specific regulations of the country of destination.

We ask for the cooperation of our customers in defining, as early as in the quotation phase, the final use of the products we supply, in order to achieve the correct and appropriate labelling.

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