Labeling of packaging in Italy
From January 1, 2023, packaging must be properly labeled in Italy. This regulation is based on the Legislative Decree of September 3, 2022 (116/220) which transposes the Waste Framework Directive and the EU Directive 2018/852 on packaging and packaging waste (which in turn amends the Packaging Directive 94 /62/EG ) into Italian law.
The actual application of the obligations by the manufacturers and distributors is commented and described in detail in a guide from the packaging consortium CONAI:
In any case, we recommend that our customers consult these documents again before implementing them in-house. An English, German and Spanish language version is also available in addition to the original Italian version.
The key obligations are:
a) on all packaging (without distinguishing between primary, secondary or tertiary), all producers must indicate the alphanumeric code, which can be found in Annex 1 of Commission Decision 97/129/EC for the respective packaging https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:31997D0129&from=EN
b) the marking must indicate the family of materials. If the codes of Decision 87/129/EC are not sufficient for this (especially in the case of plastic packaging made with polymers or a combination thereof), the UNI 1043-1 standards can be used.
c) the labeling should be "reasonable". Here each user has a certain leeway in terms of the way that appears "suitable" and "effective".
d) all materials that can be separated by hand must be marked. For composite materials there is a 5% rule above which a substance is considered a substance in its own right.
d) instructions for separate collection of waste must be shown on packaging intended for end users.
e) The manufacturer (producer) of the packaging is initially responsible for the labelling, but responsibility must be ensured down the supply chain. Therefore, distributors, dealers and importers of packaging are also obligated. Information about the types of packaging may also be provided via digital channels, such as websites, if it is too difficult or impossible to physically attach the label. (see instructions from CONAI:
From January 1, 2023, stock that is not yet marked can be sold off.
On January 26, 2023, the Ministry of Environment and Energy Safety published an statement communicating that the obligation for environmental labeling of packaging, pursuant to article 219 paragraph 5 of Legislative Decree 152 of 2006, does not apply to products for which an obligation already exists for energy efficiency labeling in accordance with the provisions of Regulation (EU) 2017/1369. According to the Ministry, this includes specific products such as car tires and electrical and electronic equipment in particular.
The statement is available in Italian via the following link.