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Partial suspension of the environmental labeling obligation for packaging



The environmental labeling of packaging was a matter of discussion in the Milleproroghe 2021 Decree. Specifically, the suspension of the obligation to include information on packaging intended for the final consumer to help the

citizen in the correct disposal of packaging at the end of its life.



The obligation to affix the identification code of the material used on all packaging(primary, secondary, tertiary)remains in force.



What information must the packaging contain?


From the analysis of the Legislative Decree of 09/03/2020, it can be seen how the contents to be reported on the environmental labeling of packaging differ depending on the intended use of the packaging.


Indeed:

- If the packaging is intended for the final consumer, the mandatory contents concern:

  • The alphanumeric coding identifying the material as per Decision 129/97/EC, and the information to support the final consumer in the correct separate collection of the packaging (e.g. Separate waste collection + Family of material. Check the provisions of your Municipality).

- If the packaging is intended for the B2B channel, the mandatory contents concern only the identification coding of the material as per Decision 129/97/EC, < /p>

while it is the pure will of the manufacturer, to include further additional information on the collection.


In summary, every part of the packaging must be identified: for example, if a glass bottle has a cap, capsule and label, which are easily separable, each element must

be identified, in order to facilitate the correct disposal of the materials in question.


What has changed with the new provision?


The decree did not provide for the suspension of the obligation to affix the alphanumeric coding identifying the material on packaging as per Decision 129/97/EC, in force since 26 September 2020. Therefore all packaging (primary, secondary, tertiary) must provide such coding. Regarding the affixing of the identification codes of the material, the obligation is expressly incumbent on the producers.


The obligation to affix indications for correct disposal in separate waste collection on packaging intended for B2C channels is suspended until 31 December 2021. For this reason, companies in the sector will have one year to comply with the obligation and also provide this information on packaging intended for the final consumer.


If you have questions related to the topic and want to find out more, comment below or write us an email.

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