Introduction of Environmental Labelling Requirement in Italy

The decree is intended to bring about a joint responsibility of all actors along the supply chain; therefore, any sector operator who places packaging on the market is obligated.

Producers are defined as “suppliers of packaging materials, manufacturers, processors and importers of empty packaging and packaging material”. However, the obligation is also directed at traders, distributors, and fillers.

Manufacturers are required to identify the material type of the packaging with reference to the alphanumeric coding of Decision 97/129/EC.

The physical affixing of the labelling is a shared activity between packaging supplier and user, which operators may find necessary to regulate and formalise through agreements between various parties involved.

• Producers must indicate the material of the packaging. For this the alphanumeric code according to Decision 97/129/EC will be used
• Packaging intended for end consumers must be clearly labelled with appropriate instructions for disposal, including if the materials can be separated by hand. These must be written in Italian. The law recommends using graphics or short text such as “Empty Packaging” to help consumers separate and dispose of waste correctly

The packaging should be labelled according to its predominant material weight. If packaging consists of several materials but the secondary material is less than 5% of its weight, it is classified as single material packaging.

In cases where physically affixing the label directly on the packaging is impossible, the mandatory information is presented through external media such as digital channels, websites, accompanying documents to packaging or external labels.

Producers can also apply alphanumeric coding and labelling through QR codes.

The new environmental labelling requirements apply to primary, secondary and tertiary packaging. The alphanumeric codes for identifying materials must be applied to both B2B (Business to Business) and B2C (Business to Consumer) packaging.

However, information regarding the correct disposal of the packaging is mandatory for packaging intended for final consumers only.

From 30 June 2022 all packaging, unless exempt, must be marked with an alphanumeric code to identify the materials. Information on the correct disposal must also be provided by this deadline.

Packaging already in circulation may continue to be distributed without the new labelling. However, this exemption only lasts until the existing stock is used up.

Anyone who places non-compliant packaging on the Italian market can be held accountable. In the case of missing or incorrect labelling, fines ranging from €5,200 – €40,000 can be imposed.