Introduction of Environmental Labelling Requirement in Italy

Ellena Boote, International Account Manager, takes a look at Italy's Environmental Labelling Requirement and what this means for affected businesses.

As a result of Law on.15 introduced on 25 February 2022, there has been an amendment to legislative Decree No.116 which has postponed the implementation of the environmental labelling requirements within Italy for a second time. The new requirements will now enter into force from 1 January 2023 and packaging placed onto the Italian market before this date without the new environmental labelling requirements can now be marketed while stocks last.


The legislative Decree No.116 of 3 September 2020 imposed a strict obligation of environmental labelling standards on participants along the supply chain, making environmental labelling mandatory on all packaging in Italy. Under this the Commission Decision, 97/129/EC requires producers to use alphanumeric codes to indicate the type and quantity of packaging materials used, to help with the identification and classification of packaging.

The aim of the law is to reduce the impact of packaging and its waste on the environment, by using identification codes, to facilitate the reuse, recovery and recycling of packaging whilst providing consumers with information on the correct end-of-life treatment of the waste.


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.

Valpak International Compliance Service

If your business is affected by environmental legislation overseas, Valpak will remove the administrative and resource intensive burden of complying and has a range of services that can be tailored to suit your business’s needs.

To find out more about international environmental legislation and how Valpak can help please call us on 03450 682 572 or complete our online enquiry form.