Updates on environmental packaging labelling

Law Decree 3 December 2020, no. 183 (the so called “Milleproroghe 2021”) was published in the Italian Official Journal on 31 December 2020. Comma 6 of article 15 provides for the suspension of the application – until 31 December 2021 – of the first sentence of comma 5, article 219 of legislative decree no. 152 of 2006 as amended, i.e. “All packaging should be suitably labelled as established in the applicable UNI technical norms and in compliance with the decisions adopted by the Commission of the European Union, to facilitate the collection, reuse, recovery and recycling of packaging, as well as for a correct information to consumers on the final destination of packaging”.

On the other hand, the second sentence of comma 5 of article 219 was not suspended: “Manufacturers have the obligation to indicate the nature of the packaging materials used, based on decision 97/29/EC of the Commission, for the purposes of identification and classification of the packaging”.

The law decree is in force as of 31 December 2020. Therefore, the decree includes no suspension of the obligation to report an identifying alphanumeric code for the material as per Decision 129/97/EC, in force as of 26 September 2020.

All (primary, secondary, tertiary) packaging shall include such code. Reporting these identifying alphanumeric codes on the materials based on Decision 129/97/EC is an expressed obligation of manufacturers.

The obligation to report the indications on the correct disposal for the aim of recycling on packaging intended for the B2C channel was suspended until 31 December 2021.