The regulations do not exclude such packaging from the obligation. However, for some of these cases, important technological limitations have been identified that may not allow the physical affixing of environmental labeling on the packaging.
In this regard, in the clarification note sent by the Ministry of Ecological Transition on May 17, 2021, it is made clear that for neutral packaging in general, with particular reference to transport packaging and / or possible semi-finished products, given the critical issues encountered by operators, economically and structurally, in meeting this obligation, it is necessary to consider a possible alternative to the traditional labeling to be affixed to the packaging itself. Therefore, for these packaging, which are mostly part of the B2B channel, the identification of the packaging material can be conveyed and communicated by the manufacturer on the transport documents accompanying the goods, or on other external media, including digital ones.
Packaging intended for B2B must obligatorily re-code the composition materials in accordance with Decision 129/97/EC. All other information is voluntarily applicable.
In the case of wooden packaging, reference is made to Annex IV of the decree 129/97 / EC which provides for the identification code of the material: FOR 50.
It should be noted that the environmental labeling can be affixed / printed / imprinted directly on the packaging, or on a support if it is provided in the packaging system.
In these cases, the environmental labeling must be shown on the finished packaging, not necessarily on each semi-finished product that will make up the packaging; unless they are components made of different materials than the main body.
Last modified on 19/11/2021