How to report environmental labeling information on the transport documents that accompany the goods (e.g., ddt)?

Pursuant to the legislative decree of 3 September 2020, all packaging (primary, secondary and tertiary) released for consumption in Italy is subject to the obligation of environmental labeling. Packaging intended for B2B must necessarily include the coding of the composition materials in accordance with Decision 129/97 / EC. Every other information, instead, remains voluntary.

In fact, the standard does 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 conveyed by the Ministry of Ecological Transition on May 17, 2021, it is made explicit that for neutral packaging in general, with special reference to transport packaging and/or possible semi-finished products, given the critical issues faced by operators, both economically and structurally, in meeting this obligation, it is necessary to consider a possible alternative to traditional labeling to be placed on 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.

The standard does not provide precise guidance regarding the graphic style or form in which to convey environmental labeling information, but recommends that packaging be appropriately labeled, with a view toward achieving the objective, then that mandatory information be provided, which for transport packaging concerns only material identification coding.

Last modified on 04/10/2023

The contents of the labeling