In the case of packaging in which it is difficult / impossible to apply environmental labeling (also for reasons related to HACCP), can it be remedied in any way?

Neutral packaging means unprinted packaging that does not include graphics or the affixing of any symbols and information, and which are sold as such to customers by the manufacturers.

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, two particular cases are made explicit:

  • Neutral packaging in general, with particular reference to transport packaging and / or possible semi-finished products.

The note defines that given the critical issues encountered by operators, both 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.

  • Pre-wrapping and variable weight distribution packaging

The pre-wrapped items are defined by the circular of 31 March 2000, n. 165 of the then Ministry of Industry, Commerce and Crafts published in the Official Gazette no. 92 General Series of April 19, 2000, refers to variable weight packaging, often used at the fresh counter or for self-service and which are finalized once the food product is contained.

Also for this case of packaging there are objective difficulties for the physical affixing of the environmental labeling of the packaging: it could in fact be packaging intended for fresh food products (e.g. fish products) that cannot be printed, it is about packaging whose intended use is not known with certainty at the time of production and sale (i.e. whether it will be packaging or products intended for domestic use), in others it is packaging prepared / cut to measured at the point of sale (eg aluminum or plastic film), and therefore not susceptible to immediate printing.

With the aim of overcoming these critical issues, the Ministry of Ecological Transition clarified, with reference to the note sent on May 17, 2021, that for these cases the labeling obligation is considered fulfilled if the information regarding the composition of the packaging pursuant to decision 129/97 / EC and the information to support the consumer in the correct separate collection, can be inferred from information sheets made available to end consumers at the point of sale (e.g. next to information on allergens, or with specific information sheets placed next to the Banco), or by making this information available on websites with predefined standard cards.

Last modified on 19/11/2021

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