For some types of packaging, it can be extremely difficult, if not impossible, to affix the complete environmental labeling (for example, small-sized packaging or packaging with limited spaces, those for which the manufacturer may encounter technological difficulties in affixing the identification code of the material on the packaging, the multilingual ones, or those of import).
For some of these cases, the Ministry of Ecological Transition clarified, with a note issued on May 17, 2021, that, given the objective criticalities underlying the physical affixing of environmental labeling to packaging, the obligation is considered fulfilled if the mandatory information provided for by paragraph 5 of article 219 of the TUA, is conveyed and communicated through digital channels (such as App, QR code, barcode, etc.), and if it is not possible even through these tools, make it available through websites.
The note also clarifies that in general, it is allowed to privilege the use of digital tools in order to fulfill the obligation of environmental labeling of packaging (eg. App, QR code, websites), in line with the process of technological innovation and simplification. , moreover fundamental aspect foreseen within the National Recovery and Resilience Plan (PNRR).
To make the mandatory environmental information about the composition and – in the case of packaging intended for the final consumer – the correct management of the packaging at the end of its life more easily available and consultable, it is suggested to provide clear indications on the packaging or at the point of sale, regarding the methods by which the consumer can search for them through digital tools or websites.
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