Should the packages intended for the final consumer made up of bottles of less than or equal to 125 ml have the environmental labeling or are they excluded?

The standard does not provide for any exemption for packaging of small dimensions, and / or with reduced printed space, nor for multilingual ones, nor for those imported.

However, for these cases there are often operational difficulties in foreseeing the physical affixing of environmental labeling on the packaging, in particular for small-sized packaging, for which, if contained in a multipack, the way could be to affix environmental labeling on presentation packaging, but when they are sold in bulk, there may be physical limitations for affixing environmental labeling, and / or difficulties in the visibility and legibility of the information.

In this regard, with a note dated May 17, 2021, the Ministry of Ecological Transition clarified that where there are actual physical and / or technological limits for the physical affixing of environmental labeling on the packaging, such information can be conveyed through digital channels.[1] , or where even this route is not feasible, they must be made available through the websites of the company and / or the retailer.

To make the mandatory environmental information about the composition and correct management of packaging at the end of its life more easily available and accessible to the final consumer, 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.

Being packaging intended for B2C, pursuant to art. 219 paragraph 5, they must submit:

  1. The packaging material’s identification code under Decision 129/97/EC
  2. Collection guidelines. We suggest using the wording “(Material family) collection” and inviting the consumer to check their local municipal guidelines.

All other additional information is voluntarily applicable.


[1] In this regard, it should be noted that in general the use of digital channels is particularly encouraged by the explanatory note sent by MITE on 17 May 2021 (see FAQ no. 16 on digital channels).


What does small packaging mean?

The standard does not provide for a univocal definition of small packaging, however in the note released on May 17, 2021 by the Ministry of Ecological Transition, the definitions of small packaging already used by the Legislator in Regulations of specific supply chains, such as food and hazardous substances. These Regulations define the small packaging as follows:

  1. Packaging in which the largest surface is less than 25 cm 2 – definition taken from Regulation (EU) No. 1169/2011, which indicates the obligation to carry the nutritional declarations of the products contained on the food packs and which provides for the possibility of exempting small-sized packaging thus identified from the obligation;
  2. Packaging with a capacity not exceeding 125 ml – definition taken from the CLP Regulation (Regulation (EC) No. 1272/2008, Article 29 paragraph 2 and Point 1.5.2 of Part I of Annex I), which provides that substances classified as dangerous, and contained in a package, are provided with a label containing specific elements , and considers some exceptions to this obligation precisely for the small packaging thus identified.

Last modified on 19/11/2021

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