Up to which packaging should the environmental label be affixed? Should it be envisaged only for primary and secondary, or should it also be applied to tertiary (transport) packaging?

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 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, 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.

Last modified on 19/11/2021

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