When does the labelling requirement come into force?

On May 21, 2021, the conversion law no. 69, of the decree law 22 March 2021 n. 41, so-called DL Sostegni.

The changes made in the process of converting the decree also include the suspension of the obligation of environmental labeling of packaging until 31 December 2021, as well as the possibility for sector operators to market products without the new environmental labeling requirements. already placed on the market or already labeled while stocks last.

In particular, paragraph 1-ter is added to article 39 of the decree, which provides that “Until 31 December 2021 the application of article 219, paragraph 5, of the legislative decree 3 April 2006, n. 152. Products without the requirements prescribed therein and already placed on the market or labeled on 1 January 2022 can be marketed while stocks last“.

Therefore, for all packaging, the suspension of the labeling obligation (the obligation to identify the packaging materials according to Decision 129/97 / EC, and to indicate the correct management at the end of life of the packaging intended for the final consumer), is extended until 31 December 2021. In addition, companies in the sector will have the opportunity to market products without environmental labeling requirements that are already on the market or that are already labeled as of January 1, 2022, while stocks last.

Entry into force of the obligation: the chronology of the measures

Following the entry into force of the environmental labelling requirement for packaging on 26 September 2020, Confindustria and many other Associations have urgently proposed a transitional regime of eighteen months to allow packaging producers and users to adapt their production and management processes to the new obligations laid down by the regulations. This necessity had also been mentioned in CONAI’s Guidelines for the environmental labelling of packaging.

On 31 December 2020, the decree law of 3 December 2020, n. 183, so-called “ Milleproroghe 2021“, Whose paragraph 6 of article 15, had provided for the suspension, until 31 December 2021, of the sole obligation to affix on the packaging intended for the B2C channel the indications for the correct disposal in separate waste collection, while the suspension was not foreseen of the obligation to affix on the packaging the alphanumeric identification code of the material as per Decision 129/97 / EC (already in force from 26 September 2020).

The companies and associations in the sector, together with CONAI, immediately reiterated the need for the suspension of the entire labeling obligation, as the issue of warehouse stocks was very relevant for companies, both in terms of economic, both in environmental terms, as the large quantities of obsolete packaging, as they do not comply with the standard, could not have been marketed.

The response of the institutions came with the publication in the Official Gazette on 21 May 2021 of the conversion law no. 69, of the decree law 22 March 2021 n. 41, so-called DL Sostegni.

Last modified on 21/11/2021

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