It should be noted that the labeling obligation as introduced by decree no. 116 concerns packaging released for consumption in Italy, therefore it must certainly be provided in Italian. It is also advisable to check whether any labeling obligations in force in other countries where the packaging is released for consumption are envisaged. Furthermore, it should be noted that the information on collection valid for Italy may not be valid for other countries.
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.
[1] In this regard, it should be noted that in general the use of digital channels is particularly encouraged by the clarification note sent by MITE on 17 May 2021 (see FAQ no. 16 on digital channels).
Last modified on 19/11/2021