The text of the law explicitly indicates that all packaging (B2B and B2C) bears the identification of the materials by decision 129/97 / EC. Packaging intended for final consumers must also include indications on the correct collection. CONAI suggests clearly indicating the prevailing material family packaging (according to which the packaging is given in correct collection), preceded by the indication “Collection”, or accompanied by “Separate collection”.
However, the law requires that all packaging be appropriately labeled, therefore in the form and in the freely chosen graphic and presentation methods, as long as they are effective and consistent with the objectives set out in art. 219 paragraph, 5.
The standard does not provide specific indications regarding the graphics, colors and dimensions of the labeling.
If you want to adopt colored labeling, CONAI suggests the use of the colors coded by the UNI 11686 standard – Waste management – Waste visual elements – Visual identification elements for the containers for the collection of urban waste.
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 art 219 of the TUA, is conveyed and communicated through external media (in the case of neutral packaging), or digital channels (such as App, QR code, bar code, etc.), and if this is not possible not even through these tools, make them 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.
Last modified on 19/11/2021