Environmental labeling for packaging

Environmental labeling for packaging

GUIDELINES FOR BUSINESSES

Legislative decree dated 3 September 2020 has made environmental labelling compulsory, introducing new rules that need to be clarified. In order to provide companies with useful information on this subject, CONAI had drawn up its own Guidelines and an interactive online tool called e-tichetta.  


Letter from President CONAI

 

There has long been a growing demand for information on environmental sustainability, particularly when it comes to packaging.

As far back as 1997, when this issue was not so “fashionable”, the European lawmakers had already set up an environmental labelling system for packaging, and this, although voluntary, was adopted by most companies.

Recent regulatory developments have made environmental labelling mandatory, but this has raised many doubts of interpretation as to what information the labels should in fact contain.

Over the years, CONAI has developed unique experience in sustainable packaging design. Through collaboration with its member companies, over ten years ago the Consortium kicked off  Pensare Futuro, a container of tools, guidelines and initiatives dedicated to this issue.
This project resulted, among other things, in Epack, CONAI’s information desk on sustainable packaging design, which has been offering companies significant support since 2013.
Increase in demand over the last year has led CONAI to start working on its  e-tichetta tool, dedicated exclusively to the environmental labelling of packaging so as to share its long-standing experience in this field.

The hope is that these Guidelines and the  e-tichetta tool may clarify any doubts over the interpretation of the new regulations and direct companies towards their correct application.
The document clearly identifies the information to be reported on the environmental label, along with practical examples arising from the experience of numerous companies.

Given the above, I have considered it important to make these  Guidelines  available for public consultation.
More than 300 users have registered for the public consultation platform  Design for Recycling , which has received over one hundred comments.
More than 1000 emails have been sent by companies and associations through the  epack channel, asking us to handle certain issues, requesting clarifications, and highlighting the various problems this new obligation has generated.
Such feedback has helped to make the document more comprehensive and complete.

But in addition to the  Guidelines  and the  e-tichetta tool, I also think it is important to create fertile ground for a virtuous contamination of good practices - which is why we are pursuing our  call to action  aimed at collecting and promoting virtuous environmental labels, so that they can be an example and inspiration for all companies, especially small and medium-sized ones.

To conclude, I would like to thank all those who have worked to produce this document, with competence and commitment.

 

Luca Ruini
President of CONAI


Letter from the President of the Italian Institute of Packaging

 

The Law introducing the obligation to affix an environmental label on all packaging is undoubtedly positive for consumers and for the environment, as it defines the structure of the packaging and its management of the end of its useful life.

Packaging is crucial to preserving, protecting and making products available, but it is also a vehicle of valuable information for the consumer: it indicates the shelf life and expiry date of the product, its composition, ingredients and allergens, the correct method of storage and use, and other useful information. 

The time frame and manner in which the European Directive has been transposed by our Government have proved a considerable problem for companies in this sector, who have had to adapt or are striving to adapt very quickly.

In particular, several doubts of interpretation over the new regulations have made it even more difficult for the industry’s players to understand clearly what information is to be reported on the label.

To meet this urgent need for clarity, CONAI has drawn up these guidelines on the new labelling procedure. The Italian Institute of Packaging has contributed its regulatory experience to the drafting of this document. It has been a real honour for the Institute to participate in this project, carried out in the spirit of sharing competencies with a view to obtaining as coherent and unambiguous an interpretation as possible, to be submitted to all the companies and institutions concerned.

The Italian Institute of Packaging works alongside packaging companies specialising in every product category and market, providing legal advice, technical training and continuing education courses, as well as disseminating information on raw material market dynamics.

We have set up a Commission for the Environment, which has drawn up a practical guide to reducing environmental impact, and last year we also established a Sustainability Commission, which works closely with CONAI to help resolve any doubts in the interpretation of the Law.

We believe we have taken the right approach, identifying solutions to these doubts and providing clear indications so that companies may address the central issue of providing consumers with the information that will allow them to act in the best interests of the environment.

We have long been concerned with issues such as environmental sustainability, the circular economy, respect for the environment, and achieving a positive packaging culture through sustainable packaging design.

Because the choices we make as individuals affect the community as a whole, and taking care of the future means making the right choices, today.

 

Anna Paola Cavanna
President of the Italian Institute of Packaging


Introduction

 

On 11 September 2020, issue no. 116 of the Official Journal of the Italian Republic published Legislative Decree no. 3 of September 2020, which implements EU Directive 2018/851 on waste and EU Directive 2018/852 on packaging and packaging waste.
Art. 3, paragraph 3, letter c) of said decree introduces amendments to art. 219, paragraph 5 (Criteria inspiring the management of packaging waste) of Legislative Decree no. 152 (“Environmental regulations”) dated 3 April 2006, as updated and amended.
The wording of the labelling requirement introduced by the new regulations leaves room for interpretation, particularly as regards the content of the labels, the parties to whom the obligation applies and its scope, as well as generating great concern among companies as to the time frame granted in which to comply with the obligation.
It is for this reason that CONAI, in collaboration with the Italian Institute of Packaging, has organised a working table tasked with analysing and managing the numerous reports made by individual companies and associations of producers and industrial/commercial users, with the involvement of UNI, Confindustria and FederDistribuzione, with a view to obtaining a clearer reading of the new obligation imposed at the national level. As a result of this meeting, the document entitled “Environmental labelling of packaging” was drawn up. This guide aims to offer a clearer interpretation of the regulations, enabling companies to resolve their main doubts and address the main problems relating to the application of art. 219, paragraph 5. These Guidelines will continue to be updated with any further clarifications that should arise in the coming months.
CONAI has also developed a tool, made available through its website, entitled e-tichetta. This support tool has been designed to help businesses create their environmental labels independently. Moreover, it allows users to simulate different, recommended labelling models based on the specific needs of the company and its products.

Approach to environmental labelling

Legislative Decree no. 116 of 3 September 2020 states that all packaging shall be “appropriately labelled in accordance with the procedures laid down in the applicable UNI technical standards and in compliance with the decisions of the European Commission, in order to facilitate the collection, reuse, recovery and recycling of packaging, and to provide consumers with proper information on the final destination of packaging. For the purposes of identifying and classifying packaging, producers are also required to indicate the nature of the packaging materials used, on the basis of Commission Decision 97/129/EC.”

The subject of Article 219, paragraph 5 is the environmental labelling of packaging, and does not take into consideration any other product label to be displayed on the packaging.

Below is our interpretation of the various passages of the article, on which we have based the explanations and insights provided herein, supported by concrete examples. Let's see them together.


All packaging must be appropriately labelled in accordance with the procedures laid down in the applicable UNI technical standards.


  • All packaging must be labelled “appropriately”, and therefore in the form and manner that the company considers most suitable and effective for achieving the goal.
  • The reference to UNI standards is generic, especially if we consider their voluntary nature. Therefore, the regulations imply that, if a company wishes to state certain contents on the environmental label, then the reference UNI standards should be adopted. But what information can be communicated through the UNI standards to which the regulations refer?
    • Identification of packaging materials for plastic packaging. When Decision 129/1997 does not include a specific identification code for a specific polymer, the applicable standards are UNI 1043-1 for the identification of plastics not included in Decision 129/1997 and UNI 10667-1 for the identification and recognition of recycled polymers.
    •  Identification of packaging materials for multi-layer plastic packaging. Also in these cases, Decision 129/97/EC does not include specific identification codes: the UNI 11469 standard lends a helping hand in communicating the composition of structures made up of several polymers.
    • Environmental self-declarations. Where additional voluntary information concerning the environmental qualities of the packaging is to be provided (inscriptions, symbols/pictograms or other similar messages, environmental claims), reference should be made to UNI EN 14021.

and in compliance with the decisions of the European Commission, in order to facilitate the collection, reuse, recovery and recycling of packaging


At present, among the “decisions” adopted by the European Commission in relation to environmental labelling, we find only Decision 129/1997/EC, which is later mentioned specifically.


and to provide consumers with proper information on the final destination of packaging.


Who are consumers?
According to the Consumer Code (art. 3, paragraph 1), the consumer or user is a “natural person who acts for purposes extraneous to any business, commercial, artisanal or professional activity carried out…”
In a similar fashion, art. 218, paragraph 1, letter v) of Legislative Decree 152/2006 refers to the consumer as the party who, acting outside the exercise of a professional activity, buys or imports packaging or packaged articles or goods for his or her own use.

What is the information on the final destination of packaging?
Information on the final destination of packaging is that which communicates its correct disposal at the end of its useful life (e.g. separate waste collection. Check your local municipal guidelines).

So, what packaging should be covered?
Said information should cover:

  • packaging offered to the end consumer as is, for sale or even free of charge;
  • packaging offered to the end consumer in the form of a pre-packaged product, for sale or even free of charge.

Instead, said information should exclude packaging destined for the B2B channel (packaging assigned, as is or in the form of a pre-packaged product, to a “professional”, i.e. a “natural or legal person, or an intermediary thereof, acting in the exercise of his business, commercial, artisanal or professional activity” (art. 3, paragraph 1 of the Consumer Code).


For the purposes of identifying and classifying packaging, producers are also required to indicate the nature of the packaging materials used, on the basis of Commission Decision 97/129/EC.


  • In their breakdown of identification codes per material, the lawmakers did not make explicit reference to packaging destined for the use of the “consumer”, therefore there is no evidence to exclude packaging destined for professional use from the process of identification and classification under Decision 129/97/EC. All packaging, therefore, is subject to identification and classification.
  • Only with regard to affixing identification codes of materials on the basis of Decision 97/129/EC is the obligation expressly imposed on producers.
  • If Decision 129/97/EC does not require specific identification of plastic polymers in the packaging’s composition, voluntary use may be made of the UNI standards described above.

 


TO RECAP

This interpretation of the decree gives rise to important observations:

  • Producers must indicate the alphanumeric code provided for in Decision 97/129/EC on all packaging (primary, secondary and tertiary);
  • All packaging must be labelled in the form and manner that the company considers most suitable and effective for achieving the goal;
  • Packaging destined for the consumer must also bear suitable inscriptions aiding its disposal;
  • For plastic packaging made from polymers or polymer combinations not expressly provided for in Decision 97/129/EC, reference may be made to the UNI 1043-1 standards for the identification of plastics not included in said Decision, and to the UNI 10667-1 standards for the identification and recognition of recycled polymers.

 
APPLICABLE LEGISLATION AND REFERENCE GUIDELINES
Tabella numerata riassuntiva

 

To be clear

When is packaging considered recyclable?
Packaging considered recyclable in accordance with the technical standard UNI EN ISO 13430 meets the criteria of eligibility for existing recycling technologies, namely:

  • existence of an efficient recycling technology for the type of packaging;
  • existence of a critical mass so that an efficient recycling process may be managed;
  • existence of a market for recycled materials.

These criteria must be assessed via specific surveys and studies.
(For more information, see the Design for Recycling Guidelines).

 

When is packaging considered compostable?
The biodegradability and compostability claim of packaging may be communicated when the packaging complies with technical standard UNI EN ISO 13432. The biodegradability and compostability certification is issued, together with compostability marks, by several accredited certification bodies.

 

What packaging can be collected separately?
All packaging may be collected separately, whether or not it is recyclable. Through CONAI’s Packaging Supply Chain Consortia, packaging will either be recycled or destined for energy recovery.

 

The content of environmental labels: some examples

Our interpretation of the decree gives rise to two different scenarios regarding the minimum content to be stated on the environmental label, based on the packaging’s destination circuit: B2B (professional) or B2C (consumer). Starting from this assumption, in addition to including distinct diagrams for B2B or B2C destinations, these guidelines also address different packaging structures: single-component and multi-component packaging/packaging systems.
The following diagrams include 3 levels of information:

  • Mandatory, to comply with the regulations
  • Highly recommended, to make communication more effective
  • Recommend, to provide additional information for efficient separate waste collection
 
ENVIRONMENTALLABELLING OF SINGLE-COMPONENT B2C PACKAGING

For single-component packaging destined for the end consumer, the following information should be given:

  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.

Other information that may be voluntarily added to environmental labels relates to the type of packaging and instructions that will guide the consumer towards efficient separate waste collection.

Single component
Legenda
 
ENVIRONMENTAL LABELLING OF MULTI-COMPONENT B2C PACKAGING

For packaging consisting of several components, it is important to distinguish between components which cannot be separated by hand (for example, a paper label attached to a glass bottle) and components that can be separated by hand by the end consumer (for example, a snack multipack). This is because identification and classification under Decision 129/97/EC are envisaged for packaging components that can be separated by hand.

 

To be clear

What are packaging components that can be separated by hand?

A component may be separated by hand when the user can separate it completely - without any risk to his health or safety - from the main body, with the sole use of the hands and without the need for additional tools or instruments.

 

This means that each packaging component that can be separated by hand must bear at least:

  1. The packaging material’s identification code under Decision 129/97/EC
  2. Information on separate waste collection when this is not indicated on the outer presentation packaging. We suggest using the wording “(Material family) collection” and inviting the consumer to check their local municipal guidelines.

When it is not possible to indicate the relevant identification code on each individual component, for example due to a lack of space or other technological constraints, this may be stated on the main body or on the presentation packaging.

In the event of placing all the environmental labels on the outer presentation packaging, we recommend using the following format:

  1. Type of packaging (full written description or graphic representation) of the various components that can be separated by hand;
  2. Identification code of the packaging material of each component that can be separated by hand under Decision 129/97/EC;
  3. Collection guidelines, clearly specifying the material family of each component.

Also in this case, voluntary information may be provided to help the consumer separate waste efficiently.

Multi component
Legenda

 

 

ENVIRONMENTAL LABELLING OF B2B PACKAGING

From our reading of the decree, B2B packaging - for example packaging destined for professionals, or transport packaging, or packaging related to logistics or exhibition activities - do not need to provide information on the final destination of the packaging, but must mandatorily bear the code of the composition materials in accordance with Decision 129/97/EC.

Every other information, instead, remains voluntary.

B2B
Legenda

 

How do you create an environmental label?

Based on the above, this section of the Guidelines sets out the information that may contribute to the contents of the environmental label:

  • Alphanumeric code under Decision 129/97/EC
  • Material family
  • Collection guidelines

Below are the Annexes to Decision 129/97/EC, for every material and for polylaminates, inclusive of the codes to be used for identification of the material making up the packaging, together with examples of complete environmental labels containing both the minimum information required by the lawmakers and additional optional information.

The examples provided are merely indicative of the type of labelling solutions that companies can adopt, and do not include every possible type of voluntary information. Companies may use graphic and presentation methods of their own choice, provided these are effective and consistent with the goals set forth in art. 219, paragraph 5.

For the graphic rendering of wordings and symbols, we suggest using the colour coding set forth by the UNI 11686 standard - Waste management - Waste visual elements.

In the following examples, we have adopted the colour coding provided for by said technical standard.

 

UNI 11686 standard

The standard defines specific colours and other visual elements for waste bins so that the end consumer may easily identify the correct bin, thereby facilitating waste collection.

Increasingly often, citizens find themselves having to separate waste in different cities and municipalities: colour coding helps them to identify bins correctly, thus facilitating separate waste collection even outside their own home town.

By adopting the following specific colour codes, the standard allows for instant visual recognition on the part of consumers:

 

Cassonetti

 

To be clear

Laminating or processing: the > 5% rule

For the purposes of Decision 129/97/EC, “composite” packaging means packaging made up of different materials, which cannot be separated by hand.

Such packaging may be the result of processing (e.g. coating, metallic treatment, rolling, lacquering) or laminating techniques.

For such packaging, the alphanumeric coding of Decision 129/97/EC is provided in Annex VII, which includes different codes depending on the material family prevailing in weight and the secondary material family.

 

The 5% threshold

For the proper coding of packaging materials, it is taken that, when the weight of the secondary material(s) is less than 5% of the total weight of the packing, this is considered single-material packing and labelled based on the material prevailing in weight. Otherwise, the applicable codes are those provided for in Annex VII to Decision 129/97/EC.

This simplification is based on the approach adopted in COMMISSION IMPLEMENTING DECISION (EU) 2019/665, according to which, for the purposes of calculating and verifying attainment of recycling targets, Member States are required to report composite packaging and other packaging composed of more than one material, but may “derogate from this requirement where a given material constitutes an insignificant part of the packaging unit, and in no case more than 5 % of the total mass of the packaging unit”.

 

How should glues, adhesives and inks be treated?

If packaging is made up of one packaging material (steel, aluminium, paper, wood, plastic, glass), laminated or processed with a material other than the packaging material (e.g. glue, adhesive, ink), it can still be considered single-material packaging.

For example, HDPE packaging with a layer of ink and the use of glues weighing more than 5% of the total weight of the packaging will display the code for HDPE single-material packaging.

 
STEEL PACKAGING
Schema acciaio
Examples
Spray Can
 
ALUMINIUM PACKAGING
Aluminium
Examples
Can

Code 42: when the metal in neither steel nor aliminium

Whenever packaging consists of metal other than steel or aluminium, not associated with any specific code in Annex III to Decision 129/97/EC, we suggest adopting the number “42”, i.e. the first code in the table to which no material is associated, and therefore “available” for other types of metals not foreseen.

 
PAPER PACKAGING
Paper

Paper, paperboard or corrugated cardboard?

Proper paper has a grammage of up to 150 g/m2, while cardboard features a grammage in excess of 600 g/m2, and as high as 1100 g/m2. Paperboard, on the other hand, is a paper-based material with a grammage that lies between paper and cardboard, identified by a grammage in the 250 to 450 g/m2 range. If we look at the above figures, we can see that there are two apparently undefined ranges, namely between 150 and 250 g/m2, and between 450 and 600 g/m2: within these ranges, the line between paper and paperboard (in the case of the former range) and between paperboard and cardboard (in the case of the latter) is a little blurred.

Tabella peso carta

https://www.comieco.org/glossario/

Examples
Forno
Pane
Etichetta Pirottino
Scatola
Astuccio coating plastico
 
WOODEN PACKAGING
Legno
Examples
Tappo
Cassetta legno
Pallet
PLASTIC PACKAGING
Plastica

How can the polymer of plastic packaging be identified if it is not provided for in decision 129/97/EC?

Polymers for which no specific coding is provided for in Decision 129/97/EC

Decision 129/97/EC includes alphanumeric codes for the identification of just 6 different polymers. However, numerous polymers are used for the production of plastic packaging and this number is set to grow because this is a sector characterised by fast-evolving technology designed to satisfying many different needs.

So far, polymers other than those mentioned in Decision 129/97/EC have all been identified with the code “7”. In order to provide more accurate information on the composition of plastic packaging, and given the significant number of existing polymers identified by the single code “7”, we suggest accompanying the number “7” with:

  • the abbreviation of the polymer’s name as per technical standard UNI EN 1043-1, where available.
    For example, polyamide packaging may be identified as: PA 7
  • the full name or acronym of the plastic material commonly used in market practice, in cases where no abbreviation exists.
    For example, regenerated cellulose packaging may be identified as: Cellophane 7.
    For example, packaging in modified PET such as PETG may be identified as: PETG 7
  • Packaging made from biodegradable and compostable polymers, under UNI EN 13432, is a separate case as no coding is foreseen for such polymers, even in the UNI technical standards. In such cases, we recommend using the term “compostable plastic”.
    For example, polylactic acid packaging may be identified as: Compostable plastic 7.

       

Multi-layer packaging consisting of different polymers

Packaging consisting structurally of two or more polymers are identified by the code “7” since, also in this case, Decision 129/97/EC does not include specific codes for these materials.

Anyone wishing to provide more accurate information on the composition of multilayer plastic packaging should follow the provisions of the UNI EN 11469 technical standard, according to which the abbreviations of polymers making up the packaging are written between the symbols “>” and “<”, with the sign “+” placed in between.
For example, multilayer packaging made from PET and HDPE may be identified as follows: >PET+HDPE< 7.

Examples
Bottiglia etichetta separabile
Vaschetta
Sacchetto multistrato
Coprente non separabile
Vaschetta evoh
Sacchetto inchiostri
Biodegradabili Etichetta

Environmental labelling of plastic shopping bags

As early as 2017, Art. 219, paragraph 3-bis) of Italian Legislative Decree 152/2006 introduced a specific labelling requirement for biodegradable and compostable shopping bags for carrying goods, and for ultra-light biodegradable and compostable plastic bags for hygienic and/or bulk food purposes (fruit and vegetable bag), to which is added the obligation to identify the material in question in accordance with Decision 129/97/EC.
Standard EN 13432 clarifies the requirements packaging must meet in order to be compostable. Biodegradability is one of the 4 steps envisaged by the regulation: to be defined as compostable, a material must necessarily be biodegradable. Conversely, a biodegradable material is not necessarily compostable.

Shopper bio
Shopper bio ortofrutta

 

Shopper riutilizzabile

 

 
GLASS PACKAGING
Vetro

What if the colour of glass packaging is neither clear, green nor brown?

Annex VI, which sets out identification codes for glass packaging, provides for the identification of clear, green and brown glass.
For glass packaging in a colour other than those referred to in Annex VI, we recommend using GL 73, i.e. the first number to which no specific colour is associated and therefore “available” to be adopted in such cases.

Examples
Bottiglia retina
Bottiglia a rendere
 
POLYLAMINATE OR COMPOSITE PACKAGING
Schema Misti
Examples
Cartone liquidi
Sacchetto biscotti en
Tubetto
Policaccoppiato
Boccetto
Blister
 
TEXTILE PACKAGING
Tessili

 

For textile packaging, reference is made to Annex V to Decision 129/97/EC.

For textile materials not provided for in this table, i.e. materials other than “cotton” and “jute”, we recommend using TEX 62, i.e. the first available number to which no specific material is associated.

Such packaging does not fall within the scope of domestic waste collection but of specific waste collections. Therefore, in addition to the code, it is good practice to indicate the full material “fabric” and to invite the consumer to check their local municipal guidelines.


FAQ's

 
INTERPRETATION GUIDE

Below are our answers to the questions most frequently asked by companies regarding environmental labelling. In them, we provide our shared interpretations of various aspects of real interest to industry players seeking answers. The topics covered in these FAQs concern organisational aspects (such as the scope of the new requirement, responsibilities and time frames) as well as more practical ones (such as the methods, contents, and preferable features of environmental labels), and often make use of definitions that help to understand the approach to be adopted.

In separate boxes, we report certain issues - arising from our public consultation - that pose significant problems for many companies. These would deserve specific insights and measures currently not foreseen by the decree.

 

What is the scope of the environmental labelling requirement?

The environmental labelling requirement relates to packaging, i.e.: “products, consisting of materials of any kind, used to contain certain goods, from raw materials to finished products, to protect them, allow their handling and their delivery from the producer to the consumer or user, ensure their presentation, as well as disposable items used for the same purpose”.
Products other than packaging do not require an environmental label. For example, sausage casings, envelopes and cutlery are not packaging and are therefore not affected by the requirement.

To find out what constitutes packaging and what does not, please refer to the CONAI website.
At present, all the packaging placed on the market in Italy is covered by the new labelling requirement. Excluded from the regulations is packaging destined to be marketed in other European Union countries or to be exported to third-party countries.

Although the decree prescribes the compulsory labelling of all packaging, it is worth noting that with Communication dated 23 November 2020, Circular No. 010/2020 (annexed), AIFA (the Italian Medicines Agency) communicated that medicinal products are excluded from this requirement.

 

Should small packaging also be labelled?

The regulations do not include any exemption for small packaging.

Observations

Please note that, for small packages contained in a multipack, the way forward could be to place the environmental label on the presentation package. However, in the case of small packaging sold in bulk, there may be physical restrictions to affixing the environmental label, thus hampering the visibility and legibility of the information.

In these cases, for certain specific supply chains already subject to exemptions as regards the labelling of products, if it is not possible to apply the label on the packaging, we recommend making reference to corporate websites, APPs, etc.:

  1. Regulation (EU) No. 1169/2011, which states what food packaging is exempt from the mandatory nutrition declaration requirement, includes the possibility of exempting from this requirement any packaging the largest surface of which has an area of less than 25 cm2. In such cases, the information may be made available online.
  2. The CLP Regulation (Regulation (EC) No. 1272/2008, Article 29, paragraph 2 and point 1.5.2 of Part I of Annex I) exempts packages of chemicals of a capacity not exceeding 125 ml from the obligation to provide certain mandatory information.

In general, on small packaging, we recommend making use of digital channels as a possible alternative to labelling.

Should neutral packaging also be labelled?

Neutral packaging means unprinted packaging featuring no graphics, symbols or information, sold as is by producers to customers.

The regulations do not exclude such packaging from the obligation.

Observations

In some cases, such packaging encounters significant problems and technological limitations, and these should be taken into consideration by the lawmakers.

  1. Neutral, finished packaging, produced on production lines not set up for printing.
    In many such cases, firms would need to make changes to their production and logistical processes at a disproportionate cost. Also on the basis of the latest opinion of the European Commission on the compulsory inclusion on packaging of the Triman logo in France (https://ec.europa.eu/growth/tools-databases/tris/en/search/?trisaction=search.detail&year=2020&num=410), bearing in mind, among other things, that such packaging is often of an unambiguous nature, the labelling requirement seems to be disproportionate to the technological and economic investment required.
    Furthermore, such packaging is often used for transport or logistical purposes, which cases ought to be exempt or, where possible, subject to specifying the packaging composition on the transport documents accompanying the goods, or on other such media.
  2. Variable-weight packaging, such as that used at fresh food or self-service counters, defined - once it contains foodstuff - as “pre-packaging” in Circular No. 165 published on 31 March 2000 by the then Ministry of Industry, Commerce and Crafts in issue no. 92 of the Official Journal of the Italian Republic, General Series, dated 19 April 2000. In this case, there are several observations to be made:
    1. In some cases, such packaging is used for foodstuffs (e.g. fish) and therefore cannot be printed.
    2. In other cases, the intended use of such packaging is unknown at the time of production and sale, i.e. it is unknown whether it will be used for domestic use (e.g. aluminium foil and trays, plastic plates and cups, etc.).
    3. Very often, such packaging is prepared/cut to size at the point of sale (e.g. aluminium foil or plastic film).

In these situations, it is objectively difficult to comply with the packaging labelling requirement. It is to be hoped that the lawmakers will allow for communicating the information of the environmental label on data sheets, made available to end consumers, for example, at the point of sale (e.g. alongside information on allergens, or through specific data sheets placed on the counter), or through a website.

To whom does the requirement apply?

“Producers” must indicate the alphanumeric code provided for in Decision 97/129/EC on all packaging (primary, secondary and tertiary).
“Producers” are defined in Legislative Decree 152/2006 as producers of packaging materials, manufacturers, processors and importers of empty packaging and packaging materials.

However, it should be borne in mind that most packaging is brought to the market, and in particular to the end consumer, through pre-packaged products.

It is well known that the labelling of these sales units is often decided and defined by the user of the packaging, who chooses the contents and form, and who approves the layout to be printed and/or reproduced on the packaging.

In this regard, the choice of the environmental label will inevitably be shared by the packaging supplier and user. This combined decision will lead to the choice of the wording to appear on the environmental label.

As proof of this need for cooperation between the parties (the producer and user of the packaging), article 261, paragraph 3 states that a financial penalty of EUR 5,200 to EUR 40,000 shall be applied to any party who places on the market packaging not bearing the required label.

It is clear that any sector operator is potentially punishable.

And “any sector operator” could equally include:

  • Producers of packaging materials, manufacturers, processors and importers of empty packaging and packaging materials,

or

  • Traders, distributors, fillers, users of packaging, and importers of filled packaging.

When does the labelling requirement come into force?

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, Italian Legislative Decree no. 183 of 3 December 2020 - the so-called “Milleproroghe 2021” [a decree postponing the entry into force of certain regulatory provisions or extending the effectiveness of laws that would otherwise expire] - was published in the Official Journal of the Italian Republic, article 15, paragraph 6 of which suspends application - until 31 December 2021 - of the first part of art. 219, paragraph 5 of Italian Legislative Decree no. 152 of 2006, as amended: “All packaging shall be appropriately labelled in accordance with the procedures laid down in the applicable UNI technical standards and in compliance with the decisions of the European Commission, in order to facilitate the collection, reuse, recovery and recycling of packaging, and to provide consumers with proper information on the final destination of packaging.”

Instead, no suspension has been envisaged for the second part of art. 219, paragraph 5: “For the purposes of identifying and classifying packaging, producers are also required to indicate the nature of the packaging materials used, on the basis of Commission Decision 97/29/EC.”
Said Legislative Decree has been in force since 31 December 2020.

The Decree, therefore, did not suspend the obligation to affix to packaging the alphanumeric identification codes of materials under Decision 129/97/EC, in force since 26 September 2020. Therefore, all packaging (primary, secondary, tertiary) must include such codes. With regard to the affixing of identification codes of materials on the basis of Decision 97/129/EC, the obligation is expressly imposed on producers.

The need to provide information to help dispose of packaging destined for the B2C channel into the correct waste stream has been suspended until 31 December 2021. Consequently, the companies concerned will have a year to adjust to the obligation and to include such information on packaging intended for end consumers.

Observations

Confindustria has requested the exclusion of transport (or tertiary) packaging, as defined by art. 218, paragraph 1, letter d) of the Environmental Code, insofar as the purpose of the law is to “provide consumers with proper information on the final destination of packaging” and consumers only come into direct contact with primary and secondary packaging, in our opinion making tertiary packaging extraneous to the law. Similarly, Confindustria has also requested the exclusion of packaging of products destined to be marketed in other European Union countries or to be exported to third-party countries, insofar as - the provisions of Article 219, paragraph 5 and the relevant UNI technical standards being valid only within our national borders - such packaging may incur different labelling requirements depending on the country of destination.Finally, we cannot fail to consider the period we are living through, which has hit most companies very hard. In some cases, adapting to this requirement will lead to significant costs that not everyone can easily sustain.

Confindustria and many other Associations have pointed out these difficulties to the competent institutions, proposing as a matter of urgency a transitional period of eighteen months to allow the producers and users of packaging to adapt their production and management processes to the new obligations laid down by law. Furthermore, a petition has been put forward to request that the labelling requirement be applied only from the provision’s effective date of entry into force, so as to exclude existing stocks even beyond the 18-month transitional period proposed, while safeguarding the principles of economic efficiency and environmental protection.
Moreover, Confindustria has also requested the exclusion of transport (or tertiary) packaging, as defined by art. 218, paragraph 1, letter d) of the Environmental Code, insofar as the purpose of the law is to “provide consumers with proper information on the final destination of packaging” and consumers only come into direct contact with primary and secondary packaging, in our opinion making tertiary packaging extraneous to the law. Similarly, Confindustria has also requested the exclusion of packaging of products destined to be marketed in other European Union countries or to be exported to third-party countries, insofar as - the provisions of Article 219, paragraph 5 and the relevant UNI technical standards being valid only within our national borders - such packaging may incur different labelling requirements depending on the country of destination.

Does the content of the environmental label need to be printed directly on the packaging or can it be placed on a medium (e.g. a separate label)?

The content of the environmental label may be applied/printed/embossed directly on the packaging or placed on a separate medium if this is made possible by the packaging system in question.

How should multi-component packaging be labelled? Must the environmental label be placed on every component of a single sales unit?

The approach taken by CONAI is that set out in the “Etichetta per il cittadino” handbook: we do not believe it is necessary to label components that cannot be separated by hand, whereas labelling every component that can be separated by hand is in fact mandatory.

Therefore, environmental labels (at least the alphanumeric codes set forth in Decision 129/97/EC) should be affixed to each of the various components making up the sales unit that can be separated by hand.

Where this is not possible, they may be affixed either to the main body of the packaging, or to another label or any other component that makes the information easily visible to the end consumer.

The same applies in the case of multipacks, where it is always preferable to affix the label to each packaging component, but when this is not possible, the label may be affixed to the sales unit (i.e. on the multipack).

For example, in the diagram below, the ideal choice is to place the label, at least the one identifying the material, on each component, i.e. individually on the tray and film. If this is not possible, then you can place the label of the tray and film on one of the two components.

The same goes for single-portion chocolates (thin sheet): if it is not possible to place the label on the individual single-portion packaging, the relevant information may be included on one of the components of the sales unit.

If the product is sold with a leaflet (e.g. food supplements) or with instructions for use, and it is not possible to place the environmental label on the packaging due to a lack of space or other technological constraints, the content of the environmental label may be stated on such media.

Cioccolatini

Should non-packaging accessories enabling use of the product (e.g. straws, cutlery) be labelled?

As such accessories are not packaging, they are not subject to the labelling requirement, but the packaging containing them is.

When is packaging defined as composite? How should it be labelled?

Packaging is defined as composite when it is made up of different packaging materials which cannot be separated by hand.
For the purpose of identifying the packaging material, the codes under Annex VII to Decision 129/97 are only affixed on composite packaging when the secondary packaging material exceeds 5% of the total weight of the packaging; otherwise, the code to be used is not that provided for in Annex VII but that of single-material packaging, based on the material prevailing in weight.

How should paper-based composite packaging destined for the end consumer be labelled?

Without prejudice to the C/PAP… alphanumeric coding, which unambiguously identifies packaging composed primarily of paper, under Annex VII to Decision 129/97/EC further information on waste collection should be stated as follows:

  • Paper-based composite packaging with a paper fraction percentage between 60% and 95% of the total weight of the pack
    • Specify that the packaging is to be separated as paper waste;
  • Paper-based composite packaging with a paper fraction percentage below 60% of the total weight of the pack
    • Indicate the material family as Paper - Check your local municipal guidelines (optional);
  • Containers suitable for the containment of liquids -> Specify that the packaging is subject to separate waste collection + link to the website http://www.tiriciclo.it/raccolta-e-riciclo/ (optional).

Can the symbol represented by three arrows in the shape of a triangle, containing an alphanumeric code as per Decision 97/129/EC, or another such symbol be used as to identify the packaging material?

Over the years, the identification of packaging material - not a legal requirement before 26 September 2020 - has been widely adopted by companies, in the different manners laid down by various rules and regulations. For example, many packages have been labelled with symbols that refer to the CEN/CR 14311 report (i.e. the Alu symbol inside circular arrows, the icon of a magnet to identify steel packages, or plastic polymer codes inside arrows in the shape of a triangle); plastic packaging made of one or more polymers not covered by Decision 129/97/EC has often been identified with the symbol “7” or “07 other”, sometimes placed within three arrows in the shape of a triangle.

Although these solutions have become consolidated market practice for the identification of such packaging materials, it should be noted that the regulation clearly states that packaging materials should be identified based on the provisions of Decision 129/97/EC and adopting applicable UNI standards, not other existing regulations or common practices.

Is it true that only recyclable packaging can be separated?

Please note that all packaging can be separated, whether or not it is recyclable using existing technologies, provided it is separated efficiently (e.g. always empty the packaging of its contents, reduce its volume when possible). Through CONAI’s Packaging Supply Chain Consortia, packaging will either be recycled or destined for energy recovery.

An evaluation of the packaging's recyclability is one of the additional pieces of information that a company may choose to display on the packaging, but this is independent of the information regarding the correct disposal of the packaging.

When is it possible to voluntarily claim the recyclability of packaging using the Mobius loop?

Mobius 1

The producer can claim the recyclability of packaging using the Mobius loop, in accordance with UNI EN ISO 14021, when the packaging is recyclable under technical standard UNI EN ISO 13430:2005.

 

The UNI EN ISO 13430 technical standard

Packaging considered recyclable in accordance with the technical standard UNI EN ISO 13430 meets the criteria of eligibility for existing recycling technologies, namely:

  • existence of an efficient recycling technology for the type of packaging;
  • existence of a critical mass so that an efficient recycling process may be managed;
  • existence of a market for recycled materials.

These criteria must be assessed via specific surveys and studies.


For more information, see the CONAI guidelines “Requirements defined by Directive 94/62/EC on packaging and packaging waste” available at the following link.

 

The UNI EN 11743:2019 technical standard

Companies wishing to assess the recyclability of their paper packaging may ask a laboratory to perform a recyclability test, which simulates the main steps of the industrial paper recycling process, in accordance with the procedure defined by UNI 11743:2019.

 

When can the biodegradability and compostability of packaging be claimed?

The biodegradability and compostability of packaging may be claimed, under UNI EN ISO 14021, when the packaging complies with technical standard UNI EN ISO 13432:2002.

The biodegradability and compostability certification is issued, together with compostability marks, by several accredited certification bodies.

In particular, the new decree specifies that biodegradable and compostable packaging may only be collected and recycled with food waste if:

  1. it is certified, by certification bodies, in accordance with the UNI EN 13432 technical standard;
  2. it is appropriately labelled, in particular:
    1. stating compliance with the above European standards,
    2. bearing identification details of the producer and certifier,
  3. stating appropriate instructions enabling consumers to dispose of it as separate food for recycling purposes.

Such information stems from the need, expressed by said decree, to track, distinguish between and separate, by 31 December 2023, such packaging from conventional plastics in waste sorting plants and food-waste recycling plants.

In particular, it should be noted that this obligation concerns biodegradable and compostable packaging which cannot be attributed to food and kitchen waste (e.g. cork stoppers).

How can the secondary raw material content of packaging be communicated voluntarily?

Mobius 2

The secondary raw material content of packaging may be communicated using the Mobius loop containing a percentage value indicating the percentage weight of the recycled material.

Must the label be affixed to the packaging or can the information also be conveyed to the end consumer via digital channels (e.g. specific Apps, QR Codes, etc.)?

The European Commission’s latest opinion on the new obligation in France to affix the Triman symbol to packaging supports the use of digital solutions to meet this obligation, precisely because this is a way of simplifying and solving problems of size and space, and because it avoids the risk of companies using even more raw materials in order to have more room, thereby going in a direction contrary to prevention - something that should be promoted at all times and not hindered.

Furthermore, if we turn to certain other communication obligations in force in some sectors, when such communication is not possible due to space constraints it is already possible to refer the consumer to a website for full and exhaustive information.

In fact, it is worth noting that a CONAI survey, conducted in collaboration with the Sant’Anna School of Advanced Studies, reveals that consumers are making increasing use of digital channels, and the Internet in general, to search for information when making purchases, whether online or in stores. And of course, during the current pandemic, this type of instrument has taken even more hold as many sectors are trying to eliminate or reduce paper as a possible vehicle of infection.

For these reasons, we would advise making it possible to use digital channels to convey the information to be displayed on the label. This option could be particularly useful for very small packaging, or for packaging with space constraints, or for multilingual packaging.

Is the producer bound by a specific graphic design for its environmental labels?

The graphic designer is free to choose the style, shape and colours of the environmental label: the regulations don’t specify these aspects, but they do recommend that packaging be appropriately labelled in such a way as to achieving the required goal.

Of course, in addition to being clear, not misleading and easy to understand by any consumer, the label must also be clearly legible. We therefore suggest referring to the provisions already laid down, in the food sector, by art. 13 of Regulation (EU) 1169/2011, which states that said information should be displayed on the packing in characters using a font size where the x-height is equal to or greater than 1.2 mm.

If, instead, the largest surface of the packaging has an area of less than 80 cm2, the x-height of the font size shall be equal to or greater than 0.9 mm.
From the point of view of design and colour, there are no mandatory provisions to be followed. Environmental labels may be designed in a single colour.

For coloured environmental labels, in order to provide citizens with consistent, standardised indications, CONAI suggests basing the colours used on the UNI 11686 standard on Waste Visual Elements, which prescribes the following colour codes:

  • blue for paper,
  • brown for food waste,
  • yellow for plastic,
  • turquoise for metals,
  • green for glass,
  • grey for unsorted waste.

Should the environmental label include the pictogram of a man throwing the packaging into a bin?

Non disperdere

This pictogram is an invitation not to release the packaging to the environment. Its design has not been laid down by law, but the lawmakers have requested the use of a pictogram, freely designed, to invite citizens/consumers to adopt a suitable environmental behaviour. The pictogram was introduced in Ministerial Decree dated 28 June 1989, later repealed by art. 36 of Law no. 14 dated 3 February 2003 (later also repealed by the current Legislative Decree 152/2006).

How is infringement of art. 219, paragraph 5 punished?

Pursuant to article 261, paragraph 3, a financial penalty of EUR 5,200 to EUR 40,000 shall be applied to any party who places on the market packaging not bearing the required environmental label.


Environmental labelling in a nutshell

 

The table below summarises the contents of these Guidelines with a breakdown of the issues of greatest interest: the contents of the label, split by mandatory and recommended; the position and format, which are suggestions but not binding; and the timing.

This information applies to all packages with the exception of medicinal products, which AIFA (the Italian Medicines Agency) has communicated is exempt from this requirement.

However, it is worth noting that in some cases - especially with regard to neutral or small packaging (see the observations to FAQ 1) - certain technological limitations could make it impossible or disproportionately burdensome, from an organisational and logistical point of view, to affix the environmental label to packaging.

 

Riassunto en

 


e-tichetta: the environmental labelling TOOL

 

Given the growing interest of companies in environmental labelling, CONAI has been working for a few months now on a special online tool (e-tichetta) designed to help companies create their environmental labels independently.

The aim of this tool is to guide companies step-by-step towards adopting a suitable, standard labelling system that complies with the law and provides end consumers with useful information and guidance.

e-tichetta is based on CONAI's Guidelines for the environmental labelling of packaging and is available either at CONAI or directly at e-tichetta.conai.org

 

HOW DOES THE TOOL WORK?
    1. Select the type of packaging
      Screenshot 1
    2. Select whether it is single-material or composite packaging
    3. Select the material (or prevalent material) family
    4. Select the specific material
    5. If it is composite packaging, select the other secondary material(s)
Screen4
  1. Answer any additional questions that may help you obtain additional environmental information to be communicated to the end consumer
    doamnda 1
    domanda 2
    domanda 3
    domanda 4

The tool outputs a series of information to be placed on the environmental label, including:

  1. Mandatory information:
    • Type of packaging (1)
    • Identification code of the packaging material (under Decision 129/97/EC or CEN/CR 14311:2002 in the case of steel, aluminium or plastic) (2)
    • The material family in full so as to help the consumer correctly identify the packaging material, which is not always clearly recognisable from the alphanumeric code (3)
    • Information on the type of separate waste collection and an invitation to consumers to check their local municipal guidelines (4)
  2. Voluntary information that may help the consumer separate waste efficiently (5).
    doamnda 5
  3. Voluntary information on any further environmental characteristics of the packaging (recyclability and recycled content of each component) and on its compliance with the CONAI system through use of the consortium’s specific trademark (6).

    domanda 6

Glossary

 
SELF-PRODUCER
(Conai (n.d.). Glossary. Available in the Glossary CONAI)

“Self-producers” are defined as any parties that purchase raw materials and packaging materials in order to manufacture/repair packaging for their own products (which are different from the packaging). For all intents and purposes, self-producers are considered users, also with reference to the raw material involved in repairing their own packaging.

 

BIODEGRADATION
(Greene, J.P. (2014). Sustainable Plastics: Environmental Assessments of Biobased, Biodegradable, and Recycled Plastics. (1st Ed). John Wiley & Sons.)

Biodegradation is a thermochemical process that takes place in a specified time frame and under specific environmental conditions. During biodegradation, the materials/products are converted to biomass, water and carbon dioxide.

 

COMPOSTABILITY
(Greene, J.P. (2014). Sustainable Plastics: Environmental Assessments of Biobased, Biodegradable, and Recycled Plastics. (1st Ed). John Wiley & Sons.)

Compostability is the property of a material to generate compost (biomass) through the composting process, namely an aerobic biological process that takes place under externally imposed environmental conditions. In industrial composting plants, the temperatures used usually range from 50 °C to 60 °C, with a moisture content in the 45% to 55% range.

 

The technical standard UNI EN 13432 states the requirements for packaging recoverable through composting:

  • Packaging shall be designed, produced and commercialised in such a way as to permit its reuse or recovery, including recycling, and to minimise its impact on the environment when packaging waste or residues from packaging waste management operations are disposed of;
  • Packaging waste processed for the purpose of composting shall be of such a biodegradable nature that it should not hinder the separate collection and the composting process or activity into which it is introduced;
  • Biodegradable packaging waste shall be of such a nature that it is capable of undergoing physical, chemical, thermal or biological decomposition such that most of the finished compost ultimately decomposes into carbon dioxide, biomass and water.

 

PACKAGING SUPPLY CHAIN CONSORTIA
(CONAI (2020). Guide to membership and to the application of the Environmental Contribution (Volume 1). Available from CONAI)

According to art. 223 of Italian Legislative Decree 152/06, packaging producers are required to join together in a Consortium for each packaging material (steel, aluminium, paper, wood, plastic and glass). The six Packaging Supply Chain Consortia are as follows:
Ricrea – National Consortium for the Recycling and Recovery of Steel Packaging;
Cial – National Aluminium Packaging Consortium;
Comieco – National Consortium for the Recovery and Recycling of Paper-Based Packaging;
Rilegno – National Consortium for the Collection, Recovery and Recycling of Wooden Packaging;
Corepla – National Consortium for the Collection, Recycling and Recovery of Plastic Packaging;
Coreve – Glass Recovery Consortium.

Instead of joining the Packaging Supply Chain Consortia, producers can opt instead, pursuant to art. 221, paragraph 3, of the same Decree: “a) to organise the management of their own packaging waste autonomously - even collectively - throughout the country; [...] c) to certify, under their sole responsibility, that a take-back scheme has been put in place for the return of their packaging, supported by suitable documentation demonstrating the scheme's self-sufficiency [...].”

 

CONSUMER
(Conai (n.d.). Glossary. Available in CONAI Glossary)

Packaging consumers are individuals who purchase or import packaging or packaged items or goods for their own use, and not for the purpose of carrying out their business.

 

WASTE MANAGEMENT
(Conai (n.d.). Glossary. Available in the CONAI Glossary)

According to art. 183, paragraph 1, letter n) of Italian Legislative Decree 152/06, waste management refers to: “the collection, transport, recovery and disposal of waste, including the control of said operations and work following the closure of disposal sites, as well as operations carried out as traders or brokers.”

 

PACKAGING
 (Legislative Decree 152/06, Article 218 (3 April 2006). Available from the Italian Chamber of Deputies)

According to Italian Legislative Decree 152/06, Art. 218, packaging means “the product, consisting of materials of any kind, used to contain certain goods, from raw materials to finished products, to protect them, allow their handling and their delivery from the producer to the consumer or user, ensure their presentation, as well as disposable items used for the same purpose.”

 

COMPOSITE PACKAGING
(Decision 129/97/EC EUR-Lex)

“Composite” packaging is defined as packaging made up of different materials, which cannot be separated by hand.

 

MULTI-MATERIAL PACKAGING
(Conai (2020). Guide to membership and to the application of the Environmental Contribution (Volume 1). Available from CONAI)

This term is used to mean packaging consisting of a number of independent parts made from different materials. Unlike composite packaging, in this case the various materials making up the packaging can be separated. For example, the following qualify as multi-material packaging: chocolate box (paper for the box, plastic for the shaped insert), sweet bag (plastic for the bag, paper for the individual sweet wrappers), coffee tin (aluminium for the tin, plastic for the lid), etc...

 

FULL PACKAGING
(Conai (n.d.). Glossary. Available in the CONAI Glossary)

The term “full packaging” means any packaged goods and, in particular, the packaging of these goods. For example, for an importer of cans of beer, “full packaging” means the aluminium in the cans as well as any other secondary and tertiary packaging used.

 

PRIMARY PACKAGING (OR SALES PACKAGING)
(Conai (n.d.). Glossary. Available in the CONAI Glossary)

In art. 218, letter b) of Italian Legislative Decree no. 152/06, primary packaging is defined as “packaging conceived so as to constitute a sales unit to the end user or consumer at the point of purchase”. Generally speaking, primary packaging is used for an individual product ready for consumption.

 

SECONDARY PACKAGING (OR GROUPED PACKAGING)
(Conai (n.d.). Glossary. Available in the CONAI Glossary)

In art. 218, letter c) of Italian Legislative Decree 152/06, secondary packaging is defined as “packaging conceived so as to constitute, at the point of sale, a grouping of a certain number of sales units, whether the latter is sold as such to the end user or consumer, or whether it serves only as a means to replenish the shelves at the point of sale. It can be removed from the product without affecting its characteristics”. Generally speaking, secondary packaging is used to group a certain number of individual products ready for consumption. Once removed from the secondary packaging, the product is unaltered and ready for use in its primary packaging.

 

TERTIARY PACKAGING (OR TRANSPORT PACKAGING)
(Conai (n.d.). Glossary. Available in the CONAI Glossary)

In art. 218, letter d) of Italian Legislative Decree 152/06, tertiary packaging is defined as “packaging conceived so as to facilitate handling and transportation of goods, from raw materials to finished products, or of a certain number of sales units or grouped packaging to prevent physical handling and transport damage, excluding containers for road, rail, sea and air transport”. Generally speaking, tertiary packaging is used to protect and facilitate the handling of goods during transportation.

 

SECONDARY RAW MATERIAL (SRM)
(Italian Legislative Decree 205/10, Article 184-ter of 3 December 2010.
Available from the Italian Chamber of Deputies)

Set of waste that ceases to be such if it is subject to recovery operations, including recycling, and if it meets specific criteria.

 

UNI STANDARDS
(UNI (n.d.). About us. Available from UNI)

The letters UNI identify “voluntary regulatory documents (UNI standards, technical specifications, technical reports and reference practices) in all industrial, business and tertiary sectors.”

 

Technical standards are standards - compliance with which is voluntary - approved and published by an international, European or national standardisation body; they are basically regarded as “best practices”.

Compliance with same is not mandatory, and alternative, equivalent solutions are possible, provided they are proven to be effective.

 

PACKAGING PRODUCER
(Conai (n.d.). Glossary. Available in the CONAI Glossary)

Based on art. 218, paragraph 1, letter r) of Italian Legislative Decree 152/06, packaging producers are “suppliers of packaging materials, manufacturers, processors and importers of empty packaging and packaging materials”.

 

SEPARATE WASTE COLLECTION
(Italian Legislative Decree 152/06, Article 183, paragraph 1, letter f) of 3 April 2006. Available from the Italian Chamber of Deputies)

Separation - performed according to cost-effectiveness, efficacy, transparency and efficiency criteria - designed to sort municipal waste into like fractions at source, when the waste is collected or, for the food waste organic fraction, even at the processing stage, and to separate packaging waste from other municipal waste, on condition that all the above-mentioned waste is actually sent for recovery.

 

RECOVERY OF PACKAGING WASTE
(Italian Directive 2008/98/EC, Article 3, paragraph 15 of 19 November 2008. Available from EUR-Lex)

The recovery of generated waste means any operation whose main result is to allow waste to serve a useful purpose by replacing other materials that would otherwise have been used to fulfil a particular function, or to prepare waste to fulfil that function, in the plant or in the wider economy.

 

ENERGY RECOVERY (WASTE-TO-ENERGY)
(CONAI (2020). Guide to membership and to the application of the Environmental Contribution (Volume 1). Available from  CONAI)

According to art. 218, paragraph 1, letter n) of Italian Legislative Decree 152/06, energy recovery from packaging waste is achieved where said packaging waste is combustible and is used to produce energy by means of waste-to-energy plants (with or without other types of waste).

 

PACKAGING RECYCLING
(Directive 2008/98/EC, Article 3, paragraph 17 of 19 November 2008. Available from EUR-Lex)

Any recovery operation by which waste materials are reprocessed into products, materials or substances whether for the original or other purposes. It includes the reprocessing of organic material but does not include energy recovery and the reprocessing into materials that are to be used as fuels or for backfilling operations.

 

PACKAGING WASTE
(Directive 2008/98/EC, Article 3, paragraph 1 of 19 November 2008.
Available from EUR-Lex)

Any substance or object which the holder discards or intends or is required to discard.

 

PACKAGING USER

According to art. 218, paragraph 1, letter s) of Italian Legislative Decree 152/06, users are “traders, distributors, fillers, users of packaging, and importers of filled packaging.”


Appendix

 

Environmental labelling

(This information can also be found in the Guidelines for the environmental labelling of packaging )

The different types of environmental label may be broken down according to their purpose, namely:

  • Identification of the packaging’s composition material: Decision 129/97/EC;
  • Participation in the CONAI system;
  • Communication of the packaging’s environmental performance.

 

Identification of the packaging’s composition material: Decision 129/97/EC

Directive 94/62/EC, addressed to packaging producers and users, and covering all packaging placed on the market, required Member States to:

4) achieve recycling and recovery goals;

5) comply with essential requirements;

6) identify the packaging material by means of identification codes to facilitate collection, reuse and recovery, also through recycling, on the basis of Decision 129/97/EC.

Since 1997, the labelling of packaging had remained voluntary, but the mandatory regulatory framework to be taken into account for the identification of packaging materials was already Decision 129/97/EC.

All plastica
All carta
Allegato semplice acciaio
All legno
All tessili
Allvetro
all misti

 

OTHER REGULATORY REFERENCES FOR THE IDENTIFICATION OF PACKAGING MATERIALS (for plastic packaging)
  • UNI EN ISO 1043-1, Plastics — Symbols and abbreviated terms — Part 1: Basic polymers and their special characteristics.
    This standard confirms the identification system of Decision 129/97/EC for plastic packaging.
  • UNI EN ISO 11469 Plastics — Generic identification and marking of plastics products
    This standard is applicable in general to plastic products, in order to facilitate recognition in end-of-life recovery operations. The material’s identification code should be placed between the two symbols “>” and “<”; in the presence of more than one polymer or of additives and adjuvants, the characters “+” or “-” are placed respectively in between the abbreviations.

Participation in an EPR system

 

CONAI trademark

Companies producing and using packaging can communicate their membership in CONAI - Consorzio Nazionale Imballaggi (National Packaging Consortium) by placing the CONAI trademark on their packaging.

The right to use the trademark is given, free of charge and upon request, to companies producing or using packaging, as defined in articles 35, paragraph 1, letters q) and r) of Decree 22/97, who have joined CONAI and have complied with the Consortium’s statutory and regulatory requirements.

The application procedure includes:

  1. Submission to CONAI of a special application form signed by the legal representative of the member company concerned;
  2. Evaluation by CONAI of the member company’s eligibility;
  3. Signing of the license agreement;
  4. Registration of the agreement on the register of licensees held by CONAI.
COMIECO trademark        

Click here to read the Consortium Regulations, inclusive of the rules regarding the Comieco trademark.

CiAl trademark        

The right to use the trademark is given to CiAl consortium member companies upon request.

Communication of the packaging’s environmental performance

 

Type II Environmental Labels (ISO 14021)       

This standard includes all “self-declared environmental claims”, in other words all the environmental statements, labels and symbols found on the packaging. The party making these declarations is responsible for the truthfulness of their content.

The standard excludes the possibility of using expressions that are too generic or meaningless (such as “friend of the environment”, “green” or “non-polluting”).

As regards packaging in particular, the standard sets forth specific requirements and assessment methods for the use of certain claims, such as:

  • compostable;
  • degradable;
  • recyclable;
  • recycled content;
  • low energy consumption;
  • reusable and rechargeable;
  • waste reduction.

The standard allows the optional use of symbols to make environmental claims. The standard does not set forth any specific symbol with the exception of the Mobius Loop, which is used for claims relating to recycled or recyclable content.

cicli Mobius fine

Consumer instructions for separate waste collection

 

(This information can also be found in the Vademecum per un’etichetta volontaria ambientale che guidi il cittadino alla raccolta differenziata degli imballaggi)

In order to standardise and clarify information addressed to consumers and help companies guide end consumers towards correct disposal of packaging, in 2014 CONAI drafted the document entitled “Etichetta per il cittadino – Handbook on voluntary environmental labelling guiding citizens in the separate collection of packaging”.


Although environmental labelling was not yet a legal requirement, over the years the method proposed by CONAI was applied by many companies, who considered it important to integrate legally required environmental information with additional indications providing concrete support for the management of packaging waste.

Originally, the aim of the project was to identify the minimum environmental information to be reported on the packaging in order to guide consumers towards effective waste separation.

This basic information answers the following questions:

  • WHAT IS IT?
    It is important to indicate which component you are referring to, especially in the case of multi-component packaging, in order to provide relevant information and not create confusion. It should also be made clear that the product in question is packaging and can therefore be collected separately.

 

  • WHAT MATERIAL IS IT MADE FROM?
    The type of material is expressed using the alphanumeric codes under Decision 129/97/EC. These codes may not always be clear or fully explanatory, therefore it is important to indicate the material family of the packaging component, in order to remove all doubt and help the consumer recognise the packaging materials.

 

  • WHERE DOES IT GO?
    Stating the correct waste stream for that particular type of packaging is key to getting the consumer to dispose of it adequately. It is worth noting that different municipalities adopt different separate waste collection methods, but that these are always referable to the nature of the materials. In any case, given the variety of collection systems in existence throughout Italy, it is always worth reminding citizens to check their local municipal guidelines.