Avv. Silvio Marzari
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Product packaging and environmental labelling


after release of this video the deadline of June 30th 2022 has been extended to December 31st 2022!

This is important news for companies, which sell products in the EU, but also for consumers. Packaging is boxes, bottles, jars, baskets and generally all those containers for products bought by consumers.

The origin of the issue comes from the EU Directive 851 of 2018, which has also been transposed into Italian law, defined as the “environmental labelling standard”. The aim of this legislation is to ensure that product packaging is reused as much as possible as part of the so-called circular economy.

For all packaging, therefore, an obligation has been introduced to identify the packaging materials by means of identification markings, as set out in Decision 129/97/EC, and to indicate how they can be recycled. For paper packaging, for example, there will be the abbreviation PAP followed by a number. Given the variety of packaging, the standard takes up the principle of accountability, and it is therefore possible that companies' solutions will vary, but all will be suitable for achieving the intended purpose.

Sometimes products are so small that it is difficult to add other indications on the labels: then the regulation provides that a QR code can be print, with a link to a web page, where all the information is available to the consumer.

These new indications had to be in place on products already on sale by 31st December 2021, but at the end of last year this deadline was extended to 30th June 2022 and then to 31st December 2022. However, even after that date, companies can sell products that are already on the market or that are already labelled on 1st January 2023, even though they do not have the environmental labelling requirements, until stocks are sold out.

Given that the extension came at the last minute, it is quite possible that products bearing the new packaging recycling information are already on the market.

It is important for companies to know that these are mandatory rules and that failure to comply with them will result in heavy fines. But with the deadline being extended to 30th June 2022, it is to be expected that everyone will comply, to take another step in the direction of a greener economy.


updated June 2022



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